ML18163A120
| ML18163A120 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 05/24/2018 |
| From: | Fuertsch M - No Known Affiliation |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00142, NRC-2018-052 | |
| Download: ML18163A120 (2) | |
Text
~--dl_l/ __, 2018 May Ma Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUNSI Review Complete Template= ADM-013
- E-RIDS=AD M-03 ADD= Anntoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (#142)
PUBLICATION DATE:
3/30/2018 CITATION: 83 FR 13802 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 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
.~ommunities nationwide. I do not *cc:msent 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.
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I formally rec.;.uest a 60-day ExteHsion Of Time For*rf':ifa"Comment Period. A 60-day comment period places an undo burden on the public to responJ to this 543-page technical document. In addition, thi~ oveJilaps several other comment periods in New Mexico, including three comment periods for the,Waste Isolation Pilot Plant (WIP.P~ and* one' for Los. Ahini.oL'! atidrial Laboratory.
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- 1 formally request that each of the 3 scheduled meetings have time for public comment, and that the Ro~well Open Hous~* if:l~lude a regular scoping meeting as well, or be cancelled. I 111~() reques_t additional,PubHc,Scoping.Meetings for other Mew!Mexico tcfo1nfunitiesthat will bi: iriip~ct~d by the tran§iport, iqoluding:but n<Jt ilimitetl*to: Albuquerque; Cl:ovis; fu'i.d Gallup;and *at !dist otle in Dallas/Ft.,Worth, San Antonio, and Midland,:*Texas:since there would likely be ex'ten"sive:tra:risport through these cities.
This Holtec Proposal Is Contrary to Current Law
,. Current law onl~; allows the US. Depaiirrient of Energy to take title to comrrierciai' spent fuel '.'followir.g commen:c,~ment of opei'ation*of a :repository'*' bi at a DOE-owned and' operated*monitored retrie1iable-storage facili'cy,The Holtec si'te n1eets neither requirement,
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- Holtec Must Rem~:,ve Copyrights And All Red2ctions in the Environmental Report e. NRG mw,t require Holtec to produce an ER that has no such 'tcipyright restriction and has
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The Impacts. Of Per.10,auent-Stoi*age* Must Be Anak;,*zed.
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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:
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More Alternatives Must Be Analyzed 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 done at an existing licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed.
The Environmental Report inadequately discusses the Transp'l>rtation Risks This ER must include all transportation routes and the potential impacts of accidents or terrorism incidents on public health and safety along all the routes.
The ER is inadequate and incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and the risks and impacts of such shipments.
The Consequences To An Accident-Exposed Individual Must Be Analyzed Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual.
Cracked And Leaking Casks Must Be Addressed The ER does not analyze exactly how radioactive waste from a cracked and leaking canister would be handled, since there is no wet pool or hot cell at the site.
More Cumulative Impacts Must Be Analyzed The ER mentions WIPP but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
Impacts Of Future Railroads And Electric Lines Must Be Analyzed The railroads and electric lines are not in place, but must be analyzed.
How many of the estimated 135 jobs will go to locals?
The total number of annual workers at the site could total as many as 135 when construction jobs are combined with the operating workforce.
Seismic Impacts On Stored Casks Must Be Stated Although the ER gives.a statement on recent seismic acfrvity.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 __ /'1_~---~--~------------
Name (Print)
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