ML18120A104
| ML18120A104 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/09/2018 |
| From: | Orr G - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00035, NRC-2018-0052 | |
| Download: ML18120A104 (4) | |
Text
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May Ma Office ofAdministratiort Mail St9p:*TWFN~7_;"A60M
- u:s. Nuclear Regulatory Commission.
Washington, DC 20555- 0001 *
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SUNSI Review Complete Template= ADM-013 E-RIDS= ADM-03
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.* :.~.3 Ff< 13 s-o*;,. \\ p f2J o/_R_,oig RE: Docket ID NRC-2018-0052; Holtec International's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico -,
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- .* t 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 tchransporting 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 th~ health of plan.ts, 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 J?eriods_forthe 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 I
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 the Environmental Report NRC must require Holtec to produce an ER that has no such copyright restriction and has
- no redactions.
The Impacts Of Permanent Storage M~st Bi~ Analy~ed The Environmental Report. (Eij.) l_S, iw1pequate ancl incqmplete-becaU'se, it does' not analyze the impacts 6:f the spent foel°b~ing _leffat the Holtec site in9efj.nitely.. * :.*,,.,,
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More Alternatives Must Be Analyzed,
- ., Keeping the spent fuel casks iri some forqi ~f Hardened 0~ Site Storage (HOSS}on the
. reac_tor *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) mu~t be analyzed. :...
l'he Environm.ental Report inadequately discu~ses; the h~~n~poftation Ri~b,:.:;.
This ER must include*'all transportation rout~s and the-potential impacts of accide:µts or terrorism incidents on public health and safety along flll the routes. * *..
The ER is inadequate and incomplete because it does not discuss h<;>w raHshipments from reactors' without tail 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.
Crac~ed 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 efectric 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.
- Sincerely, Signed
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Name (Print) &'1-A.( IY}. 0A k.,
City & State ~
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April _1_, 2018 May Ma Office ofAdministration Mail Stop:-TWFN-7___; A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 i.-i ",\\.. '
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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'fransporting 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 the Environmental Report NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions.
The Impacts Of Permanent Storage Must Be Analyzed The Environmental Report (ER) is inaqequate and incomplete *because. it does* not analyze the impacts of the sperit fuel b~ing left at th_e Holtec site inc;lefinitely.
More Alternatives Must Be Analyzed.
. *, Keeping the spent fuel casks in some form of Hardened On Site Sto,rage (HOSS) on the reactor sites must be ai'.lalyzed.
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!, :i The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) mu~t be ana~yzed....
The Enviro.nmental Report inadequately dis'cusse~ the fra~Sl)Ortation Risks.
This ER must include 'all transportation rnut~s and the potential impacts of accidents or terrorism incidents on public health and safety along,all tl:ie routes.. *,._
The ER is inadequate and incomplete because it does not discuss how rail _shipments from reaotors without tail 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.
Crac~ed 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.
- Sincerely, Signed d_~ £ Av:.
Name (Print) &frAY IYJ_ 0A ~
City & State ~
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