ML18155A312

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Comment (130) of Rodney Mccullum on Holtec International HI-STORE Consolidated Interim Storage Facility Project: Comments of Nuclear Energy Institute on Scoping for Nrc'S NEPA Review Process (NRC-2018-0052)
ML18155A312
Person / Time
Site: HI-STORE
Issue date: 05/29/2018
From: Mccullum R
Nuclear Energy Institute
To: May Ma
Rules, Announcements, and Directives Branch
References
83FR13802 00130, NRC-2018-0052
Download: ML18155A312 (2)


Text

RODNEY MCQJLWM DiredrJr, Used Fuel Programs SUNS! Review Complete 1201 F Street, NW, Suite 1100 Template= ADM-013 Washington, DC 20004 E-RIDS=ADM-03 NUCLEAR ENERGY INSTITUTE P: 202.739.8082 ADD= Anntoinette Walker-rxm@nei.org nei.org Smith, Jill Caverly (JSCl)

May 29, 2018 COMMENT (#130)

PUBLICATION May Ma DATE: 3/30/2018 Chief, Program Management, Announcements, and Editing Branch CITATION: 83 FR Offire of Administration, MS TWFN-7-A60M 13802 U.S. Nudear Regulatory Commission Washington, DC 20555-0001

Subject:

Holtec International HI-STORE Consolidgted Interim Storage Facility Project:* Comments of Nuclear Energy Institute on Scoping for NRC's NEPA Review Process (NRC-2018-0052)

Ms. Ma:

The Nuclear Energy Institute (NEl) 1 is pleased to provide scoping comments to the Nuclear Regulatory Commission regarding Docket No. 72-1051; NRC-2018-0052, Holtec International's HI-STORE Consolidated Interim Storage Facility Project.

NB has a longstanding policy of supporting the development of a consolidated used nuclear fuel storage facility in parallel with *completion the Nuclear Regulatory Commission's (NRC) review of the Yucca Mount.ain repository license application. Therefore, we welcome the NRCs ongoing environmental review of_ this project.

In preparing the Draft: Environmental Impact Statement (DBS) regarding this project, the NRC is tasked with meeting the precepts of the National Environmental Policy Act (NEPA); the purposes of which are to declare a policy:

[W]hich will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and

  • stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources imporl:ant to the Nation.

1 The Nudear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NB's members indude entities licensed to operate mmmercial nuclear power plants in the United States, nudear plant designers, major architect and engineering finns, fuel cyde facilities, nuclear materials licensees, and other organizations involved in the nudear energy indusby.

NUCLEAR. CLEAN AIR ENERGY

Ms. May Ma May 25, 2018 Page 2 Responsible, well-planned oonsolidated interim storage of used nuclear fuel - as proposed by this project -

fits firmly into what Congress had in mind when it sought the balance of "enjoyable harmony between man and his environment" The purpose and need of this project are straightforward: to provide a safe, retrievable storage facility where nuclear materials currently stored at numerous installations across the country can be oonsolidated into one suitable location, in preparation for future relocation to a final repository. To that end, we respectfully submit the following for your consideration:

  • Holtec's HI-STORE Consolidated Interim Storage Facility Project is essentially a larger version of an independent spent fuel storage installation, of whid! there are 79 currently operating successfully in 34 states. Working with the NRC as the regulator, the nuclear industry has a long history of property designing and building facilities that safely and securely store used fuel.
  • We understand that, during this scoping process, the NRC already has received requests to dramatically expand the breadth and scope of the NEPA process and the DEIS beyond what is appropriate under NEPA. We strongly recommend the agency resist those entreaties. Doing so would simply delay the nation's efforts to address used nuclear fuel storage, while providing no meaningful additional protection of human health and the environment. Further, the NRC licensing/permitting process already has numerous built in redundancies that provide added assurances that environmental- resources, as well as safety, will be protected.
  • We also understand that, in addition to analyzing environmental impacts, the DEIS will conduct a dose review of the socio-economic impacts of the project. Development of this facility will provide many socio-economic benefits, not only at and around the New Mexico site, but also in the oommunities from which used fuel will be removed. Relocation of used fuel will allow communities to redevelop the reclaimed areas where fuel is currently stored.

In oonclusion, we believe that this project is in the long-term best interest of the United States as a nation, the Eddy-lee region of New Mexico, and the communities from where currently stored fuel will be removed.

As such, it is an important U.S. infrastructure project that requires predictable licensing, and therefore we urge you to proceed in a timely fashion by establishing and adhering to a reasonable schedule.

We thank you for this opportunity to provide comments.

~~~

Rodney McCullum C: Joy Russell, Holtec International