ML18131A156
| ML18131A156 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/26/2018 |
| From: | Johnson V - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00072 | |
| Download: ML18131A156 (2) | |
Text
Phone:
SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Anntoinette Walker-Smith' Jill Caverly (JSCl)
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COMMENT #72 PUBLICATION DATE:
3/30/2018 MayMa Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 CITATION: 83 FR 13802 RE: Do~e!-~.o~ 72-'.!_05i;_J:Ioltec International's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New MeXIco*....
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NRC:
I/We respectfully submit th~se scoping comments on the Holtec Environmental Report (ER) to bring up to 100,000 metric tons of spent fuel,.liigh-ievel radioactive waste, froni nuclear reactors around tl:te country to s.outheast New Mexico. Please know that I/we do not consent to becoming a national radioactive waste dumping ground-or to transporting up to 10;000 canisters of highly radioactive waste through thousands of communities. I/We should not have to risk the contamination o(our land, aquifers or ait or the health of plants, wildlife and livestock, endangering present and future generations.
This Holtec Proposal Is Contrary~ Current Law
.. Current law only allows* the u~s. Department of Energy to take title to commercial spent fuel
~following commenc~ment of operation of a. repository" or at a DOE-owned and operate_d monitored re_trievable storage facility. The Holtec site meets neither requirem,ent, as it is a private *facility.
Holtec Must Remove Copyripts An:d All Redactions in the Environmental Report NRC must require Holtec,to pro4uce an.ER tliat 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
- iµipacts of Uie spent fuel being left at the Holtec site indefinitely.
More Alternatives Must Be Analyzed Keeping th~ 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 tran~portation 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 o~ such shipments.
The Consequences To An Accident-Exposed Individual Must Be Analyzed
<ll Terms*like "collective dose* risk and "person-rem;,. ~re us~d 'to igno*re the_ potential i~pacts t9 ~
single *individual.
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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, sfoce there is n9 wet p~ol.~r ~ot ceffat the*site.
More C~nutlati~e Imp~cbi Mu~ Be ~al~~d.
The ER mentions WIPP but does riot analyze the: i-hipacts 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 Di.any of the estimated 135 *j~bs ~
g~' to locals?
,o The'total"number of annuafworkers at the site could total as many as 135 when construction jobs are combine~fwith the operating workforce.'*
Seismic Impacts On Stored Casks. M~st Be s~~ed Although the* ER gives a statement on recent seismic actiyio/ in the area, there is n_o a~~ysis of ~hat
. niany 3.C> - 4.0 frackfog-induced ea~qil_ak~s will have on the buried casks.
Other
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- 15. ~:' cf;d)~,8 ~,-, C9!>. rLes 1:,, ~er Comments may also be submitted online at: https:f/www.regulations.gov/cominent?D=NRC-2018-0052-0001