ML18218A165
| ML18218A165 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/30/2018 |
| From: | Murphy-Young P - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00263, NRC-2018-0052 | |
| Download: ML18218A165 (9) | |
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-0262 Comment on FR Doc # 2018-10418 Submitter Information Name: Paige Murphy-Young General Comment See upload file/comments which exceed this panel's word limit.
Attachments July Comments re Holtec NM
- As of: 8/1/18 10:53 AM Received: July 30, 2018 Status: Pending_Post Tracking No. lk2-94kq-frfg 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 (263)
PUBLICATION DATE:
3/30/2018 CITATION# 83 FR 13802
COMMENTS CONCERNING HOLTEC'SPROPOSED CONSOLIDATED INTERIM STORAGE PROJECT IN NEW MEXICO Docket No. 72-1051: NRC-2018-0052
- The breadth, depth and independence of NRC' s environmental impact analysis for the the proposed Holtec International HI-STORE Consolidated Interim Storage Project must be commensurate with the grave -
virtually permanent -
hazards posed by plutonium and spent nuclear wastes in all its manifestations.
NRC's own statements acknowledge that "a substance with the potential to have as much impact on the environment as plutonium" should be subject to "a very thorough, deliberate process." South Carolina v. United States, 1:16-cv-00391-JMC (ECF No. 100 at 16). In a brief filed with the US Court of Appeals for the Fourth Circuit,* NRC further explains:
"Unfortunately, the same nuclear properties of plutonium that make it attractive to science also make this element hazardous to human beings."
Many forms of plutonium can spontaneously ignite when exposed to air. In addition, plutonium's radioactivity requires "a comprehensive safety program[ t involving "planning, personnel practices and engineered
- controls, 11 as well as "mass limitations, training, procedures, postings, personn~I and area radiation monitoring, and emergency response.
Brief of United States at 2, No. 18-1148 (4th Cir. March 19, 2018) (internal citations omitted),
as quoted in State of South C<!uolina v. DOE et al, Preliminary Injunction Order, Civil Action No.
1 :18-cv-01431-JMC, United States District Court, D. South Carolina, Aiken Division (June 7, 2018.
I.
The comments which follow supplement the public comments, both written and oral that have already been submitted or transcribed and are filed in NRC Docket No. 72-1051.
A.
Holtec canister vulnerabilities Basic design faults have been detected in Holtec International HI-STORM 100 canisters.
Several of these deficiencies were identified in public comments concerning the NRC rule that approved Amendment 1 to Certificate of Compliance No. 1040 issued for Holtec's HI-STORM UMAX canister storage systems. 80 Fed. Reg. 53691 through 53694 (September 8, 2015).
This NRC rule-making approved a seismically enhanced version of Holtec's HI-STORM UMAX canister to be used in areas with high seismic risk. NRC deemed other serious risks and deficiencies presented by Holtec's canister to be "outside to the scope of this rule-making".
Some of the commenters' serious concerns which, while perhaps outside Amendment 1 to Certificate of Compliance No. 1040, are directly apposite to Holtec's proposed interim storage site in Eddy County, New Mexico. NRC's summary response to these concerns was to dismiss them, stating that they were beyond the scope of that particular rule-making.
Page 1
Issues highlighted in re Amendment 1 to Certificate of Compliance No. 1.040
- a.
Transfer Cask Commenters asked if the transfer casks were approved for storage of an MPC in case of a failed MPC. What are Holtec's plans should this occur at the proposed Lea-Eddy facility?
- b.
Failed Canister Remediation A commenter asked if there is a plan to remediate a failed canister. What are Holtec's plans for failed canisters at the proposed Lea-Eddy facility?
(c)
MPC Thickness Commenters questioned the maximum MPC thickness allowed in this amendment, noting that although the FSAR indicated 0.5" as the maximum thickness, Holtec has proposed using a thickness of 0.625 at San Onofre.
What thickness ~ill be required at the proposed Lea-Eddy facility?
(d) Definition of "Long-term" Commenters requested the NRC require a definition of "long-term" in the FSAR. What standards apply at the conclusion of proposed 20-year (e) 1 Vertical Ventilated Module Needs Substantiation for Expected Lifespan Commenters questioned Holtec's claims of a design life of 60 years, a service life of 100 years and a licensed life of 40 years. Since no substantiation was provided for these claims, the commenters requested the claims be removed from the FSAR.
(e) High Burnup Fuel Commenters also raised questions regarding the long-term acceptability of the extended storage of high burnup fuel (HBF).
All of the above-described comments apply to the casks propo~ed to by used by Holtec in the proposed New Mexico facility. NRC cannot demure here: New Mexico residents and other,
comments deserve serious analysis and answers.
Additional problematic aspects the Holtec Canisters The problematic Holtec canisters found at San Onofre Nuclear Generating Stattion starkly demonstrate the canister's design flaws as well as the inadequacy of the NRC regulatory program:
Page2
Four nuclear waste canisters with a potentially defective design have been loaded with spent fuel and buried in a "concrete monolith" yards from the beach at the shuttered San Onofre Nuclear Generating Station.
Southern California Edison is moving tons of waste from the reactors' two spent fuel pools into a Holtec HI-STORM UMAX dry storage system.
Experts say dry storage is far safer than wet storage, and Edison aims to transfer it all to the Holtec system by mid-2019.
Since there's no federal repository yet, the nuclear waste is "stranded" on site.
Edison was preparing to load a canister with spent fuel in February when it discovered a loose bolt inside, about four inches long by a half-inch thick, according to the Nuclear Regulatory Commission.
The bolt secures a shim support, which helps center the basket that actually holds the waste. The shim also allows helium to flow around the waste to keep it cool.
Edison alerted Holtec and the NRC, and halted work.
Teri Forza, Orange County Register, March 23, 2018, updated March 25, 2018.
In light of these flaws discovered at San Onofre, Vermont Yankee halted its transfer of spent nuclear fuel to Holtec casks and instituted inspections on those Holtec casks which had not already been filed with spent nuclear fuel.
B.
Transportation NRC's assurances fail to adequately address the perilous state of infrastructure in the United States today. The American Society of Civil Engineers Report Card (issued every four years) Report Card for 2017 gives the USA an overall D+ grade.
How can NRC/Holtec assure the American public using the nationwide transportation routes to the proposed Holtec plant that accidents....:. mishaps involving devastating release of
. spent nuclear fuels -
will not occur when 9.1 °/o of our bridges were found to be structurally deficient (2016); when American roads received a D grade ("one in five miles of highway pavement is in poor condition". See ttps://www.infrastructurereportcard.org/making-the-grade/
The environmental impact statement must address transportation of high-level radioactive wastes considering the current Holtec canisters and in light of the current and anticipated, real-world conditions of American, roads, bridges and rail system. 1 O C.F.R § 72.108.
It should also be noted that safe transportation of materials suitable for the Waste Isolation Pilot Project cannot be extrapolated to support the safety of transportation o*f the spent nuclear fuel presuma~ly destined for a possible Holtec Lea-Eddy facility.
Page3
C.
Impact on precious water resources.
The environmental impact of the Holtec project must be evaluated in the current and
)
anticipated reality of extended drought. The State Engineer of New Mexico's website, http://
www.ose.state.nm.us, states that drought is expected year-round and encourages conservation by all.
Proponents of the Holtec facility claim that the Eddy-Lea site is dry. In truth, however, the site is surrounded by aquifers, including the Capitan Reef Aquifer. NRC must pm-actively and independently investigate the groundwater resources underlying, and potentially affected, by the proposed Holtec facility.
In New Mexico, there is no water or aquifer to waste: no water or aquifer to risk.
D.
- Regulatory flux In view of the Trump Administration's roll-back of EPA regulations and other environmental regulatory regime (both those fully realized and those in progress), the public cannot reasonably assume that current NRC regulations and current administrative protections will be maintained. For example, the Trump Administration recently limited the Defense Nuclear Safety Board's access to critical information. How would similar restrictions on NRC impact the Holtec facility?
NRC should address the impact of regulatory roll-backs on the long-term safety of Holtec project. Additionally, adding a anti-backsliding provision to any license it ultimately proposes should seriously be considered.
F.
Financial Assurances While Holtec seems to have provided financial information concerning operation and contractual matters, its resources to cover liability expenses are less clear.
The EIS should clarify the sources of funding should Holtec (and/or the NRC) be found liable for virtually unremediable accident(s) occur, injuring numerous people and causing significant destruction of critical natural resources.
G.
Duty to Provide Complete and Accurate Information Under 19 CFR § 72.11, information provided to the NRC Commission by a licensee or an applicant for a license "must be complete and accurate" in all material respects. In view of information publicly available at thi; time, Holtec's past behavior raises concern about its.
trustworthiness:
"According to an article distributed by the NRC, the problem with the loose bolt or pin found in one of the Holtec casks functioning as a shim at San Onofre was believed to Page4
' i.
I I
have been caused in part by a design change initiated by Holtec, but without the permission of the NRC." Vermont Yankee's fuel move is still on hold Susan Smallheer I March 30, 2018; https://www.rutlandherald.com/articles/vermont-yankees-fuel-move-is-still-on-hold/ (accessed on July 30, 2018)
Holtec was debarred fromTVA and pay a 2 million dollar administration feee in response to alleged bribery. http://oig.tva.gov/reports/node/semi/55/semi55.pdf H.
Holtec's apparent contempt for public concerns Holtec's intentions and assurances are difficult to trust when its spokespersons, including its CEO, Dr. Kris Singh, openly express their contempt for public commenters (and presumably for the serious issues they raise):
... nuclear power generation, which emits no greenhouse gases, is I
hounded by self-appointed environmentalists. Disingenuously, they invoke the absurd accident scenarios to stop nuclear energy at every step of the way. In an act of brazen prevarication, they have even termed a used nuclear fuel facility -
which cannot possibly become a risk to public health and safety under any conceivable extreme environmental phenomenon delivered to it by Nature or mendacity of man -
as a pc;>tential Fukushima or a p.utative Chernobyl ! Unfortunately, we in the industry have been passive and clumsy in educating the public. The dishonest narrative against nuclear energy is noisily r(;Jpeated endlessly by the canard-mongers while we in the industry sniffle at their ignorant polemic but do little to raise our collective voice. The dialog in the public square is not fair and balanced. I call upon you, the stewards of nuclear technology, to take your rightful place in the public square and join the battle to protect truth and facts against mischievous and untrue propaganda.
Remarks by Dr. Kris Singh, General Chair of the American Nuclear Society's Annual Meeting in Philadelphia (June 18, 2018), https://holtecinternational.com/2018/06/22/dr-kris-singhs-opening-remarks-at-the-2018-annual-meeting-of-the-american-nuclear-society/ accessed July 4, 2018/ (emphasis added).
- Ed Mayer, Holtec program director for the Lea-Eddy site, also disparaged public meetings:
"The misunderstanding is so high, when you go to the public meetings, there are so many things that are off-base. It's hard to address everything because it's so outrageous." Santa Fe New Mexican, by Adrian C. Hedden, Carlsbad Current-Argus, June 18, 2018, http://
www.santafenewmexican.com/news/local news/what-is-holtec-company-touts-experience-in-nuc!ear-storage/artjcle 5d83bbbd-cdf2-522b-a 1 fa-fdca 16a6c4bd,html, accessed July 30, 2018.
Pages
How can New Mexico's residents responsibly "ga*mble" their health, their economy and their children's future on the slim confidence that Holtec will honor its commitments? To the extent it acquiesces in Holtec's dismissive responses to the public and its legitimate concerns, the NRC can only expect that public confidence in it, a governmental agency purportedly dedicated to public protection, will be similarly eroded.
L Consideration of alternatives The hazards presented by transporting spent nuclear fuels (1) in problematic Holtec canisters; (2) via USA's current infrastructure; and (3) without any clear demonstration that Holtec can financial cover the liabilities -
financial and/or environmental -
serious, creative evaluation and exploration of alternatives is imperative.
That this proposed NRC license is for 20 years, rather than the 40-year minimum for necessary for the government to secure a permanent high-level nuclear repository, is simply irresponsible. The NRG cannot provide legitimate assurances that a satisfactory operator can be found shoul.d Holtec not apply for (or,qualify for) a second 20-year license.
- As it happens, a superior alternative already exists: requiring hardened thick casks at existing nuclear power plants. When -
and if -
a su.itable permanent nuclear wa~te site is established, hardened thick casks can be be transported far more safely than the thin Holtec canisters (particularly after they will have been transported to the Lea-Eddy facility, stored for 40 some years and finally transported to the wastes' final resting place. See San Onofre Safety Handouts, https://sanonofresafety.org/documents-3/, Why Thick Casks need at San Onofre (June 27, 2018).
Under this alternative, no clean land and/or uncontaminated waters will have been threatened or despoiled in the service of an expensive 20-40 year experiment. Property already dedicated to nuclear power can safely continue to hold spent nuclear fuels until such time as a permanent repository is established.
- 1.
Respectfully submitted, Paige Murphy-Young July 30, 2018 Page6