ML18197A070
| ML18197A070 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/07/2018 |
| From: | Weber K - No Known Affiliation |
| To: | May Ma Office of Administration |
| References | |
| 83FR13802 00198, NRC-2018-0052 | |
| Download: ML18197A070 (2) | |
Text
I MayMa 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=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (198)
PUBLICATION DATE: 3/30/2018 CITATION# 83 FR 13802 RE: Docket ID NRC-2018-00~2; Holtec IntemationaJ,'s ID-:-STO@ Spent Pue~ W~te Facility NuclearRegulatory Commission:
I am extremely concerned about the Consolidated Interim Storage (CIS) facility proposed by Holtec International to* store up to 100,000 metrictons *of high..:level.radioactive waste 'in southeast
- New Mexico. I respectfully submit the following comments regarding the proposal itself and the scope of the Env~o~en~ Review and analysis for the Environmental Impact Statement (EIS).
. I am submitting these comments because I do not consent to New Mexico becoming a national
. dumping ground for spe~t fuel" from every nuclear reactor in the country. I do not consent.to transporting up to 10,000 cairisters of highly radioactive waste through communities nationwide. I do not consent to the risk of conia$ination of our lands, aquifers, air, or the health of our people, plants, ~dlife, and livestock. I do not cons~nt to endangering present and future generations.
I formally request ru;lditi.onal.Public Scoping M.e,etings,for oth~r ~onµnunities throughout the United.States (U.S.)th~t:w-ill be impacted by the transport of these waste qanisters.,.:
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This Holtec P~oposal J:s.Contrary To Curr~t Law.
- Current law only allows.the U.S.))eparjm~nt of.Energy to.take title to commercial spent fuel following commencement of operation of a repository" or at a DOE-owned and operated.monitored re:trlevable storage facility. The Holtec site meets neither requirement, as it is. a private facility. '
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Holtec Must Remove Copyrights,And All Redactions In rhe Environm~ntal R~port ~R)
- NRC m.ust require Holtec tO.PJ:'.Oduce ap. ER that has no such copyright restrictjons and has no redactions. It is. i.n:!.possible to make r~ommendatjoils on.the scope of analyses of thes~
redacted areas of the ER for the EIS.
The Impacts Of Permanent Storage Must :JJe Analyzed*
- The ER is incomplete because it does not analyze the lu:i.n..~J:s of the spent fuel being left at the Holtec site indefinitely. The EIS needs to incluµe*ai.. a.11a1.ysis of the impacts of permanep.t storage shollld the CIS fac.iljty becon1e a de facto permanent waste *site.
More Altern_atives Must Be Analyzed.
- The high-level radioactj.ve waste is too dangerous to-move and can remain on *i;;ite for p:iany more years. It should' ijOt be moved until all alternatives are analyzed, including keeping the waste wJ:iere it is-in somefo~*ofHardened 01,1 SiteStorage.(HO.SS) on the reactor sites or at suitable locations as close to. the reactors as possible to minimize transport risks.
- The alternative of'corisolidated storage at an existing licensed Independent Spent Fuel Stor~ge Facility q~FSI) ~ustalso be*.anaiyzect. ~. :.
All Tran~port?tion *.Roµt~~.And Risks Must Be.Analyzed
- .
- The EIS nJ.Ust--include all possible transportation routes and study'~e potential impacts froin accidents, terrorism incidents, and how new rail lines or roa4s for waste shipments will impapt p:gblj~ health, environment,, water sources, flora, fauna.(especially any
~ndangere4 sp~cies ), mid occ1:1patioral safety along these routes:
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The Consequences To An A~cident-Exposed IQ.dividual Must Be Analyzed Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual.
All possible human exposw:es from routine and accidental radioactive releases during
- transport and at the site must be clearly defined in plain language, for individuals near waste on occasion and workers who_are transporting or working at the CIS site long-term.
Cracked And Leaking Canisters Must Be Addressed
- c 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. The EIS must
. include how cracked and leaking canister.s will be handied onsite and during transport and analyze possible environmental impacts if leak~ or spills occur from cracked canisters.
More Cumula~~ Impacts Must Be ~alyzed The ER nientions the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts
-* _____ ofa.radiologicreleaseSronLWIPP.onJhe_proposed_CIS.site~. _____________ -*- ______ _
- The impacts from WIPP and. possible impacts from and to the local oil and gas industries need to be analyzed and included in the EIS.
Seismic Impacts On Stored Casks Must Be Stated Although th~ ER gives a ~tement on recent seismic activity in the area, there is no analysis *of what fracking:...induced-earthquakes will have on :the buried casks. These impacts need to be analyzed and included in the EIS.
Future Electric.al Transmission Lines And Other Infrastructure Must Be Ana~ed Impacts from new electrical lines, surface and subsurface projects must be included in EIS.
Econoiµ*c Impacts Must Be Analyzed For The Different Phases Of The Project The economic impacts must be studied and ~leatly stat~ any positive or negative impacts from this site: initially, ~er construction is complete, and throughout the whole 120 years.
How many jobs will be created? How m?,D.y are only* temporary and how many are permanent? How may will go to local residents?
. A Thorough Environmental Justice (El) Analysis Must B~ Included In The EIS Impacts to EJ communities near the site and along transport routes must be studied, including but not limited to economic and health impacts that.are specific to lower income and people of color 9-9.mr.n.µnities. For indigenous populations located near the site or along tiansporl routes, tlns*.f:;j*,-tlalys1s must mchide nnpacts toculturally nnportaiitnatural --
resources, such as: sacred places, traditional food sources, and traditional medical plants.
Sincerely, V~
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