Text

Comment (121) of 25 Individuals Opposing Holtec Internationals HI-STORE Cis Facility for Spent Nuclear Fuel
	ML18155A323
Person / Time
Site:	HI-STORE
Issue date:	05/19/2018
From:	; - No Known Affiliation
To:	May Ma; Office of Administration
References
	83FR13802 00121, NRC-2018-0052
	Download: ML18155A323 (48)
	v • d • e

{{#Wiki_filter:/ / I ~.*e. //'(, 2018 I May.Ma Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Comnrission Washington, J;)C 20555- 0001 Template= ADM-013 E-RIDS=ADM-03 ADD= Anntoinette Walker-Smith, Jill Caverly (JSCl) COMMENT (#121) PUBLICATION DATE: 3/30/2018 CITATION: 83 FR 13802 RE: Doc~et ID NRC-2018-0052~ Holtec Intemational's*ID-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC: I resp.ectfiµly sub~t these scoping comments on the Holtec Environmental Report (ER) to bring up to* 100,000 metric tons of spent fuel, high-level radioactive waste, fro~ nµ~lear 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 dumpiJ}g ground. I do not consent to ~-g up t9 J Q,000 canisters of highly radioactive waste. tbrough tbo:usan$ of communities nationwide. I do not consent to the risk of contamination of. our lands,. aq~fers, air, or the health of plants, wildlife, and livestock. I do not consent to endangerlng present and future generations. I formally.request 'a 60~ Extension Of Time For This Comment P~od." A 60~day eotnment period places an undo burden on the public to respond to this* 543-page technical document. In addition, tbi~ *overlaps several c,tp.er. comment _periods ip. :New Mexico, i.J;u;l~dµig three comment periods foF'llie Waste Isolation Pilot Plant-(WIPP) and*'one for Los.. Alaniqs ~tfonal Laboratory. I formally request that each of the 3 scheduled meetings have tiip.e for p:uhµ~ co~ent, and th.at the Roswell Open,House include a regular scoping meeting as* well, or be cab.celled. I also *reqiiJst additional-Public Sooping*M~gs for 6th.er New M~xico commumtiest!i~i will be.impacted by the transport, including but not limited to:*Aibuqµerque~ Ciovis, and Galliip and at least bne in Dallas/Ft. Worth, San Antonio, and Midland, Texas sjn~ there would ~~ly be ~xtensiye. transport through these cities. This°Il(jltec Pro:iiosal Is Contrary to Current Law * ':/.. Current law only allows the U.S. Department of Energy to take title to conmitWiaI spent fuel "following commencement *of operation of a :rq>0sitory'~ or at a DOE-owned and operated monitored retrievable storage facility. The Holtec site meets neither requirement, as it is a private facility. Holtec"l\\fust Remove Copyrights And_.A.ll Redactions in the Environmental Report NRC must require Holtec to.produce an ER that has no such copyright restriction arid has no* redactions.

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The Impacts Of Pe~~t:Storage Must Be Analyzed * - The_Environmental Repotffflll}i~.. in.a<Jequate@d incoinpl<<e*because it does not anaj.yze the. impacts of the spent fuel being 1eft a{the-Holtec sfte*iii~fimtely. More Alternatives. Must-:U,e Analyzed

May 17, 2018 May Ma Office of Administration Ma.ii Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 RE: Docket ID NRC-2018--0052; Holtec International' 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~ 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,vill 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 AnalyLed 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 l\\'lust He Analyzed

Keeping the spent fuel casks in some form of Hardened On Site Storage (HOSS) on the reactor sites mustbe 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 Toe railroads and electric lines are not in place, but must be analyzed. How many of the estimated 135 jobs will go to locals? oto 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.

May 21, 2018 Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052; Holtec International's ID-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC Members: I do not consent to New Mexico becoming a national radioactive waste dumping ground and making Carlsbad the Nuclear Waste Dump of America. Holtec's application is for up to 120 years with a high possibility of waste remaining for at least 300 years. By that time the fragile, thin-walled containers will mostly likely be too delicate to move leaving all the nation's high level waste in a permanent, shallow landfill. If this were a permanent repository, and engineered for that, there would be few that would oppose it. Since you have little control of Holtec as a private company, for however long it is profitable and solvent, and given that there would be little motivation to move it once it is there, this will likely be a long term problem, with a short term benefit, and a few jobs. Given our political volatiJity lately, it seems ludicrous to as~ume there will be the political will and finances to move all these deteriorating and leaking cask_s 40 to 120 years from,now. What a radioactive gift that keeps* on giving for our descend~nts and *the civilizatio~s that follow us! Why not just do it once and do it right and.permanent? *we wouldn't think of.doing te~pora.ry storage with any other kind of~aste, especially with this price tag. Geological and hydrological investigations at least as robust and comprehensive as those for WIPP must be undertaken_ as the site is a complex geological area with earthquakes, many natural resources, and ka..--st formations including massive sinkholes. Those investigations were many and. took years. Even ifWJPP is sited on an island of non-karst in the middle of one of the largest karst areas in the world, the likelihood that Holtec is also sited in such a so-called safe area is remote; much more needs to be known about the geology and hydrology of the Holtec site before we can be sure it is safe. The studies for Holtec more resemble studies for a local gas station than those for a site planning to store and possibly dispose of the most deadly wastes in the entire nuclear fuel cycle. Tile Impacts Of Permanent Indefinite Storage (De Facto Disposal) 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. Eco1;1omic Effects On Current New Mexico industry And Agriculture Must Be Analyzed Impact<; of potential conta~_ati~n on local dairy.&_ pe~an farms; tourism, c.;attle ranching and the oil -and gas industties that employ moreJhan 15,.000 peqple must l;>e ru;i.~yzed. Impacts of loss of iricome and property values from the perception of contamination even if it doesn't actually occur must also be analyzed. How many current jobs would be lost ifno one wants to buy . so~theastem N e-yv Mexicp cattle, dairy, aµd agri~_µltural products or our oil and gas be.cause it's believed it could b~ conta.ritinated? e This analysis must be ex~ended to current industrie$ and agriculture along the transportation routes to see what effects an accident with and without a release would have.on those local econon;ries.

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. There doesn't appear to be any way to deal with problem casks during transportation or at the site. e The application seems to make assumptions that both transportation and containment at the site for centuries to come will be perfect. This is unreasonable and irresponsible. 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 or how a release from Holtec could affect WIPP. Impacts Of Future Railroads And Electric Lines Must Be Analyzed a The railroads and electric lines are not in place, but must be analyzed. 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-induccd earthquakes or a much larger earthquake will have on the buried casks. This is an area with a long history of fracking and unstable geology. For the good of our future, our nation and the City of Carlsbad, please reject this application. Many of our elected city and county officials have been awe struck enough with the prospect of 55 jobs to gamble our whole future economy and health on this one ill advised short term fix for a long term problem. Please say no to this so we can do nuclear waste disposal once and do it right. ~~4-Nicholas King Pastor, Carlsbad Mennonite Church 1107N Canal Carlsbad, NM 88220 575 887 0606

MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052; Holtec Intemational's ID-STORE CIS Facility for Spent Nucle¥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, 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 pe1iod places an undo burden on the public to respond to this 543-page technical document. fu addition, this overlaps several other comment periods in New Mexico, including three comment periods for the Waste Isolation Pilot Plant (W]PP) 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 cmnmunities 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 lfoltec 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. Toe 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

Mail comments to: MayMa Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 Or submit online at: https://www.regulations.gov/ comment?D=NRC-2018-005 2-0001 [Any information ( e.g., personal or contact) you provide on this comment form or in an attachment may be publicly disclosed and searchable on the Internet and in a paper docket and will be provided to the Department or Agency issuing the notice.] RE: Docket ID NRC-2018- 0052; Holtec Intemational's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC: I/We 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. Please know that I/we do not consent to becoming a national radioactj.ve waste dumping gro_und or to tr_ansporting up to 10,000 canisters of highly radi9active waste through thousands of communities. lfWe should not have to risk the contamination of our land, aquifers or air or the health of plants, wildlife and livestock, endangering present and future _generations. This Holtec Proposal Is Contrary to Current Law. Curr:ent law oniy allows the U.S. Department of Energy to take title to commercial spent fuel "following commencement of operation of a repository or at a DOl;:-owned and operated monitored retrievable storage facility. The Holtec site meets neither requirement, as it is_a private'facility. Holtec Must'Re~ove.Copyrights And_ All Reda~ons 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 P~rmanent Storage Must Be Analyzed The Environmental Report (ER) is inadequate.and incomplete because it does not analyze tlie 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 c_onsolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed.

The Environmental Report inadequately discusses the transporG.1tion Risks This ER must include.all transportation routes ~nd the potential impacts of acciE!ents or tertorisll). incidents on public health.and safety along all the route~...
The ER is inadequate and incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and th~ 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. t C~cked kidLe~g Casks Must* B~;Addres~ed.

The ER does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet poot or hot cell at the site.

1 /.. 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 r-ailroads,and electric lines are *not in place, bufmust be analyzed. How many oftbe 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. wdrlcforce. Seismic hnpacts On S~red 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 fraddng-induced earthquakes will have on the buried casks. Sincerely, . 0 \\;V\\.o...\\ 'PC'J('{-if ~--- / 5)/2_ ~_('( _CA1250AI D. ~ 1 y_~(i-~.tJ ~ ~ 7 3(J'_)r [Please provide at least Name, City, & State] The link to these comments - https:/ /www.nukewatch.org/nohlwnm.html The link to the ER'."" https://www.nrc.gov/docs/ML18Q2(ML18023A90.4.pdf And here's the Federal Register Notice -... https:1fwww.gpo.gov/fdsys/pkg/FR-2018-03-30/pdf/i018-064.95.odf Links to more info -- https://www.nirs.org/campaigns/dont-waste-america/cis/ http:/ /www.beyondnuclear.org/ centralized-storage/ http;//neis.org/current-radioactive-waste-issues/, http://nukefreetexas.org

Keeping the spent fuel casks in some form ofHardened On Site Storage (HOSS) on the reactQr sites must be analyze_d. The alternative of consolidated storage being done at an existing* licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed. The Environmental Report in.adequately discusses the Transportation Risks ~. This ER must include all transpo~tion routes and the potential impacts of accidents or terrorism incidents on public health arid 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 arid impacts.of such shipments. The Consequenc~s To An Accident-E:q>osed Individual Mµst Be Analyzed Tenns 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 WlPP 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 wiii 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 earthquak:~*,M.'*ill have on the buried casks. Sincerely, C'

~~~!st~~~

City & State 60vl ~Up ) N /Vl

Mc,_,g l 1- , 201s MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission

washington, DC 2055.5- 00.01 RE: Docket ID NRC-2018-0052; Holtec Intemational's Ill-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New M~xico 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 b~use I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do not consent to trap.sporting 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 pl~ts. 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 respo]).d to this 543--page technical document. In additio~ 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 Meeti.J,igs for other New Mexico com.niunitjes that~ 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 th~t 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 ~t the Holtec site indefinitely. More Alternatives Must Be Analyzed

April _ _2l}_, _2018 MayMa Office of Administrat:j:00:,.. Ma,i.J-Stop: TWF,N:-~ 7--:e-, f\\.l?Ofyl . *\\"'*. U.. S. Nuclear Regulatory ~9n:;nois~i9n Wasbjngtop., DC_Z05~5-0001; RE: Docket m'NRC-2018-0052; Holtec Intemational's ID-STORE CIS Facility.forSp_ent Nuclear Fuel, Lea County, New Mexico i*.... 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. radioactiye waste, from nuclear reactors ~ound the country to s9uth~~t New Mexi~o. I~ _sul,nnit:ti.ilg tpe_following comments pe_GauseJ do not consettt.fo'.New* ~e~cp \\)~oMin'g a_-.n~~o~~;:r~clio~~~y~ ~~ 44ajp~g,f¥?1ll.1~:-_1A~ ~6_t_ consent to transporting up to 10,000 canisters of highly radioactive waste tlrrougli thous.ands. of*. ' communities nationwide. I do not consent to the~~~ of cqn~~µ.011 o~ ()~ lands, aquifers, air, or the health of plants, wil~e, and livestock I do nofcon.'sen(to eridangeniig-pr~ent arid.future generations..... :, ' I formally request a 60-day Ex,tensioI\\ Of Tune For Tbis Comment Perio.d. A 60-day comment period places an undp burden 6n the 'public to responci' to'.tfus. 543-page tecbnitai 'docli~enf In' addition, this overlaps several *other comment periods in New Mexico, inclti.ding three comment periods for the Waste Isolation Pilot Pl~t ('yIPP) ~done !or It:>s Alamos National Laboratory. I formally 'request that each of the 3 scheduled meetings have t.4ne for the public to make verbal comments to those present, not just a recording, including at the Roswell Open House. 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. 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 anal~ 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 WlPP 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. Sincerely, Signed~~ - Name~ 1£t<f/[<;ft /W City:_&- State ---rM)G/ /J J1

April 3D_, 2018 MayMa Office of Administration Mail Stop: TWFN A6GM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018--0052; Holtec Intemational's-ID-STORECIS 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 COlllDlUlllties* natibnwide. 1-_do -~9t C~iisent to the IlS~ of _COJ;ltamin~tj9°: of _om; )ands,.aquifyI;S, air, or the health of plants, wildlife;_ ~d._ livestock. I do not consent to endangering present *and future generations. I formally request a 600.day Exte:risfon "t>f Tim~ Fo_r* This _Comment Period. A 60-day (:Orµtnent period plates an tindo burden-on tlii{ public to tespoiici to this 543-p~ge technical document. 1n* addition; this overlaps several other comment periods iri New Mexico, including three comment periods for t11e Waste Isolation Pilot Plant (WIPP) and one for Los Alamos National Laboratory. I formally.request that*each bf the 3 scheduled meetmgs 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 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. 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 o . NRC must require Holtec to produce :an ER that has no such *copyright restriction and has no redactions. The Impacts Of Permanent Storitge Must *B~ Analyzed

The* Environmentai Report (ER) i~ *itiadequat~ -_and irit~rtipfot~ b~~rise* it d~s. n~t analyze

.* the impacts of the*;spenffiiel being ieft at the-Iioltec site indefinitely. More Alternatives Must Be Analyzed Keeping the spent fuel casks m' soine form ~f Hard~n~d. On Slte. Storag~ (Hoss) *on the. reactor sites mu~t_oe an~yzed.

ci 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 mipatt:s**of accidents or. ' terrorism incidents on public health and safety along=allthe torites~ : *- The ER is inadequate and incomplete because it does not discussrhow 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 Mus.t ~e,Adck~se4 * *

... 'l;he ER-d~{iiC>i'analyz~-exa~4Y.ii6w_'r~~~~~~V6 ~~f~i6~ ~:~!~C~~4-;aitd.°l~~g __
caiii:~i¢r wouJ.1 Jlt!. ~#idle4. ~mce.the_re *_is_ ~9 vVei poc;,I 9r-i10t
re,il ~1* the, sfre. - **. *
Mor~ C~ufative I~p-~~ts M~ B~-An~yzed '._* :..

The ER mentions WJPP but does not analyze the impacts of a*radiologic release f:roil_l WJPP on the proposed CIS site. ~pacts Of:Future Railroads &ici ~~ec~ic £~~ ~ust B~ '4~~ly~ci;l. :* *. *, J i - ~ '

.}ne railroads and electric lines are p.ot _iµ p~a~e,_ put must be analyzed.

iiow many of the estimated 135 jobs will go to locals?. The total number of ~ual workt!rs_ fit _the site could total as many~ ps 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. Sincerely, _J'I? A ',1~. _7; '1) 1 11 S1gned. ___ -...:..._F--tt'..;__,,__.,~~--=-~__::_-_~'-".;yJ..:....=~~/J_,_~~~~~~~~~~- v Name (Print) -~f!._0_£, __ ~_1-_L_... ~rS-...,~-s~t,~1;-+'p~-------,--- City & Btate __ ~~ft.-"-o-~_,_-lcJ-"ivL.::....::.... __________ _ I

lbttr lb ,2018 MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 RE: Docket ID NRC-2018-0052; Holtec Jntemational's In-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, 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 ti.me 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 m 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 talce 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. Boltec Must Remove Copyrights And AD 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 Analyud 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 disc~ the Transportation Risks This ER must include all transportation routes and the potential impacts of accidents or terrorism incidents on public health mid 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 Aecident~Exposed Individual Must Be Anal~ 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 Ad~ 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 bot 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 ope~g 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 frocking-induced earthquakes will have on the buried casks. Sincerely, c-* Signed \\',~/~06-d -/'::-cJ, -:!_,*~(L Name (Print) "'* L c-.e t l}. 51/lP c,Jde,....,..

MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052; Holtec Intemational's ID-STORE Spent Fuel Waste Facility Nuclear Regulatory Commission: 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, and livestock. I do not consent to endangering present and future generations: I formally request a 60-0ay Extension Of Time For This Comment Period. A 60-day comment period places an undue burden on the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those present. A thorough Environmental Justice analysis must be complete to consider all possible future impacts from this facility to the local communities and those along transport routes, including but not limited to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may adversely impacted at the site and along transportation routes. This Holtec Proposal Is Contrary *To Current Law; o Current law only allows the U.S. Department of Energy to take title to commercial spent

.fuel "following' commencement of ope:ratioi;i 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 "1 NRC must ~etjuire Holtec to produce an E~ that h~ Q.O such cop~ght restriction and has no redactions. The Impacts Of Permanent Storage Must.Be Analy.red The Environmental Report (ER) is inadequate and incomplete because it does not analyze the impacts.of the spent fuel being left at the ll_?ltec site inc;le:finitely. More Alternatives Must Be Apalyzed ; i 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 do~e at ~ existing licensed Independent Spent Fuel Storage Facility (ISFSI) must"b~ ~alyzed; The waste can and should remain on site for i;nany more years and does not need to move until thorough analyses of alternatives are complete.

The E~vironmental Rep~rt inadequately discusses the transportation Risks ir. This ER must incl~de.-all transpotlation routes and the potentit11 impacts of accidents or terrorism incidents on public heal.th and s~ety ruong all the mutes. The ERjs*incomplete because it does not disc,uss how rail shipments from reactors without rail access would be accomplished aq.d ttw 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:

*An.possible exposure~ to hllp).allS from,routj_ne releases from transport casks and site storage must be clearly defined in plain language, for individuals near waste canisters on occasion and workers who are transporting or working at the site long-term.

Cracked And Leaking-Canisters Must Be A~~~ed, 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 Im.pacts Must Be Analyzed The ER mentions the Waste Isolation Pilot Plant (WWP) but does not analyze the impacts of a radiologic release from WJPP on the proposed C:IS si<<?. The impacts from the local oil anq g~ industry on the "proposed "site need to be analyzed. Seismic Impacts On Stored Casks Must Be Stated -. *... Although the ER gives a statement mi"recent*seismic adivity.in the area, there is no analysis of what many 3.0-4.0 fracking-induced earthquakes will have on the buried casks. Impacts Of Future Railroads And Electric Lines Must Be Analyzed The railroads and electric lines ate not in place, but must be analyzed. How many of the estimated 135 jobs will go to locals and how many are only temporary? The total number of annual workers at the site could total as many as 135 when short-term, construction jobs are combined with the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents? Sincerely, 5/t<t-/JB J

MayMa Office of Administration Mail Stop: TWFN A60M U.S.- Nuclear Regulat9ry CommissiC?~ Washington, DC ?055~~ 0001

RE:*Docket ID NRC~2018-0052; Holtec.Jntemation.al'.s III-STQ.Rt: Spent F,uel Waste.Fa~illiy

~. Nuclear Regulatory Commission: I respectfully submit these* scqp~g -~qmµients oh t,he Holtec Environmental Report (ER) to bring up to 100,000 metric.tons of spent fuel, high-level radioactive waste, froin 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 radio~ctive waste dumping ground. l do not consent. to transporting up to 10,000 canisters of highly radi.9actjve waste through thousands of communities nationwide. I do not consent to the dsk of contamination of our lands, aquifers, air, or the health of plants, wild~fe, and livestock. I do ~ot consent to endangeting present and futare generations. I formall-y request a 60-day Extension Of Time Fm: This ~m;rµnent Period. A 60-q;iy comment period places an undue burden on-the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings.for other communities in New Mexico and nationwide that will be impacted' by the transp*ort and that any addition.al meedngs Qave time for the public to make verbal comments' to those present... :. '.. ' A thorough Environmental Justice analysis must be complete to consider all possible foture. impacts from this facility'to the local comrntinities:and those along.transport rou~es,,including but not limited to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous na~ions whose people, cultural resources, or sacred places may adversely impacted at the sit~ and along trans~ortatio~ routes. 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 Ail Redactio.: s 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 th~ reactor sites must be analyzed. ill The altem~tive of consolidated storage being don:e*at*an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed. o The waste can and shouid remain mfsite fo(manymore years* and does*not need tcfmove until thorough analyses of alternatives ~e complete.

The Environmental Report inadequat_ely discusses the transportation Risks This ER must include all transportation.routes and the potential ittipacts of accidents or terrorism incidents on public health and safety along all the routes*.*

The ER is incomplete becaus~ it does not'discuss how.rail shipments from-reactors without rajl access would be accomplished and the risks and-in;ipacis,of suc.h shipments.,

The Con~~q~enc~ To An Accide~t~E~osed'mdi~cfo.ai Must Be* Analyzed. . ' -~'.:.-;'l'e~ lil_ce "colle.ctiy~-.d~s.e risl<." ~d.'~person-:-rern" ~~ usedtb ignore-the potential impacts to a single individual. *

.. II>

Allpos~ible ~xpos~ to hwn~s :fio:cp. roiitine telease~*(ro~ transport casks and site storage must be clearly defineq iµ_plai~ ~anguage, for individuals near waste canisters on occasion and workers who are transporting o*r wotkirig:aithe*site long-term. Cracked And Leaking Canisters Must Be Addressed ,a, The ER does riot 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 the Waste Isolation Pilot Plant (WIPP) but does not anaiyze the impacts of a radiologic release from WIPP on the proposed CIS site. The impacts from the local oil and gas industry on the pr~posed site need to be analyzed. Seismic Impacts On Stored Casks Must Be Stated '. *""*,Although the ER gives fi"statementonrecent 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. Impatts Of Future Railroads And Electric Lines Must Be Analyzed . *,. Jhe railroads and electric lines are not in place, but must be analyzed. How many of the estimated 135 jobs will go to locals and how many are only temporary? The total number of annual workers at the site could total as many as 135 when short-tenn, construction jobs are combined with the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents? Sinc;:erely, si~aibre If) ~.* /;_)a;t.1011\\_ Name (friµt), OJ 0A ~tk~{C ( :JA TS& :N *

MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052;-Ho-itec Intenfational's HI-STORE--Spent Fuel Waste Facility Nuclear Regulatory Commission:

I respectfully submit these scoping comments oiI 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 countryto 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 i0,000 canisters ofhighly radioactive waste through thousands of communities :tiationwicie~ 'I dd noF consenf to lhe *risk of contamination' of out :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 undue burden on the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those present. A thorough Environmental Justice analysis must be complete to consider all possible future impacts from this facility to the local communities and those along transport routes. including but not limited to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may adversely impacted at the site and along transportation routes. 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 Redact.~~ iri. the Environmental Report ~ NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions. The Impacts Of Pe_rinanent Storage Must Be Analyzed The Envirorn:nental Report (ER) is inadequate arid-incomplete because it does not analyze the i_mpacts of the spent fuel being left at the Holtec site iridefmitely. i More Alternatives Musi Be Analyzed

Keeping the spt;!n,t.f\\lel caslc.s in _some form of Hanl~ned On Site Storage (HOSS)" on the reactor sites rriusibe analyzed.. - :, -:.. -.. -.. :. -. ---

The alt~~ativ~* bf co~:~.~lidated" ~torJg~ "b~ini{ done' at aif~xi~tfug "licensed "Independent $pent Fuel Storage Fa,cHity (ISFSI) __ ITiust.~e ~alyzed. The waste ~an: ~4 should remain 'on she for: ~~y. more years 'and does not need to move until thorough analyses of.alternatives are complete..

The Enviroi:imental 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 incomplete because it does not discuss how rail s~p~ents ftom 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 ',<~.. -*Terins lik.e!'collectivedose:tisk~' andYperson.;rem';.,:ate uI;ed to:ign<>re t;hepqt~ntjal impa~ts to a single individual. All possible exposures to humans from routine releases from transport. casks ~d site storage ~us~ be cl~arly defined i11 plaip. l~guage, for individuals near waste canisters on OGCasjon an~J°w.01:kers'who are t:ranspqrting or working at 'fhe site.long-tem1. Cracked And Leaking Canisters Must Be Addressed The ER does not analyze* exactly how radioactive *waste from a cracked and leaking canister would be handled, since there 1s no wer pool or hot cell at the site. M~~e;C~~~.;tiv~ i~~;~~-.:fyi~t B~*;A~~y~~~ '*!'.. r: :.:*~*:.':*** _; :.;. ::*.. _\\.*. *;.-.,..

~-

The ER mentions the Waste Isolation Pilot Plant (W]PP) but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site. The impacts from the locaf oil and gas industry on the _proposed.site need to be analyzed. Seismic Impacts On Stored Casks -Must B~ -S~t~.. '.

.-, Although the*ER gives.a-statement o:ri._re~ent seisnric activ~ty in the* area, then~ is.no
analysis of what many 3.0-4.0 fracldng:-indu~eq,earthqu~es,~111 hav.e on*th~ buried casks.

Impacts OfFuture:Railroads And Electri~.Lin~ Must Be ~.alyz~

**(!* *The--railroa:ds and *electric lines are notiwpl~c~. but mus_t be,an~yzed; Ho~.many of the estimat~ 135.j~b~ ~II. go t~,l9~Js '~rtd b~w ~any are orily temporary?

The total number of annual workers at thi *site could total as many as' 135 when short-term, construction jobs are combined with the operating wo'rkforc~. How many of these jobs will create long-term careers for local communitie~? How many jobs and careers will benefit local residents?

MayMa Office of Administration Mail Stop: TWFN-7:...:. A60M. U.S. Nucl~ar Regulatory Cqmmission Washington~ DC.20555"""'." 0001

RE: Docket ID NRC--:20l84>052; H9lte~ In.te~~t,ional;,s HI-;STORE_ ~pen,t f~el Waste Facility Nuclear* Regulatory Corru;nission:

I resp;ctl'ully ~~brit thc:.se scoping comments on the-Holtec Environmental Report{ER) to bring up to 100,000 metric tons of spent fuel; high-level ni.dioactive 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 radioactiv~ waste dumping ground. I do not consent to transporting up to 10.000 ~anisters of hlgWiraciiq~ctive :waste tlirou:gh thousands of comm.unities 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.preseq.t ~d future generations: I formally request a 60-day E~tt;nsion Of Thne For Thi~ *,c~~ent Period. A* 60-day comment period places an undue burden on the public to respond to* this 543-page technical document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by the transport and that.any additional meetings have time for th~ public to* make verbal. cormne11ts to those present.. C;:. :, : *... A thorough Environmental Justioo analysis must be complete t9 co~sider all possible future impacts from this fadlityto the local communities and those along transpQrt-routes,Jncluding but not. limite.d t(): econo~c and h~alth impacts. I also request proper Tribal Consultation for any affec.ted incp.genous nations whose people;*cultural 'resources; or sacred places may adversely impact~~- lJ the_ sit~* and al.o~g tr:ansportati_on* routes.. This Holtec Proposal Is Contrary To Current Law - ,i, 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 Q 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 e 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 µi some form of Hardened On Site Storage (HOSS) on the reactor shes inust.be analyzed. ., The alternative ~f consolidated storage'beirrg done at an *existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed. 1$1 The waste can* and should remairi ori" site "fot"many more years and does not neecl to move until thorough analyses of alternatives are complete.

The Environmental Report inadequately discusses ~~e ~ransportation Risks This ER must include cµl transportation rout~~ and the po~n~ai impacts of accidents or terrorism incidents on publjc health and safety along all the routes. * ' 1 Q The ER is incomplete because it does not discuss how fail shipments from reactors without . rail access would be accomplished and the risks and imp~cts ~f such shipments.. The c~~eq~e~ces.To A~ A~~ident2Exposecffu'dividual Must Be-Analyzed..

- Te111JS lik~:"C.olle~tjye.d~~~ ris~~:_.iµtd."p_erson::~m"_~--µ"s~ci fo_igriore:the potential impacts to a single individual.

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. All.possjbl~.exposures to humans.from ioi;itinetefoases* ftorri trarispbrt casks and site storage must be clearly defined)n' plain l~guage~* fodndividuals near waste canisters on occasion and workers who are transporting dr 'vibrking at the* ~1te'lcmg-term.

Cracked And :J,eaking Canisters 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 the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS. site.

., The impacts from the local oil and gas industry on the proposed site need to be analyzed. Seismic Impacts On Stored Casks Must Be Stated e Although the ER gives a statement on recent seismic activity in the area, there is no analysis of V¥,hat many 3.0-4.0_fracking-induced earthquakes will have on the buried casks. Impacts Of Future Railroads And Electric Lines Must Be Analyzed =* iii *The railroads -imd*electric lines are-not in-place, but.must be analyzed. How many of the estimated 135 jobs will go to locals and how many are only temporary? The total number of annual workers at the site could total as many as 135 when short-term, construction jobs are combined wjth the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents? Sincerely,

MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ,RE~*Docket ID NRC-2018--0052; Holteclntemational'-s_ HI-STO~.Spent Fuel,Waste Facility Nuclear Regulatory Commission: I respectfully submit these scoping comments on ~~.H.Pi~~ Enyironmental_ ~eport (ER) to bring up to 100,0QO metric:tons of spent fuel, high-level.ra~oactive.waste, from nuclear reactors around the country to southeast New M:exico. I am submitting t;he following comments because I do not consent to New Mexico b~oming a national radioactive ~aste.ciuU1ping groµ~d. I d9 not consent to transporting up to 10,000 canisters of highly radioactive waste tlrro~gh thousands of. co~unities-nationwide_. ldo;!lQtconsent.to the.risk.of contamination of our l~ds,.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 undue burden on the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by.the transport and that any additional meetings have time for the public to make verbal comments to those present. A thorough Environmental Jµstice analysis must be complete to consider all possible future impacts from this facility to the local communities and those along transport routes, including but not linli~ed to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may adversely impacted at the site and along transportation routes. 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 AU 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 Mu.st Be Analyzed The Environmental ~eport (ER) is in~dequate and incomplete because it does not analyze the-impacts o~ the s~nt fuel.being left at the Holtec site indefinitely. More Alteniatives Must Be Analyzed ~ e Keeping thy spen(.fuel casks in some form of Har<iened On Site Storage (HOSS) on the

.-rea.ctor sitesniust be ~alyzed..

The alternative of consolidated storage being'done at. an existing "licensed Independent Spent Fuel Storage Facility (IS~SI) must be analyzed.. The waste can and should remain on.:s.iie for many mo.re years and does not need to move until thorough analyses of alternatives are co~plete*.

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 ~ the routes. *
The ER is 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. -,

Th~ Conseqqences To An Accident-E~osed Individual Must Be Analyzed .* ~.. ~. . e Terms like "collective dose risk" and "person-rem!-' are* used-to ignore the potential impacts to a single individual. All possible exposures to humans from routine releases from transport casks. and site,. storage must be clearly.defil).ed_in plai1,1lru;i.guage, for individual~ nefll' waste cani.sters on occasion and workers who ar~:tr'1._Gsporting or wor~ng at the site'fong-term:. Cracked And Leaking Qmjsters M~t Be Addressed. The ER dqes not ~alyze exa~tiy how r~dioactive_waste from a cracked and leaking canister would be.handled;since ther'~ is no wet' pool orhot"eelFat the *site.:,;._.-. -.,- More Cumulative Impacts.Must:*Be Analyzed

The ER mentions the Waste Isolation Pilot Plan~ (WIPF) but' do~s-*nc>t' anaiyzeth~*i111pacts of a ra,diologic release from W)PP. on the. proposed CIS site.

The imp;cts from th~ l~c!11 oii and *g~ ~h_dtistry 0~ the proposed site need to be ~alyzed. Seismic Impacts On Stored Casks,Must Be Stated Although the ER gives a-statement on recent seismic activity (n the are~*tJ.:iere is no analysis of what many 3.0-4.0 fracking-inquced earthquakes wil} have._on_ th<?_hu11-~ casks. Impacts Of Future Raikoads'And:Etectric Lines.Must Be An,alyzed.,:. _ ..*.-. The.railroads* and el~ctric ;liri.es--are not*inplace,-but mu.st pe. at1.al~ed;. How man; of' the ~~~ted i35 j~b_s :wm:,go t~ loci~ ~d. ho~ ~=:thY are only temporary?-

Q, The total number of annual workers at the site couid total as _many as 135 when short-term.

construction jobs are combined with the operating workforce. How many of ti:iese'jobs will create long-term careers for local communities? How ma,ny jobs and careers will benefit local residents? Sincere!~, L Signature~ j~ Name_ {Print) R U T fi J a.ca b 5

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Aprll-24,*"l01ff Ms.May Ma Office of Administration Mail Stop: 1WFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re: Docket ID NRC-2018-0052 ..!,/,': ' _'i't' Holtec International's HI-STORE Consolidated Interim Storage Facility Project for Spent Nuclear Fuel, Lea County, New Mexico

Dear Ms.Ma:

I respectfully submit these scoping comments about the Holtec International Environmental Report (ER) to bring up to 100,000 metric tons of spent plutonium fuel, high-level radioactive waste, from nuclear reactors around the country to southeast New Mexico. Please know that I 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 1 communities. We should not have to risk the contamination of our land, waters and air or the health of plants, wildlife and livestock, endangering present and future generations. I Request a 60-Day Extension of Time for this Comment Period A 60-day comment period places an undue burden on the public to review and provide informed comments about the 543-page Environmental Report (ER) technical document. In addition, this comment period overlaps several other comment periods currently on-going in New Mexico, including three comment periods for proposals to expand the Waste Isolation Pilot Plant (WIPP) and one for Los Alamos National Laboratory (LANL). There is also a public hearing about LANL operations scheduled for April 20, 2018. This Holtec Proposal is Contrary to Current Law Current law only allows the U.S. Department of Energy (DOE) 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 (ER) NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions. The comment period should be extended 60 days from when a revised ER is noticed in the Federal Register and provided for public review and comment:

The Impacts of Perm.anent Storage Must Be Analyzed The ER is technically inadequate because it does not analyze the impacts of the spent fuel being left indefinitely at the proposed Holtec site. More Alternatives Must Be Analyzed for in the Environmental Report Keeping the spent fuel casks in some form of Hardened On-Site Storage (HOSS) at the reactor sites must be analyzed for. The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed for. The Environmental Report Inadequately Discusses the Transportation Risks This ER must include all possible transportation routes from all the reactor sites to the proposed Holtec site. It must include the potential impacts of accidents or terrorism incidents _to public health and safety along all routes. The ER is technically 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 Exposures to individuals are not addressed. Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual Impact to an individual must be analyzed for. Cracked and Leaking Casks Must Be Addressed The ER does not analyze completely how radioactive waste from a cracked and/ or leaking canister would be handled. Many nuclear reactor sites do not have a wet pool or hot cell to repac.kage the spent.fuel rods. The ER must analyze this scenario. SeisJDic 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 M fracking-induced earthquakes would have on individual and collective buried casks. More ~ulalive Impacts Must Be Analyzed The ER mentions WIPP but doe~ not analyze the impacts of a radiological release from WIPP on the proposed H9ltec site. Nor does it analyze for a radiological release from the proposed Holtec site on WIPP. A release from either facility could have c~.tastrophic public health and environmental impacts. Analyses of both releases must be done. Impacts of Future Railroads and Electric Lines Must Be Analyzed The railroads and electric lines to the proposed Holtec site are not in place. The essential services must be analyzed for.

How Many of the Estimated 135 Jobs Will Go to Local People? The total number of annual workers at the site could total as many as 135 when construction jobs are combined with the operating workforce. The ER neglects to e¥_Plain how many of those jobs will go to local people. Sincerely, ~~ Rick Brown Taos1 New Mexico

1Jn.Ly ID, 201s MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 - ! "\\, ~t-e,C-.OV\\ ~-,. e1--~ (lD C (J'f. ( (J:ld- &,.,11-~y /V"f'1 .'i!?fCRr RE: Docket ID NRC-2018--0052; Holtec futernational'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 10,0.00 canisters of highly radioactive waste through thousands of communities nationwide. I do *not consent to the risk of contaminati9n of our lands, aquifers, air, or the health of plants, wildlife, and livestock. I do not consent to endangering present and future gen~tions. *

I formally request-a: 6b~day Extcilm~ri Of Time For Tin's Comment Period. A 60-day.comment period pl~~ at1 l,llldo burden on the public to respond to this 543-page technical document In addition,_ ~s overlaps*sev~ other comment periods in ~~w Mexico, incl~g thre~ comment periods for the Wastelsolation Pilot Plant {WIPP) and one'for Los Alamos National Laboratory.

~*.

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~ I formally request that each of the 3 scheduled meetings have ~e for public comment, and that the Roswell Open Hotise 'mclude a regular scoping meeting as well, or be cancelled. I also request additional Pub lid Scoping* Meetings *to{ other New 'Mexico coilll11unities that will be impacted by the transport, in~l.uding b~t. ~?t limit_~ to: ~~_qu~~gue,' 9~~vis~ an~ 9aHup *and ~t_ I~t on¢ in Dalfas/Ft'. ~Wo~ 'San A.rifomo~* aiicl Midland,'* texas *:silire-'there would likely be exfehsive transport through these cities. This Holtec Proposal Is Contrary to Current Law

** *...
Current law only allows the U.S. Department of Energy to takh*title -t~'corinnetcial. spent fuel foilowing ooirunencement of operation o:fa reposit9ry or ~t *a o'oE-~wned ~d.

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 'mm;t r~~e H_ciitec to produce an ER that ~ no ;such copyright restnction and has no redactions. The Impa~ts-or Pcimai:ient sto'~age 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 react0:r sit~s 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 incompl~te 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 fo 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 13 5 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 are~ there is no analysis of what many 3.0- 4.0 fracking-induced earthquakes will have on the buried casks.. Sincerely, Signed ~71:jl.~ i_~ Name (Print) 9tephen l,.Ro3 ev 2 City& State DQ ({v..f, (/)ft )5.7Jor:

MayMa Office of Administration Mail Stop: TWFN A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018-0052; Holtec Intemational's HI-STORE Spent Fuel Waste Facility Nuciear Regulatory Commission: 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, 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 undue burden on the public to respond to this.543-page techniGal document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those present. A thorough Environmental Justice analysis must be complete to consider all possible future impacts from th,is facility to the local communities and those along transport routes, including but not limited to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may adversely impacted at the site and along transportation routes. This Holtec Proposal Is Contrary To Current Law Ci 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 ineets 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. Stor~ge M~t Be,A.~~lyzed

it** Tue Environmental Report (ER) js inadequate ~d
i-q.cQmplete because it dpes riot analyze the impacts or me spent fuel being left at:ihe Hohc:c:site indcfinitdy. * * *. *
More;Jte!~tivesM~t.ll~Analy~¢..., *,*. **. ;,-.-.*.;. :: :;,,:.* ~:*~. _.

Keeping ~e spent fuel casks in *some fortrr*ofHardened,Qn Site Storage (HOSS) on the reactor sites mu*st be *analyzed.. *,..;*. ;* : :.. '*' *' '*. a,*.

. tlie*alterilative.:-of conse!idated. storage. h~ing ~oni ~t-an.' ~xi~hng}t<;~ti~e~ fu~~p~iident Spent Fuel Storage Facility (ISFSI) must be analyzed.
*' The waste carrand should*remain on site for many ~ore.years.µid d~e~ ~~t need-to move

\\ftitil th<?tOtigh an'alyses of alternatiYef: are COIU.plet~...

The E~'1t"onmenW llepo~. inadeq~tely discusses the transportation ~ks,..,,, This ER mu;tJ~clude ati"trtinspb~timi-'routes and t:h6;p0teptml irop~ts pf-,acciqe~ts or terrorism incidents on public: hehltli and safety along alt the r~tes... ' :,...... :. e The ER is incomplete because it does not discuss.!low _raj.I,shipment~ from reactors without

,. *rail access.Yloulct be J1qco~v.~s,h~fl.and tb.t?. r-~~ an~_;i_rt_ip3:cul of sutlfsiiipments/"., *:... -:' /

~J- ~-.. ; :* 1, ' . t ** * -, * ~- The C~nsequ~n,ces '.fo.An Accident-Exposed IndividualiMust Be.An.aly~. ** 1 -~-. Te~s iik~***colleetive dose risk'~*and ~fpersonrrem--are,~~aj,u; \\gQOfe*-~.p~t~p.tial impacts to a sin_gle individual. ..; *.,* * ' * *,. * -~ '..-_ -'* * * :-*. *' -., : ** --~*-....... *

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All possible exposuies* to *numaiis from routine releasesi f.roµi-tr~spp_g ~~~~ ~*4 sit~

storage must be dearly defined'-in.'.'plainJanguage; forjn(J.ividuaj~ n~m-,.~8$te ~~sters on occasion and workers who are transporting or.working at the.site ioiig~tei:iii.,. Cracked And Leaking Canisters 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 the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts of }U/;\\diologic release from WIPP on th~.P~C?,pos~d CIS site. ~, The impacts from the local oil and gas industry on the proposed site need to be analyzed. Se~~ ~~c~ O~Sto~ed Casks Must Be Stated _ ~. Although the.ER give~ a statement on recent seismic activity in the area, there is no . analysis of what many 3~(j-4j::f fracking.:inauced earthquakes :wjll have on* the-buried cas~:. ~ Iinpacts *or 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 ~timated 135 jobs will go to locals and bow many are only temporary? The total number of annual workers at the site could total as many as 135 when short-term, construction jobs are combined with the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents? I

Sincerely,.::.: ;*;.*.
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May 6, 2018 MayMa Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2018--0052; Holtec Intemational's I-Il-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico NRC: I respectfiilly submit these scoping_oomments on the Holtec Environmental Report (ER) to bring up to l 00,000 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 groood. 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 of New Mexicans and other-residents of the Southwest. I fonnally request that each of the scheduled meetings have time for public comment, and that the Roswell Open House include a regular scoping meeting as wea or be canceled. I also request additional Public Scoping Meetings for other New Mexico communities that will be impacted by the transport, including hut 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 v Current law only allows the U.S. Department of Energy to t.ake 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 bas no such copyright restriction and has no redactions. The Im.pa~ Of Permanent Storage Must Be Analyzed. The Environmental Rq,ort (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

1bis 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 Mo.st Be Analp.ed e 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 an~ electric lines are not in place, but must be analyze,!.!?e h~th of Qlants, wildlife, and livestock. I. do not consent to endangering present and future ~!p.~rations. I formally request a 60-day Extension Of Time For This Comment Periog. A 60-day comment period pla~s an.undue.burden on the*publicto r~pop.d to this 543-page technical document. I formally~ ~equestadditionalPubl,ic Scoping ~ti~gs for othei:,corrun~nities in N~w Me)!.:i~o: an4 nationwide t.b~t :W~l\\,be,impacteJl byftpe. ~~P9rt aµ~ 1tl;i~t.. ~WY additional meetings have time for thepublj~tO.I):iake_.verbal:_CQID1Il~nts~tQ~9$.e._presept; *.;*.,~,,.:.,;/* ( :.,.~,: **: ~.~ * **. ** ,*;* r '"*

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r
* ** -.r A thorough Eii,yJroiun~ntal Jus~clarthlysis must be complete to consider all P.(:)Ssible future
\\mP~~t~ ~~~~ ~~: ~~dlityto *the 'lck?} 'coniihuriiti~s and iliose*hlong ttan~porl foutes/ including* but not 1imitcd lo: economic' and b'ealth *impacts. I also request proper Tribal Consultation for any. affected ip.digenous natipns, whose. peoBle., _cultural ;resources_, or ~ac.re.o.. places may adversely -rmeacted.at the.. ~ite zjq..c..Jong tra,nsport~~o~ r.out~s.~.. * -.~.-:-; -~-'~:*,_ -
~
-:: *. :f:; ~*~t~. ~ -~:-.*; This Holtec Proposal Is Contrary To Current Law Cuitentlaw*only allows the U.S. Department of Energy to take title to commercial spent fuel ~'following* commencement ofoperation of a;repositary" or. at--a))Ofr-owned and - operated*monitored retrievable storage facility. The Holtec site meets neither requirement, as it is a private facility. Holtec Must.-Remove Copyrigbts. And All Redactions. in tµe Environmental Report " NRC imist require-Holtet'to*produce *an,ER. that has no such copyright yestriction and has tio *redacti6ns.-*:; * : ':., *, :. * ~ J. ~
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1 The impacts O{Perinanent Sfu~age MusfBe Analyzed

,~,(.~ ~µv4'Q~~tal1~eport (ER).. is inade9.u:ate and incomplete because it does not analyze
~ i~pactsof_$e~pentfuel peing left a~ the _R.o~te.c sit~.41~~-~ni,~y~Y*
MorfAiternatives*MustBe'Anatyzed**,*.,*: *- *' *:.-**~...., * -<;*. *._:, ::._ *. -=*-,_._,.:;.* :_ ::.* _:'1:*...-**~:-)<~~tti'ii_lti.~ spent1fu~l"'~~~;in.~o~e'fortn of Hardened On 'Sitd'Stbrage* (HOSS) on'the: i
rcidofsites diusfbe 'ai1Afyzetl) :,:,
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p *'Ih~:altepiat:ivie :of consolid~ted ~torc!,ge. g~J.n.g. done at an existing licensed fu.dependent

.*,n,". Spe.qt:Fue~\\Storage-:Raeility (JSf§.B.. mJ:!.St \\}~ ~aly~ed. ':,; *
~- .' !.* :, The waste* caµ.:-and *s.~ld r,emain-on-,site,for *many=more. years-and does J;IOt ~~d ~o mo'{e until thorough:~alyses*of alternatives.are complete. ~. :. '.... ~-.
The Environmental Report inadequately discusses the transportation Risks This ER must include all transportation rm.1tes and the potential impacts of accidents or terrorism incidents on public health and safety along all the routes. The ER is 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. ,e All possible exposures to humans from routine releases from transport casks and site storage must be clearly defined in plain language, for individuals near waste canisters on occasion and workers who are transporting or working at the site long-term. Cracked And Leaking Canisters 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 <n> The ER mentions the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site. fl The impacts from the local oil and gas industry on the proposed site need to be analyzed. Seismic Impacts On Stored Casks Must Be Stated I;.\\ 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. Impacts Of. Future Railroads And Electric Lines Must Be Analyzed it> The railroads and electric lines are not in place, but must be analyzed. How many of the estimated 135 jobs will go to locals and how.many are only temporary? The total number of annual workers at the site. could total as many as 135 when short-term, construction jobs are combined with the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents?
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.. ;...J, ~ Name (Print) \\1c1DFJA ~k-k ¢;1Y~~J:£iG#l1i 4-{0~
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n*~ lt) : ~?1s-_: May.Ma Office of Administration
Mail *stop: TWFN,;:_7-A60M*'
U.S: Ntidear Regulatory_Comn:µs~o:q., W asbingto~ DC 20555--0001.. * ~; Dq'*et ID NRC-2018-00;>2-; Holtec Inte~ational 's JU-STORE CIS Facility for Spent Nucl~ Fuel, Lea.,County,.New Mexico NRC: , I i;esp~y.~bm.it these scoping comments on the Hoi~_Enyironmental R~rt (ER) to bring Up to *10(),000 metric tons of spent fuel, high-level radioactive waste, from nu~}~ Ie8,ciors 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 dumpj.p.g gwood. I dQ not ~nsent to transpo$.pg,µp tQ Jq,o_oo canistel'$ of highly radioarjive w.aste.throug4 $0~~--0.f. communities nationwide. I do not consent tQ the risk ot contmrihia#o;n..pf.-01g J~ds~ -aqiµfers, air, or the health of plants, wildlife, arid livesfuclc. I do not consent to endangering'j;,res.ent and future generations~ I formally r~est a 6<Riay E~~ion of 1'ime Frir This' Comiri~~-P.~()d.*. A 60--0ay co~ent penod places :an undb -~~en 0~ th~ public to respond to this 543-page* fecbni~ documeµt In addition; tins overlaps several qf!ter,G.<mm1ent:p.erio~_ip._N~w Me~co,_ µ,.~lµdjpg ~- <;omrp.eµt pciiods 'for the waste Iso)atfon Pilot' Pl~t (WIPP) and* one _fc,r Los.'Alamqs '.Natfonal Laboratory. \\ ~. - I formally requ~t that each of the 3 sche;xlul~.. m~~ hay~, time. for_ P:'P'lH<J ~mm~~}~~~-~ the Roswell.Opep,_Ho~e.include ~ r~gµlar ~.C~~g meeting as*,~tjP:~-orb~ ~~ll~._,I_:~o *re.qu~t additional'Publi~ s&". *.* Meciiti.. fot"o'ther'New Mektco *oomhiumticidfuitwillli~'iiii "acted b. pmg gs -. -- P.. y the transport, including but ii.of limited tb: 'Albuquerque; Clovis~ and *ctfilihp 'and atieiist One in_, Dallas/Ft. Wo~ San Antonio, and Midland, Te~as since there W:Quld likely be ~xtensive transport through these cities. This'ii'oit~~-k-op~sai i:~ cJntt~':to *current t~~,-*, -. e,* Current law only allows the U.S. Department of Energy to take title to comni~~al spent fuel "following 'commencement of operaji90 of a repository" or at a DOE-owned and* operated monitored retrievable storage-f"acility. The Holtec site meets neither requirement, as* it is a private fucility. Holt~~ust R~move Cop~ts ~tt,An Redacfitj~S in thrEnvironme~tid.-R~ort ,, ~C m~t req~_*Holtec to.ptbdu~ ~ J~R. that has no.such copyright.testriction arid has . nc,:tedact:foris.. *.. :' ;* ' *. * *': Th~*'im.pacts Of Pci~i~~rage Mu~ Be J\\llalyzed * ***
TheJmvirotm.1~tai-Report-~).;~~:,Ma,rl~u~t¢.~.~~-~use it does n~~-:~)Ze
¥,'itnpacts of ~spent: fu~~ _b~gjeft.~e'.Ift>l~~indefimtely: More Aifotnatives M'.ust>>e ~ed
Keeping the spent fuel casks in some form of Hardened On Site Storage (HO.SS) on the reactor sites "must be analyzed..

The alternative of consolidated storage being done at an existing licensed Indepeij.dent-Spent Fuel Storage Facility (ISFSI) must be analyzed.
The Enviro~ental Report inadequately discusses the Transp~rtation*_Ris~ * * *....
This ER must include* all trimsportatio:n routes* ah.d..fhe PQtentfa.i. mip~* of accidents or terrorism incidents on public health and safety alo:ng all:the routes. '..

The ER is inadequate imci incomplete because it does*not.discuss *how rail shipnj:en~ from reactors without rail access would be accomplished and the risks :and. im.pacts of'such

shipments.
The Consequences To An Accident-Exposed Individual Must Be Analyzed
Terms like*"colleclive dose risk"*and person:.:rem;; are used to ignore the'potentjalunpacts to ir sfugle individual.* * : * *.
~!." Cracked ~d Leaking Casks Must Be-Addressed
The ER cioes not analyze ~xactly bow radioactive waste from a cracked and* leaking

. ~~tel' would _be *handled, *-smce there is lio *wet pool or hot cell at tlie site~ *.
More Cumulative Impacts Must Be Analyzed
1 The ER, IJ,lentions WIPP bu~ _does ~ot analyze the impacts of a radiologic rel~e :from
.WiPP ori the i>,oposed CIS'site.
Impa~ or li'.u~ Jlailroads Ail!l ;Eiectric Lin~._Must Be A,lalyzed...
.. *. The railroads and electric" lines"are not in place, "but must be arialyzec[ How ~y-offlie estimated 135 jobs.*willgo tolocaJs*t* .,*:.; ~ th~.totai n¢tib~ of m.mJuil workera aj: "i:he site could tota.I as. many ~ 135 ~b~--.
co~~op.J9bs ~
comb~~-with fueoperatmgwor~~rce. Seismic Impacts On Stored Casks Mu.sf Be Stated
Although the ER gives a statement on recent seismic activity in the ~ea,, there is no analysis_ofwhat many 3.0-4.0 :frac~g-jndq~-;~~-will ~v~.?11 ~f;b.prj.ed casks.

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?l{a+,, 7.,2018 (' MayMa Office of Administration Mail Stop: 1WFN-7-A60M U.S. Nuclear Regulatory Conimission. Washington, DC 20,555-0001 RE: Docket ID NRC-2018-0052; Holtec Intemational's lll-.STORE CIS Facility for Spent Nuclear Fuel,. Lea Comity, 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 µuclear reactors around the country to southeast New Me:.riC9. I am submitting the following comments because I do not. consent to New Mexico becoming a national radio~ve waste dwnping*ground. I-do not-consent'. to tnm.sporting up to 10,000 canisters of bjghly radioactive waste through thousands of communities natioJJ.wide. I do *not com;ent to the -risk of contamination of our lands, aquifers; air, or the health ofpfants, wildlife, and livestock. I do not consent to endangering p~ent and future generati~ns'. _*_,;*,.*.;... _: _......,.-.-_.. _ *::*.*.* _,.. _. *::,*:,.: ;: : l.(q~y}eqi:i~\\:~Y.tx@.s~~Jw:i.fuii_F~r_:This ¢b~t p~~d.*A.60-day rommertf p"eriod places an'Widobmden oil the public to *respond to 'ibis 543-page technical document. In addition, _.thi~ Qyerjaps several other comment periods in New Mexico, including three comment periods fQr the.Waste Isolation Pilot Plant (WIPP) and one for Los Alaoo,os N_ational Laboratory. --:*.. ';.,.,*-_:_:*_; ~~---*=~-*.. *_*_*:.!_(:*.-*=.~.. _~---i*:~*:;.:::.:.. : -,;/,~_-.*~~-.,; --;_~_!::.. :**--~-~* r fo~y ~est that each\\>f ilie 3 scheduled riieetings have time for public comment, and that the Roswell Open House.~clude a regular scoping meeting as well, or be cancelled. I also request additional ~1ic S~ping:Mee~~ for othe(New Mexico co~=umti . _ will be impacte_d by the ~rt, *mcluclirig but not limited to: "Albuquerque, CloVLS, an at least on~ m
Dallasif.t. Worth, San Antonio, and MJ,cllan~ Texas since there*wo

ely be extensive transport 1hr01igh/'es~ cities.
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TiuklI6.1~ Proposal 1s*¢-0ntrary to Current Law
.* * ~t law only allows the U.S. D.epartment of Energy to talce title to commercial spent
fu¢l.}f'following cohmiencement of operation of a repository"' or at a DOE-owned and. *
@ed moniton:;q retrievable storage fucili.ty. The Holtec site m~.neither requirement, -~-'~Jf.~privatt:.. ~lit)'.* . iioltec Musfilemove ~ppyrights-And All-Redactions in the *Enviromnental R~port ~ NRC}must ~uir~ Holtec to produce an ER that has no such copyright restriction-and has ':.'.l\\_:._;:;;;.#~.,:~fda,,~.*3,.ri$.~/::..*.'._ :.. '.:, :_*::.; ;**.. ;_:*.. ;: : ... *,.:;_,':.=; __./_* :;_:.~ __.:~.*...,:_._:*:.. _.,_*.! '.,':,.**.;.. ~---.. L :.. -*~
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w; ~:: ilfo En:vi~nrtitfutal R,epori'(ER)'.is;mad~fu-and:moomplete because 1filoes nritinalyze
._.,. *.*/.)lli.e_impaq§'of t4e spent ~l being left at the Holtec site indefinitely. A}i~~~Attemaf Mtr~~ .. : : ~- -.-.::. ;*....-... --~.. *;.. *. *.
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 anal~ The Environmental Report inadeq~ately 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 shipmei;i.ts from reactors without rail access would be accomplished and the risks and impacts of such shipments. The Consequences To An Accident-Exposed mdmdu.al Mu.st Be Analyzed.* Terms like "collective dose risk" and petson-n;m" are used to. ignore the potent:W impacts to a single individual. Cracked And Leaking_Cas~ Must Be Addressed The ER does not analyze exactly how radioactive waste from a cracked and leak.mg canister would be hand.I~ since there is no wet pool or bot cell at the site. More Cumulative Impacts Mu.st Be.Analyzed The ER mentions WIPP but does not analyze the impacts of a :radiologic re~_ease from WIPP on the proposed CIS site. Impacts Of Future Railroads And Electric Lines Must Be Analyz~ e 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 toml as many as 135 when construction jobs are combined with the operating wo:rkforce.
Seismic Impacts On Stored Casks Must Be Stated Although the ER gives a statement on recent seismic activity in the area, there is no ~ysis of what many 3.0-4.0 fraclcing-induced earthquakes will have on the buried casks. Sincerely,
_____,2018 MayMa. Office of Administration Mail Stop: TWFN A60M.*.. U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 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 ~mments 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 nationwi4e. 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 prese:ot and future generations; I for,mally.reqµest a 60-day Extension Of Time For This Comment Period. A 60-day comment p~od p\\aces an undo burden on the public to respond to this 543-pag~ 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 for~.ally 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 talce 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 restrictiori and has no redactions. . The Impacts Of 'Permanent Storage Must Be Analyzed Tue Environmental Report (ER) is:inadequate and incomplete because it does not analyze the impacts Qfthe spent fuel being left at the-Holtec site indefinitely. More Alternatives Must Be Analyzed
Keeping the spent fuel casks in ~ome 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 ~ot analyze exac~ly how radioactive waste from a cracked and leaking canister would be hand~ed, 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 arid 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 worlcers 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 i.s no analysis of what many 3.0- 4.0 fracking-induced earthquakes will have on the buried casks. Sincerely,
fY\\.a.tf' 'g , 2018 \\ MayMa Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 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:..}evel 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 thn~ugb tho"QSands 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 th~ public to respond to this 543-page technical document. In addition, this overl~ps several other comment periods in New Me~co, including three comment periods'for the W:ast~ Isolation Pilot Plant (WIPP) and o:q.e for Los Alamos National Laboratory~ I formally :r:eqQest that each of the 3 scheduled meetings have time for public comment, and that the Roswell Open i{ouse include a regular scoping meeting as well, Or;be cancelled. I also request addi.tional Public Scpping Meetings for other New Mexi~ CQJDPlunities that.Wj.ll be impacted by the transport, including but not limited to: Albuquerque, Clovis, and Gallup and at least one in Dallas/Ft. Wocth, San Antonio, and Midland, Texas since there would likely be extensive transport through these cities. This Holtec Proposal ls Contrary to C~rrent Law Current law oniy 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 ~ private facility. Holtec Must Remove Copyrights And All Redactions in t;b.e *Environmental Report ,.,
NRC must require Holtec to produce an ER that has no such copyright restrictio:!]: and has no redactio~.
The Imp_~cts Of Permanen.t.~torage Must Be Analyzed the Environmental Report(ER) is inadequate and incomplete-because_it*does not analyze the ~pac~ of the spent fµel being left at the Holtec site iµdefinitely. More Alternatives Must Be Analyzed
Keeping the*>spent fuel casks in some foqn of Hardened On Site.Storage (HOSS) on the reactor sites must be analyzed. *. The*alten_iafrve of consolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be ana1yzed. The Environmental Rep*ort inadequately discusses tb.e Tran$p9rtation 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 An.alyz~ Terms like "collective dose risk" and ~'person-rem" are used to ignore the potential impacts to. a single individual. Cracked And Leakmg*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 radiologi.c release from WIPP-on the*propo~ed CIS site. Impacts Of Future Raiirc,ads And Electric,Lines Must Be*An,al~ The railroads and electric lines are not in place, but must be analyzed. How mmiy of ~e estimated 135 jobs will go.to locals? The total -number ef annual workers at the site could total as many as 13 5 when constructionjobs 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 frack:ing-induced earthquakes will have on the buried casks. Sincerely, Siw,ed~~~- Name (Print) JG AI/\\V\\ 'b--e\\f\\ev\\O..,+l City & State Ga HtLp ) 6.,.1 l"i\\
M"o ID :~ :, 2018 May.Ma. Office of Administration Mail Stop: TWFN=-7-A60M U.S~ Nuclear Regu}atoiy_ Comi!µssion Washington, P~ 20555- 0001 .RE; ~m NRC-2018--0052; Holtec Intemational's JII--'-STORE CIS:Facil for.Spent Nuclear.Fuei, iea.. County, New Mexico NRC: I ~Y:~mit these _scoping comments on the llolt~.Env:ironmep.tal R ort (ER).*to bring up to -100,000 metric tons of spent fuel, high-level radioactive waste,- from n11~l.*.. t'.eactors around . the country to southeast New Mexico. I am submitting the following comments because I do not consent to New Mexico_becoming a national.radjoactive_waste dumpjpg gro"Qll *.I 4o *not.~nsent to ~~g_µp t<> lJ),QOC> canisters.of highly radioactive w~~ $oµs. ~iof conmiunities nationwide. I do not consent 1:Q the risk of co~tamin~tioiiQf.ourJ d;J~:~ers, air, or the health of plants, wildlife, and livestock. I do not oorisent to. endangering pr ent and future generations. I forinally;~~est'i 6~y Extensio~ Of Time Frii This ~tP~~d.:.x 6 ~d-iy-ent period plac.es an undo burden on the public to respond to this' 543:page*techm documeµt. In -addition, this ov~laps seyern.l:eth.~.C9~t,p~}P.:.N,~ ly.lezj.eo,. w..9lw\\ip :~ comip.~t periods for the Waste Isolati.6nPil~t Pl~t (\\VJPP)'arid *#e _fo.r LosAI~os ~i/ _*_nal Laboratory. fformally~ that each of the 3 sch~ul~-:~~~--_pay'?,!,Jtpe fox:.~-!ic,,p~ ~,. -~~;~~c~ the Roswell 9penJI~~-~~l-ud~-~ -~,gµlaf. S.~~_g fp.~g as* w~~.of~:~~.¥-:_I"~~ *r~~ additionarPublic s*-,.. iii' *-M~ for 'other New Mexico communities *truifwi be.. *.: acted b top g... ~-.. .,,.~- y the transport, including but riotliniited tb:.Albuquerque, Clo~s;.and Galliqfand at least one in Dallas/Ft Worth, San Antonio, and Midland, T~as since _there would likely be x4mSiye ~rt through these citi~_._ ~110~ :Proposal 1fcoiiirary.'i<</&rrenit~:-
Current law only allows the U.S. Department of Energy to take title to mriiAf'cihl spent fuel "following -commencement of operation of a repository" or at a DO -owned and operated monitored retrievable storage iacili.ty. The Holtec site meets ne ther requirement, as it is a private fucility.
Holtei.ust Remove Copyrights ~d'Ail Redactions in die Environmental eport_, "' NRC must require Holtec to 0,produce an ER that has no such copyriBbt r striction arid has-no redactions. :
Tfi~;'Jinpacis Of P~~t~$fu~ Must Be Aualyud*-**
~e.Environmental Report~~xi~:i!.l.~-~~~-~---W~~i.~*because it does~~~ -~]J~yze th,ttimpacts of the spent fuel oeiiig 1:eft-itt*J)ii'Ffo1ree':siteibde:ffiiliely;.
Keeping 1e spent fuel casks in some form of Hardened On Site Storage (HOSS) on the reactor si es must be analyzed. The alt. ative of consolidated storage being done at an existing licensed Independent Spent Fu 1 Storage Facility (ISFSI) must be analyzed. The Environme tal Report :inadequately* discusses the Transportation Risks, This ER ust include all transportation routes and the potential impacts. ofaccidents or terrorism * -cidents on public health and safety along all the routes. ~ The ER i :inadequate mid incomplete because it-does not discuss how_ rail shi~ents from reactors - ithout-rail access-would be.accomplished-and:the-nsks *and:-impacts-0f such-: - shipmen. The Consequen es To An Accident-Exposed Individual Must Be Analyzed
Terms.. '.'lt'crillective dose risk"-aiid "person-rem" are use<lto ignore the poteptia.l _impacts to asingl *mmvidriaL --*
Ctadred Ami ~~a1<41g Casks MlJSt Be Addressed
The ER :o~ not analyze exactly how radioactive waste from a cracked mid leaking
. : **~canister otd~ _be]1ai1<l3:citsmce there IS no wet pooi or hot cell at tlie site~,-. More CumnJati e Impacts Mu.st Be Analyzed The ER entlons WIPP but dQes not analyze tb,e impacts of a radiologic release from WJPP on the proposecfCIS;site. - - -~ : Imp.am'Of Fu tc*Jhilroads And-~lectrlc*Lme:s Must~ ~myzed* - * : : *The railr itds and electric*lih~.-m-e not 1D. place, 'but must be ariaiyz.ecf JI.ow'*Y: ii;'. -e _es!bnated 13~jobs will go to'locais?: . :' -"'
Th.~ 1Ptal ~Wb,ber of~ual. workers ~t tlielsite ~lij.d.total as many~ 1~5 wben construe' OJl Jobs ~e comb~¢ with ~e operating v.rorldbi'ce. - -.
Seismic Impact On Stored Casks MusfBe Stated ~ Altb.ou the ER gives a statement on recent seismic activity in the ~ there is no analysis, f what many _3.0 - 4.0 :fracking-m.duced ea.rtb,quak~ will hav~ ;Qn :th~ buried casks. '... --~**- Sillcerely, Signe4~--;...,..,,;1'-=-----.:~--'-----,."':i--:(PJ,-+--------- Name(PrinQ~"-"'.l~~__:__:__:_-!.,~__.:::...._;__e_,1---=-,c.-.---:---~
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ML18155A323

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Dear Ms.Ma:

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