ML18142B015
| ML18142B015 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 05/22/2018 |
| From: | Public Commenter Public Commenter |
| To: | Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| NRC/NMSS/DFCSE | |
| References | |
| 83FR13802 | |
| Download: ML18142B015 (3) | |
Text
1 ADMRegs-Holtec-CISFEISCEm Resource From:
ADMRegs-Holtec-CISFEIS Resource Sent:
Tuesday, May 22, 2018 1:30 PM To:
ADMRegs-Holtec-CISFEISCEm Resource
Subject:
HOLTEC COMMENT #76 Attachments:
NRC-2018-0052 DRAFT 0066 #76.pdf Holtec CISF FDMS Comment Number:
DOCKET ID: NRC-2018-0052 83-FR-13802
PUBLIC SUBMISSION As of: 5/22/18 1:12 PM Received: May 11, 2018 Status: Pending_Post Tracking No. 1k2-9333-i6kf Comments Due: May 29, 2018 Submission Type: Web Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0001 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0066 Comment on FR Doc # 2018-06398 Submitter Information Name: Katherine O'Sullivan Address:
1825 Riverside Drive New York, NY, 10034 Email: xkosullivan@hotmail.com General Comment Docket ID NRC -2018-0052 Risk of De Facto Permanent Surface Storage Parking Lot Dumps Southeast New Mexico, near the Texas border, has the dubious distinction that every single train car load of high-level radioactive waste will pass through on its way into (and, if it ever leaves, out of) Holtec International/Eddy-Lea [Counties] Energy Alliance (ELEA). But transport impacts, to eventually import more irradiated nuclear fuel than currently exists in the U.S. into s.e.NM, will be felt nation-wide. Transporting 100,000 metric tons, or more, of irradiated nuclear fuel to NM makes this proposal even bigger than the highly controversial, unacceptable Yucca Mountain, Nevada permanent burial dump scheme, in terms of transport impacts (limited to 70,000 metric tons under current law). In that sense, when it comes to radioactive waste transportation risks, we all live in New Mexico.
For this reason, only four NRC public comment meetings (three in s.e. NM, and one at the agencys HQ near Washington, D.C.), are woefully inadequate. Countless millions of Americans, in most states in the Lower 48, would be put at risk by these highly radioactive, irradiated nuclear fuel shipments by train, truck, and/or barge. (See, for example, the national transport impacts associated with the proposed Yucca Mountain, Nevada permanent burial dump for highly radioactive waste:
For this reason, NRC should be holding environmental scoping public comment meetings across the country, not just in s.e. NM (and a single national meeting at the agencys HQ in Rockville, MD). Americans Page 1 of 2 05/22/2018 https://www.fdms.gov/fdms/getcontent?objectId=090000648325a7e8&format=xml&showorig=false 6816,5HYLHZ&RPSOHWH
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nationwide should demand NRC hold a hearing in their impacted community! The U.S. Department of Energy (DOE), during its Yucca Draft Environmental Impact Statement (DEIS) public comment period many years ago, initially planned a dozen meetings nationwide. Under public pressure, DOE was forced to double the number of such meetings, in communities impacted elsewhere across the U.S., as well.
But a de facto permanent surface storage parking lot dump at Holtec/ELEA in s.e. NM would only increase safety risks. It would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly, even if decades, or centuries, or more, can be called temporary!). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified thats a big IF! Yucca is NOT suitable!). And that could be back in the same direction from which it came in the first place, meaning transport corridor communities could see these high risks coming and going!
Holtec/ELEAs assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed. And DOEs current estimate for the opening of the U.S.s first repository is 2048, 31 years from now. Except they have no idea where that will be. There is every likelihood that the 2048 date will slip into the future as well.
The failed Private Fuel Storage, LLC (PFS) parking lot dump targeted at the Skull Valley Goshutes Indian Reservation in Utah, likewise assumed the Yucca dump would open. They were, of course, incorrect. PFS was based on Holtec casks, just as is the current NM scheme.
Maine Yankee was a PFS nuclear power industry consortium member. More than 50 rail sized containers of highly radioactive irradiated nuclear fuel would have traveled 5,000 miles round trip, from Maine to Utah, accomplishing absolutely nothing, other than exposing millions of people in numerous states to high-risk shipments.
This game of high-risk, highly radioactive waste musical chairs, or highly radioactive waste hot potato, on the roads (initial leg heavy haul truck shipments), rails, and waterways (initial leg barge shipments), is unacceptable. It amounts to Radioactive Russian roulette on the roads, rails, and waterways. Multiplying transport risks for no good reason is wrong, and makes no sense.
This is not a solution. The american people do not want this.
Page 2 of 2 05/22/2018 https://www.fdms.gov/fdms/getcontent?objectId=090000648325a7e8&format=xml&showorig=false