ML18120A103
| ML18120A103 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/09/2018 |
| From: | Orr J - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00034, NRC-2018-0052 | |
| Download: ML18120A103 (4) | |
Text
April __!j_, 2018 May Ma Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUNSI Review Complete
. Template= ADM-013 E-RIDS= ADM-03
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RE: Docket ID NRC-2018-0052; 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 nationwide:. l do not consent to the risk of 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 Extension Of.Time For This Comment Period:.,A 60-day comment period places an undo burden ori the1,ublic to respond to this.543-page tecbnical:~ocumem. In addition; this overlaps several other comment periods inJ~few Mexico, including three comment periods for the Waste Isolation Pilot Plant (WIPP) and one for Los Alamos National Laboratory.
I formally reque'st that each:ofthe 3 scheduled.meetings1have time forthe,,public t<>,make yerbal comments to those present, not just a recording, including, at the Roswell Open,H;ouse, I also request additional Public Scoping Meetings for other New Mexico communities that will be impacted by the transport, including but not limited to: Albuquerque, Clovis, and Gallup.
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 repository" or at a DOE-owned and operated monitored retrievable storage facility. The Holtec site' meets neither reqairement, as it is a private facility.,
- Holtec Must Remove Copyrights And AH,Redactions in';tb,e Envir~n~~ntal Rep~rt NRC must require Holtec to prod1.1ce an.~R that has. no. such copyrig~t, restriqtion al).cl; has no redactions.
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Thelinpacts*Of Permanent Storage Must Be Analyzed,*.*
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1 The Environmental Report (ER) is inadequate and ;incomplete because it does not an~lyze the impacts of the spent fuel being*leftat the:Holtec site indefinitely....
Mote Alternatives Must Be Analyzed Keeping the spent fuel casks in some form of Hardened On Site Storage (H.OSS) on the i'eactor sites must be analyzed. *.
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The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel 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 c~nister 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 13 5 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.
- Sincerely, Signed ~2 t{ &k Name (Print) ~MpadyoJ /( {)ll!L, City & State C}t, A!JJ [?8i'J,S d,
April __3_, 2018 May Ma Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052; 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 canisters of highly radioactive waste through thousands of communities nationwide. I do not consent to the risk of 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 Extension Of Time For This Comment Period_.,A 60-day comment period places an undo burden on the public to respond to this.543-page technical document. In addition, this overlaps several other comment periods in New Mexico, including three comment periods for the Waste Isolation Pilot Plant (WIPP) and one for Los Alamos National Laboratory.
I formally request that each,of the 3 scheduled meetings :have time for the,_public to,make verbal comments to those present, not just a recording, including. at the Roswell Open,House. I also request additional Public Scoping Meetings for other New Mexico communities that will be impacted by the transport, including but not limited to: Albuquerque, Clovis, and Gallup.
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 repository" or at a DOE-owned and operated monitored retrievable storage facility. The Holtec site meets neither requirement, as it is a private facility.
Holtec Must Remove Copyrights And All:Redactions in'.th,e Environ~ental Rep~rt NRC must require Holtec to produ~e an ER that has,no such copyright restriction and.has no redactions.
- ..* ~ '...
The Iinpacts*Of Permanent Storage Must Be Analyzed
- . The Enviroim1ental Rep01t (ER) is inadequate and,incomplete because it, does not analyze the impacts of the spent fuel being left at the Holtec site indefinitely.
Mo're Alternatives Must Be Analyzed Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the i"eactor sites miist be analyzed. *.,,
i
- The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel 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 13 5 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.
- Sincerely, Signed ~
4 M!v Name (Print) -:5, Mjt<.eJ yo/ /( {) ~IL City & State C}4 AIA'J gg;;,sJ,