ML24268A127
| ML24268A127 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility, HI-STORE |
| Issue date: | 09/03/2024 |
| From: | Allison E Public Citizen |
| To: | Shana Helton Division of Fuel Management |
| References | |
| Download: ML24268A127 (1) | |
Text
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest Texas by E. C. Allison September 2024 WIPP (Eddy County, New Mexico) / Holtec International (Lea County, New Mexico).
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
iii
SUMMARY
There could be four nuclear waste storage facilities, in a 40-mile area, in southeast New MexicoWest 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) 0was 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 cant reinstate an illegal NRC license.
Why did NRC issue two illegal licenses? NRC and Southwest Research Institute (SwRI) employees, who work for SwRIs Center for Nuclear Waste Regulatory Analyses (CNWRA), didnt 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 NMwest Texas. That is, if two new nuclear waste storage facilities are built. There isnt another place in the United States or the world, with four nuclear waste storage facilities clustered together in a 40-mile area.
It appears NRC and CNWRA employees left this information out of NRCs illegal 2021 and 2022 EISs written for ISP and Holtec. Its for this reason the public, and the courts, dont know about it. Its important to note. What the two companies are proposing to do, hasnt been done before in the United States.
Whats more, they would store the most dangerous nuclear waste in the United States. Its for that reason it was imperative good EISs were written for Holtecs and ISPs 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 of NRC license, for private, untested and untried, away-from-
iv Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest Texas. The red line is the New MexicoTexas state line.
WIPP (Eddy County, New Mexico) / Holtec International (Lea County, New Mexico).
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.
ISP and WCS may be 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 NRCs 2021 EIS written for Interim Storage Partners.
v 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 Holtecs NRC license. Therefore, much of the text in this report is concerned with NRCs illegal 2022 EIS (NUREG-2237) written for Holtec.
Nine employees, who work for SwRIs CNWRA, were assigned the job of writing two EISs at the same time. (The same NEPA violations were made in NRCs illegal 2021EIS for 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 NRCs 2001 EIS (NUREG-1714) for the first proposed CISF facility.
Nine people, to write two EISs at the same timethere 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. Whats more, theyre 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.
vi TABLE OF CONTENTS World Nuclear News, July 2024, first page of news article ii
SUMMARY
iii TABLE OF CONTENTS vi INTRODUCTION 1
I.
Unprecedented Violations, of the National Environmental Policy Act, Results in Issuance of an Illegal NRC License to Holtec International......1 II.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest 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.
Holtecs 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 of NRC License.....6 E.
The Ultimate NEPA Violation..13 F.
NRC Staff Tells US They Didnt Write an EIS........................13 G.
Moving Spent Nuclear Fuel is Missing From NRCs 2022 EIS.......16 H.
NRCs EIS Written for Three Years of a 40-Year Business21 I.
Missing 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 MexicoWest Texas...41 A.
What Are the Facilities?...........................................................51
vii
- 1. Waste Isolation Pilot Plant (WIPP) existing51
- 2. Waste Control Specialists (WCS) existing..51
- 3. Holtec International (Holtec) proposed...51
- 4. Interim Storage Partners (ISP) proposed.51 B.
Why Issue a 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 MexicoWest Texas...iv, 3, 50 Exhibit 2.
Holtec Wants to Move Spent Nuclear Fuel from 12 Power Plants or Reactors7 Exhibit 3.
ISP Wants to Move Spent Nuclear Fuel from 12 Power Plants or Reactors8 Exhibit 4.
Section 6A in New NRC Licenses9 Exhibit 5.
Section 6A in Previous NRC Licenses...11 Exhibit 6.
Manuscript and Final Report Completed July 2022 for Holtec..14 Exhibit 7.
Manuscript and Final Report Completed July 2021 for ISP...15 Exhibit 8.
Correct Cover for a Final EIS.17 Exhibit 9.
Moving spent Nuclear Fuel From Eight Power Plants or Reactors To Private Fuel Storages Nuclear Business...19 Exhibit10. Amendments (Phases 2 thru 20) Excluded From NRCs 2022 EIS...22
viii Exhibit 11. NRC Approves Holtecs Plan of Operations, Not BLM.24 Exhibit 12. Impact Analysis May Have Been Limited to Holtecs Facility, Rail Spur, and Road............................................................................26 Exhibit 13. Recreation Information Missing From NRCs 2022 EIS27 Exhibit 14. Recreation in Vicinity of Holtecs Proposed Facility.28 Exhibit 15. List of Preparers in NRCs 2022 EIS Written for Holtec...30 Exhibit 16. List of Preparers in NRCs 2021 EIS Written for ISP........33 Exhibit 17. CNWRA Employees Work for Southwest Research Institute (SwRI).36 Exhibit 17 Center for Nuclear Waste Regulatory Analyses is One of Eleven Divisions at SwRI...37 Exhibit 18. List of Preparers in 2018 Draft EIS Written for BLM39 Exhibit 19. List of Preparers and List of Reviewers in NRCs 2001 EIS..42 Exhibit 20. Information About WIPP52 Exhibit 21. A Paragraph About WIPP in NRCs 2022 EIS for Holtec.53 Exhibit 22. Waste Control Specialists (WCS) Information...54 Exhibit 23. A Paragraph About WCS in NRCs 2022 EIS for Holtec..56 Exhibit 24. A Paragraph About ISP in NRCs 2022 EIS for Holtec.57 Exhibit 25. Map of ISPs Proposed Facility at WCSs Nuclear Waste Storage Facility...58 Exhibit 25. Diagram Showing ISPs Proposed Facility (Blue Square) at WCSs Nuclear Waste Storage Facility..59 Exhibit 26. Text About ISPs Proposed Facility at WCSs Existing Nuclear Waste Storage Facility...61 Exhibit 27. Four Low-Level Nuclear Waste Disposal Facilities, in Four States in the United States.63
1 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 dont know what Holtec wants to do. Holtec wants to obtain a new kind of NRC 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?
Its not known why. NRC and SwRIs 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 NEPA. Ive 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, its a rarely seen NEPA violation. Writing a report instead of an EIS is the ultimate NEPA violation.
Ive 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, cant be reinstated by the U.S. Supreme Court.
II.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest 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
2 (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 southeast New Mexicowest Texas (see Exhibit 1).
NRC and SwRIs CNWRA employees knew about this situation, when they wrote the illegal EISs for the businesses proposed by Holtec and ISP. For people, experienced in writing EISs, it appears the information was left out of the EISs.
NRCs efforts to issue licenses, for the first consolidated interim storage facilities (CISF), as theyre called, resulted in a huge case of fraud. Why? NRC and SwRIs CNWRA employees wrote two reports. NRC employees presented, and defended, them as legal EISs to the public and the courts. Because EISs werent 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 Internationals licenses. Now, the U.S. Supreme Court has to deal with Holtecs request to reinstate an illegal NRC license. Reinstating Holtecs illegal NRC license, by the U.S. Supreme Court, would be a worse tragedy than NRCs issuance of it.
New Mexicans, Americans 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 shouldnt be any place in the United States, with four nuclear waste storage facilities clustered together in a 40-mile area. Whats more, the two facilities would store the most dangerous nuclear waste (spent nuclear fuel) in the United States.
3 Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest Texas. The red line is the New MexicoTexas state line.
WIPP (Eddy County, New Mexico) / Holtec International (Lea County, New Mexico).
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.
ISP and WCS may be 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 NRCs 2021 EIS written for Interim Storage Partners.
4 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 Holtecs NRC license, are immaterial. Why? NRC had to write a legal EIS before it could issue (1) (whats called) an NRC Record of Decision and (2) an NRC license. That didnt happen.
A Record of Decision (ROD) states 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 SwRIs CNWRA employees didnt write a legal 2022 EIS for Holtec International, NRCs 2023 ROD isnt a legal document. The illegal EIS and ROD couldnt be used to issue Holtec an NRC license. Its no wonder Holtec was issued an illegal license.
A.
Holtecs 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. Its 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 Holtecs business. At the end of 20 years (20 phases), Holtec would store 10,000 canisters of spent nuclear fuel for 20 to 38 years, before the end of Holtecs 40-year NRC license. The length of time (20 to 38) is based on the year the spent nuclear fuel is stored at Holtecs business.
Its assumed the 10,000 canisters would be moved, before the end of Holtecs 40-year license, to a permanent geologic repository.
It took 20 years to store 10,000 canisters. Itll take 20 years to move Holtecs 10,000 canisters to a permanent repository. Holtec
5 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 differencebetween three companies proposing to build and operate consolidated interim storage facilities (CISFs)is the number of canisters. Holtecs proposed 10,000 canisters are nearly three times the (1) 4,000 canisters proposed by Private Fuel 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.
Holtecs business would be the first of its kind, private, untested and untried, away-from-reactor, nuclear waste storage facility in the U.S.
Its 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.
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
6 (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. isnt required to comply with NEPA. Federal agencies are required to comply with NEPA. Its important to note.
Holtecs Environmental Report cant 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 ISPs 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 whats been allowed and licensed before. NRC has to issue a new kind of NRC 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 hasnt been built.
What makes the new licenses different from the licenses previously issued to companies? Its whats 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).
7 Exhibit 2 Holtec Wants to Move Spent Nuclear Fuel from 12 Power Plants or Reactors.
8 Exhibit 3.
ISP Wants to Move Spent Nuclear Fuel From 12 Power Plants or Reactors.
9 Exhibit 4.
Section 6A in New NRC licenses.
10 Exhibit 4 (continued).
Section 6A in New NRC Licenses.
11 Exhibit 5.
Section 6A in Previous NRC Licenses.
12 Exhibit 5 (continued).
Section 6A in Previous NRC Licenses.
13 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). Its not known why NRC and SwRIs CNWRA employees didnt do the most basic thing of all. Write an environmental impact statement (EIS) for Holtecs proposed nuclear waste storage facility.
As unbelievable as it is, NRC and SwRIs CNWRA employees wrote a report instead of the EIS they were required to write to comply with NEPA. Ive never seen anything like it in my 30-year career with the government. Its the ultimate NEPA violation.
F.
NRC Staff Tells US They Didnt Write an EIS.
NRC and SwRIs CNWRA staff tells us, they wrote a Final Report, on the cover of NRCs 2022 EIS for Holtec. (The NEPA regulations [40 CFR §1502.11(d)] tell employees to identify the final document as a final EIS, not a final report.) NRC and SwRIs CNWRA staff tells us, on the cover. They completed work on a manuscript in July 2022. (You wont see the word manuscript in (1)
NEPA, (2) the NEPA regulations, (3) NRCs NEPA regulations, or (4) EISs.) NRC has its own set of NEPA regulations (10 CFR 51).
NRC and SwRIs CNWRA staff tells the public, and the courts, they did the same thing for ISPs proposed nuclear waste storage facility. They wrote a report instead of the EIS they were requiredto write to comply with NEPA.
This is an unbelievable unimaginable NEPA violation. See the cover on NRCs illegal 2021 and 2022 EISs written for Interim Storage Partners and Holtec International (see Exhibits 6 and 7).
The best proof, an EIS wasnt written for Holtecs 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
14 Exhibit 6.
Manuscript and Final Report Completed July 2022 for Holtec. Its not a final EIS.
15 Exhibit 7.
Manuscript and Final Report Completed July 2021 for ISP. Its not a final EIS.
16 completed in 2001. The information, in NRCs 2001 EIS, is the information that needed to be in NRCs 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 NRCs 2001 EIS.
G.
Moving Spent Nuclear Fuel is Missing From NRCs 2022 EIS.
When you write an EIS, you tell the public everything a company plans on doing. Holtecs plans, for its business, are in the Environmental Report submitted to NRC. (Business proposals, submitted by companies, are called Proposed Actions in EISs.
Holtecs plans, for its business, are in (whats called) an NRC Proposed Action in NRCs 2022 EIS.)
The most important information, in Holtecs Environmental Report, is moving spent nuclear fuel from 12 power plants or reactors to its business in southeast New Mexico. NRC employees didnt put this information in NRCs 2022 EIS. Its not known why. Its a huge, unbelievable NEPA violation.
There are a few sentences, in NRCs 2022 EIS, Holtec will move spent nuclear fuel from multiple nuclear facilities. Its 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 didnt include the table (in NRCs 2022 EIS),
listing the 12 power plants or reactors, in Holtecs Environmental Report. On the other hand, theres a lot of information, on moving spent nuclear fuel from eight power plants or reactors to PFSs proposed nuclear business, in NRCs 2001 EIS (see Exhibit 9).
For people, experienced in writing EISs, it appears this information was left out of NRCs 2022 EIS. Because this information isnt in NRCs EIS, a huge part of (whats called) the NRC Proposed Action is missing from NRCs 2022 EIS. Next to writing a report instead of an EIS, this is the next, worst NEPA violation.
17 Exhibit 8.
Correct Cover for a Final EIS. Youre told its a final EIS on the cover.
18 Exhibit 8 (continued).
Final EIS is Noted at the Top of Most of the Pages in NRCs 2001 EIS.
19 Exhibit 9.
Moving Spent Nuclear Fuel From Eight Power Plants or Reactors to Private Fuel Storages Nuclear Business.
20 Exhibit 9 (continued).
Figure 1.3 Shows the Eight Reactors Spent Nuclear Fuel Would be Moved From to PESs Private Nuclear Waste Storage Business in Utah.
21 This NEPA violation, if an EIS had been written, would have caused the failure of the EIS. As it is, its an unbelievable error in a worthless report. The report cant be used for anything. The report couldnt be used to issue an NRC license to Holtec International.
H.
NRCs 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). Holtecs planned expansion is in Holtecs Environmental Report. Although mentioned in NRCs 2022 EIS, Phases 2 thru 20 were excluded from NRCs 2022 EIS (see Exhibit 10). Why?
Were told NRCs 2022 EIS was writtenfor the action pending before NRC at the timeNRCs 2022 EIS was written. This is noted on page 2-1 of NRCs 2022 EIS (see Exhibit 10). What was the action? Its the approval of an NRC license for Phase 1 of Holtecs proposed nuclear waste storage business.
What about the next 19 years of Holtecs business?
Were 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. Holtecs application would be processed in 2027. Therefore, the second year of Holtecs business (Phase 2) was illegally excluded from NRCs 2022 EIS. The same thing happened for years 3 thru 20 (Phases 3-20). They were illegally excluded from NRCs 2022 EIS. The most important words, in this fatally flawed approach to writing NRCs 2022 EIS, are action pending before NRC.
NRCs illegal 2022 EIS ends up being written for the first three years of Holtec Internationals planned 40-year business. Its unbelievable NRC and SwRIs CNWRA employees wrote a 736-page report for (1) one year of business and (2) storing 500 canisters, of Holtecs proposed 10,000 canisters, at Holtecs proposed 40-year business. Holtecs proposed business would be located about15 miles north of the low-level nuclear waste storage facility at the existing Waste Isolation Pilot Plant (WIPP) in southeast New Mexico.
22 Exhibit 10.
Amendments (Phases 2 thru 20) Illegally Excluded From NRCs 2022 EIS.
23 I.
Missing Bureau of Land Management.
NRC and SwRIs CNWRA staff tells us on the cover of NRCs 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 dont know anything about Holtecs 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. Theres basically one sentence about BLMs role in Holtecs proposed 40-year business (see Exhibit 11).
Having worked for BLM for 30-years, this isnt a BLM Proposed Action. Its a proposed decision for (whats called) a Record of Decision. The statement is wrong. BLM wouldnt approve Holtecs Plan of Operations. NRC has to do that. BLM has to approve a right-of-way permit for Holtecs proposed five-mile long rail spur.
Based on my 30-year career with BLM, it looks like. BLM employees didnt have anything to do with the one sentence BLM Proposed Action in NRCs 2022 EIS. Its no wonder it is wrong.
(CFO employees finished work on a draft EIS, for CFO, in 2018.)
Theres a BLM Proposed Action in NRCs 2001 EIS (see page 18). Its the proposed action that needed to be in NRCs 2022 EIS. It would have been a simple thing to use the BLM Proposed Action (as an example) for the BLM Proposed Action in NRCs 2022 EIS. Having looked at NRCs 2001 EIS, it appears NRC employees didnt use NRCs 2001 EIS to write NRCs 2022 EIS. (I would have used a lot of the 2001 EIS).
Its noted on the cover of NRCs 2022 EIS. BLM employees were involved in the preparation of NRCs EIS. There isnt any information in NRCs 2022 EIS. BLM employees had anything to do with it. If they had, their names should have been in the List of Preparers in NRCs 2022 EIS.
The end result is the fact. Thirty-seven (37) years, of Holtecs proposed 40-year business, are missing from NRCs 2022 EIS.
24 Exhibit 11.
NRC Approves Holtecs Plan of Operations, Not BLM.
25 BLMs Proposed Action is also missing from NRCs 2022 EIS. Ive never seen anything like it in my 30-year career with BLM.
BLMs missing Proposed Action resulted in more unbelievable NEPA violations. It also 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 cant use its expensive and expanding nuclear waste storage facility, if it doesnt have a (BLM approved) rail spur to transport spent nuclear fuel to its business. And here, all the BLM information is missing from NRCs 2022 EIS.
J.
Only 1,080 Acres.
It appears NRC and SwRIs CNWRA employees limited the area of consideration for analyzing impacts to (1) Holtecs facility (1,040 acres), (2) a five-mile long rail spur (39 acres), and (3) a mile long road (1 acre) (see Exhibit 12). Its illegal to do this. This resulted in more NEPA and FLPMA violations.
The best example, NRC and SwRIs 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 of NRCs 2022 EIS (see Exhibit 13). Holtecs proposed facility is in the circle. A Google map shows the points of interest (recreation) in the vicinity of Holtecs proposed facility (see Exhibit 14).
For people, experienced in writing EISs, it appears. NRC and SwRIs CNWRA employees left recreation information out of NRCs 2022 EIS. By focusing, on Major Parks and Recreation Areas, NRC and SwRIs CNWRA employees made it look. Like there wouldnt be impacts to recreation from Holtecs proposed nuclear business.
26 Exhibit 12.
Impact Analysis May Have Been Limited to Holtecs Facility, Rail Spur, and a Road.
27 Exhibit 13.
Recreation Information Missing From NRCs 2022 EIS.
Holtecs proposed nuclear waste storage facility is in the circle.
28 Exhibit 14.
Recreation in Vicinity of Holtecs Proposed Facility.
Black dot shows approximate location of Holtecs proposed facility.
29 K.
Nine CNWRA Employees Assigned to Write Two EISs at the Same Time.
NRC and SwRIs CNWRA employees committed unbelievable unimaginable NEPA violations not once, but twice. They wrote two reports instead of two EISs for Holtecs and ISPs 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 SwRIs Center for Nuclear Waste Regulatory Analysis (CNWRA), were assigned the job of writing an EIS for Holtecs proposed facility. They were also assigned the job of writing an EIS, for ISPs proposed nuclear facility, at the same time they were writing Holtecs EIS. See information about the Southwest Research Institute (SwRI) and CNWRA in Exhibit 17 NRC managers gave nine CNWRA employees the impossible job of writing two EISs at the same time. Its 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 teamlike the team that wrote NRCs 2001 EISwrites one EIS, never two EISs at a time. How many people were involved in the preparation of NRCs 2001 EIS? Seventy-five (75) people worked on NRCs 2001 EIS. Thirty-five people worked on the last EIS, I worked on, for BLM.
The names, of the NRC managers and SwRIs CNWRA employees, are in the List of Preparers in (1) NRCs 2021 EIS for ISP and (2) NRCs 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 18).
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 violations two
30 Exhibit 15.
List of Preparers in NRCs 2022 EIS Written for Holtec.
31 Exhibit 15 (continued).
Its not known why people are listed as contributors. Ive never seen that in a List of Preparers. The employees, in CNWRA, wrote NRCs 2021 EIS for ISP.
32 Exhibit 15 (continued).
Maybe contributors is noted for contributions to NRCs 2022 manuscript-report.
33 Exhibit 16.
List of Preparers in NRCs 2021 EIS Written for ISP.
34 Exhibit 16 (continued).
Its not known why people are listed as contributors. Ive never seen that in a List of Preparers. The employees, in CNWRA, wrote NRCs 2022 EIS for Holtec.
35 Exhibit 16 (continued).
Maybe contributors is noted for contributions to NRCs 2021 manuscript-report.
36 Exhibit 17.
CNWRA Employees Work for Southwest Research Institute (SwRI).
37 Exhibit 17 (continued).
Center for Nuclear Waste Regulatory Analyses (CNWRA) is one of 11 Divisions at SwRI.
38 Exhibit 17 (continued).
39 Exhibit 18.
List of Preparers in a 2018 Draft EIS Written by BLM.
40 Exhibit 18 (continued).
41 for Holtec. There are 12 BLM employees in the List of Reviewers in NRCs 2001 EIS (see Exhibit 19).
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 of NRCs 2022 EIS. Theres more information in this report, about Holtecs plans to move spent nuclear fuel from 12 power plants or reactors, than is in NRCs 2022 EIS. It appears the missing information was meant to insure an NRC license would be issued to Holtec International. NRCs 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 MexicoWest Texas.
NEPA required NRC and CNWRA employees address (1) ISPs proposed nuclear waste storage facility, (2) Waste Control Specialists (WCSs) existing nuclear waste storage facility, and (3) WIPPs existing nuclear waste storage facility in NRCs 2022 EIS written for Holtec. Why?
NEPA requires (whats 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 Mexicowest 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 look 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 of NRCs 2022 EIS.
42 Exhibit 19.
List of Preparers and List of Reviewers in NRCs 2001 EIS.
43 Exhibit 19 (continued).
Thirty-seven in List of Preparers and 38 in List of Reviewers in NRCs 2001 EIS.
44 Exhibit 19 (continued).
45 Exhibit 19 (continued).
The fact an EIS was written is at the top of most of the pages in NRCs 2001 EIS.
46 Exhibit 19 (continued)
Twelve (12) BLM employees are in the List of Reviewers in NRCs 2001 EIS.
So you can find them, theyre identified with red stars.
47 Exhibit 19 (continued).
Its not known if NRC 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.
48 Exhibit 19 (continued).
49 Exhibit 19 (continued).
50 Exhibit 1.
Four Nuclear Waste Storage Facilities, in a 40-Mile Area, in Southeast New MexicoWest Texas. The red line is the New MexicoTexas state line.
WIPP (Eddy County, New Mexico) / Holtec International (Lea County, New Mexico).
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.
ISP and WCS may be 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 NRCs 2021 EIS written for Interim Storage Partners.
51 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). Its been operational since 1999. Theres a paragraph, about WIPP, in NRCs 2022 EIS (see Exhibit 21).
- 2. A Waste Control Specialists (WCS) business is about a mile east of the NM-Texas state line (see Exhibit 22). Its approved to store low-level nuclear waste. Its (about) 40 miles east of WIPP and Holtecs proposed high-level nuclear waste storage business. See Exhibit 23 for a paragraph, about WCS, in NRCs 2022 EIS.
- 3. Holtecs proposed high-level nuclear waste storage facility is (about) 32 miles east of Carlsbad, NM and 15 miles north of WIPP. Its (about) 40 miles west of (1) WCSs low-level nuclear waste storage business and (2) Interim Storage Partners proposed high-level nuclear waste storage nuclear facility.
- 4. Interim Storage Partners proposed high-level nuclear waste storage facility would be at WCSs complex of four businesses that includes WCSs low-level nuclear waste storage facility. ISPs proposed high-level nuclear waste storage facility is (about) 40 miles east of WIPP and Holtecs proposed high-level nuclear waste storage business. Theres a paragraph, about ISP, in NRCs 2022 EIS (see Exhibit 24).
There would be two nuclear waste disposal facilities at WCSs four businesses (see Exhibit 25). Why put two facilities at one location? ISPs facility would store high-level nuclear waste.
52 Exhibit 20.
Information about WIPP.
53 Exhibit 21.
A Paragraph About WIPP in NRCs 2022 EIS for Holtec.
54 Exhibit 22.
Waste Control Specialists Information.
55 Exhibit 22 (continued).
56 Exhibit 23.
A Paragraph About WCS in NRCs 2022 EIS for Holtec.
57 Exhibit 24.
A Paragraph About ISP in NRCs 2022 EIS for Holtec.
58 Exhibit 25.
Map of ISPs Proposed Facility at WCSs Nuclear Waste Storage Facility.
59 Exhibit 25 (continued).
Diagram Showing ISPs Proposed Facility (Blue Square) at WCSs Existing Nuclear Waste Storage Facility.
60 B.
Why Issue an NRC License for a Second Nuclear Waste Storage Facility at an Existing Nuclear Waste Storage Facility?
Its noted on page 2-2 in NRCs 2021 EIS written for ISP. Its facility will be at WCSs existing nuclear waste management facility (see Exhibit 26).
Were told in NRCs 2021 EIS. ISPs nuclear waste storage facility will be 0.37 miles east of the NM-Texas state line. As is shown in Exhibit 25, ISPs nuclear waste storage facility would be on WCS land. Theres information, about WCSs Federal Waste Disposal on page 2-2.
Its because of the way NRCs 2021 and 2022 EISs were written. I didnt realize ISPs high-level nuclear waste storage facility would be at WCSs low-level nuclear waste storage facility. This is a huge violation of NEPA.
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 Holtecs facility, there would be three, privately owned nuclear facilities, in a 40-mile area, in southeast NMwest Texas.
Is NRC, turning over the storage of spent nuclear fuelfrom 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?
61 Exhibit 26.
Text About ISPs Proposed Facility at WCSs Existing Nuclear Waste Storage Facility.
62 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 NRCs 2021 and 2022 EISs were written, it appears. There would only be one nuclear waste storage facility in southeast New Mexicowest Texas If you read NRCs 2022 EIS, youd think there would be one nuclear waste storage facility. It would be Holtecs facility. If you read NRCs 2021 EIS, youd think the same thing. It would be ISPs facility. Whats more, it appears ISPs facility would be out in the middle of nowhere at (about) 0.37 miles east of the NM-Texas state line. Turns out, 0.37 miles east of the state line, is WCS land. Youre at WCS business that includes a nuclear waste storage facility.
You could do what I did. I looked at both of NRCs EISs. After I looked at them, there was still no way to figure out thered be two new, nuclear waste storage facilities separated by (about) 40 miles.
You also, wouldnt know, theres a third, existing WCS nuclear waste storage facility. Most people wouldnt 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 this 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.
Its noted at NRCs web page. There are four low-level nuclear waste storage facilities in the United States (see Exhibit 27). Why did NRC (1) issue licenses or (2) approve the storage of low-level nuclear waste at four facilities in four states? And then, issue NRC licenses in 2021 and 2023. That could result in four nuclear waste storage facilities, in a 40-mile area, in southeast NMwest Texas.
63 Exhibit 27.
Four Low-Level Nuclear Waste Disposal Facilities, in Four States, in the U.S.
WIPP is a federal low-level waste disposal facility. Why isnt it on this list?
WIPP, Holtec, ISP and WCS are in (about) a 40 mile area of land.
64 To add insult to injury, as they say. Because EISs werent written for Holtecs and ISPs proposed nuclear waste storage facilities, the NRC licenses are illegal. Holtec and ISP couldnt use them. Holtec Internationals illegal NRC license cant 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 finding out there would be two new, private, high-level nuclear waste storage facilities in southeast NMwest Texas. Not only that, one of the licenses would be issued for a second nuclear waste storage facility at WCSs 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 NMwest Texas. They were writing EISs for two new (Holtec and ISP) nuclear waste storage facilities in southeast NMwest Texas. And yet, there isnt anything in NRCs 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 NMwest Texas. This results in a huge case of fraud.
F.
Violating Other Laws.
NRC and SwRIs 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 didnt 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.
65 The statutes of limitations, for prosecuting APA and MFA 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.
66 CONCLUSION New Mexicans, Americans 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 SwRIs CNWRA employees committed unprecedented unimaginable violations of NEPA 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 couldnt use.
If Holtec 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 SwRIs CNWRA employeeswho wrote, reviewed, and approved (1) NRCs illegal 2021 EIS for Interim Storage Partners, and (2) NRCs illegal 2022 EIS for Holtec Internationalcommitted fraud. What did they do?
First of all, they tell us they didnt 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 cant reinstate Holtec Internationals illegal NRC license (SNM-2516) issued on May 9, 2023.
The U.S. Department of Justice needs to investigate and prosecute the NRC and SwRIs CNWRA employees, who wrote, reviewed, and approved NRCs illegal 2021 and 2022 EISs. Why? They committed blatant violations of NEPA and other laws. The most unbelievable thing is the fact. NRC and SwRIs CNWRA employees didnt do the simplest thing required of them. They didnt write EISs for Holtec Internationals and Interim Storage Partners proposed nuclear waste storage facilities.
Finally, there shouldnt be any place in the United States, with four nuclear waste storage facilities clustered together in a 40-mile area. Whats worse, Holtecs and ISPs facilities would store the most dangerous nuclear waste (spent nuclear fuel) transported from dozens of power plants or reactors in the United States.
67 REFERENCES 10 CFR Part 51. Code of Federal 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 of Federal Regulations, Title 40, Protection of the Environment, §Part1502.17, 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 BLMs Laguna Plata Special Management Area (SMA). SMA is next to (west of) land for Holtecs facility.
Holtec. Holtec Receives U.S. NRCs License for Building and Operating Americas 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 SHUTDOWN 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.
68 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-2237, Environmental Impact Statement for the Holtec Internationals 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 LLCs 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. (Dont 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. (Dont 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 Tooele County, Utah. ADAMS Accession No. ML020150170. Washington, DC: U.S. Nuclear Regulatory Commission. 2001.
69 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 Nuclear News. 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-New-Mexico-license.html. Yahoo Internet query August 2024.