ML24257A078
| ML24257A078 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE, Consolidated Interim Storage Facility |
| Issue date: | 09/10/2024 |
| From: | Allison E Public Citizen |
| To: | John Lubinski Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML24257A078 (1) | |
Text
E. C. A II ison September 10, 2024 Mr. John Lubinski, Director Office ofNuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-000L
Subject:
NRC and DOJ need to withdraw from the U.S.
Supreme Court case (23-1352) filed by Holtec International (Holtec). A legal environmental impact statement (EIS) wasn't written for Holtec's high-level nuclear waste storage facility. This resulted in an illegal NRC I icense (SNM-2516) being issued to Holtec.
Dear Mr. Lubinski; This letter provides information for correcting a situation that resulted io the issuance of ilJegal NRC I icenses to (1) Interim Storage Partners (ISP) and (2) Holtec. Two illegal ElSs were written. Irrefutable proof is included with this letter that proves the EISs couldn' t be used to issue NRC Licenses SNM-25 l 5 and 2516. You and others need to correct this situation.
You need to deal with this situation immediately. Why? Holtec International filed an appeal witb the U.S. Supreme Court to get its illegal NRC license reinstated. You can check the status of the case at the court's web page. Through no fault of her own, Ms. Helton issued Holtec's illegal NRC license (SNM-25 16). She had no way of knowing the license shouldn't be issued. It would be a worse tragedy, if the U.S. Supreme Court reinstates an illegal NRC license that should never have been issued.
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This iso 'ta Final EIS.
Environmental Impact Statement for the Holtec lnternational's L icense Application for a Consolidated Interim Storage Facility for-Spent Nuc lear Fuel in Lea County, N e w M exico.--------------,
.. Final Report A final report doesn't take the place of a Final EIS.
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- I had to review EJSs, written by other agencies, for the agency I Four nuclear waste storage facilities, in a worked for. I was responsible for making sure legal EISs were written 40-mile area, in southeast NM-west Texas.
by employees in my office. NRC EISs NUREG-2237 and 2239 aren't legal ElSs. The enclosed report focuses on unprecedented National Environmental Policy Act (NEPA) violations. Because legal EISs weren't written, other laws were violated. One of the laws is The Major Fraud Act (MF A) of 1988. The statute of limitations, for prosecuting MFA violations, may have begun on May 9, 2023 with the issuance of Holtec's illegal NRC license (SNM-2516).
They may have begun on September 13, 2021 with the issuance of ISPs illegal NRC license (SNM-2515).
Please look at the attachments. They provide infonnation about a 736-page NRC report written for (l) one year of business and (2) the storage of 500 canisters at Holtec's proposed 40-year business. What happened? You' ll find in the report. Nine, Center for Nuclear Waste Regulatory Analyses (CNWRA), employees were given the job of writing two EISs at the same time. It's impossible to do this. Why issue ISP's license? ISP's high level nuclear
_waste storage facility would be at the existing Waste Control Specialists' low-level nuclear waste storage facility.
Why put two nuclear waste storage facilities at one location at the New Mexico--Texas state line?
Why did J send this letter? J live about 180 miles northwest of what could end up being four nuclear waste storage facilities, in a 40-mile area, in southeast NM-west Texas. Because of the unprecedented violation of laws, l have one question. Was anyone paid (bribed) to make sure NRC licenses were issued for one or both companies?
Sincerely, r.E. C..JL{[ison Attachment I : Selected pages from September 10, 2024 report. : Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast NM-Texas State Line.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico-West Texas Chaves County Proposed nuclear storage facility HOLT EC IN r[RNATIONA l Existing nuclear storage facility by E. C. Allison September 10, 2024 11 t bklo
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II Interim Storage Partners at 0.37 miles east of NM-Texas state line.
I~ I Waste Control Specialists at (about) 1 mile east of NM-Texas state line.
Hof tee calls for US Supreme Court to reinstate New Mexico licence 08My2024 Holte< International has joined the US Nuclear Regulatory Commission (NRC) and the US Federal Government in filing petitions asking the Supreme Court to reinstate the licence for a proposed interim storage facHity for used fuel to be blilt in New Mexico,
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HrJtei:irendffitgof tht HI-STORE IN~: Hdleq The NRC issued the licence in May 2023 for Holtec to build and operate the HI-STORE consolidated interim stQraCJe facility (CISF) on land owned by the Eddy lea Energy Alliance (ELEA), a region~ economic development entil'f in SoutheastNew Maico. But in March this year, the Frfth Circuit Court of Appeals published a decision to "vilate* the licence following a similar ruling aganst another prwate interim storage licence in Texas.
11
SUMMARY
There could be four nuclear waste storage facilities, in a 40-mile area, in southeast New Mexico-West Texas (see Exhibit 1). That would happen, if two illegal United States (U.S.) Nuclear Regulatory.Commission (NRC) licenses are reinstated. One illegal NRC license (SNM-2515) was issued to Interim Storage
- Partners (ISP) on September 13, 2021. The.other illegal NRC license (SNM-2516) was issued to Holtec International (Holtec) on May 9, 2023.
The Appeals Court for the Fifth.Circuit vacated both licenses. Holtec filed an appeal with the U.S. Supreme Court, to reinstate its NRC license. The court can't reinstate an illegal NRC license.
Why did NRC issue two illegal licenses? NRC and Southwest Research Institute (SwRI) employees; who work for SwRl's Center for Nuclear Waste Regulatory Analyses (CNWRA), didn't write legal environmental impact statements (EISs) for the nuclear waste storage facilities proposed by Holtec and ISP. The unprecedented National Environmental Policy Act (NEPA) violations, in the NRC EISs, are presented in this report. NRC employees used the illegal EISs to issue the licenses. This resulted in the issuance of two illegal NRC licenses.
The issuance of the two illegal NRC licenses could result in four nuclear waste storage facilities, in a 40-mile area, in southeast NM-* west Texas. That is, if two new nuclear waste storage facilities are built. There isn't another place in the United States or the world, with four nuclear *waste storage facilities clustered together m a 40-mile area.
It appears NRC and CNWRA employees left this information out ofNRC's illegal 2021 and 2022 EISs written* for ISP and Holtec. It's for this reason the public, and the courts, don't know about it. It's important to note. What the two companies are proposing to do, hasn't been done before in the United States.
What's more, they would store the most dangerous nuclear waste in the United States. It's for that reason it was imperative good EISs were written for Holtec' s and ISP's proposed nuclear waste storage businesses.
Reinstating an illegal NRC license, that should never have been issued, would be a worse tragedy than issuing it. It would also set a precedent for issuing more, of a new kind ofNRC license, for private, _untested and untried, away-from-111
Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico--West Texas. The red line is the New Mexico--Texas state line.
New Mexico Ch av e s COll"'t~
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Proposed nuclear storage facility H O L TEC IN T£R NATl0 '1 Al
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Interim Storage Partners at 0.37 miles east of NM-Texas state line.
Waste Control Specialists at about 1 mile east of NM-Texas state line.
II C __ jj I @ I ISP and WCS about five miles east of Eunice, New Mexico.
Figure 5.1-1 Location of Facilities within 80 km [50 mi] of the Proposed CISF Project.
in NRC's 2021 EIS written for Interim Storage Partners.
lV
reactor, nuclear waste storage facilities in the United States. They are also called consolidated interim storage facilities (CISFs).
Holtec filed an appeal with the U.S. Supreme Court asking the court to reinstate Holtec' s NRC license. Therefore, much of the text in this report is concerned with NRC's illegal 2022 EIS (NUREG-2237) written for Holtec.
Nine employees, who work for SwRI' s CNWRA, were assigned the job of writing two EISs at the same time. (The same NEPA violations were made in NRC's illegal 2021EIS f~r ISP and 2022 EIS for Holtec.) Thirty-five people worked on the last EIS I worked on for the government. Seventy-five people worked on NRC's 2001 EIS (NUREG-1714) for the first proposed CISF facility.
Nine people, to write two EISs at the same time---there was never any intention off writing one legal EIS, much less two legal EISs for the second and third proposed CISF facilities in the United States. What's more, they're untested and untried facilities. They would store the most dangerous nuclear waste ( spent nuclear fuel), transported from dozens of power plants or reactors, in the U.S.
V
TABLE OF CONTENTS World Nuclear News, July 2024, first page of news article
SUMMARY
TABLE OF CONTENTS 11 111 Vl INTRODUCTION 1
I.
Unprecedented Violations, of the National Environmental Policy Act, Results in Issuance of an Illegal NRC License to Holtec International......... 1 IL Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico-West Texas............................................ 1 ARGUMENT 4
I.
Unprecedented Violations, of the National Environmental Policy Act, Results in Issuance of an Illegal NRC License to Holtec International.........4 A.
Holtec's Plans for Its Nuclear Waste Storage Business...........4 B.
A New Kind of Nuclear Waste Storage Facility................... 5 C.
Moving Spent Nuclear Fuel From 12 Power Plants or Reactors................................................................................ 5 D.
A New Kind ofNRC License......................................... 6 E.
The Ultimate NEPA Violation...................................... 13 F.
NRC and CNWRA Staff Tells US They Didn't Write an EIS.......................................................... 13 G.
Moving Spent Nuclear Fuel is Missing From NRC's 2022 EIS....................................................... 16 H.
NRC's EIS Written for Three Years of a 40-Year Business... 21 I.
Missing U. S. Bureau of,Land Management..................... 23 J.
Only 1,080 Acres..................................................... 25 K.
Nine CNWRA Employees Assigned to Write Two EISs at the Same Time...................................................................... 29 II.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico-West Texas.......................................... 41 Vl
A.
What Are the Facilities?............................... ~........................... 51
- 1. Waste Isolation Pilot Plant {WIPP) existing.................. 51
- 2. Waste Control Specialists (WCS) existing.................... 51
- 3. Holtec International (Holtec) proposed........................ 51
- 4. Interim Storage Partners (ISP) proposed...................... 51 B.
Why Issue an NRC License for a Second Nuclear Waste Storage Facility at an Existing Nuclear Waste Storage Facility?................................................ ~...................... 60 C.
No One Could Figure Out There Would Be More, Than One Nuclear Waste Storage Facility in Southeast NM-West Texas................................................................................ 62 D.
Four Low-Level Nuclear Waste Disposal Facilities, in Four States, in the United States................................. 62 E.
Unbelievable Unimaginable NEPA Violations................... 64 F.
Violating Other Laws................................................ 64 CONCLUSION 66 REFERENCES 67 List of Exhibits.
Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico--West Texas...........................iv, 3, 50 Exhibit 2.
Holtec Wants to Move Spent Nuclear Fuel from 12 Power Plants or Reactors..................................................................... 7 Exhibit 3.
ISP Wants to Move Spent Nuclear Fuel from 12 Power Plants Exhibit 4.
Exhibit 5.
Exhibit 6.
Exhibit 7.
Exhibit 8.
or Reactors..................................................................... 8 Section 6A in New NRC Licenses.......................................... 9 Section 6A in Previous NRC Licenses.................................... 11 Manuscript and Final Report Completed July 2022 for Holtec........ 14 Manuscript ai:id Final Report Completed July 2021 for ISP............ 15
- Correct Cover for a Final EIS.............................................. 17 Vll
Exhibit 9.
Moving spent ;Nuclear Fuel From Eight Power Plants or Reactors to Private Fuel Storage's Nuclear Business.............................. 19 Exhibitl0. Amendments (Phases 2 thru 20) Illegally Excluded From NRC' s 2022 EIS.................................................................................. 22 Exhibit 11. NRC Approves Holtec' s Plan of Operations, Not BLM............... 24 Exhibit 12. Impact Analysis May Have Been Limited to Holtec's Facility, Rail Spur, and a Road ******** ~****************************************************************26 Exhibit 13. Recreation Information Missing From NRC's 2022 EIS~.............. 27 Exhibit 14. Recreation in Vicinity ofHoltec's Proposed Facility................... 28 Exhibit 15. List of Preparers in NRC's 2022 EIS Written for Holtec...............30 Exhibit 16. List of Preparers in NRC's 2021 EIS Written for ISP....................33 Exhibit 17. CNWRA Employees Work for Southwest Research Institute (SwRI)......................................................................... 36 Exhibit 18 Center for Nuclear Waste Regulatory Analyses is One of Eleven Divisions at SwRI............................................................ 3 7 Exhibit 19. List of Preparers in 2018 Draft EIS Written for BLM.................. 39 Exhibit 20. List of Preparers and List of Reviewers in NRC's 200.1 EIS...........42 Exhibit 21. Information About WIPP................................................... 5 2 Exhibit 22. A Paragraph About WIPP in NRC' s 2022 EIS for Holtec............. 53 Exhibit 23. Waste Control Specialists (WCS) Information........................... 54 Exhibit 24. A Paragraph About WCS in NRC' s 2022 EIS for Holtec.............. 56 Exhibit 25. A Paragraph About ISP in NRC's 2022 EIS for Holtec................ 57 Exhibit 26. Map ofISP's Proposed Facility at WCS's Nuclear Waste Storage Facility................................................................ 58 Exhibit 26. Diagram Showing ISPs Proposed Facility (Blue Square) at WCS 's Nuclear Waste Storage Facility................. ~................. 59 Exhibit 27. Text About ISP's Proposed Facility at WCS's Existing Nuclear Waste Storage Facility in NRC's 2021 EIS for ISP.......... 61 Exhibit 28. Four Low-Level Nuclear Waste Disposal Facilities, in Four States in the United States...........,.............................................. 63 Vlll
INTRODUCTION I.
Unprecedented Violations, of the National Environmental Policy Act, Results in Issuance of an Illegal NRC license to Holtec International.
The law, the U.S. Supreme Court has to consider, is the National Environmental Policy (NEPA) of 1969. Federal agencies have to comply with NEPA before they can issue licenses. In this case, before NRC could issue Holtec International (Holtec) an NRC license.
For people, who don't know what Holtec wants to do. Holtec wants to obtain a new kind ofNRC license for a new kind of nuclear waste storage facility. Holtec wants to (1) transport the most dangerous nuclear waste in the United States, from 12 power plants or reactors, and (2) store it at its privately owned business in southeast New Mexico (NM). What Holtec is proposing to do, has never been done before in the United States. Has it been done anywhere in the world?
It's not known why. NRC and SwRI's Center for Nuclear Waste Regulatory Analyses (CNWRA) employees wrote a report instead of the environmental impact statement (EIS) they were required to write to comply with NE~A. I've never seen anything like it in my 30-year career with the government. As far as I know, nothing like this has happened before. If it has, surely, it's a rarely seen NEPA violation. Writing a report instead of an EIS is the ultimate NEPA violation.
I've written a lot of environmental assessments (EAs) and worked on EISs.
I know, from experience. It was illegal for NRC to use a report to issue Holtec International an NRC license. The illegal NRC license, issued to Holtec International, can't be reinstated by the U.S. Supreme Court.
II.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico--West Texas.
I wanted to find out what Holtec was _proposing to do at its nuclear waste storage business. During that process, I discovered a shocking and unimaginable situation that has to be considered and addressed by the U.S. Supreme Court.
The issuance of two illegal NRC licenses, in 2021 and 2023, created an unexpected, shocking, and surprising situation. As of May 9, 2023, there were 1
(1) two existing, low-level nuclear waste storage facilities (WIPP and WCS) and (2) two newly licensed, high-level nuclear waste storage facilities (Holtec and ISP), in a 40-mile area, in sout,heast New Mexico-west Texas (see Exhibit 1).
NRC and SwRI's CNWRA employees knew about this situation, when they wrote the illegal EISs for the businesses proposed by Holtec and ISP. For people,
NRC's efforts to issue licenses, for the first consolidated interim storage facilities (CISF), as they're calied, resulted in a huge case of fraud. Why? NRC and SwRI's CNWRA employees wrote two reports. NRC employees presented, and defended, them as legal EISs to the public and_the courts. Because EISs weren't written, they violated The Major Fraud Act of 1988 and other laws.
The Fifth Circuit Court of Appeals vacated (1) Interim Storage Partners' and (2) Holtec Intemational's licenses. Now, the U.S. Supreme Court has to deal with Holtec's request to reinstate an illegal NRC license. Reinstating Holtec's illegal NRC license, by the U.S. Supreme Court, would be a worse tragedy than NRC's issuance of it.
New Mexican's, American's deserve better than this. So too, does Holtec International and Interim Storage Partners. The companies expected NRC employees to do their jobs and issue them legal NRC licenses.
Finally, there shouldn't be any place in the United States, with four nuclear waste storage facilities clustered together in a 49~mile area. What's more, the two facilities would store the most dangerous nuclear waste (spent nuclear fuel) in the United States.
2
Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico--West Texas. The red line is the New Mexico--Texas state line.
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lnterim Storage Partners at 0.37 miles east of NM-Texas state line.
Waste Control Specia lists at about 1 mile east of NM-Texas state line.
II<.'* ---- 111 ~ I ISP and WCS about five miles east of Eunice, New Mexico.
Figure 5.1-1 Location of Facilities within 80 km [50 mi] of the Proposed CISF Project.
in NRC' s 2021 EIS written for Interim Storage Partners.
3
ARGUMENT I.
Unprecedented Violations, of the National Environmental Policy Act, Results in Issuance of an Illegal NRC license to Holtec International.
NRC has to comply with NEPA before it can issue NRC licenses. In this case, before NRC could issue Holtec International an NRC license. Questions, as to which nuclear law gives NRC the authority to issue Holtec's NRC license, are immaterial. Why? NRC had to write a legal EIS before it could issue (1) (what's called) an NRC Record of Decision and (2) an NRC license. That didn't happen.
A Record of Decision (ROD) sta~es the decision the agency makes about a proposed project. The ROD is based on the information in the EIS. A ROD has to be issued before an NRC license can be issued. Because NRC and SwRI' s CNWRA employees didn't write a legal 2022 EIS for Holtec International, NRC's 2023 ROD isn't a legal document. The illegal EIS and ROD couldn't be used to issue Holtec an NRC license. It's no wonder Holtec was issued an illegal license.
A.
Holtec's Plans for Its Nuclear Waste Storage Business.
Holtec plans on taking two years to construct its facility. Holtec would store 500 canisters of spent nuclear fuel in the first year of business. It's expected to take 3 years to complete what Holtec calls Phase 1. Holtec plans on expanding its facility every year for 19 years.
Holtec calls this Phases 2 thru 20.
Each year, 500 canisters of spent nuclear fuel would be (1) transported from 12 power plants or reactors and (2) stored at Holtec's business. At the end of 20 years (20 phases), Holtec would store 10,000 canisters of spent nuclear fuel for 20 to 38 y~ars, before the end ofHoltec's 40-year NRC license.. The length of time (20 to 38) is based on the year the spent nuclear fuel is stored at Holtec' s business.
It's assumed the 10,000 canisters would be moved, before the end of Holtec's 40-year license, to a permanent geologic repository.
It took 20 years to store 10,000 canisters. It'll take 20 years to move Holtec's 10,000 canisters to a permanent repository. Holtec 4
would need to get in line, with all the companies and business, who want to move spent nuclear fuel to the permanent repository.
The biggest difference-between three companies proposing to build and operate consolidated interim storage facilities (CISFs)--is the number of canisters. Holtec' s proposed 10,000 canisters are nearly three times the (1) 4,000 canisters proposed by Private Fud Storage and (2) the 3,400 canisters proposed by Interim Storage Partners.
B.
A New Kind of Nuclear Waste Storage Facility.
Holtec wants to (1) move the most dangerous nuclear waste from 12 nuclear power plants or reactors and (2) store it at its privately owned business in southeast New Mexico. What Holtec is proposing to do has never been done before in the United States.
Holtec' s business would be the first of its kind, private, untested and untried, away-from-reactor, nuclear waste storage facility in the U.S.
It's also called a consolidated interim storage facility (CISF).
Holtec announced it obtained an NRC license for the first CISF in the U.S. See the headline in a post Holtec issued on May 9, 2023.
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Home U,ttpo-J/holtccint-tion;,l.c:om) > 2023 (bttps:/lholtedntemationalcom/202311 > May lhtms://hollcc.intcmatiooal.com/2023/05/) >
Holtec Receives U.S. N RC's License for Building and Operating America's First Below-Ground Consolidated Interim Storage Facility for Used Nuclear Fuel C.
Moving Spent Nuclear Fuel From 12 Power Plants or Reactors.
Holtec wants to move spent nuclear fuel (SNF) from 12 power plants or reactors, from Maine to California, to southeast New Mexico 5
(see Exhibit 2). This information is in an Environmental Report (ER)
Holtec submitted to NRC, when Holtec applied for a license.
Tetra Tech, Inc. wrote the Environmental Report for Holtec.
Tetra Tech, Inc. isn't required to comply with NEPA. Federal agencies are required to comply with NEPA. It's important to note.
Holtec's Environmental Report can't be used in place of an NRC EIS.
To get a better idea, as to how unusual and different these nuclear waste storage facilities would be, if approved. A map shows the 12 power plants or reactors Interim Storage Partners (ISP) wants to move spent nuclear fuel from ( see Exhibit 3 ). It would be transported from 12 nuclear facilities, from the east coast to the west coast, to ISP's proposed nuclear waste storage facility at 0.37 miles east of the NM-Texas state line.
What Holtec and ISP are proposing to do is a huge change in what's been allowed and licensed before. NRC has to issue a new kind ofNRC license for a new kind of nuclear waste storage facility.
D.
A New Kind of NRC License.
Holtec is asking NRC to issue it a new kind of license. The first, of this new kind of license, was issued to Private Fuel Storage in 2006. The second was issued to ISP in 2021. The third was issued to Holtec in 2023. The PFS facility hasn't been built.
What makes the new licenses different from the licenses previously issued to companies? It's what's stipulated in section 6A of the licenses. Section 6A allows for the removal of"Spent nuclear fuel elements from commercial nuclear utilities." This stipulation lets companies move spent nuclear fuel from any power plant or reactor in the United States. See Section 6A in the licenses issued to Private Fuel Storage and Holtec International (see Exhibit 4).
Previous NRC licenses limit companies to removing spent nuclear fuel from one power plant or reactor. See Section 6A in two of these licenses ( see Exhibit 5).
6
Exhibit 2 Holtec Wants to Move Spent Nuclear Fuel from 12 Power Plants or Reactors.
ATTACHMENT 4 TO HOLTEC LETTER 5025012 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Table 2.1.1:
DECOMMISSIONED SHUTDOWN SITES Site Couotv State Big Rock Point Charlevoix County Michigaµ Connecticut Yankee Middlesex County Connecticut Crystal River Citrus County Florida Kewaunee Kewaunee County Wisconsin Lacrosse Vernon County Wisconsin Maine Yankee Lincoln County Maine Humboldt Bay Humboldt County California RanchoSeco Sacramento County California San Onofre San Diego California Trojan Columbia County OreRon Yankee Rowe Franklin County Massachusetts Zion Lake County Illinois HOL TEC INTERNATIONAL COPYRIGHTED MA TERTAL HI-2167521
. I Rev. 0 2-2 Page 30 of 482 7
Exhibit 3.
ISP Wants to Move Spent Nuclear Fuel From 12 Power Plants or Reactors.
Figure 2.2-4 Decommissioned Reactor Sites in the United States (ISP, 2020) 2.2. 1.3 Facility Description The site plan for the proposed CISF Is shown in EIS Figure 2.2-5. A fence would enclose the approximate 130-ha [320-ac) OCA, and a doubfe fence would surround the approximate 41-ha
[100-ac] protected or restricted-access area within the OCA. The protected area would be approximately centered within the OCA and would contain the storage pads, storage systems, and support facilities and infrastructure for receipt, transfer, and storage of the SNF waste canisters.
2.2.1.3.1 Construction Under the proposed action (Phase 1 ), construction activities would include construction of the first storage pad (in the southwestern portion of the protected area) and the other major components of the proposed CISF, including the cask-handling building, the security and administration building, and the rail sidetrack. The objective of constructing the initial phase of the CISF {i.e., Phase 1) would be to provide an operational facility capable o f storing 5,000 MTU
[5,500 short ton] of SNF, GTCC, and a small amount of MOX fuel, which would originate from shutdown or decommissioned reactors (ISP. 2020). ISP estimates that a maximum of 50 construction workers would be directly involved in construction of Phase 1 o f the proposed CISF (ISP, 2020), which ISP estimates would take approximately 1 year to complete.
If authorized by the NRC, Phases 2-8 of the proposed CISF would include construction of additional storage pads, each capable of storing an additional 5,000 MTU [5,500 short tons].
Construct.ion of Phases 2-8 would allow receipt and storage of SNF from future decommissioned and decommissioning reactors, as well as from operating reactors prior to decommissioning.
2-7 8
Exhibit 4.
Section 6A in New NRC licenses.
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PAGES LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Pursuant to the Atomic Energy Act of 1954, as amended, 1he Ene<gy Reorganil:ation Act of 1974 (Public Law 93-438), and TIile 10, Code of Federal Regulations, Chapter 1, Part 72. and in reliance 0111 statements and representations heretofore made by the licensee, a license is hereby issued authorizng the licensee to receive, acquire, and possess the power reactor spent fuel and other radioactllle materials assoelated with spent fuel slorage designated below; to use such material lorthe purpose(s) and at the place(s) designated below; and lo deillef-or transfe< such matenal to persons authorized to receiw it in accordance with the regulations of the applicable Part{s). This license shall be deemed to conlall the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and IS suoJect 10 811 applicable rules, regu1at10ns, and ort1ers or tile Nuclear Regulatory Commission now or hereaner In effect and to any conditions specified herein.
Licensee
- 1. Private Fuel Storage, Limited Liability Company
- 3.
License No.
SNM-2513 Amendment No.
0
- 2. Private Fuel Storage Facility 1 Oniqui Road
- 4.
Expiration Date February 21. 2026 Reservation of the Skull Valley Band of Goshute Indians
- 5.
0ocl(etor Grantsville, UT 84029 Reference No.
72-22
- 6. Byproduct, Source, and/or Special Nuclear Material
- 7. Chemical and/or Physk:al Form
- 8. Maxmum Amount That ucensee May Possess at Any One rime Under This License
____.. A. Spent nuclear fuel elements from A. Intact fuel assemblies, damaged
__,,. commercial nuclear utilities licensed fuel assemblies, and fuel debris, as pursuant to 10 CFR Part 50 and allowed by Certificate of Compliance A. 40,000 Metric Tons of Uranium in the form of intact spent fuel assemblies_., damaged fuel assemblies, and ruel debris.
associated radioactive materials No. 1014, Amendment 0, for fhe HI-related to the receipt, transfer and STORM 100 Storage Cask System, In addition, the cumulative amount of material received and accepted during the licensed term of the facility may not exceed 40,000 storage of that spent nudear fuel.
modified as descnl>ed in paragraph 9 below.
- 9.
- 10.
- 11.
- 12.
- 13.
Metric Tons of Uranium.
Authorized Use: The material identified in 6.A and 7.A above is authorized for receipt, possession, storage, and transfer in the Private Fuel Storage Facility (PFSF). as described in the PFSF Safety Analysis Report (SAR) dated June 20, 1997, as revised or supplemented through Revision 22 dated November 21. 2001 and as may be further supplemented and amended in accordance with 10 CFR 72.70 and 10 CFR 72.48. Storage is authorized only in casks designed in accordance with Certificate of Compliance No. 1014, Amendment 0, for the HI-STORM 100 Storage Cask System, modified to incorporate the lid shims and weld modifications described in Holtec Report Hl-2033134, as revised (PFS Hearing Exh. 257, pp. 7-14 through 7-16, 8-28, and Figures 26A and 26B).
Authorized Place of Use: The licensed material is to be received, possessed, transferred, and stored at the PFSF, on the Reservation of the Skull Valley Band of Goshute Indians geographically located within Tooele County, Utah.
The Technical Specifications contained in the Appendix attached hereto are incorporated into the license. The licensee shall operate the installatiorn in accordance with the Technical Specifications in the Appendix. The Appendix contains Technical Specifications related to environmental protection to satisfy the requirements of 10 CFR 72.44(d)(2).
The licensee shall comply with the "Environmental Conditions* specified in Section 9.4.2, Mitigation Measures, of the "Final Environmental Impact Statement for the Construction and Operation of an Independent SpE!nt Fuel Storage Installation on the Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility in Tooele County, Utah," NUREG-1714 (December 2001)
The licensee shall submit a Final Safety Analysis Report within 90 days from the date of this license that incorporates the accident analyses and commitments provided by PFS in the U.S. Nuclear Regulatory Commission's (NRC's) adjudicatory proceeding on the PFS license application. concerning aircraft crash and munitions impact events.
9
Exhibit 4 ( continued).
Section 6A in New NRC Licenses.
NRCFORM5&8 (1o.al00) 10CF'R77 U. S. NUCLEAR REGULATORY COMMISSION PAGE
- 1. OF -3.. PAGES LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Pursuant to the Atomic Energy Act of 1954, as amonded. the Energy Reorganization Act M H74 (Public Law 93-438). and Trtle 10, Code of Federal Regulations, Chapter 1, Part 72, and in reliance on slatemoolS and representations heretofore made by the licensee, a license ls nereoy,ssuec:t autl10rt%lng 111e licensee 10 receive. acquire, ano possess Ille power reao1or spent fuel and other rooioaotiw materials associated with spent fuel storage designated below: to use such material for the purpose(s) and at the place(s) designated below: and to deliver or transfer such material to persons authorized to receive tt in accordance with the regulations of the applicable Part(s). This license shal be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, 88 amended, and is subject to all applicable rules, 1'8QUlalions, and orders of the Nuclear Regulatory Commission now or hereafte< in effect and to any conditions specified herein.
This llcense Is conditioned upon fulliltlng the requirements of 10 CFR Part 72, as applicable. the attached Appendi* A (Technical Specificalions). and the conditions specified below Li~nseo
- 1.
Holtec International
- 2.
Holtec Technology Center 1 Holtec Blvd Camden, NJ 08104 6
Byproduct, Source and /or Special Nuclear Malerial
- ..r, Spent nudear fuel elemenlS from I -,, oommeraal nuelear utilities licensed pursuant 10 10 CFR Part SO and associated radioactive materials related to the receipt, transfer, and storage of that spant nuclear fuel.
- 3.
License No.
Amendment No.
4 Expiration Date
- 5.
Docket or Reference No
- 7.
Chemical and/or Physical Form A.
Undamaged fuel assemblies, damaged fuel assemblies, and fuel debns, as allowed by Certlfia>te of Compliance No. 1040, Amendmen1S 0, 1. and 2. for the HI-STORM UMAX Canisler Storage System, and described in Paragraph 9 below.
SNM-2516 0
May 9, 2063 72-1051 a
Maximum Amount That Licensee May Possess at Any One lime Under This License A_
B.680 Metric Tons of Uranium (500 loaded canisters) In the form of unc:lamegod fuol a1'SOfflblios,, d<>m:,ged fuel assemblies. and fuel debris.
- 9.
Authorized Use: The material identified in 6.A and 7.A above is authorized for receipt, possession, storage, and transfer in the HI-STORE Consolidated Interim Storage (CIS) Facility, as described in the HI-STORE CIS Facility Final Safety Analysis Report (FSAR). Storage is authorized only in casks designed in accordance with Certificate of Compliance No. 1040, Amendments 0, 1, and 2, for the HI-STORM UMAX Canister Storage System.
- 10.
Authorized Place of Use: The licensed material is to be'received, possessed, transferred, and stored at the HI-STORE CIS Facility localed in Lea County, New Mexico.
- 11.
The Technical Specifications contained in the Appendix attached hereto are incorporated into the license. The licensee shall operate the HI-STORE CIS Facility in accordance with the Technical Specifications in the Appendix.
- 12.
The design, construction, and operation of the HI-STORE CIS Facility shall be accomplished in accordance with the NRC's regulations specified in Title 10 of the Code of Federal Regulations. All commitments to applicable Commission Regulatory Guides and to applicable engineering and construction eodes shall be met.
10
Exhibit 5.
Section 6A in Previous NRC Licenses.
v u.s. NUCLEAR AEoULATORY ~v LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE l'umwll 10 tbe Atomic: ~y Ac:1 of I~. u amended. the Energy Reorp11iu1ion Ad of 197* (Public: LaYr 93-433), and Trtlt 10, Code of Fedc,-J Reaulations, ~I.Part 72. and in rcli&Jlec -
-eme,,u and reprc-.atlON louctoforc....Sc by the lk,ensce.
- lk:cnsc is hcn:by issued audlorizma the licensee to rucivc. acquire. and pos.seu Ille JIOWtt reactor spent flld and Oilier ndioac:live materials a$$0Ciated wilh Jpa,t f*cl s&on&c designated below; to use a.ch material '°' the purpose<s) and at the plact(s) dcsipialed below; and to deliver or transfer such m,tcrial to pe.rs<>n$ authorized to rc<<lvc l t In accordance with the reg\\llatiOM of the applicable l'ar1{a). This li<<11sc shall be deemed to conta in the conclitlons specified in Section 183 of lbc Atomic: &crgy Act of 11>S*. u amended. Uld is sobjec, to all applicable rules. rqulations. ud ordcn or lbc Nuclar Reaulatory Commission now cw llcrcafter In effect and to u y conditions spccifd lleffin.
Licensee SNM-2508 I.
United States Department of Energy
- 3. License Number Idaho Operations O<<-ioe 850 Energy Place.
Idaho Falls. Idaho 83401 6. Byproduc:t. Source, and/or Special Nuclear Material
....._ A) Radioactive material from
~
the Three Mile Island Unit 2 (TMl-2) reactor core damaged by the March 28, 1979, reactor accident, lnclud'ing the remains of 177 Babcock and Wicox 15x15 fuel assemblies with a maximum of 2.98% U-235 Isotope, 61 control rod assemblies, and mlscellaneous Irradiated core and core basket material.
S) Radioactive material related to receipt storage.
and transfer of the above radioactive material, Including 265 fuel c;an1$ters, 12 knockout canisters. and 67 fitter canisters used to confine the above TMl-2 core debris In the absence or Intact fuel assembly cladding.
4.Eiq,intiool>u:
S. Dock.ct or Reference No.
- 7. OlemicaJ and/or Physical Form A) ks debris consisting of significantly damaged fuel and control assemblies and non-fuel reactor components In the form of partially Intact assembfies, conglomerate core material, previously molten materials, rubble, and fines.
- 'iR03260306 990319 PDR ADOCK 07200020 /
B PDR 1...
11 March 19. 2019 72-20
- 8. MuimomAmounlthat Licemec May Possess at Any One Tame Under This Licellsc A) 82,985.9 kg U Initially contained In the fuel assemblies of the damaged TMl-2 reactor core, contained In roughly 139,293 kg of material remOYed fn>m the TMl-2 reactor vessel.
Exhibit 5 ( continued).
Section 6A in Previous NRC Licenses.
NRC FORM588 U. S. NUCLEAR REGULATORY COMMISSION (1~)
IOCFR7' PAGE 1_
OF __L_ PAGES LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL ANO HIGH-LEVEL RADIOACTIVE WASTE Pursuant to the Atomic Energy Act of 1954, as amende<I, the Energy Reorganization Act of 1974 (PubUc Law 93-438), and nue 10, Code of Fe<leral Regulations, Chapter 1, Part 72, and in reliance on statements and representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire. and possess the power reactor spent fuel and other radioactive materials associated with spent fuel storage designated below; to use such material for the purpose(s) and at the place{s) de$ignate<I below: and to deliver or transfer such material to persons authorized to receive it in accoroance with the regulations of the applicable Part(s). This license shaH be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter In effect and to any conditions specifle<l herein.
Licensee
- 1. Pacific Gas and Electric Company
- 3.
License No.
SNM-2511 Amendment No.
0
- 2. Oiablo Canyon Power Plant P.O. Box56 Avila Beach, CA 93424
- 4.
Expiration Date March 22, 2024
- 5.
Docket or 72-26 Reference No.
- 6. Byproduct, Source, and/or Special Nuclear Material
- 7. Chemteal and/or Physical Fonn
- 8. Maximum Amount That Licensee May Possess at Any One Time Under This License A.
Spent nuclear fuel from the A.
O,ablo Canyon Power Plant, Units 1 & 2, and associated radioactive materials related to receipt, transfer and storage of the fuel assemblies.
Spent fuel assemblies as A.
UO,. clad with zirconium alloy.
Damaged fuel assemblies or 2100 MTU of intact spent fuel assemblies, damaged fuel assemblies and fuel debris.
- 9.
- 10.
- 11.
- 12.
fuel debris as uo,. contained in Damaged Fuel Containers.
Authorized Use: The material identified in 6.A. and 7.A. above is authorized for receipt, possession, storage and transfer using the HI-STORM 100 dry cask storage system design as described in the Diablo Canyon ISFSI Safety Analysis Report dated December 21, 2001, as revised or supplemented on October 15, 2002, and October 3, 2003, a.nd as further supplemented and amended in accordance with 10 CFR 72.70 and 10 CFR 72.48.
Authorized Place of Use: The licensed material is to be received, possessed, transferred and stored at the Diablo Canyon ISFSI located on the Diablo Canyon Power Plant site in San Luis Obispo County, Califomia, near Avila Beach, California.
The Technical Specifications contained in the Appendix attached hereto are incorporated into the license. The licensee shall operate the installation in accordance with the Technical Specifications in the Appendix. The Appendix contains Technical Specifications related to environmental protection to satisfy the requirements of 10 CFR 72.44(d)(2).
The licensee shall follow the physical protection plan entitled..., "Oiablo Canyon Power Plant Physical Security Plan*, dated April 18, 2002, as revised January 31, L003, and the Safeguards Contingency Plan and the Guard Training and Qualification Plan incorporated therein, and as they may be further amended under the provisions of 10 CFR 72.44(e) and 10 CFR 72.180.
12
E.
The Ultimate NEPA Violation.
Holtec wants to build and operate a private, untested and untried, away-from-reactor, nuclear waste storage facility in the U.S.
Holtec tells us it would be the first in the U.S. (see page 5).* It's not known why NRC arid SwRI's CNWRA employees didn't do the most basic thing of all. Write an environmental impact statement (EIS) for Holtec's proposed nuclear waste storage facility.
As unbelievable as it is, NRC and SwRI's CNWRA employees wrote a report instead of the EIS they were required to write to comply with NEPA. I've never seen anything li~e it in my 30-year career with the government. It's the ultimate NEPA violation.
F.
NRC and CNWRA Staff Tells US They Didn't Write an EIS.
NRC and SwRI's CNWRA staff tells us, they wrote a Final Report, on the cover ofNRC's 2022 EIS for Holtec. (The NEPA regulations [40 CFR §1502.ll(d)] tell employees to identify the final document as a final EIS, not a final report.) NRC and SwRI's CNWRA staff tells us, on the cover. They completed work on a manuscript in July 2022. (You won't see the word manuscript in (1)
NEPA, (2) the NEPA regulations, (3) NRC's NEPA regulations, or (4) EISs.) NRC has its own set ofNEPA regulations (10 CFR 51).
NRC and SwRl's CNWRA staff tells the public, and the courts, they did the same thing for ISP' s proposed nuclear waste storage facility. They wrote a report instead of the EIS they were required to write to comply with *NEPA.
This is an unbelievable unimaginable NEPA violation. See the cover on NRC's illegal 2021 and*2022 EISs written for Interim Storage Partners and Holtec International (see Exhibits 6 and 7).
The best proof, an EIS wasn't written for Holtec's nuclear waste storage facility, is an NRC EIS written for Private Fuel Storage.
It was written for the first application for the first of its' kind, private, away-from reactor, nuclear waste storage facility. The EIS was 13
Exhibit 6.
Manuscript and Final Report Completed July 2022 for Holtec. It's not a final EIS.
~U.S.NRC Pro1rr11ng Proplr nnd the £,wironmr,11 This isn't a Final EIS.
Environmental Impact Statement for the Holtec lnternational's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico Final Report A final report doesn't take the place of a Final EIS.
Manuscnpt Completed-July 2022 Date Published* July 2022
... Prepared by U S Nuclear Regulatory Comm,ss,on u _s. Bureau or Land Management Carlsbad Field Office Carlsbad. New Mex100 Office of N uclear M aterial Safety and Safeguards 14 NUREG -2237
Exhibit 7.
Manuscript and Final Report Completed July 2021 for ISP. It's not a final EIS.
~U.S.NRC Protecting People and the Environment This isn't a Final EIS.
Environmental Impact Statement for Interim Storage Partners L LC's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas
... Final Report A final report doesn't take the place of a Final EIS.
... Manuscript Completed: July 2021 Date Published: July 2021 Office of Nuclear Material Safety and Safeguards 15 NUREG-2239
completed in 2001. The information, in NRC's 2001 EIS, is the information that needed to be.in NRC's 2021 and 2022 EISs.
See the cover, for the EIS written for PFS, in Exhibit 8. To date, the only EIS written for the (three) first of their kind, private, away-from-reactor, nuclear waste storage facilities, is NRC's 2001 EIS.
G.
Moving Spent Nuclear Fuel is Missing From NRC's 2022 EIS.
When you write an EIS, you tell the public everything a company plans on doing. Holtec's plans, for its business, are in the Environmental Report submitted to NRC. (Business proposals, submitted by companies, are called Proposed Actions in EISs.
Holtec's plans, for its business, are in (what's called) an NRC Proposed Action in NRC's 2022 EIS.)
The most important information, in Holtec's Environmental Report, is moving spent nuclear fuel from 12 power plants or reactors to its business in southeast New Mexico. NRC employees didn't put this information in NRC's 2022 EIS. It's not known why. It's a huge, unbelievable NEPA violation.
There are a few sentences, in NRC's 2022 EIS, Holtec will move spent nuclear fuel from multiple nuclear facilities. It's stated on page 2-2. "For the initial and subsequent phases of the proposed CISF, SNF would.be received from operating, decommissioning, and decommissioned reactor facilities."
NRC employees didn't include the table (in NRC's 2022 EIS),
listing the 12 power plants or reactors, in Holtec's Environmental Report. On the other hand, there's a lot of information, on moving spent nuclear fuel from eight power plants or reactors to PFS's proposed nuclear business, in NRC's 2001 EIS (see Exhibit 9).
For people, experienced in writing EISs, it appears this information was left out ofNRC's 2022 EIS. Because this information isn't in NRC's EIS, a huge part of (what's called) the NRC Proposed Action is missing froin NRC's 2022 EIS. Next to writing a report instead of an EIS, this is the next, worst NEPA violation.
16
Exhibit 8.
Correct Cover for a Final EIS. You're told it's a final EIS on the cover.
- Final Environmental Impact Statement for the Construction and Operation of an Independent Spent Fuel Storage Installation on the Reservation of the Skull Valley Band NUREG-1714 Vol. 1 of Goshute Indians and the Related Transportation Facility in Tooele County, Utah Docket No. 72-22 Private Fuel Storage, L.L.C.
U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards U.S. Bureau of Indian Affairs U.S. Bureau of Land Management U.S. Surface Transportation Board December 2001 17
Exhibit 8 ( continued).
Final EIS is oted at the Top of Most of the Pages in NRC's 2001 EIS.
Purpo e and eed government relationship with, and trust responsibility (including consideration of environmental impacts) to the Skull Valley Band. This difference has ramifications for the scope of BIA's NEPA review and the range of the BIA's reasonable alternatives. As part of its government-to-government relationship with the Skull Valley Band, BIA's NEPA review is limited to the scope of the proposed tease negotiated between the parties, not evaluation of actions outside the lease (e.g., ultimate disposition of the SNF). Similarly, the range of BIA's reasonable alternatives is limited to those that will serve the Skull Valley Band's economic development, consistent with the BIA's trust responsibility [i.e.,
the approval of the proposed PFSF site location(s) on the Reservation, or no action-disapproval of the lease}. PFS has identified an alternative site location on the Reservation (see Section 2.2.3). If BIA identifies this alternative site as the preferred alternative, it would require the Skull Valley Band and PFS to amend the proposed lease.
... 1.5.3 BLM Fede ral Actio n 1.5.3.1 Rights-of-Way and Resource Management Planning By letter dated August 28, 1998, PFS applied to BLM for separate rights-of-way to provide transportation routes from the Interstate 80 corridor to the proposed PFSF site on the Reservation.
T he applicant's preferred route is a rail line from Skunk Ridge along the base of the Cedar Mountains on the western side of Skull Valley, then east to the proposed site (Figure 1.2). The alternative transportation mode is an ITF located 2.9 km (1.8 miles) west of the intersection of 1-80 and Skull Valley Road (see Section 2.2.4.2). At the ITF, SNF would be transferred from railcars to heavy-haul vehicles and transported to the proposed PFSF via the Skull Valley Road.
The location of either the rail corridor or the ITF would occupy public land that is included within the BLM Pony Express resource management plan (RMP). The decisions in the current RMP do not provide for a major right-of-way, such as a rail line, along the west side of Skull Valley. The PFS proposal would, therefore, require an amendment to the RMP, Transportation and Utility Corridor Decision 1, prior to BLM granting the rail line right-of-way. The amendment would add an exception to the resource management plan decision to allow the construction and use of the proposed rail line outside the established corridors. This FEIS will serve as the NEPA document for BLM's determinations with respect to granting a right-of-way and the proposed plan amendment, should BLM approve the rail line right-of-way.
The following planning criteria have been established by BLM to guide the development of the amendment to the Pony Express RMP:
The Plan will address only BLM lands administered by the Salt Lake,Field Office and will not address private lands or lands administered by other government agencies.
Coordination and cooperation across interagency administrative boundaries will take place in both planning and implementation.
The public will have an opportunity to provide information and recommendations on the proposal and to review and comment on the proposed action before a final management decision.
Social and economic impacts to local communities resulting from public land management will be considered.
BLM's action-dependent on NRC issuing a license and BIA approving a lease-is to issue a right-of-way grant under 43 CFR Part 2800 for the rail line, or for the ITF, or to deny both applications.
If the rail line alternative is selected, BLM would require resolution of a planning restriction imposed by 1-17 RE - 17J4 18
Exhibit 9.
Moving Spent uclear Fuel From Eight Power Plants or Reactors to Private Fuel Storage's uclear Business.
- 1. PURPOSE AND N EED 1.1 Introduction Private Fuel Storage L.L.C. (PFS). a limited liability company owned by eight U.S. electric power generating companies. proposes to construct and operate a privately-owned independent spent fuel storage installation (ISFSI) on the Reservation of the Skull Valley Band of Goshute Indians (Reservation) (see Figure 1. 1 ). The Reservation is bordered on all sides by Tooele County, Utah. To transport spent nuclear fuel (SNF) to the ISFSI, PFS proposes to construct and operate a rail siding and rail line on land managed by the U.S. Department of Interior's Bureau of Land Management (BLM). The project, as proposed, requires approval from four Federal agencies: the U.S. Nuclear Regulatory Commission (NRC), the U.S. Department of Interior's Bureau of Indian Affairs (BIA) and BLM, and the U.S. Surface Transportation Board (STB). The NRC. BIA, BLM, and STB (the Cooperating Federal Agencies) have cooperated in the preparation of this final environmental Impact statement (FEIS).
This FEIS evaluates the potential environmental effects of the ISFSI proposed by PFS, including the construction and operation of new transportation facilities that would provide access to the proposed ISFSI. and a consideration of alternatives to that proposal. This FEIS has been prepared in compliance with the National Environmental Policy Act of 1969 (NEPA), NRC regulations for implementing NEPA (10 CFR Part 51), and the guidance provided by the Council on Environmental Quality (CEO) regulations implementing the procedural provisions of NEPA (40 CFR Part 1500).
1.2 The Proposed Action The proposed action would include construction and operation of the proposed ISFSI (also called the Private Fuel Storage Facility (PFSF)), including transporting SNF to the proposed PFSF. and the construction of a rail line from Skunk Ridge to the proposed PFSF s ite (see Figure 1.2 for project locations).
The proposed PFSF would be constructed and operated on the Reservation at a location 93 km (58 miles) straight-line distance southwest of Utah's State Capitol Building [or about 120 km (75 miles) by road] and approximately 44 km (27 miles) west-southwest of Tooele, Utah (see Figure 1.1). PFS proposes to build the ISFSI on a 330-ha (820-acre) site teased from the Skull Valley Band of Goshute Indians (Skull Valley Band). The site (designated Site A) would be located in the northwest corner of the Reservation approximately 6 km (3.5 miles) from the Skull Valley Band's village.
T he proposed PFSF would be designed to store up to 40,000 metric tons of uranium (MTU}
(44,000 tons) of SNF. The capacity of the proposed PFSF would be sufficient to store all the SNF from the PFS membej companies, as well as some S N F from nuclear power reactor licensees that are not members of The eight members of PFS are Entergy Corporation, Southern California Edison Company, Genoa FuelTech, Inc., Indiana-Michigan Company (American Electric Power), Florida Power and Light Company, GPU N uclear Corporation (which does not plan to use the proposed PFSF for storage), Xcel Energy Inc., and Southern Nuclear Operating Company. (Previous members of PFS listed in the DEIS, but not listed above, have been renamed, acquired by, or merged with other companies.) The locations of their reactors are shown in Figure 1.3.
1-1 NUREG-1714 19
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t>I *
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.b.
Son Onofre (SC)
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JM
" lndlono-Mlchlgan Powor SC "Southern California Edison SN " Southern Nuclear Operating Co.
XL
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/
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-Turkey Point (FPL)
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This NEPA violation, if an EIS had been written,*would have caused the failure of the EIS. As it is, it's an unbelievable error in a worthless report. The report can't be used for anything. The report couldn't be used to issue an NRC license to Holtec International.
H.
NRC's EIS Was Written for Three Years of a 40-Year Business.
Holtec wants to expand its business in years 2 thru 20 (Phases 2-20). Holtec's planned expansion is in Holtec's Environmental Report. Although mentioned in NRC's 2022 EIS, Phases 2 thru 20 were excluded from NRC's 2022 EIS (see Exhibit 10). Why?
We're told NRC's 2022 EIS was written-*for the action pending before NRC at the time-NRC's 2022 EIS was written. This is noted on page 2-1 ofNRC's 2022 EIS (see Exhibit 10). What was the action? It's the approval of an NRC license for Phase 1 ofHoltec's proposed nuclear waste storage business.
What about the next 19 years ofHoltec's business?
We're told, when Holtec submits an application, to amend its license for a second year of business (Phase 2), say in 2027. That will be the action pending before NRC at that time. Holtec's application would be processed in 2027. Therefore, the second year ofHoltec's business (Phase 2) was illegally excluded from NRC's 2022 EIS. The same thing happened for years 3 thru 20 (Phases 3-20). They were illegally excluded from NRC's 2022 EIS. The most important words, in this fatally flawed approach to writing NRC's 2022 EIS, are "action pending before NRC."
NRC's illegal 2022 EIS ends up being written for the first three years ofHoltec Intemational's planned 40-year business. It's unbelievable NRC and SwRI's CNWRA employees wrote a 736-page report for (1) one year of business and (2) storing 500 canisters, of Holtec's proposed 10,000 canisters, at Holtec's proposed 40-year business. Holtec' s proposed business would be located aboutl 5 miles north of the low-level nuclear waste storage facility at the existing Waste Isolation Pilot Plant (WIPP) in southeast New Mexico.
21
Exhibit 10.
Amendments (Phases 2 thru 20) Illegally Excluded From NRC's 2022 IS.
2 PROPOSED ACTION AND ALTERNATIVES 2.1 Introduction By letter dated March 30, 2017, the U.S. Nudear Regulatory Commission (NRC) received an application from Holtec International (Holtec) requesting authorization to construct and operate a consolidated interim storage facility (CISF) for spent nuclear fuel (SNF) and Greater-Than-Class C waste in Lea County, New Mexico (Holtec. 2017). The application included an Environmental Report (ER) (Holtec, 2020a) and Safety Analysis Report (SAR) (Holtec, 2020b).
The proposed Holtec CISF would provide an option for away-from-reactor interim storage of SNF and Greater-Than Class C waste as well as a small quantity of mixed oxide fuel from nuclear power reactors (collectively referred to in this document as SNF), before a permanent repository is available. Holtec prepared the license application in accordance with requirements in Trtle 1 o of the Code of Federal Regulations ( 10 CFR). Part 72, Ucensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. This environmental impact statement (EIS) was prepared consistent with NRC's National Environmental Policy Act (NEPA)-implementing regulations contained in 10 CFR Part 51,
- Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functionsn and the NRC staff guidance in NUREG-1748.
-environmental Review Guidance for Licensing Actions Associated with NMSS Programs" (NRC, 2003).
Descriptions of the proposed action and alternatives to the proposed action are provided in the following sections for use in developing the EIS. The sections discussed include (i) the proposed action; (ii) reasonable alternatives to the proposed action to be analyzed in detail in the EIS; and (iii) additional alternatives that were considered in the EIS but eliminated from detailed analysis, including reasons for elimination. The reasonable alternatives to the proposed action considered in the discussion below include the
- No-Action" alternative (i.e., the license would not be authorized). as NEPA requires_
2.2 Alternatives Co nsidered for Detailed Analysis 2.2.1 The Proposed Action The proposed action is the issuance, under the provisions of 10 CFR Part 72, of an NRC license authorizing the construction and operation of the proposed Holtec CISF in southeastern New Mexico at a site located approximately halfway between the cities of Carlsbad and Hobbs, New Mexico. Holtec requests authorization for the initial phase (Phase 1) of the proposed project to store 5,000 metric tons of uranium (MTUs) [5,512 short tons} in 500 canisters for a license period of 40 years. However, because the capacity of individual canisters can vary, the 500 canisters proposed in the Hottec license application have the potential to hold up to 8,680 MTUs [9,568 short tons]. Therefore, the analysis in this EIS and in the corresponding safety review will analyze the storage of up to 8,680 MTUs [9,568 short tons) for Phase 1.
Holtec anticipates subseq~
requesting amendments to the license to store an additional 5,000 MTUs [5,512 short tons( for each of 19 expansion phases of the proposed CISF to be completed over the course of 20 years to expand the facility to eventually store up to
...!.QJ)OO canisters of SNF (Holtec, 2020a,b}. Holtec's expansion of the proposed project Phases 2-20) is not part of the proposed action currently pending before the agency_
However, the NRC staff considered these expansion phases in its description of the affected 2-1 22
I.
Missing U.S. Bureau of Land Management.
NRC and SwRI's CNWRA staff tells us on the cover ofNRC's 2022 EIS. The EIS was prepared by NRC, Bureau of Land Management (BLM), and Carlsbad Field Office (see page 14).
For the public, and the court, who don't know anything about Holtec's plans. Holtec needs to obtain a BLM right-of-way permit for a short segment of railroad built on BLM land, what Holtec calls a rail spur. There's basically one sentence about BLM's role in Holtec's proposed 40-year business { see Exhibit 11 ).
Having worked for BLM for 30-years, this isn't a BLM Proposed Action. It's a proposed decision for (what's called) a Record of Decision. The statement is wrong. BLM wouldn't approve Holtec' s Plan of Operations. NRC has to do that. BLM has to approve a right-of-way permit for Holtec's proposed five-mile long rail spur.
Based on my 30-year career with BLM, it looks like. BLM employees didn't have anything to do with the one sentence BLM Proposed Action in NRC's 2022 EIS. It's no wonder it is wrong.
(CFO employees finished work on a draft EIS, for CFO, in 2018.)
There's a BLM Proposed Action in NRC's 2001 EIS (see page 18). It's the proposed action that needed to be in NRC's 2022 EIS. It would have been a simple thing to use the BLM Proposed Action ( as an example) for the BLM Proposed Action in NRC's 2022 EIS. Having looked at NRC's 2001 EIS, it appears NRC employees didn't use NRC's 2001 EIS to write NRC's 2022 EIS. (I would have used a lot of the 2001 EIS).
It's noted on the cover ofNRC's 2022 EIS. BLM employees were involved in the preparation ofNRC's EIS. There isn't any information in NRC's 2022 EIS. BLM employees had anything to do with it. If they had, their names should have been in the List of Preparers in NRC's 2022 EIS.
The end result is the fact. Thirty-seven (37) years, ofHoltec's proposed 40-year business, are missing from NRC's 2022 EIS.
23
Exhibit 11.
NRC Approves Holtec's Plan of Operations, Not BLM.
where appropriate, when the environmental impacts of the potential future expansion can be determined so as to conduct a bounded analysis for the proposed CISF project. The NRC staff conducted this analysis as a matter of discretion because Holtec provided the analysis of the environmental impacts of the future anticipated expansion of the proposed facility as part of its license application (Holtec, 202oa,b). For the bounding analysis, the NRC staff assumes the storage of up to 10,000 canisters of S NF. During operation, the proposed C ISF would receive SNF from decommissioned reactor sites. as well as from operating reactors prior to decomm issioning. The CISF would serve as an interim storage facility before a permanent geologic repository is available.
The NRC has previously licensed a consolidated spent fuel storage installation (Private Fuel Storage}, and NRC regulations continue to allow for licensing private away-from-reactor interim spent fuel installations (e.g., G.E. Morris) under 10 CFR Part 72. For more information on the NRC 's regulation of spent fuel transportation. see https://www.nrc.gov/waste/spent-fuel-transp.html.
1.2.2 U.S. Bureau of Land Management (BLM) Proposed Action Holtec proposes buildi1 g a rail spur across SLM-managed lands to connect existing rail lines to the proposed CISF The BLM's Federal decision is to either approve H oltec's Plan of Operations (pending submission), subject to mitigation in. luded in the Holtec license application and this EIS, or deny approval of the Plan of Operations found that Holtec's proposal would result in unnecessary or undue degradation of the public lands. The total amount of SLM-managed land expected to be disturbed by Holtec for construction and operation of the rail spur would be 15.9 hectares (ha) [39.4 acres (ac)]. The rail spur would be routed across SLM-managed land west of the proposed CISF project an d would not cross any major highways (Holtec, 2020a). A site access road would also be constructed across SLM-managed land from the proposed C ISF project sou thward to U.S. Highway 62/180 and would be approximately 1.6 kilometers (km) [1 mile (mi)] in length. Construction of the rail spur and site access road would require right-of-way approval on Federal lands from BLM.
1.3 Purpose and Need for the Proposed Action 1-3.1 NRC Purpose and Need T he purpose of the proposed Holtec CISF is to provide an option for storing SNF from nuclear power reactors before a permanent repository is available. SNF would be received from operating. decommissioning, and decommissioned reactor facilities.
The proposed CISF is needed to provide away-from-reactor S N F storage capacity that would allow SNF to be transferred from existing reactor sites and stored for the 40-year license term before a permanent reposit ory is available. Additional away-from-reactor storage capacity is needed, in particular, to provide the option for away-from-reactor storage so that stored SNF at decommissioned reactor sites may be removed so the land at these sites is available for other uses.
The Nuclear Waste Policy Act of 1982 required the Federal government to site, build, and operate a geologic repository for high-level radioactive waste (HLW) and spent fuel by the mid-1990s. Several factors have contributed to the delay, but in 2003 the U.S. Department of Energy (DOE) reaffirmed the Federal Government's commitment to the ultimate disposal of the spent fuel and predicted that a repository would be available by 2048 (DOE. 2003). The delay 1-2 24
BLM's Proposed Action is also missing from NRC's 2022 EIS. I've.
never seen anything like it in my 30-year career with BLM.
BLM' s missing Proposed Action resulted in more unbelievable NEPA violations. Italso resulted in violations of the Federal Land
- Policy and Management Act (FLPMA) of 1976. If an EIS had been written, these violations would have caused the failure of the EIS.
The public, and the U.S. Supreme Court, need to know and understand. The BLM right-of-way permit is the key to what Holtec wants to do. Holtec can't use its expensive and expanding nuclear waste storage facility, if it doesn't.have a (BLM approved) rail spur to transport spent nuclear fuel to its business. And here, all the BLM
. information is_missing from NRC's 2022 EIS.
J.
Only 1,080 Acres.
It appears NRC and SwRI's CNWRA employees limited the area of consideration for analyzing impacts to (1) Holtec's facility (1,040 acres), (2) a five-mile long rail spur (39 acres), and (3) a mile long road (1 acre) (see Exhibit 12). It's illegal to do this~ This resulted in more NEPA and FLPMA violations.
The best example, NRC and SwRI's CNWRA employees limited the area of consideration for impact analyses, can be shown on two maps. Major Parks and Recreation Areas are shown in Figure 3.2-5 ofNRC's 2022 EIS (see Exhibit 13). Holtec's proposed facility is in the circle. A Google map shows the points of interest (recreation) in the vicinity ofHoltec's proposed facility (see Exhibit 14).
For people, experienced in writing EISs, it appears. NRC and SwRI's CNWRA employees left recreation information out ofNRC's 2022 EIS. By focusing, on Major Parks and Recreation Areas, NRC and SwRI's CNWRA employees made it look. Like there wouldn't be impacts to recreation from Holtec' s proposed nuclear business.
25
Exhibit 12.
Impact Analysis May Have Been Limited to Holtec's Facility, Rail Spur, and a Road.
3.2.1 Surface and Subsurface Property Rights The Eddy-Lea Energy Alliance (ELEA) currently owns the surface rights to property within the proposed CISF project area. ELEA is a limited liability company jointly owned by Eddy and Lea counties and the cities of Carlsbad and Hobbs (Holtec. 2020b). In April 2016. Holtec and ELEA executed a memorandum of agreement (MOA) describing the design. licensing. construction, and operation of the proposed CISF and the terms by which Holtec could purchase the surface rights to property within the proposed project area (ELEA, 2016}. On July 19, 2016, the New Mexico Board of Finance (NMBF) approved the sale of the surface property rights to Holtec (NMBF. 2016). Holtec h as committed to purchasing the surface property rights from ELEA (Hallee, 2020a, 2019a) if NRC licenses the proposed CISF.
Surface rights to property surrounding the proposed CISF project area are either privately-owned or owned by the SLM or the State of New Mexico (EIS Figure 3.2-1 ). Split estate occurs on privately-owned land within and surrounding the proposed CISF project area. Split estate is an estate where property rights (or ownership) to the surface and the subsurface are split between two parties. The State of New Mexico owns the subsurface property rights (commonly referred to as m ineral rights) wit.hin the proposed CISF project area, and BLM or the State of New Mexico owns subsurface property rights on privately-owned surface estate surrounding the proposed C ISF project area (EIS Figure 3.2-2).
BLM
~:!:'e~fNew Figure 3.2-1
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NM Hwy c:::::J County l-US Hwy 0-1=2--=
=:::,,o--e t<,-e,s Surface Property Rights Ownership Within and Surrounding the Proposed CISF Project Area (Source: BLM, 2012a) 3-2 26
Exhibit 13.
Recreation Information Missing From NRC's 2022 EIS.
Holtec's proposed nuclear waste storage facility is in the circle.
the Brantley Dam. Avalon Reservoir located 4.8 km (3 mi) north of Carlsbad is a shallow 27-ha
[66-ac] lake on the Pecos River, and the New Mexico Depanment of Game and Fish (NMDGF)
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Figure 3.2--.Major Parks and Recreat.ional Areas in the Vicinity of the Proposed CISF Project Area (Modif"led from ELEA, 2007) stocks It for fishing. The W.S. Huey Waterfowl Area, located northeast of Artesia, is a stopping and resting area for migrating waterfowl, including sandhill cranes and snow geese. Green Meadow Lake Fishing Area, located north of Hobbs, the NMDGF stocks for fishing. l ocal parl<s and recreational facilities (e.g.. sport complexes, swimming pools, golf courses, hiking and biking trails, shooting ranges, and lakes) are also maintained by the cities of Carlsbad, Hobbs, Artesia, and Lovington.
3 2.4 Mineral Extraction Activities Mineral extraction in the area of the proposed CISF project area consists of underground potash mining and oil and gas extraction (EIS Section 4.4.1.2) (Holtec, 2020a,b). As described in EIS Section 3.2.1, BLM or the State of New Mexico owns the mineral rights (potash and oil and gas) beneath the proposed CISF project area and surrounding area. These minerals are leased to production companies for development The BLM administers mineral leases on mineral estate owned by the United States Government. and the New Mexico State Land Office administers mineral leases on mineral estate owned by the State of New MeJCico.
3-6 27
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Nine CNWRA Employees Assigned to Write Two EISs at the Same Time.
NRC and SwRI's CNWRA employees committed unbelievable unimaginable NEPA violations not once, but twice. They wrote two reports instead of two EISs for Holtec's and ISP's proposed nuclear waste storage facilities. Questions have to be asked about the decisions made by NRC managers (1) Jill Caverly, (2) John Cuadrado-Cabarallo, (3) Stacey Imboden, (4) James Park and (5)
Diane Diaz-Toro (see Exhibits 15 and 16).
Nine NRC employees, in SwRI' s Center for Nuclear Waste Regulatory Analysis (CNWRA), were assigned the job ofwriting an EIS for Holtec's proposed facility. They were also assigned the job of writing an EIS, for ISP's proposed nuclear facility, at the same time they were writing Holtec' s EIS. See information about the Southwest Research Institute (SwRI) and CNWRA in Exhibits 17 and 18.
NRC managers gave nine CNWRA employees the impossible job of writing two EISs at the same time. It's important to note. It usually takes two years to write _a draft EIS and two years to write a final EIS before NRC licenses can be issued.
A much larger team-like the team that wrote NRC's 2001 EIS-writes one EIS, never two EISs at a time. How many people were involved in the preparation ofNRC's 2001 EIS? Seventy-five (75) people worked on NRC's 2001 EIS. Thirty-five people worked on the last EIS, I worked on, for BLM.
The names, of the NRC managers and SwRl's CNWRA employees, are in the List of Preparers in (1) NRC's 2021 EIS for ISP and (2) NRC's 2022 EIS for Holtec (see Exhibits 15 and 16). For
- comparison purposes, see the List of Preparers for a draft EIS written by the Carlsbad Field Office (see Exhibit 19).
An insignificant NEPA regulatory requirement, to list the names of people who prepare EISs, turns out to be the answer. Why the NRC committed unbelievable unimaginable NEPA violaJions two 29
Exhibit 15.
List of Preparers in NRC's 2022 EIS Written for Holtec.
~U.S.NRC Uniu*d Su1c,, Nudc-:u R~ul.110,y Coru m, ~,or>
llrotecti11g Peopk.n,ul llH E11vironnu1u Environmental Impact Statement for the Holtec l*nternational's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico Final Report Manuscript Completed July 2022 Date Published July 2022 Prepared by U S Nuclear Regulatory Commission US. Bureau of Land Management Car1sbad Field Offtce Carlsbad New Mex,co Office of Nuclear Material Safety and Safeguards 30 NURE0-2237
Exhibit 15 ( continued).
It's not known why people are listed as contributors. I've never seen that in a List of Preparers. The employees, in CNWRA, wrote NRC's 2021 EIS for ISP.
10 LIST OF PREPARERS This section documents all individuals who were involved with the preparation of this final Environmental Impact Statement (EIS). Contributors include staff from the U.S. Nuclear Regulatory Commission (NRC) and consultants. Each individual's role, education, and experience are outlined next.
10.1 U.S. Nuclear Regulatory Commission Contributors Jill Caverly: Environmental Project Manager B.S., Civil Engineering, George Washington University, 1992 M.8-, Civil Engineering, George Washington University, 1996 Years of Experience: 28 Jose Cuadrado-Caraballo: Safety Project Manager B.S., Chemical Engineering, University of Puerto Rico, Mayaguez Campus, 2002 M.B.A., Finance, University of Maryland, College Park, 2007 Years of Experience: 19 Stacey Imboden: Environmental Project Manager B.S., Meteorology, Pennsylvania State University, 1999 M.S., Environmental Engineering, Clemson University, 2001 Years of Experience: 20 10.2 Center for Nuclear Waste Regulatory Analyses (CNWRA) Contributors Nathan B. Hall: Waste Management B.S., Fire Protection Engineering, University of Maryland, 2006 M.B.A., Business Administration, Johns Hopkins University, 2012 Years of Experience: 15 Taylor Holt: Water Resources, Cumulative Impacts B.S., Biological and Agricultural Engineering, Texas A&M University 2014 M.E., Biological and Agricultural Engineering, Texas A&M University 2017 Years of Experience: 5 Lane Howard: National Environmental Policy Act (NEPA) Reviewer, Public and Occupational Health B.S., Civil Engineering, Texas A&M University 1988.
M.S., Nuclear Engineering, Texas A&M University 1995.
Years of Experience: 33 Miriam Juckett: Senior Program Manager, NEPA Reviewer, Public Outreach, Waste Management B.S., Chemistry, University of Texas at San Antonio, 2003 M.S., Environmental Sciences, University of Texas at San Antonio, 2006
' Years of Experience: 18 10-1 31
I Exhibit 15 ( continued).
Maybe 'contributors' is noted for contributions to NRC's 2022 manuscript-report.
Patrick LaPlante: Transportation, Public and Occupational Health B.S., Environmental Studies, Western Washington University, 1988 M.S., Biostatistics and Epidemiology, Georgetown University, 1994 Years of Experience: 32 Amy Hester Minor: Ecological Resources, Socioeconomics, Environmental Justice B.A., Environmental Studies, University of Kansas, 1998 Years of Experience: 22 Marla Morales: Principal Investigator, Land Use, Noise, Visual and Scenic, Geology and Soils B.A., Geology, Vanderbilt University, 2001 M.S., Geology, University of Texas at San Antonio, 2007 Years of Experience: 20 James Prikryl: Geology and Soils, Water Resources B.S., Geology, University of Texas at Austin, 1984 M.A., Geology, University of Texas at Austin, 1989 Years of Experience: 36 Bradley Werling: Meteorology, Climatology, Air Quality, Cost Benefit B.A., Engineering Physics, Westmont College, Santa Barbara, 1985 B.S., Chemistry, Southwest Texas State University, 1999 M.S., Environmental Science, University of Texas at San Antonio, 2000 Years of Experience: 25 10.3 CNWRA Consultants and Subcontractors Hope Luhman: National Historic Preservation Act Section 106 Support B.A., Anthropology, Muhlenberg College, 1980 M.A., Social Relations, Lehigh University, 1982 M.A., Anthropology, Bryn Mawr College, 1988 Ph.D., Anthropology, Bryn Mawr College, 1991 Years of Experience: 32 Andrew Wilkins: Cultural and Historic Resources B.A., Historic Preservation, University of Mary Washington, 2006 M.A., Historical Archaeology, University of Massachusetts Boston, 2009 Ph.D., Anthropology, University of Tennessee, 2017 Years of Experience: 13 10-2 32
Exhibit 16.
List of Preparers in NRC's 2021 EIS Written for ISP.
<isu.S.NRC United States Nuclear Regulatory Commission Protecting People and the Environment Environmental Impact Statement for Interim Storage Partners LLC's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas Final Report Manuscript Completed: July 2021 Date Published: July 2021 Office of Nuclear Material Safety and Safeguards 33 NUREG-2239
Exhibit 16 ( continued).
It's not known why people are listed as contributors. I've never seen that in a List of Preparers. The employees, in CNWRA, wrote NRC's 2022 EIS for Holtec.
10 LIST OF PREPARERS This section documents all individuals who were involved with the preparation of this final Environmental Impact Statement (EIS). Contributors include staff from the U.S. Nuclear Regulatory Commission (NRG) and consultants. Each individual's role, education, and experience are outlined next.
U.S. Nuclear Regulatory Commission Contributors James Parle Environmental Project Manager; Contracting Officer's Representative (COR)
B.S., Geology, Virginia Polytechnical Institute and State University, 1986 M.S., Structural Geology & Rock Mechanics, University of London, England, 1989 Years of Experience: 26 Diana Diaz-Toro: Environmental Project Manager, Assistant COR B.S., Chemical Engineedng, University of Puerto Rico, 2001 M.B.A., Business Administration, American University, 2007 Years of Experience: 18 Center for Nuclear Waste Regulatory Analyses (CNWRA) Contributors Nathan B. Hall: Waste Management (Draft EIS)
B.S., Fire Protection Engineering, University of Maryland, 2006 M.B.A., Business Administration, Johns Hopkins University, 2012 Years of Experience: 13 Taylor Holt: Water Resources, Noise, Visual and Scenic (Final EIS), Cumulative Impacts S.S., Biological and Agricultural Engineering, Texas A&M University 2014.
M.E., Biological and Agricultural Engineering, Texas A&M University 2017 Years of Experience: 6 Lane Howard: Principal Investigator, National Environmental Policy Act (NEPA) Reviewer, Waste Management (Final EIS), Public and Occupational Health B.S.. Civil Engineering, Texas A&M University 1988.
M.S., Nuclear Engineering, Texas A&M University 1995.
Years of Experience: 33 Miriam Juckett: Senior Program Manager, NEPA Reviewer, Public Outreach S.S., Chemistry, University of Texas at San Antonio, 2003 M.S., Environmental Sciences, University of Texas at San Antonio, 2006 Years of Experience: 1 8 Patrick LaPlante: Transportation, Public and Occupational Health B.S., Environmental Studies, Western Washington University, 1988 M.S., Biostatistics and Epidemiology, Georgetown University, 1994 Years of Experience: 32 Amy Hester Minor: Ecological Resources, Socioeconomics, Environmental Justice B.A., Environmental Studies, University of Kansas, 1998 Years of Experience: 21 10-1 34
Exhibit 16 ( continued).
Maybe 'contributors' is noted for contributions to NRC's 2021 manuscript-report.
Marla Morales: Land Use, Geology and Soils B.A., Geology, '-'.'anderbilt University, 2001 M.S., Geology, University of Texas at San Antonio, 2007 Years of Experience: 20 James Prikryl: Noise (Draft EIS), Visual and Scenic (Draft EIS), Groundwater Resources B.S., Geology, University of Texas at Austin, 1984 M.A., Geology, University of Texas at Austin, 1989 Years of Experience: 30 Bradley Werling: Meteorology, Climatology, Air Quality, Cost Benefit B.A., Engineering Physics, Westmont College, Santa Barbara, 1985 B.S., Chemistry, Southwest Texas State University, 1999 M.S., Environmental Science, University of Texas at San Antonio, 2000 Years of Experience: 27 CNWRA Consultants and Subcontractors Hope Luhman: National Historic Preservation Act Section 106 Support B.A., Anthropology, Muhlenberg College, 1980 M.A., Social Relations, Lehigh University, 1982 M.A., Anthropology, Bryn Mawr College, 1988 Ph.D., Anthropology, Bryn Mawr College, 1991 Years of Experience: 33 Andrew Wilkins: Cultural and Historic Resources B.A., Historic Preservation, University of Mary Washington, 2006 M.A., Historical Archaeology, University of Massachusetts Boston, 2009 Ph.D., Anthropology, University of Tennessee, 2017 Years of Experience: 15 10-2 35
Exhibit 17.
CNWRA Employees Work for Southwest Research Institute (SwRI).
-,,
- WrKIPEDIA
\\\\
The Free Encyclopedia Southwest Research Institute Southwest Research Institute (SwRI). headquartered in San Antonio, Texas, is an independent and nonprofit applied research and development (R&D) organization. Founded in 1947 by oil businessman Tom Slick,[1) it provides contract research and development services to government and industrial clients.
Southwest Research Institute Description SOUTHWEST RESEARCH INSTITUTE Logo Abbreviation SwRI The institute consists of eleven technjcaJ divisions, The Center for Nuclear Waste Regulatory Analyses, a federally funded research and development center sponsored by the U.S.
Nuclear Regulatory Commission, also operates on the SwRJ grounds. More than 4,000 projects are active at the institute at any given time. These projects are funded between the government and commercial sectors. At the close of fiscal year 2021, the staff numbered approximately 3,000 employees an d research volume =as nearly $726 million. The institute provided more than $8 million to fund research through its internally sponsored R&D program.
Formation Founders Type Location Official language A partial listing of research areas includes space science and Revenue engineering; automation, robotics, and intelligent systems; avionics and support systems; bioengineering; chemistry and Employees chemical engineering; corrosion and electrochemistry; earth and p]anetaxy sciences; emissions resear ch; engineering Website mechanics; fire technology; fluid systems and machinery dynamics; and fuels and lubricants. Additional areas include 1947 Thomas Slick, Jr.
Independent research and development San Antonio, TeJCas, United States English Nearly $726 million (FY 2021)
Nearly 3,000 (FY 2021) swri.org (http:/fswr i.org/)
geochemistry; hydrology and geobydrology; materials sciences and fracture mechanics; nondestructive evaluation; oil and gas exploration; pipeline technology; surface modification and coatin gs; and vehicle, engine, and powertrain design, research, and development. In 2021, staff members published 872 papers in the technical literature and made 212 p resentations at technical conferences, seminars and symposia around the world; and submitted 48 invention disclosures; filed 46 paten t applications; and received 25 U.S. patent awards.
For 75 years, Southwest Research Institute has addressed challenges from deep sea to deep space and everywhere in between. For example, early work in submersibles has led to engineers developing re motely operated deep water rescue vehicles for the U.S. and Australian navies. SwRI is curren tly adapting extensive expertise in engines, fuels and lubricants for electrified powertrains 36
Exhibit 18.
Center for Nuclear Waste Regulatory Analyses (CNWRA) is one of 11 Divisions at SwRI.
Advanced science. Applied technology.
CENTER FOR NUCLEAR WASTE REGULATORY ANALYSES (CNWRA)
HomP (I) >> Industries >> Energy & Environment (/industry/energy-environment)
>> Environment (/industries/environment) >> Center for Nuclear Waste Regulatory Analyses (CNWRA)
N DAVID PICKETT, PH.D.
(/CONTENT/CLIENT-SERVICES-CONTACT-FORM?TID=S90&URL=INDUSTRIES/CENTER-NUCLEAR-WASTE-REGULATORY-ANAL YSES-CNWRA)
\\.
+1210522 5582 (tel:1210522 5582)
The Center for Nuclear Waste Regulatory Analyses (CNWRA ) is a federally funded research and development center that was established in 1987 by the U.S. Nuclear Regulatory Commission (NRC). The initial purpose of the CNWRA was to support licensing and regulatory oversight of the potential high-level radioactive waste repository at Yucca Mountain, NV. Over the past 30 years, the scope of the CNWRA support has grown to provide technical and programmatic assistance to 37
Exhibit 18 ( continued).
the NRC staff and their agency's m ission to protect public health and safety, and the environment.
The CNWRA offers the NRC, and other US and international regulatory agencies unique expertise related to nuclear power generation, transportation of radioactive materials, storage and disposal of radioactive waste, environmental assessments, safety evaluations of nuclear fuel-cycle facilities, and decomm issioning of nuclear facilities.
RELATED SERVICES
- Nuclear Fuel Cycle Evaluations (/taxonomy/term/601)
- Environmental Compliance (ltaxonomy/term/512)
- Water Resource Services (ltaxonomy/term/559)
(lindustry/center -n uclear-waste-regulatory-analyses-cnwra/center-nuclear-waste-regu latory-a na lyses)
Center for Nuclear Waste Regulatory Analyses (CNWRA) Services (lindustry/center-nuclear-waste-regulatory-analyses-cnwra/center-nuclear-w aste-regulatory-an alyses) 38
Exhibit 19.
List of Preparers in a 201 8 Draft EIS Written by BLM.
39
Exhibit 19 ( continued).
Draft Resource Management Plan/Envlronmen.tal Impact Statement Chapter 5: Consultation and Coordination List of Preparers 5.5 LIST OF PREPARERS Reviewers and preparers of the Draft RMP/EIS, including members of the Interdisciplinary Team, are listed in Table 5-5.
Table 5-5.
Draft RMP/EJS List of Preparers
~l'llame~ei:i,,.~a:0r:;l11t~~f?W.~f&i\\:1lf&li2ilf;'.,~t:.~ '.&!'title;:iaiid%o,¥.;Resp_onsi)iili *** '.,., *"'"'* '* 1' ;./,Y-.'il:biifr.: *.* -.. ~:>.... :;)1;,, *,
'* Carlsbad Field Office Interdiscit,linarv Team Bruce Boeke Archaeolo<nr and Cultural Resources Cassandra Brooks I Kelley Reid Wildlife Biologist Chelsie Dugan Hydrologist Christooher Wa11s Petroleum Enl?.ineer / Fluid Minerals Colleen Ceoero Rios Surface Protection Emily Metcalf/ Rolando Hernandez Geoirranhic Infonnation Systems Hector Gonzalez Planninl?. and Environmental Soecialist / RMP Team Lead Indra Dahal / James Rutlev Geolol?.V and Mineral Resources Katie Sandborn Botanist/ Soil/ Ve1?.etation / Noxious Weeds Kvle Rvbacki Cave / Karst Resources Michael Ramirez Ranl?.e I Grazing/ Soil /Vegetation/ Noxious Weeds Robert Gomez Realty Tracv Hu!!hes Recreation / Visual Resources / Travel Mana1?.ement I Wilderness TyeBrvson Fire Mana1?.ement
- Pecos District/ Carlsbad Field Office Mamu?:ement Tea in James Stova11 District Manager Kari Vasenden Associate Field Manager Ty Allen Assistant Field Manager. Resources Cody Lavton Assistant Field Mana1?.er, Minerals New Mexico State Office Mana2ement and Review Team Aden Seidlitz State Director (Acting)
Leslie HoUand Associate State Director (Acting)
Sheila Mallory / Michael Gibson Deputy State Director, Minerals / Branch Chief, Minerals Melanie Barnes / Sarah Schlanger Deputy State Director, Resources/ Branch Chief. Resources Bradlev Hiedon Plannim! and Environmental Coordinator (Actine)
Calvin Deal Geograohic Infonnation Svstems Michael Johnson Socioeconomics Terrv Heslin Recreation / Travel / NSHT Zoe Davidson Botany I A lM / Rare Plants Dave Herrell / Sharay Dixon Soil I Water /Air Resources Cvnthia Heman/ Phil Gensler Cultural Resources. Tribal Consultation / Paleontolol?.V McKinney Briske Wilderness / Visual Resources / NLCS John Shennan Wildlife / Riparian / Fisheries Nathan Combs Range and Weeds Mark Coca Forestrv / Healthy Lands Marikay Ramsey Wildlife Bioloeist / T&E Rebecca Hunt/ Meredith Camobell Fluid Mineral / Surface - Oil and Gas Stipulations Adrienne Brumlev Fluid Minerals / Geolol?.V Anthony Bates / William AubY Solid Minerals / Locatables / Salables Debby Lucero / Sarah Naranio Realtv LisaBve Fire and Fuels
. Consultant SWCA Environmental -Consultants BLM Carlsbad Field Office 5-8 40
. for Holtec. There are 12 BLM employees in the List of Reviewers in NRC's 2001 EIS (see Exhibit 20).
Assigning nine people to write two EISs at the same time-there was never any intent to write one, much less two legal EISs for the first of their kind, private, untested and untried, away-from reactor, nuclear waste storage facilities in the United States.
Information was left out ofNRC's 2022 EIS. There's more information in this report, about Holtec's plans to move spent nuclear fuel from 12 power plants or reactors, than is in NRC's 2022 EIS. It appears the missing information was meant to insure an NRC license would be issued to Holtec International. NRC's illegal 2022 EIS ends up being a justification statement instead of the environmental impact statement required by NEPA.*
II.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area,
. in Southeast New Mexico--West Texas.
NEPA required NRC and CNWRA employees address (1) ISP' s proposed nuclear waste storage facility, (2) Waste Control Specialists' (WCS's) existing nuclear waste storage facility, and (3) WIPP's existing nuclear waste storage facility in NRC's 2022 EIS written for Holtec. Why?
NEPA requires (what's called) cumulative impact analysis be conducted in EISs. You look at the impacts that could occur from (1) adding two new, nuclear waste storage facilities to (2) two existing nuclear waste storage facilities in close proximity to each other. When you look at where the four facilities would be located, four nuclear waste storage facilities would be in a 40-mile area in southeast New Mexico-west Texas. The two existing and two proposed nuclear waste storage facilities are shown in Exhibit 1 on page 50.
NRC and CNWRA employees were required to l.ook at the cumulative impacts of two existing and two proposed'nuclear facilities, in a 40-mile area, in southeast New Mexico. The information was left out ofNRC's 2022 EIS.
41
Exhibit 20.
List of Preparers and List of Reviewers in NRC's 2001 EIS.
Final Environmental Impact Statement for the Construction and Operation of an Independent Spent Fuel Storage Installation on the Reservation of the Skull Valley Band NUREG-1714 Vol. 1 of Goshute Indians and the Related Transportation Facility in Tooele *County, Utah Docket No. 72-22 Private Fuel Storage, L.L.C.
U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards U.S. Bureau of Indian Affairs U.S. Bureau of Land Management U.S. Surface Transportation Board December 2001 42
Exhibit 20 ( continued).
Thirty-seven in List of Preparers and 38 in List of Reviewers in NRC's 2001 EIS.
- 11. LIST OF PREPARERS AND COOPERATING AGENCY REVIEWERS 11.1 Preparers T. J. Blasing; Oak Ridge National Laboratory-Air Quality Modeling; Ph_D_, Meteorology, University of Wisconsin (Madison); M.S., Meteorology, University of Wisconsin (Madison); B.S., Meteorology, University of Wisconsin (Madison); 20 years experience in environmental assessment.
K. E. Bowman; Oak Ridge National Laboratory-Graphics and Document Preparation; CPS; 8 years experience in environmental document design and publishing.
S. A. Carnes; Oak Ridge National Laboratory-Socioeconomics; Ph.D., Political Science, Northwestern University; M_S_, Political Science, University of New Mexico; B.S., Chemistry, University of New Mexico; 21 years experience in socioeconomic and environmental impact assessment.
D. I. Chanin; Consultant-Accident Economic Costs; B.S. Mathematics, University of New Mexico; 18 years experience in reactor accident consequence modeling.
J. R. Cook, Nuclear Regulatory Commission-Transportation; M.S., Environmental and Industrial Health, The University of Michigan; B.A.. Chemistry, State University of New York at Oneonta; 25 years experience in radioactive materials regulation.
M. S. Delligatti; Nuclear Regulatory Commission-NRG Senior Project Manager; MPA, Public Administration, American University; B.A., Political Science, State University of New York (Oneonta); 17 years experience regulation and licensing of high-level nuclear waste and spent fuel storage facilities and systems.
C. E. Easterly; Oak Ridge National Laboratory-Human Health and Health Physics; Ph.D., Health Physics, University of Tennessee; B.S. Physics, Mississippi State University; 24 years experience in environmental impact assessment.
S. C. Flanders; Nuclear Regulatory Commission-NRG Technical Monitor/Environmental Project Manager; B.S., Mechanical Engineering, University of Maryland; 9 years experience in environmental assessment and nuclear regulation.
C. W. Hagan; Oak Ridge National Laboratory-Technical writing and editing; M.A., English, Virginia Tech; B.S. Biology, Virginia Tech; 18 years experience in technical report publishing.
T. Harris; Nuclear Regulatory Commission-Environmental; B.S., Civil engineering, University of Maryland; 12 years experience in environmental assessment.
M. Huskey; Oak Ridge National Laboratory-Document Preparation; Associate Secretarial Science, Knoxville Business College; 16 years experience in document preparation and publishing.
11-1 NUREG-1714 43
Exhibit 20 ( continued).
FINAL EIS-Preparers C. R. Hudson; Oak Ridge National Laboratory-CosUBenefit Analysis; MBA, University of Tennessee; B.S., Nuclear Engineering, University of Tennessee; 23 years experience in electric utility economics and cost/benefit evaluations.
P. E. Johnson; Oak Ridge National Laboratory-Transportation; M.S., Geography, University of Tennessee; B.A., Geography, University of Minnesota (Duluth); 20 years experience in transportation routing modeling.
R. S. Jolly; Nuclear Regulatory Commission-NRG Environmental Specialist; B.S., Environmental Science, Virginia Tech; 3 years experience in environmental assessment and nuclear regulation.
B. P. Kennedy; Science Applications International Corporation (SAIC)-EIS Review; B.A.,
- Environmental Planning and Design, California State University, Chico; 18 years experience in environmental planning and studies.
R. H. Ketelle; Oak Ridge National Laboratory-Geology and Hydrology; M.S., Geology, University of Tennessee; B.S., Geology; University of Tennessee; 20 years experience in environmental assessment.
R. R. Lee; Oak Ridge National Laboratory-Geology and Hydrology; M.S., Geology, Temple University; S.S., Geology, Temple University; 16 years experience in environmental assessment.
K. D. Leigh; Nuclear Regulatory Commission-Environmental Specialist; B.S., Environmental Sciences, Western Kentucky University; 3 years experience in environmental assessment and nuclear regulation.
R. J. Lewis; Nuclear Regulatory Commission-Transportation; M.S., Nuclear Engineering, University of Arizona; B.S., Physics, State University of New York at Fredonia; 8 years experience in nuclear regulation.
R. E. Luna; Consultant-Sabotage Analyses, Responses to DEIS comments; Ph.D., Aerospace and Mechanical Sciences, Princeton University; MSE, Mechanical Engineering, Princeton U.; B.S.
Mechanical Engineering, Rutgers University; 35 years experience in risk/safety assessment technology, 20 years related to radioactive materials transportation.
L. N. McCold; Oak Ridge National Laboratory-Project Management, Technical Integration and Peer Review; M.S., Mechanical Engineering, Oregon State University; B.S., Physics, Oregon State University; 17 years experience in environmental assessment.
R. L. Miller; Oak Ridge National Laboratory-Climatology and Air Quality; M.S., Meteorology, Pennsylvania State University; B.S., Meteorology, Pennsylvania State University; 17 years experience in environmental assessment.
NUREG-1714 11-2 44
Exhibit 20 ( continued).
The fact an EIS was written is at the top of most of the pages in NRC's 2001 EIS.
FINAL EIS-Preparer:,,,*
G. S. Mills; Sandia National Laboratories-lntermodal transfers, Responses to DEIS comments; Ph.D., Physics, University of Texas (Austin); B.S. Physics, University of Texas (Austin); 34 years experience in weapons research, radiation diagnostics, and radioactive materials risk assessment.
K. S. Neuhauser; Sandia National Laboratories-Responses to DEIS comments; Ph.D., Biology, Harvard University; M.S., Plant Pathology, University of Arizona; B.S., Botany, University of Arizona; 25 years experience in radioactive materials risk assessment.
P.R. Nickens; Pacific Northwest National Laboratory-Cultural Resources; Ph.D., Anthropology, University of Colorado; M.A., Anthropology, University of Colorado; B.A., Anthropology, University of Colorado; 25 years experience in cultural resource management and Native American consultation.
C. Poslusny Jr, Nuclear Regulatory Commission-Environmental Review Team; M.S. Management, Hood College; M.A., Economics, Florida Atlantic University; B.A., Mathematics, Florida Atlantic University; 26 years experience in nuclear regulation and project management.
W. J. Reich; Oak Ridge National Laboratory-Transportation; M.S., Nuclear Engineering, University of Missouri (Rolla); B.S., Nuclear Engineering, University of Missouri (Rolla); 8 years experience in transportation analysis and risk assessment.
M. S. Salk; Oak Ridge National Laboratory-Wildlife, Plant, and Wetland Ecology; Ph.D., Plant Ecology, University of Louisville; M.S., Botany, University of Iowa; B.A., Biology, Albion College; 25 years experience in environmental assessment.
M. J. Scott; Pacific Northwest National Laboratory--Socioeconomi.cs and Environmental Justice; B.A.,
Economics, Washington State University; M.A., Economics, University of Washington, Ph.D.,
Economics, University of Washington; 25 years experience in regional economic analysis and socioeconomics with an emphasis on environmental issues and social and economic impacts of major development projects, and approximately 5 years experience explicitly conducting environmental justice analyses.
L. B. Shappert; Oak Ridge National Laboratory-Transportation; M.S., Nuclear Engineering, University of Michigan; B.S. Chemical Engineering, University of Illinois; 38 years experience in transportation of radioactive materials.
J. L. Sprung; Sandia National Laboratories-Accident Source Terms, Responses to DEIS comments; Ph.D.,Chemistry, University of California (Los Angeles); BA, Chemistry, Yale University; 33 years experience in environmental chemistry and radioactive materials risk assessment.
G. F. Suber; Nuclear Regulatory Commission-NRG Project Manager; Masters in Environmental Science, Duke University; Master of Civil/Environmental Engineering, Howard University; B.S. in Mechanical Engineering, Howard University; 7 years experience in environmental research and impact assessment.
L. C. Suttora; Nuclear Regulatory Commission-Health Physicist; M.S. Biology, University of Michigan; B.S. Biology, Boston University; 10 years experience in environmental assessment and nuclear and hazardous waste management.
11-3 NUREG-1714 45
Exhibit 20 ( continued)
Twelve (12) BLM employees are in the List of Reviewers in NRC's 2001 EIS.
So you can find them, they're identified with red stars *.
Fl AL EI. -
Preparers J. W. Van Dyke; Oak Ridge National Laboratory-Aesthetics and Cost/Benefit Analysis; M.S.,
Economics, Colorado State University; S.S., Economics, Purdue University; 21 years experience in environmental impact assessment.
M. D. Waters; Nuclear Regulatory Commission-Project Engineer; M.S., Nuclear Engineering Sciences, University of Florida; B.S., Nuclear Engineering, University of Florida; 4 years experience in regulation and licensing of independent spent fuel storage installations and spent fuel storage and transportation casks.
M. C. Wong : Nuclear Regulatory Commission-Environmental Review Team; M.S., Johns Hopkins University; B.A, Cornell University; 5 years experience in environmental studies.
G. P. Zimmerman; Oak Ridge National Laboratory-Project Management and Technical Integration; M.S., Mechanical Engineering. University of Tennessee; S.S., Mechanical Engineering, University of Tennessee; 22 years experience in safety/accident analysis and environmental impact assessment.
11.2 R evie wers D. Allison; Bureau of Indian Affairs-BIA Superintendent, Uintah and Ouray Agency; B.A., Range Management, Montana State University; 25 years experience in resource management.
M. Bean; Public Affairs Management-EIS Review; BA., Environmental Studies and Planning, University of California, Santa Barbara; 11 years experience in public and private environmental planning.
L. E. Berggren; Bureau of Land Management, Salt Lake Field Office-SLM Project Leader, Environmental Planning and Review: B.S., Wildlife Biology, New Mexico State University; 33 years experience in environmental studies.
G. J. Cantley; Bureau of Indian Affairs, Western Regional Office-EIS Review; M.A., Archaeology, Arizona State University; B.A., Anthropology, Universidad de las Americas; 24 years experience in archaeological studies.
G. A. Carpenter; Bureau of Land Management, Salt Lake Field Office-EIS Review; B.S., Range Science; 30 years experience in environmental studies.
B. Carson; Science Applications International Corporation (SAIC}-EIS Review; M.S., Environmental Engineering, Colorado School of Mines: B.S.. Geology and Geophysics. Missouri School of Mines; B.S.. Applied Mathematics and Computer Science, Washington University; 13 years experience in environmental studies.
C. Crabtree; Science Applications International Corporation (SAIC)-
EIS Review; B.A., Environmental Studies, University of California; 16 years experience in environmental studies.
C. B. Deeney, TREC, lnc--EIS Review; B.S. Chemical Engineering, Montana State University; 14 years in environmental engineering/consulting focusing on water. resource and waste management.
URE -1714 11-4 46
Exhibit 20 ( continued).
It's not known ifNRC staff know (1) how to write joint EISs with other agencies and/or (2) they can include the names of other agency staff in the List of Preparers.
Prepllrers E. Dietrich; Science Applications International Corporation (SAIC)-EIS Review; B.A., Anthropology, University of Illinois; 22 years experience in environmental studies.
E. Dille; Science Applications International Corporation (SAIC)-EIS Review; B.A., Geology, University of Colorado; 16 years in environmental studies.
G. Diwachak; Bureau of Land Management, Utah State Office----EIS Review; B.S.. Environmental Sciences; 22 years experience in environmental studies.
K - Edinger; Bureau of Land Management, Salt Lake Field Office; EIS Review; M.S.. Soil Chemistry, University of Wyoming ; B.S., Rangeland Ecology and Watershed Management, University of Wyom ing; 5 years experience in environmental studies.
M-Ford; Bureau of Land Management, Salt Lake Field Office--EIS Review; M.S., Baylor University; S.S.. Ball State University; 11 years experience in environmental studies.
C. L. Gardiner; Public Affairs Management (contractor of the Surface Transportation Board)-EIS Review for STB; B.A., Chemistry and Political Science, University of North Carolina at Chapel Hill; 1 B years experience in environmental review.
D. Hanberg; Bureau of Indian Affairs-EIS Review; B.S., Animal Science (minor in Agronomy),
Brigham Young University; 28 years experience as soil conservationist and range conservationist (with BIA).
R - V. Hardy; Bureau of Land Management, Salt Lake Field Office--EtS Review; B.S., Botany, Brigham Young University; 25 years experience in environmental studies.
R. Henke; Science Applications International Corporation (SAIC)-EIS Review; M.S., Wildlife Biology, University of Vermont; B.S., Forest Management, University of Missouri; B.S., Fisheries and Wildlife Management, University of Missouri; 16 years experience in environmental studies A. L. Heuslein; Bureau of Indian Affairs, Western Regional Office--BIA Project Leader, Environmental Review; B.S., Biology, Stephens College; 22 years experience in wildlife biology, surface reclamation. and environmental protection.
S. C. Howard; Science Applications International Corporation (SAIC)-EIS Review ; B.S., Civil Engineering, Virginia Polytechnic Institute; 20 years experience in environmental studies.
I. Johnson; Science Applications International Corporation (SAIC)-EIS Review; M.A., Economics, University of Washington; S.S., Economics, University of Washington ; 15 years experience in environmental studies.
P. Johnson-Ball; Surface Transportation Board-EIS Review; B.A. Political Science, Syracuse University; M.A., Urban and Regional Planning, Howard University; 26 years experience in environmental planning.
E. K. Kaiser; Surface Transportation Board-EIS Review; B.A., Political Science, Simmons College; J.D., Suffolk Law School; 26 years experience in environmental review and transportation and public interest law.
11-5 UR G-1714 47
Exhibit 20 ( continued).
Preparers J. S. Kline; Bureau of Land Management, Salt Lake Field Office--EIS Review; B.S.. Forestry, Utah State University; 19 years experience in environmental studies.
B. Laub; Bureau of Land Management, Salt Lake Field Office--EIS Review; B.S., Parks and Resource Management, University of Utah; 9 years experience in environmental studies.
H. McNulty; Surface Transportation Board-EIS Review; B.A.. Business Administration, University of Pittsburgh; 37 years experience in environmental review and transportation economics.
L. P. Naylor, II; Bureau of Land Management, Salt Lake Field Office--Cultural Resources Data Collection and EIS Review; M.S., Northern Arizona University; 10 years experience in environmental studies.
M. G. Nelson; Bureau of Land Management, Salt Lake Field Office--EIS Review; M.S., University of Utah; 18 years experience in environmental studies.
R. M. Reed ; Oak Ridge National Laboratory-Project Review; Ph.D., Botany/Plant Ecology, Washington State University; A.B., Botany, Duke University; 26 years experience in environmental assessment.
J. W. Saulsbury; Oak Ridge National Laboratory-Visual Resources; M.S., Planning, University of Tennessee; B.A., History, University of Tennessee; 11 years experience in environmental assessment.
R. Schlegel; Science Applications International Corporation (SAIC)-
EIS Review; M.S., Nuclear Engineering, Columbia University; B.S., Chemical Engineering, Massachusetts Institute of Technology; 37 years experience in environmental studies.
D. Shain; ICF Consulting, lnc.;Transportation Safety (radiological)-
EIS Review; M.S.. Ecological (Environmental) Engineering, Colorado School of Mines; B.S., Chemical Engineering. Colorado State University; 13 years of experience in transportation modeling and simulation, transportation planning, and NEPA analyses.
S. L. Simpson; Offic.e of the Solicitor, Department of the lnterior--Attorney-Advisor; A.B., College of William and Mary, Early American History, Archaeology, and Material Culture; J.D. Antioch School of Law; 15 years of experience in environmental law and regulation, specializing in NEPA compliance.
UR G-1714 11-6 48
Exhibit 20 ( continued).
Preparers P. I. Spinelli; Garcia and Associates-EIS Review; M.S., Wildland Resource Management, University of California, Berkeley; B.A. Environmental Studies/Natural History, University of California, Santa Cruz; B.A. Economics, University of California, Santa Cruz; 17 years experience as a professional wildlife biologist 15 years experience environmental consulting-wildlife biologist.
S. Steinwert; Public Affairs Management-EIS Review; B.A., Biological Sciences, California State University Chico; 12 years experience in preparing NEPA environmental documents for transportation projects.
A. Stephenson; Bureau of Land Management, Salt Lake Field Office--BLM Project Leader, Environmental Planning and Review; B.S.. Resource Economics, Colorado State University; 26 years experience in environmental studies.
A. Summerville; ICF Consulting, Inc.; NEPA compliance-EIS Review; M.A., City Planning, University of Pennsylvania; B.A., Economics and Political Science, University of Vermont; 12 years of experience preparing and reviewing NEPA documents.
J. W. Terry; Oak Ridge National Laboratory-Human Health; Ph.D., Physics, Vanderbilt University; M.A. and B.A.. Astronomy, University of South Florida; 10 years experience in environmental assessment.
C. Warrick; Bureau of Land M anagement, Salt Lake Field Office-EIS Review; A.S., Snow College, Utah; B.S., Wildlife Management, Utah State University; 26 years experience in environmental studies.
11 -7 UR
- l71 4 49
Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New Mexico-West Texas. The red line is the New Mexico-Texas state line.
New Mexico Ch8Vl?$
Couri.,
Proposed nuclear storage facility HOL T EC INT[RNATIO'JAl WIPP Existing nuclear storage facility Jal * ¥ w,n e
Texas Tokio Denver City Hgglnbotham Kermit
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~ ** PAATNEA S WASIE CONIROl SPECIAL STS Existing nuclear storage facility
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~klmElelS 0 5 10 20 3l 40 Interim Storage Partners at 0.37 miles east of NM-Texas state line.
Waste Control Specialists at about l mile east of NM-Texas state line.
11 l" -* Ii I <@> I ISP and WCS about five miles east of Eunice, New Mexico.
Figure 5.1-1 Location of Facilities within 80 km [50 mi] of the Proposed CISF Project.
in NRC's 2021 EIS written for Interim Storage Partners.
50
A.
What Are the Facilities?
- 1. The Waste Isolation Pilot Plant (WIPP) is located (about) 26 miles east of Carlsbad, NM. This federal facility stores low-level (transuranic) nuclear waste (see Exhibit 20). It's been operational since 1999. There's a paragraph, about WIPP, in NRC's 2022 EIS (see Exhibit 22).
- 2. A Waste Control Specialists (WCS) business is about a mile east of the NM-Texas state line (see Exhibit 23). lt's approved to store low-level nuclear waste. It's (about) 40 miles east ofWIPP and Holtec's proposed high-level nuclear waste storage business. See Exhibit 24 for a paragraph, about WCS, in NRC's 2022 EIS.
- 3. Holtec's proposed high-level nuclear waste storage facility is (about) 32 miles east of Carlsbad, NM and 15 miles north of WIPP. It's (about) 40 miles west of (1) WCS's low-level nuclear waste storage business and (2) Interim Storage Partner's proposed high-level nuclear waste storage nuclear facility.
- 4. Interim Storage Partners proposed high-level nuclear waste storage facility would be at WCS' s complex of four businesses that includes WCS's low-level nuclear waste storage facility. ISP's proposed high-level nuclear waste storage facility is (about) 40 miles east ofWIPP and Holtec's proposed high-level nuclear waste storage business. There's a paragraph, about ISP, in NRC's 2022 EIS ( see Exhibit 25).
There would be two nuclear waste disposal facilities at WCS's four businesses (see Exhibit 26). Why put two facilities at one location? ISP's facility would store high-level nuclear waste.
51
Exhibit 21.
Information about WIPP.
., '"'
- WrKIPEDrA
\\\\
'Jhc free Encyclopedia
\\Vaste Isolation Pilot Plant The Waste Isolation Pilot Plant, or WIPP. in New Mexico, US, is the world's third deep geological repository (after Germany's Repository for radioactive waste Morsleben and the Schacht Asse II salt mine) licensed to store transuranic radioactive waste for 10,000 years. The storage rooms at the WIPP are 2,150 feet (660 m) underground in a salt formation of the Delaware Basin. The waste is from the research and production of United States nuclear weapons onlyJ.1J[2J The plant started operation in 1999, and the project is estimated to cost $19 b illion in totaJJ3l It is located approximately 26 miles (42 km) east of Carlsbad, in eastern Eddy County, i n an area kn own as the southeastern New Mexico nuclear corridor, which also includes the National Enrichment Facility near Eunice, New Mexico. the Waste Control Specialists low-level waste disposal facility just over the state line near Andrews, Texas, and the International Isotopes, Inc. facility to be built near Eunice, New Mexico.f 41 Various mishaps at the plant in 2014 brough t focus to the problem of what to do with the growing backlog of waste and whether o r not WIPP would be a safe repository.Cs] The 2014 incidents involved a waste explosion and airborne release of.radiological materia] that exposed 21 plant workers to small doses of radiation that were within safety 1imits_f6)
History Geology and site selection In 1970 the United States Atomic Energy Commission (later merged into the Department of Energy) proposed a site in Lyons, Kansas for the isolation and storage of radioactive waste. Ultimately the Lyons site was deemed unusable due to local and regional opposition, and in particular the discovery of unmapped oil and gas wells located in tbe area.
52 Waste Isolation Pilot Plant Seal of the Waste Isolation Pilot Plant WIPP. a geological repository for radioactive waste
~
Location within N ew Mexico Show map of New Mexico Show map of the United States Show all General information
Exhibit 22.
A Paragraph About WIPP in NRC's 2022 EIS for Holtec.
constructors of the SOP project, expect the mine to have a life of 38 years with production having started in late 2021 and ramping up until 2023 (PolyNatura, 2017).
Caliche is mined near the surface and is crushed for use in surface roads and pads for the oil and gas industry, as well as other road construction activities. There is one caliche mine in Eddy County, and although caliche forms the basis of the Liano Estacada throughout northern and central Lea County, desirable caliche only occurs sporadically in the southern portion of Lea County (Consensus Planning, 2017; BLM, 2018). Both Lea County and Eddy County have high potential for the development of caliche, and as the oil and gas industry continues to grow over the next 20 to 30 years, the demand for caliche will increase (BLM, 2018).
Salt has been mined since 1931 in the vicinity of the proposed CISF project with variable production (BLM, 2018). There are currently three salt mines in Eddy County (Consensus Planning, 2017). According to BLM (BLM, 2018), the potential for development of salt mines is high, but because of the unpredictable demand, it is not possible to anticipate the actual land development areas.
Historically, there were 32 permitted brine well operations in New Mexico, with the majority of those located in Lea and Eddy County. After a collapse of two brine wells in Eddy County in 2008, a moratorium was placed on new brine wells (Consensus Planning, 2017). Currently there are only nine active brine wells in New Mexico and only one in Eddy County.
- 5. 1. 1. 2 Nuclear Facilities
... The Waste Isolation Pilot Plant (WIPP) is located approximately 25 km [16 mi] south of the proposed project area. WIPP is a permanent disposal facility for transuranic (TRU) waste. The disposal area is located 655 meters (m) [2,150 feet (ft)] underground in large panels mined out of the salt rock beds (WIPP, 2019a). The facility is the nation's only deep geologic repository (WIPP, 2019b) and currently consists of eight panels, with two more panels planned
{WIPP, 2019a). Operational since March 1999, WIPP has disposed of defense-generated TRU waste from over 22 generator sites across the nation (WIPP, 2019c) and is a major employer In Eddy County (Consensus Planning, 2017).
Approximately 37.2 km (23.1 mi] south of the proposed project area, 13.9 km [8.6 mi] south of WIPP, is the Gnome-Coach site, which covers approximately 275 ha [680 ac] (DOE, 2020).
The Atomic Energy Commission, a predecessor agency to the Department of Energy (DOE),
used the site on December 10, 1961 for Project Gnome, an underground nuclear test, in which a nuclear detonation was set off in the Salado Formation, 360.9 m [1184 ft] below the ground surface, creating a cavity at the detonation depth (DOE, 2020). Preparations for a second test, Project Coach, began shortly after Project Gnome; however, Project Coach was eventually cancelled (DOE, 2020). In 1963, a groundwater tracer test, using four dissolved radionuclides, was performed to help evaluate the potential movement of radionuclides within the Culebra Dolomite Member of the Rustler Formation (DOE, 2020). Since 1963, the DOE has performed cleanup actions at the site through a Voluntary Remediation Agreement with New Mexico (DOE, 2020). In 2015, a Conditional Certificate of Completion for the site surface cleanup was granted, certifying that all surface remediation had been completed in accordance with the State of New Mexico requirements and specifying long-term management requirements (DOE, 2020).
The BLM maintains the surface rights and has designated the surface use as grazing and nonresidential land use. However, because subsurface contamination remains, drilling, excavation, or other activities that could disturb materials deeper than 6.1 m (20 ft] below the ground surface is prohibited, along with any excavation within 12.2 m [40 ft] of the emplacement 5-3 53
Exhibit 23.
Waste Control Specialists Information.
W I KI PEDIA
\\1 Th.- Free Encyclopedia W-aste Control Specialists Waste Contro l Specialis ts LLC (WCS) is a treatment, storage, & disposal company dealing in radioactive, bazardous, and mixed wastes. Developed and controlled by Texas billionaire investor Harold Simmons until his death at the end of 2013. the company was founded in Dallas, Texas in 1989 as a landfill operator, and awarded a unique license for disposal of low level radioactive waste in 2009. Its main operations are in Andrews County, Texas.
J.F. Lehman & Company (JFLCO) acquired Waste Control Specialists LLC from Valhi, Ioc. in January 2018. The acquisition represents JFLCO's fourth platform investment in the environmental and technical services sector. [1)(2)
Waste Control Specialists LLC C omp.any type Industry Private waste Management Fou nd ed 1989 Headquarte rs New York City, New York Key peop le Number of e mployees J.F. Lehman &
Company, Owner 122 WCS also has a strategic partnership with J.F Lehman &
W e bsite Company portfolio company NorthStar Group Holdings, Inc., a www.wcstexas.com (http:/lwww.wcstexa s.com/1) leading provider of specialized environmental and technical services for commercial and government end markets, to support domestic electric utilities in safely decommissioning nuclear power generation sites.C1JC2l In partnership with Ora.no the company pursued a license for a consolidated interim storage facility (CISF)J3] The license was issued in September of 2021..[4) The license was challenged in court by the State of Texas which contends the license is not legal and seeks to invalidate the licensing decision.Cs) In August 2023 the United States Court of Appeals for the Fifth Circuit ruled that the NRC does not have the authority from Congress to license such a temporary storage facility that is not at a nuclear power station or federal site, nullifying the purported license.f 6)
Overview WCS is the only privately owned and operated facility in the United States that bas been licensed to treat, store and dispose of Class A, B, C low level radioactive waste (LLRW), and to store Greater than Class C LLRW.[71 WCS' facility in western Andrews County is the only commercial facility in the United States licensed in more than 30 yeru:s to dispose of Class A, B and Clow-level radioactive waste. It is also licensed for the treatment and storage of low-level radioactive waste, and has served as a temporary storage facility for U.S. Department of Energy (DOE) projects.l8l The WCS facility also is the site of the disposal facility for the Texas Low Level Radioactive Waste Disposal Compact, and was the site of the storage and disposal of byproduct material from the 54
Exhibit 23 ( continued).
DOE Fernald, Ohio cleanup ite in 2 009_[9 In 2 011 a vote was held b th Texas Low Level Radioactive Waste Disposal Compact Commission that will allow WCS to import waste from 36 other states aero the us.C10 Disposal of low-level radioactive waste is in concrete containers buried 45 to 100 feet below the surface in concrete-tin d cells in the red bed clay formations. Space between the container is filled to help prevent shifting. As th cells are filled, th y will be covered by more than 300 fe t of lin r material and red bed clay and the surfac will be r tored to its atural stat _[BJ Th plant is located 5 miles east of unice, N w Mexi o, and 35 miles we of Amir ws. The sUITounding area on both sides of the ta bord r, "nuclear alle ", also includes:
the National Enrichment Facility (owned and operated by the Urenco Group) in Eunice the deep geological repository Waste Isolation Pilot Plant (WIPP; managed by the United States Department of Energy), and the proposed first commercial uranium de-conversion facility in the United States, a project of International Isotopes. Inc.
References
- 1. "JFLCO buys Waste Control Specialists" (https://www.pehub.com/2018/01/jflco-buys-waste-con trol-specialists/). PE Hub. 2018-01 -29. Retrieved 2019-04-18.
- 2. "Waste Control Specialists Gets New Buyer" (https://www.exchangemonitor.com/waste-control-specia lists-gets-new-buyer/?pri ntmode= 1). ExchangeMonitor. 2018-01 -29. Retrieved 2019 18.
-.3. "Interim Storage Partners CISF Application" (https://www.nrc.gov/waste/spent-fuel-storage/cis/
waste-control-specialist.html). NRG. 2016-04-28. Retrieved 2021-06-24.
- 4. "World Nuclear News" {https://www. wand-nuclear-news. erg/Articles/US-reg ulator-issues-licenc e-for-interim-storage-fa). NRG. 2021 14. Retrieved 2022-0~31.
- 5. "The Dallas Morning News" (https://www.dallasnews.com/news/politics/2022/08/30/texas-says-supreme-cou rt-climate-ruling-may-block-license-to-store-nuclear-waste-in-state/). NRG.
2022-08-30. Retrieved 2022-0~31.
- 6. "Court annuls licence for Texas used fuel store" (https://www.wor1d-nuclear-news.org/Articles/C curt-annuls-licence-for-Texas-used-fuel-store). World Nuclear News. 30 August 2023.
Retrieved 3 September 2023.
- 7. "Treatment and Storage" (http://www.wcstexas.com/facilities/treatment-and-storage/). Waste Control Services. Retrieved 2019-04-18.
- 8. "Waste Control Specialists" (http://www.wcstexas.com/). Archived from the original (http://ww w.wcstexas.com) on 2010-08-19. "WCS is now the only facility in the United States licensed in the last 30 years, to dispose of Class A, B, and C low level radio active waste."
- 9. "TCEQ Status of Waste Management and Disposal" {https://web.archive.org/web/20170208000 355/http://www.dshs.texas.gov/radiation/201 0Conf/PDFMainSession_ F ridayWaste/02-Status _ o f_Waste_Management_and_ Disposal.doc). Archived from the original (http://dshs.texas.gov/ra diation/201 0Conf/PDFMa inSession_F ridayWaste/02-Status _of_ Waste_ Management_ and_ Dis posal.doc) on 2017-02-08. Retrieved 2023-11-11.
- 10. "Senate Approves Bringing In More Radioactive Waste" (http://www.texassolution.com/docume 55
Exhibit 24.
A Paragraph About WC in NRC's 2022 EIS for Holtec.
shaft cap (DOE, 2020). The DOE currently monitors groundwater at the site and performs inspections to ensure the long-term protectiveness of the site (DOE, 2020).
Approximately 60 km [37 mi) southeast of the proposed CISF project, near Eunice, New Mexico, there is an operating uranium enrichment facility known as the National Enrichment Facility (NEF). It is currently the only operating commercial enrichment facility in the United States, producing approximately one-third of the nation's annual enriched uranium for commercial nuclear power reactors (Urenco, 2019). The uranium is enriched by vaporizing solid uranium hexafluoride and then feeding it into a centrifuge, after which it is compressed, cooled, and stored (Urenco, 2019). The NRC licensed NEF in 2006 for 30 years (NRC, 2012a), and it began operation in 2010 (Urenco, 2019). The environmental impacts as assessed during the licensing processes were primarily deemed to be small, with the exception of the positive impact I
of increased tax revenue (NRC, 2005).
~
Waste Control Specialists (WCS) is a company that provides treatment, storage, and disposal of Class A, B, and C LLRW, as defined by 10 CFR 61.55, hazardous waste and byproduct materials. WCS's facility is located on the Texas side of the New Mexico-Texas border, east of Eunice, New Mexico, approximately 72 km (45 mij from the proposed CISF project (EIS Figure 5.1-1). Because Texas is an Agreement State, WCS is regulated by the Texas Commission on Environmental Quality (TCEQ) and is licensed by the TCEQ to dispose LLRW and by-product material in Andrews County, Texas (TCEQ, 2019). Class A, B, and C URW is disposed of by burying waste near-surface in concrete-lined cells on top of a 183-m
[600-ftJ-thick red-bed clay, which serves as a natural inhibitor to infiltration (WCS, 2019). The TCEQ's safety and environmental analysis regarding WCS concluded that, as authorized in the license. WCS's actions would protect health and minimize danger to life and the environment (TCEQ, 2019). In addition, WCS can currently store, but not dispose of, Greater-Than Class C (GTCC) and transuranic waste. These WCS disposal and storage capabilities are ongoing at the site.
In January 2015, TCEQ sent a letter to the NRG with questions concerning the State's authority to license a disposal cell for GTCC, GTCC-llke, and transuranic waste. The Commission began considering the issue and undertook actions such as development of a regulatory basis, evaluation of technical issues, and stakeholder engagement activities. In February 2016, the U.S. Department of Energy (DOE) issued a final EIS titled, "Final Environmental Impact Statement for the Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-Like Waste." The document evaluated disposition paths for GTCC, and the Final EIS identified the preferred alternative as the WIPP geological repository and/or land disposal at generic commercial facilities. In October 2018, DOE issued an environmental assessment (EA) that provides a site-specific analysis of the potential environmental impacts of disposing the entire inventory-12,000 m3 [423,TT6 ft3]- of GTCC LLRW and GTCC-like waste at WCS (DOE, 2018a). However, publication of these documents by DOE is not a decision on GTCC LLRW disposal. Under the Energy Policy Act of 2005. additional actions would be required by both DOE and Congress. The NRC's actions regarding review of the TCEQ request and determinations regarding GTCC are ongoing. The NRC reviewed the DOE's Final EIS and EA, and has developed a draft regulatory basis for GTCC and transuranic waste disposal (ADAMS Accession No. ML19059A403). The NRG GTCC rulemaking is currently in progress.
Thus. because disposal of GTCC at WCS would require completion of these NRG activities and actions by DOE and Congress, a detailed evaluation of this reasonably foreseeable future action is not feasible at this time but is noted here for completeness.
5-4 56
Exhibit 25.
A Paragraph About ISP in NRC's 2022 EIS for Holtec.
In October 2012, the NRC issued a license to International Isotopes Fluorine Products, Inc.
(IIFP) for construction and operation of a depleted uranium deconversion facility known as the Fluorine Extraction and Depleted Uranium Deconversion Plant (FEP/DUP) (NRC, 2019). The facility would be located approximately 37.6 km [23.4 mi] northeast of the proposed CISF, east of Hobbs, New Mexico, and would convert depleted uranium hexafluoride into fluoride products for commercial resale and uranium oxides for disposal (NRC, 2019). The environmental impacts, as assessed during the licensing process, were predominantly small. with air quality during construction potentially being moderate (NRC, 2012b). Since the issuance of the license, no construction activities have occurred.
On June 11, 2019, Eden informed NRC of its intent to submit a license application to construct and operate a Medical Isotopes Production Facility (Eden, 2019a). Licensing of this facility would be subject to NRC regulations at 10 CFR Part 50 (Domestic Licensing of Production and Utilization Facilities); 10 CFR Part 70 (Domestic Licensing of Special Nuclear Materials) to receive, possess, use, and transfer special nuclear materials; and 10 CFR Part 30 (Rules of General Applicability to Domestic Licensing of Byproduct Material) to possess and transPort moiybdenum-99 for medical applications. Eden has stated its intent to build their facility east of Eunice, New Mexico, 3 km [1.9 mi] west of the New Mexico-Texas State line and 69 km [43 mi]
southeast of the prop0sed CISF (Eden, 2019b). If an NRC license were issued, Eden would anticipate beginning construction in 2022 and production in late 2024 {Eden, 2019c).
5.1.1.3 Second C/SF
... In April 2016, WCS submitted a license application to the NRC requesting authorization to construct and operate a CISF for SNF at its existing hazardous and LLRW storage and disp0sal site in Andrews County, Texas. In 2018, WCS partnered with Grano CIS LLC to form Interim Storage Partners (ISP), and ISP submitted a revised license application to the NRC for the proposed CISF. The prop0sed ISP CISF would be co-located with the WCS facilities discussed in the prior section. Similar to the prop0sed Holtec CISF evaluated in this EIS, the function of the ISP CISF would be to store SNF and reactor-related GTCC LLRW generated at commercial nuclear power reactors. The SNF and reactor-related GTCC LLRW would be transp0rted from commercial reactor sites to the CISF by rail. Although the initial license request is to store 5,000 MTU [5,500 short tons) at the CISF, ISP intends to submit future license amendment requests such that the facility would eventually store up to 40,000 MTU (44,000 short tons). The NRC conducted a safety evaluation documented in a Safety Evaluation Report (SER) and also prepared an EIS (NRC, 2021 ). Based on the outcomes of those actions, the NRC granted the license (see Ml21188A096); however. construction has not begun on the ISP CISF. Because detailed information about the ISP CISF is available, information about this reasonably foreseeable future action (i.e., construction and operation of the ISP CISF) is included where appropriate in this EIS.
5.1.1.4 Solar, Wind, and Other Energy Projects New Mexico has a high potential for solar energy generation (Roberts, 2018). According to New Mexico's Energy, Minerals, and Natural Resources Department, New Mexico was generating over 254 megawatts (MW) of energy from solar sources as of January 2017, and had plans to generate 1,103 more MW of energy from solar sources within the State of New Mexico (NMEMNRO, 2017a). Within the region, there are six operating solar p0wer facilities: one in Eddy County and five in Lea County (EIA. 2022b) (EIS Figure 5.1-1). SPSS Hopi is a solar p0wer station located in south Car1sbad, New Mexico (EIA, 2022b). SPSS Hopi has been operating since late 2011 (EIA, 2022b). In Lea County, there are five operational 5-6 57
Exhibit 26.
Map of ISP's Proposed Facility at WCS's Nuclear Waste Storage Facility.
WCS Property Boundary
~
WCS Property Ex1ShngWCS Proposed Rad Ranch House 0 OS 1
Boundary Fac,~ty Sidetrack Draw M~es Proposed Proposed
-+--+- Ex1sttng Ratl -- State Hwy Kjfometers CJ CISF PrOJecl Access Road c::::J State Line 0
075 1 5 Area Figure 2 _2 -1 Location of Proposed CISF Project Area in Andrews County, Texas 2-3 58
Exhibit 26 ( continued).
Diagram Showing ISPs Proposed Facility (Blue Square) at WCS's Existing Nuclear Waste Storage Facility.
I t
Figure 2.2-2 Site Layout (modified from ISP, 2021)
P,opoff,dCISF AAU SkfeJrKk
+
A landfill for disposal of hazardous waste, including Resource Conservation and Recovery Act (RCRA) regulated waste and low activity radioactive waste. This facility operates under Hazardous Waste Permit No. 50358 (TCEQ, 2005).
A rail line encompasses the existing WCS waste management facilities (EIS Figure 2.2-2) and is c urrently used to transport LLRW to the WCS site. The rail line extends from the WCS facilities to Eunice, New Mexico, located approximately 8 km [5 mi] west of the WCS site, where it connects with the T exas New M exico Railroad. WCS controls, operates, and maintains the rail line from its site to Eunice, New Mexico (ISP, 2020).
The proposed CISF would be constructed within an approximate 130-ha (320-ac]
owner-controlled area (OCA} north of WCS's existing waste management facilities (EIS Figure 2.2-2). The OCA currently consists of vacant, undeveloped land covered with native vegetation. The topography of the OCA is relatively flat, with elevations across the OCA ranging from approximately 1,041 meters (m) [3,416 feet (ft)] in the south to approximately 2-4 59
B.
Why Issue an NRC License for a Second Nuclear Waste Storage Facility at an Existing Nuclear Waste Storage Facility?
It's noted on page 2-2 in NRC's 2021 EIS written for ISP. It's facility will be at WCS's existing nuclear waste management facility
( see Exhibit 26).
We're told in NRC's 2021 EIS. ISP's nuclear waste storage facility will be 0.37 miles east of the NM-Texas state line. As is shown in Exhibit 25, ISP's nuclear waste storage facility would be on WCS land. There's information, about WCS's Federal Waste Disposal on page 2-2.
It's because of the way NRC's 2021 and 2022 EISs were written. I didn't realize ISP's high-level nuclear waste storage facility would be at WCS's low-level nuclear waste storage facility. This is a huge violation ofNEP A.
People have to know and understand where businesses are in, or near, proposed nuclear waste storage facilities. This information is needed to identify and determine the total (cumulative) impacts. That could occur from two existing and two proposed facilities in close proximity to each other, in this case, in a 40-mile area.
What is more important the public, and the courts, have to be able to read and understand the information _in EISs. So the public knows, understands, and can determine if there could be nuclear waste storage impacts that could impact them.
An existing WCS facility and proposed ISP facility would result in two, privately owned nuclear waste storage facilities at one location. With Holtec's facility, there would be three, privately owned nuclear facilities, in a 40-mile area, in southeast NM-west Texas.
Is NRC, turning over the storage of spent nuclear fuel-from dozens of nuclear power plants and reactors-to private nuclear waste storage facilities like those proposed by Holtec and ISP?
The two proposed nuclear waste storage facilities are the first of their kind, private, untested and untried, away-from-reactor, nuclear waste storage facilities. What Holtec and ISP are proposing to do, has never been done before in the United States. Has it been done anywhere in the world?
60
xhlbit 27.
Text About I P's Proposed Facility at WC 's Existing uclear Waste Storage Facility in NRC's 2021 EIS for ISP.
analysis as a matter of discretion beca use ISP provided the analysis of the environmental impacts of the future anticipated expansion of the proposed facility as part of its license application (ISP, 2020).
In its license application, ISP has requested that NRC license the proposed CISF to operate for a period of 40 years (ISP, 2020). ISP stated that it may seek to renew the license for an additional 20 years, for a total 60-year operating life (ISP. 2020). Renewal of the license beyond an initial 40 years would require ISP to submit a license renewal request, which would be subject to an NRC safety and environmental review at that time.
By the end of the license tern, of the proposed CISF, the NRC staff expects that the SNF stored at the proposed facility would have been shipped to a permanent geologic repository. This expectation of repository availability is consistent with the NRC's analysis in Appendix B of NUREG-2157, "Generic Environmental Impact Statement for Con tinued Storage of Spent Nuclear Fuel," (NRC, 2014 ). In that analysis, the NRC concluded that the reasonable period for the development of a repository is approximately 25 to 35 years (i.e., the repository is available by 2048) based on experience in licensing similarly complex facilities in the United States and national and international experience with repositories already in progress (NRC, 2014).
2.2. 1. 1 Site Location and Description The proposed project area is situated about o....itt. [0.37 mi] east of the Texas and New Mexico state boundary at a location in Andrews County.Texas, that is approximately 52 kilometers (km)
[32 miles (mi)] west of Andrews, Texas, and 8 km [5 mi) east of Eunice, New Mexico (EIS Figure 2.2-1 ). The proposed CISF would be built and operated on an approximately 130-hectare (ha) [320-acre (ac)] project area within a 5,666-ha [14,000-ac] parcel of land that is controlled by ISP joint venture member WCS in Andrews County, Texas (ISP, 2020). In addition, construction of the rail sidetrack, site access road, and construction laydown area would contribute an additional area of disturbed soil such that the total d:stul ed area for construction of the proposed CISF would be approximately 133.4 ha [33 The project area would be located north of WCS's existing waste management facilities (EIS igure 2.2-1) and controlled by ISP through a long -term lease from WCS (ISP, 2020).
Within the land WCS controls in Andrews County, WCS currently operates waste management facilities on approximately 541 ha (1,338 ac] (EIS Figure 2.2-2). These facilities are licensed by the Texas Commission on Environmental Quality (TCEQ) and inc lude The Texas Compact Disposal Facility. This facility serves the Texas Compact (Texas and Vermont) and is authorized to dispose Class A, B, and C Low-Level Radioactive Waste (LLRW) under Texas Radioactive Materials License No. R04100, Amendment No. 30 (TCEQ, 2016a).
- ..... The Federal Waste Disposal Facility. This facility serves the U.S. Department of Energy (DOE) and is also authorized to dispose Class A, B, and C LLRW and Mixed Low-Level Waste (MLLW) under Texas Radioactive Materials License No. R04100, Amendment No. 30 (TCEQ, 2016a) and Haz ardous Waste Permit No. 50397.
The Byproduct Material Disposal Facility. This facility is a uthoriz ed to dispose byproduct materials under Texas Radioactive Materials License No. R05807 Amendment No. 10 (TCEQ, 2016b).
2-2 61
C.
No One Could Figure Out There Would Be More, Than One Nuclear Waste Storage Facility in Southeast New Mexico--
West Texas.
Based on the way NRC's 2021 and 2022 EISs were written, it.
appears. There would only be one nuclear waste storage facility in southeast New Mexico-west Texas If you read NRC's 2022 EIS, you'd think there would be one nuclear waste storage facility. It would be Holtec's facility. If you
- read NRC's 2021 EIS, you'd think the same thing. It would be ISP's facility. What's more, it appears-ISP's facility would be out in the middle of nowhere at (about) 0.37 miles east of the NM-Texas state line. Tums out, 0.37 mile~ east of the* state line, is WCS land. You're at WCS business that includes a nuclear waste storage facility.
You could do what I did. I looked at both ofNRC' s EISs. After I looked at them, there was still no-way to figure out there'd-be two new, nuclear waste storage facilities separated by (about) 40 miles.
You also, wouldn't know, there's a third, existing WCS nuclear waste storage facility. Most people wouldn't know anything about the low-level (transuranic) nuclear waste disposal facility at WIPP.
Even with my knowledge and experience. It took a lot of time and effort to figure ~s out. Based on my 30-year career with BLM, the public, and the courts, could never figure any of this out.
D.
Four Low-Level Disposal Facilities, in Four States, in the United States.
It's noted at NRC's web page. There are four iow-level nuclear waste storage facilities in the United.States (see Exhibit 28). Why did*NRC (1) issue licenses or (2) approve the storage of low-level nuclear waste at four facilities in four states? An4 then,
_issue NRC :licenses in 2021 and 2023. That could result in four nuclear waste storage facilities, in a 40-mile area, in southeast NM-west Texas..
62
Exhibit 28.
Four Low-Level Nuclear Waste Disposal Facilities, in Four States, in the U.S.
WIPP is a federal low-level waste disposal facility. Why isn't it on this list?
WIPP, Holtec, ISP and WCS are in (about) a 40 mile area of land.
Locations of Low-Level Waste Disposal Facilities The four active. licensed low-level waste disposal facilities are located in Agreement States (see ~P [#map)
). Additional information about the facilities may be found at the Web sites maintained by the respective Agreement States.
- EnergySolutlons Barnwell O perations, located In Barnwell, South Carolln a Cu rrently, Barnwell accepts waste from the Atlantic compact states (Connecticut, New Jersey, and South Carolina). B arnw ell is licensed by the State of South Carolina to d isp ose of C lass A, B, and C waste.
- U.S_ Ecology. located in Richland, Washingto n Richland accepts waste from the Northwest and Rocky Mountain compacts [/waste/llw-disposal/
licensing/compacts.html]. Richland is licensed by the State of Washington to dispose of Class A, B.
and Cwaste.
- EnergySolutions Clive Operations, located in C live, Utah Clive accepts waste from all regions of the United States. C live is licensed by the State of Utah for Class A waste only.
~
~
wcs accepts waste from the Texas Compact generators and outside generators w ith permission from the Compact. wcs is licensed by the State of Texas to dispose of Class A, e. and C waste.
63
To add insult to injury, as they say. Because EISs weren't written for Holtec's and ISP's proposed nuclear waste storage facilities, the NRC licenses are illegal. Holtec and ISP couldn't use them. Holtec Intemational's illegal NRC license can't be reinstated by the U.S. Supreme Court.
E.
Unbelievable Unimaginable NEPA Violations.
Based on my experience writing EISs, it appears there was a deliberate effort to keep the public, and the courts, from fmding out there would be two new, private, high-level nuclear waste storage facilities in southeast NM-west Texas. Not only that, one of the licenses would be issued for a second nuclear waste storage facility at WCS 's existing nuclear waste storage facility.
The information in section II.A (above) shows NRC employees knew there were two existing (WIPP and WCS) nuclear waste storage facilities in southeast NM-west Texas. They were writing EISs for two new (Holtec and ISP) nuclear waste storage facilities in southeast NM-west Texas. And yet, there isn't anything in NRC's illegal 2021 and 2022 EISs. That tells the public, and the courts, there would be four nuclear waste storage facilities in, a 40-mile area, in southeast NM-west Texas. This results in a huge case of fraud.
F.
Violating Other Laws.
NRC and SwRI's CNWRA employees committed fraud, when they wrote two reports. NRC employees presented, and defended, them as legal EISs to the public and the courts. Because they didn't write EISs, they also violated (1) NEPA (2) the Federal Land Policy and Management Act of 1976, (3) Endangered Species Act of 1973, (4) National Historic Preservation Act of 1966, (5) Administrative Procedure Act (APA) of 1946, (6) The Major Fraud Act (MFA) of 1988 and (7) other laws.
64
The statutes of limitations, for prosecuting AP A and MF A violations, may have begun on May 9, 2023, with the issuance of an illegal NRC license to Holtec. They may have begun on September 13, 2021, with the issuance of an illegal NRC license to ISP.
Government and contract employees violate federal laws. This time is different. The unbelievable NRC violations involve the most dangerous nuclear waste at dozens of power plants and reactors in the United States. The worst part, the two proposed facilities are untested and untried nuclear waste storage facilities. What Holtec and ISP are proposing to do, has never been done before in the U.S. Despite that, NRC approved two illegal licenses for full-scale, 40-year businesses.
65
CONCLUSION New Mexican's, American's deserve much better, than this. So too, does Holtec International and Interim Storage Partners. They expected NRC employees to do their jobs and issue them legal NRC licenses.
Now, to find out, after Holtec filed an appeal with the U.S. Supreme Court.
NRC and SwRI's CNWRA employees committed unprecedented unimaginable violations ofNEPA and other laws. One of which is The Major Fraud. Act of 1988.
The violations resulted in Holtec International and Interim Storage Partners being issued illegal NRC licenses. NRC licenses they couldn't use.
lfHoltec and ISP want to obtain an NRC license for their proposed nuclear waste storage facilities, NRC has to write legal EISs for them. This time with a team of employees who are knowledgeable and experienced in writing EISs. That is, if NRC will accept their applications for two new nuclear waste storage facilities in a 40-mile area, with two existing nuclear waste storage facilities.
The NRC and SwRI's CNWRA employees-who wrote, reviewed, and approved (1) NRC's illegal 2021 EIS for Interim Storage Partners, and (2) NRC's illegal 2022 EIS for Holtec International-committed fraud. What did they do?
First of all, they tell us they didn't write EISs for Holtec and ISP ( see I.E.
and I.F. ). Second, they wrote two reports. Third, NRC employees presented, and defended, them as legal EISs to the public and the courts. The Supreme Court can't reinstate Holtec International's illegal NRC license (SNM-2516) issued on May 9, 2023; The U.S. Department of Justice needs to investigate and prosecute the NRC and SwRI's CNWRA employees, who wrote, reviewed, and approved NRC's illegal 2021 and 2022 EISs. Why? They committed blatant violations ofNEPA and other laws. The most unbelievable thing is the fact. NRC and SwRI's CNWRA employees didn't do the simplest thing required of them. They didn't write EISs for Holtec Intemafional's and Interim Storage Partners' proposed nuclear waste storage facilities.
Finally, there shouldn't be any place in the United States, with four nuclear waste storage facilities clustered together in a 40-mile area. What's worse, Holtec's and ISP's facilities would store the most dangerous nuclear waste (spentnuclear fuel) transported from dozens of power plants or reactors in the United States.
66
REFERENCES 10 CFR Part 51. Code ofFederal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Washington, DC: U.S. Government Publishing Office.
40 CFR 1502.11. Code of Federal Regulations, Title 40, Protection of the Environment, §Part 1502.11 (d). "Cover sheet." Washington, DC: U.S.
Government Publishing Office.
40 CFR 1502.17. Code ofFederal Regulations, Title 40, Protection of the Environment, §Part1502.l 7, "List of Preparers." Washington, DC: U.S.
Government Publishing Office.
BLM. "Draft Resource Management Plan and Environmental Impact Statement."
BLM/NM/PL-18-01-1610. Santa Fe, New Mexico: U.S. Department of the Interior Bureau of Land Management, Carlsbad Field Office. 2018.
CNWRA. Center for Nuclear Waste Regulatory Analyses (CNWRA)"
https://www.swri.org/industries/center-for-nuclear-waste-regulatory-analyses.
Yahoo Internet search September 2024.
Google Maps. "Things to do." Google search for BLM's Laguna.Plata Special Management Area (SMA). SMA is next to (west of) land for Holtec's facility.
Holtec. Holtec Receives U.S. NRC's License for Building and Operating America's First Below-Ground Consolidated Interim Storage Facility for Used Nuclear Fuel." Holtec post. Marlton, New Jersey. May 9, 2023.
Holtec. "HI-STORE CIS Facility Environmental Report, Attachment 4 to Holtec Letter, 5025012. Chapter 2: Alternatives. Table 2.2.1: DECOMMISSIONED SHUIDOWN SITES. Page 30 of 482 pages. Marlton, New Jersey: Holtec International. 2020.
NRC. "Locations Of Low-Level Waste Disposal Facilities." NRC.gov.
https://www.nrc.gov/waste/low-disposal/licensing/locations.html.
Yahoo Internet query August 2024.
67
NRC. LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE. Holtec International.
Spent nuclear fuel elements from commercial nuclear utilities.
License SNM-2516 issued May 9, 2023. Expires May 9, 2063.
NRC. NUREG-223 7, "Environmental Impact Statement for the Holtec Intemational's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico." ADAMS Accession No. ML22181B094. Washington, DC: U.S. Nuclear Regulatory Commission. 2022.
NRC. NUREG-2239, "Environmental Impact Statement for Interim Storage Partners LLC's License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas." ADAMS Accession No. ML21209A955. Washington, DC: U.S. Nuclear Regulatory Commission. 2021.
NRC. LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE. Private Fuel Storage, LLC.
Spent nuclear fuel elements from commercial nuclear utilities.
License No. SNM-2513 issued February 21, 2006. Expires February 21, 2026.
NRC. LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE. Pacific Gas & Electric Company. Diablo Canyon Power Plant, Units 1 and 2. (Don't know how long license issued for. License No. SNM-2511; Date issued unknown. Expired March 22,2024.
NRC. LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE. United States Department of Energy. Three Mile Island, Unit 2. (Don't know how long license issued for.)
License No. SNM-2508. Date issued unknown. Expired May 19, 2019.
NRC. NUREG-1714, "Final Environmental Impact Statement for the Construction and Operation of an Independent Spent Fuel Storage Installation on the Reservation of the Skull Valley Band of Goshute Indians and the Related Transportation Facility in Tooel~ County, Utah." ADAMS Accession No. ML020150170. Washington, PC: U.S. Nuclear Regulatory Commission. 2001.
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Wikipedia. The Free Encyclopedia. "Southwest Research Institute."
https:// en. wikipedia.org/wiki/Southwest_ Research_ Institute.html.
Yahoo Internet query September 2024.
Wikipedia. The Free Encyclopedia. "Waste Isolation Pilot Project."
. https://en. wikipedia.org/wiki/Waste _Isolation_ Pilot_ Project.html.
Yahoo Internet query June 2024.,
- World NuclearNews. "Holtec calls for US Supreme Court t to reinstate
- New Mexico license." July 8, 2024 article, page 1.
https://www.world-nuclear-news.org/Articles/Holtec-calls-for--US-Supreme-Court-to-reinstate-N ew-Mexico-license.html. Yahoo Internet query August 2024.
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