ML18120A102
| ML18120A102 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/04/2018 |
| From: | - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00033, NRC-2018-0052 | |
| Download: ML18120A102 (4) | |
Text
April~' 2018 MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 SUNSI Review Complete~
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RE: Docket No. 72-1051; Holtec International 's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC:
I respectfully submit these scoping comments on the Holtec Environmental Report (ER) to bring up to 100,000 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to southeast New Mexico. I am submitting the following comments because I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do not consent to transporting up to 10,000 canisterl;l of highly radioactive waste through thousands of communities nationwide. t do not consent to the ris~ the contamination of our lands, aquifers, air, or the health of plants, wildlife, and livestock. I do not consent to endangering present and future generations.
I formally request A 60~day Extensi~ii Of Time For This Comment Period. A 60-day comment period places an undo burden on the pl,lblic to respond to this 543-page technical document. In additiori, this 'overlap~ several other C0111tlleJ1-t.perfod.s.in N~w :tvlexicQ,.'including three comment periods for the Waste lspla~fon Pilot Plant (WIPP) and on~ for Los Alamos Natiorial Laboratory.
This Holtec Proposal Is Contrary to Current Law
- *
- Current law only allows the U.S. Department of Energy to take title to commercial spent fuel "following commencement of operation of a n~pository" or at a DOE-owned and operated moru.tored retrievable storage facility. The Holtec site meets neither requirement, as it is a private facility.
Holtec Must Remove Copyrights And All Redactions in the Environ*mental Report NRC m~st* require Holtec to produce an: ER that has n:o such copyright restriction and has no redactions.
The impacts Of Permanent Storage Must Be Analyzed The 'Environmental Report (ERf is i~adequ~t~ and. incomplet~{~ecause it doe~ not analyze the imp~cts of the spent fuel being)eft at. the Holtec site iridefi¢~ely.
More Alternatives Must Be Anaiyzed.
Keeping the spent fuel c.asks in some form of Hardened On Site Storage (HOSS) on the reactor sites must be analyzed.
The alternative of consolidated storage being done a(an exjsting lic~nsed Independent Spent Ftiel Storage Facility (ISFSI) must be analyzed.
The Environmental Report inadequately discusses the transportation*Risks
- . This ER must include all transportation routes and the potential impacts.of accidents or terrorism incidents on public health and safety along all the routes.
The ER is inadequate and incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and the risks and impacts of such shipments.
The Consequences To An Accident-Exposed Individual Must Be Analyzed Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts
. to a single individual.
Cracked And Leaking Casks Must Be Addressed The ER does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site.
More Cumulative Impacts Must Be Analyzed The ER mentions WIPP but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
Impacts Of Future Railroads And Electric Lines Must Be Analyzed The railroads and electric lines are not in place, but must be analyzed.
How many of the estimated 135 jobs will go to locals?
The total number of annual workers at the site could total as many as 135 when construction jobs are combined.with the operating workforce.
Seismic Impacts On Stored Casks Must Be Stated Although the ER gives a statement on recent seismic activity in the area, there is no analysis of what many 3.0-4.0 fracking-induced earthquakes will have on the buried casks.
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April.!+/-__, 2018 MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 RE: Docket No. 72-1051; Holtec Intemational's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC:
I respectfully submit these scoping comments on the Holtec Environmental Report (ER) to bring up to 100,000 metric tons of spent fuel, high-level radioactive waste, from nuclear reactors around the country to southeast New Mexico. I am submitting the following comments because I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do not consent to transporting up to 10,000 canisters. of highly radioactive waste through thousands of communities nationwid,e. I do not co~sent to the risk the contamination of our lands, aquifers, air, or the health of plants, :wildlife, and livestock I do ~ot consent to e~dangering present and future generations.,
I formally request A 66~day Extensi~ii Of Time For This Comment Period. A 60-day comment period places.an undo burden on the p~blic to respond to this 543-page technical document. In addition, this overlap~ several other comment perfoqs in N~wMexicQ, *including three comment periods for the Waste Isolation Pilot.Plant (WIPP) an.done for Los Alamos National Laboratory.
This Holtec Proposal Is Contrary to Current Law Curre~t law only allows the U.S. Department of Energy to take title to commercial spent fuel "following colTilllencement of operation of a r~pository" or at a DOE-owned and operated monitored retrievable storage facility. The Hciltec site meets neither requirement, as it is a private facility.
Holtec Must Remove Copyrights And All Redactions in the Environmental Report NRC must require Holtec to produce an ER that has no such copyright restriction and has ilo redactions.
1 The Impacts Of Permanent Storage Must Be Analyzed The 'Environmental R~port (ER) is i~adeq~~te and incomplet~ because it does not analyze the impacts of the spent fuel heing)eft at the Holtec site indefi~Itely.
I More Alternatives Must Be An~lyzed
- Keeping the spent fuel c.asks in some form of Hardened On Site Storage (HOSS) on the reactor sites must be.analyzed.
- . The* alternative o_f consolidated storage being done at an existing licensed Independent Spent F11el *storage Facility (ISFSI) must be analyzed.
The Environmental Report inadequately discusses the transportation Risks This ER must include all transportation routes and the potential impacts of accidents or terrorism incidents on public health and safety along all the routes.
The ER is inadequate and incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and the risks and impacts of such shipments.
The Consequences To An Accident-Exposed Individual Must Be Analyzed Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual.
Cracked And Leaking Casks Must Be Addressed The ER does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site.
More Cumulative Impacts Must Be Analyzed The ER mentions WIPP but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
Impacts Of Future Railroads And Electric Lines Must Be Analyzed The railroads and electric lines are not in place, but must be analyzed.
How many of the estimated 135 jobs will go to locals?
The total number of annual workers at the site could total as many as 135 when construction jobs are combined with the operating workforce.
Seismic Impacts On Stored Casks Must Be Stated Although the ER gives a statement on recent seismic activity in the area, there is no analysis of what many 3.0 -4.0 fracking-induced earthquakes will have on the buried casks.
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