ML18215A165
| ML18215A165 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/29/2018 |
| From: | Lish C - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00242, NRC-2018-0052 | |
| Download: ML18215A165 (5) | |
Text
PUBLIC SUBMISSION Docket: NRC-2018-0052 As of: 8/1/18 6:29 AM Received: July 29, 2018 Status: Pending_Post Tracking No. lk2-94js-naer Comments Due: July 30, 2018 Submission Type: Web*
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-0241 Comment on FR Doc # 2018-10418
- Submitter Information Name: Christopher Lish
- General Comment See attached file( s)
Attachments 180729 nrc-2018-0052-0058 reject holtec cisf _proposal SUNS! Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (242)
PUBLICATION DATE: 3/30/2018 CITATION # 83 FR 13802
Sunday, July 29, 2018 May Ma Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Protect our communities, our health, and environment. Reject Holtec CISF proposal. -- Holtec International HI-STORE Consolidated Interim Storage Facility Project (Docket ID: NRC-2018-0052-0058)
Dear Nuclear Regulatory Commission Staff:
I strongly urge you to reject the application from Holtec International to build an interim storage facility for spent nuclear waste in Southern New Mexico. The Holtec project would lead to dangerous extensive transport of high-level radioactive waste that would travel through major US cities, over major aquifers and across Tribal and agricultural lands. Without routes that are designated, the public cannot adequately comment on the impacts of this massive project.
I respectfully reject the Holtec Environmental Report (ER) proposal 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 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 to line the pockets of Holtec International.
Here are a few concrete things I urge you to consider:
- 1. This Holtec Proposal Is Contrary to Current Law Centralized or consolidated interim storage sites are NOT allowed under US federal laws to the extent t~at the U.S. Department of Energy (DOE) and U.S. taxpayers are expected to own and transport the waste. Current law only allows the 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 Consolidated "Interim" Storage Facility (CISF) site for high level nuclear waste meets neither requirement, as it is a private facility. It would be, therefore, an illegal dump.
- 2. Reject and do not rely on the Environmental Report written by Tetra Tech According to the US Navy, the Environmental Protection Agency, and the California Health Department, during the last twenty years, Tetra Tech has* been falsifying radiation monitoring data, deliberately spreading radioactive soil and waste to previously clean places on and offsite, using unqualified workers to supervise Page 1 of 4
radioactive scanning and cleanup efforts, and suppressing and firing whistleblowers at the Navy's huge Hunters Point nuclear site in San Francisco, which is being converted to high-end housing. Based on this track record, Tetra Tech cannot be trusted to assess environmental impacts of the proposed Holtec dump.
- 3. Holtec Must Remove Copyrights and All Redactions in the Environmental Report
- The Nuclear Regulatory Commission (NRC) must require Holtec to produce an ER that has no such copyright restriction and has no redactions.
- 4. 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 sp~nt fuel being left at the Holtec site indefinitely. The NRC must analyze the consequences of the waste remaining indefinitely at the site, e.g., never moving to another location. Holtec proposes to "consolidate" up to
- 173,600 metric tons of high-level waste from all US nuclear power reactors to New Mexico, near the famous Carlsbad Caverns, to "temporarily" store for 40-120 years.
(It could take forty or more years to move it there!) The waste would allegedly be moved again, but if no permanent site is found or money to move it again never appears, it could stay forever, despite not being designed for permanent isolation.
- 5. 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 lndependentSpent Fuel Storage Facility (ISFSI) must also be analyzed.
6.. The Environmental ~eport 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 NRC should also include evaluation of moving tens of
- thousands of shipments of this most deadly radioactive waste in super-heavy, inadequate containers over deteriorating railroad tracks, roads and bridges and the impacts caused by these many thousands of shipments on infrastructure, on people, businesses, communities, and other resources all along the way
- 7. Cask Dangers.
None of today'.s certified waste containers are designed for real world transport conditions (temperatures, crash speeds, submersion in deep water) and have not been physically tested; Holtec misrepresents forty year-old crash-test videos on different casks as being sufficient. The storage containers cannot be monitored for potential cracks and leaks, inspected, repaired, or replaced, even though we know the waste will be dangerous longer than the containers will last. The technology is in the "future" according to NRC staff.
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- 8. Hotter High Level Waste The NRC should include full evaluation of "high burn-up" fuel. It is a significant portion of the waste that would go to Holtec.
- 9. EMERGENCY RESPONSE Assess and report on the reliability and capability of volunteer and distantly-located emergency response personnel upon which the site will rely. Include availability, training, equipping and notification of emergency responders all along the routes.
- 10. 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.
11,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.
- 12. More Cumulative Impacts Must Be Analyzed The ER mentions the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico, but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
- 13. Impacts of Future Railroads and Electric Lines Must Be Analyzed
. The railroads and electric. lines are not in place, but must be analyzed.
- 14. 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.
- 15. Harsh Environment Consider, in more than a cursory dismissive way, the decades of high temperatures, salty dry climate, potential flash floods, lightning, burrowing animals, sand, blocked vents, wind, rain, fire on the casks and waste.
16.Seismic Impacts on Stored Casks Must Be Stated Assume increased earthquake risks and other impacts from hydraulic fracturing (which is not prohibited) near and under the site! Although the ER gives a statement on recent seismic activity in the area, there is no analysis of what impacts many 3.0-4.0 hydraulic fracturing-induced earthquakes will have on the buried casks..
- 17. Climate Change The impacts of global warming on climate in the region and the resulting impacts on casks and canisters, in relation to their ratings, must be considered.
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- 18. The Holtec Site Violates Environmental and Economic Justice The proposed area has valuable industries including pecan, cattle ranches, dairy,.
and other local farming interests that would be threatened by the Holtec site. Even some of the hazardous and extractive industries that are a big part of the economy 1
oppose the dump. Samia Assed, Chair of the New Mexico Poor People's Campaign, has stated that New Mexico "has suffered enough as a. national sacrifice zone at the hands of the nuclear industry, including abandoned uranium mines, the Manhattan Project, Trinity Test, plutonium contamination in the rivers downstream from Los Alamos, uranium enrichment, and hosting the nation's transuranic waste at the Waste Isolation Pilot Plant. As one of the poorest states, and a majority minority state, New Mexico has experienced environmental racism for decades. People of Color continue to be disproportionately--impacted by hazardous and toxic wastes."
The NRC should assess the multiple stresses on New Mexicans and failures to compensate them over the history of the atomic age.
- 19. Reprocessing and Proliferation Danger The NRC must analyze the possibility of the waste being reprocessed afthe site-*
since consolidating waste is the first step to dangerous reprocessing to extract plutonium-increasing nuclear weapons proliferation, massive water use, and intense, irreversible environmental contamination. Reprocessing was proposed at this same site before and must be addressed in the Environmental Impact Statement.
Although Holtec claims a perfect storage record, they can never guarantee safe transport of radioactive materials traveling thousands of miles by rail through numerous communities. An accident involving just one ofthe nuclear waste rods could contaminate a nearly 50-square mile area, putting our most vital resources at serious risk. Accidental leaks or spills have the potential to cause devastating harm in the form of birth defects, cancers, radiation poisoning, and even death.
We do not consent to putting our lands, aquifers, air, or people at risk of contamination.
. In order to protect our public health and environment from irreparable harm, I urge you to reject the application from Holtec International to build an interim storage facility for spent nuclear waste in Southern New Mexico.
Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.
Sincerely, Christopher Lish San Rafael, CA Page 4 of 4