ML18130A561
| ML18130A561 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 05/04/2018 |
| From: | Kirschling K - No Known Affiliation |
| To: | Division of Administrative Services |
| References | |
| 83FR13802 00058, NRC-2018-0052 | |
| Download: ML18130A561 (3) | |
Text
PUBLIC SUBMISSION Docket: NRC-2018-0052 As of: 5/8/18 3:17 PM Received: May 04, 2018 Status: Pending_Post Tracking No. lk2-92yj-ij3q Comments Due: May 29, 2018 Submission Type: We.b Holtec International HI-STORE Consolidated Interim Storage Facility Project SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker Smith Comment On: NRC-2018-0052-0001 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0049 Comment on FR Doc# 2018-06398 Submitter Information Name: Karen Kirschling General Comment JILL Caverly (jscl)
COMMENT (#58)
PUBICATIO~E:
3/30/2018 CITATION# 83 FR 13802 RE: Docket ID NRC20180052; Holtec Internationals HISTORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC:
I am submitting these 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 public comment, and that the Roswell Open House include a regular scoping meeting as well, or be cancelled. 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 and at least one in Dallas/Ft. Worth, San Antonio, and Midland, Texas since there would likely be extensive transport through these cities.
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 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 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.