ML18204A154
| ML18204A154 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/19/2018 |
| From: | James H - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 000208, NRC-2018-0052 | |
| Download: ML18204A154 (2) | |
Text
PUBLIC SUBMISSION Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0058 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0209 Comment on FR Doc # 2018-10418 Submitter. Information Name: HJ James General Comment As of: 7 /20/18 9:23 AM Received: July 19, 2018 Status: Pending_Post Tracking No. lk2-94dc-bf43 Comments Due: July 30, 2018 Submission* Type: Web SUNS! Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (208)
PUBLICATION DATE: 3/30/2018 CITATION # 83 FR 13802 Southeast New Mexico (NM) will have the dubious distinction of experiencing every single train car load of high-level radioactive waste passing through on its way into (and, ifit ever leaves, out of) Holtec International/Eddy-Lea [Counties] Energy Alliance (ELEA).
With this Project, transport impacts will be felt nationwide. Transporting 100,000 metric tons, or more, of irradiated nuclear fuel to NM makes this proposal even riskier than the highly controversial, unacceptable Yucca Mountain, Nevada permanent burial dump scheme, in terms of transport impacts (limited to 70,000 metric tons under current law). In that sense, when it comes to radioactive waste transportation risks, all ofus live in New Mexico.
For this reason, the four NRC public comment meetings (three in NM, and one at the agencys HQ near Washington, D.C.), are entirely inadequate. Countless millions of Americans, in most states, would be put at.
risk by these highly radioactive, irradiated nuclear fuel shipments.
Shipments to NM, just like shipments to NV, would impact most states. For this reason, NRC should be holding public comment meetings across the country, not just in southeast NM ( and only one national meeting at the agencys HQ in Rockville, MD). I expect NRC to hold hearings in all impacted communities. The U.S.
Department of Energy (DOE), during its Yucca Draft Environmental Impact Statement (DEIS) public comment period many years ago, initially planned a dozen meetings nationwide. Under public pressure, DOE was forced to double the number of such meetings, in communities impacted elsewhere across the U.S., as well.
A de facto permanent surface storage parking lot dump at Holtec/ELEA in NM would increase safety risks. It
would not decrease them. It would multiply transport risks, as it would only be temporary (supposedly, even if decades, or centuries, or more, can be called temporary!). All that highly radioactive waste would have to move again, to a permanent burial site (yet to be identified thats a big IF! Yucca is NOT suitable!). And that waste could wind up being shipped back in the same direction from which it came in the first place, meaning transport corridor communities could see these high risks twice!
Holtec/ELEAs assumption that the dump at Yucca Mountain, Nevada will open someday, to take the highly radioactive waste away, is incredible. The vast majority of Nevadans have expressed their very adamant non-consent for 30+ years now, and still vehemently oppose it.
Holtec/ELEAs assumption that another permanent burial dump will be opened, by someone, somewhere, someday, somehow, is also inappropriate. After all, the search for a national geologic repository has gone on since the 1950s, but has failed. This game of high-risk, highly radioactive waste musical chairs, or highly radioactive waste hot potato, on the roads, rails, and waterways, is unacceptable.
The Holtecs infamous Quality Assurance (QA) failures and violations are very significant to shipping risks.
Shipping casks would be less capable of withstanding severe accidents as well as intentional attacks or other powerful explosions. See a summary of industry-and Nuclear Regulatory Commission-whistleblower revelations about Holtec QA violations posted here:
http://www. beyondnuclear.org/centralized-storage/201 7 /4/5/summary-of-oscar-shiranis-allegations-of-quality-assurance-v.html DOEs Feb. 2002 Yucca Mountain Final Environmental Impact Statement (FEIS) gives a preview of barge shipments that could well be required to ship high-level radioactive waste to NM.
(See NIRS factsheets on barge shipments of deadly high-level radioactive waste on waterways, by state, posted online September 28, 2004):
<https://web.archive.org/web/20160331035101/http://www.nirs.org/factsheets/f1bargefactsheet92804.pdf.>