ML18120A105
| ML18120A105 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 03/30/2018 |
| From: | Harris B, Harris J - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00036, NRC-2018-0052 | |
| Download: ML18120A105 (4) | |
Text
April __, 2018 May Ma Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commissfrin.
. Washington, DC 20555-0001 SUNSI Review Complete Template= ADM_ 01a E-RIDS= ADM-03 Add= llr,fo,11~-/kW(,(,/k~5PI HA
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'13 Ff< l34a'O~ I )~l3~f?_o~~r RE: Docket ID NRC-2018-0052; Holtec Intemational's HI-STORE CIS Facility fo~ '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 Ex;ten::;ion 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:
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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 ~o: 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 i~ a.privateJacility.
Holtec Must Remove Copyrights And All Redactions in the Environmental Repor:.t NRC must require Holtec to produce an ER that has IJ.O such copyright restriction and has no redactionsi. *....
The Impacts Of Permanent Storage Must Be Analyzed The Environmental Report (Ell) is inad~quate and*incomplete, because it does not analyze
- the impacts of the spent fuel being left at tp.e.Holtec site* ind.efinitely.
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More Alternatives Must Be* Analyzed.
Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the
-reactor sites must be analyzed.
- The alternative of consolidated storage being done at an existing licensed Independe~t 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.
Crack-ed-And Leaking.Ca~ks Must Be Addres~ed The ER does not analyze exactly how ~adio~~tive waste fr~m 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 workforc.e.
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,
April __, 2018 May Ma Office of Administration Mail Stop: TWFN 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 l 00,000 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 privateJacility.
- 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 inadequate and incomplete, because it does not analyze the impacts of the spent fuel being left at the Holtec site indefinitely.
More Alternatives Must Be Analyzed Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the reactor sites must be analyzed.
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 radioa~tive 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,