ML18120A111
| ML18120A111 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/17/2018 |
| From: | Mcgahey A, Mcgahey D - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00040, NRC-2018-0052 | |
| Download: ML18120A111 (2) | |
Text
April 17,.. 2018 SUNSI Review Complete Template= ADM-013 E-RIDS= ADM-03 Add= An+PltJ..e.4ie u?u.( ~*s"',../.lt May Ma Office of Administration Mail Stop: TWFN-7-A60M
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U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001
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-)j3tJ/ 2-Plg' 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. I do not consent to the risk of contamination of our lands, aquifers, air, or the health of plants, wildlife, a,nd livestock. 1 do not consent to endangering present and future generations.
- ,:I-I formally request a 60-dayExtension 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 c_onuilent periods in N:~.:w}vlex:ico, !ii1cluding three comment periods (or the,Wast.Jsolation :pilot Plant (WPP) and on~ for Los _Alamos N ationa:l Laboratory.
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- J I formally request that each of the 3 scheduled me~tings 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 add.itional Public Scoping Meetings.for other New:_Mexico communities that will be impacted by the transpqi:t,:incluc:ling bµ! not limitedt<?= AllJ.uquerqllei Clovis, and Gailup.
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This Holtec Pronosa:l.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 1"{ust Remo¥e1Copyrights And A~t.Redacti9ns, ~nJ~e Environmen~~l Report
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- NRC must require Holtec to prpduce ap E.R that has no such copyright restriction and has no redactions. -.:
The Iiµpacts Of Permanent Storage Must Be Analyzed The Environmental Report_ (ER).is inadequate and;in~ornplete pecaµse it.does not analyze the impacts of the spent fuekheing left.at the Holte_c.site indefinitely..
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Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the reactor sites must be anaJyzed.
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L The alte~ative of consolidated storage being done at an existing li~ensed Independent Spent Fuel Storage Facility (ISF~I) must be analyzed.
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The Environmental Report in~dequately discusses the transportation Risks
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This ER must include all transportation routes and the potential impacts of accidents or terrorism incidents*on pl,!.blic 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 ofwhat many 3.0 - 4.0 fracking-induced earthquakes will have on the buried casks.
Sincere!#_~
Signed,
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