ML18219A718
| ML18219A718 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/25/2018 |
| From: | Orr G - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00270, NRC-2018-0052 | |
| Download: ML18219A718 (2) | |
Text
L July 25, 2018.
~ay Ma, Office of Administration Mai1Stop:TIA{FN-7-A60M u.s. Nuclear Regutatory:Commissi()n Washingto~ DC 2055S-0001 Attn: Nuclear Regulatory Commission SUNS! Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSC 1)
COMMENT (270)
PUBLICATION DATE: 3/30/2018 CITATION# 83. FR 13802 RE:: Docket JD NRC-2018-0052; Holtec lntematiohal's Ht-:STORE CIS FaCllity for Spent Nuclear Fuel, Lea County~' New Mexico As a cimen of Jal, New Mexico and I respectfully reject the Holtec Environmental l\\eport {ER} proposal to bring up to 100,000 metric tons of spent fuel, high--level radioactive waste from *nudear 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 transpotting up to lOiOOO canisters of highly radioactive waste throughtho~nds of communities nationwide. I do not consent to the risk of contamination *of our lands1 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.
The 11oltec-projectwould'lead to dangerous extensive transport of high--level,:adioactfvewaste that would travel through major US cities, overmaj()r' aquifers and across Tribal and agricultural lands.. Without routes that are designated, the pubfic cannot adequately comment on the impacts of this massive project.
Here are a few*conaete things I urge you to t:<>nsider:
- 1. lhis Holtec Proposal"ls contrary to *current Law
- Current law oniy allows the U.S. Department of Energy to take title to commercial speitt fuel "following commenc~ment of operation of a repository" or at a DOE-owned and operated monitored retrievable storage facility. The Holtec site meets neither requirement, as it is a private fadlify.
- 2. Holtec Must Rempve topyrtgtrtsarid All.Redactions in the Environmental,fteport NRC must requite tioltec to produce *an 'ER that has no such cOJ>Yf'IRht Fe$trlctibn and has no redact.ions.
- 3. The Impacts of Permanent Storage Must Be Analyzed The Environmental R~port (ER) is.inadequate. and fncomple~ becaus~ i does not analyze the impacts of the spentfuel be1iigiim at the Holtec site indefinitely.
- 4. More Alternatives Must Be Analyzed Keeping the spent fueH:asks*in some form of Hardened On Site Storage {HOSS).on the reactor sites must be analyzed. The:altemativeof CQnsoiidated storage being done atan existing licensed Independent Spent Fuel Storage Facility (tsi=St) must also be *analyzed.
- 5. The Environmeritai Report.inadequately*dtscusses the Transpo~tion Risks This.ER must intludeaii.transportai:ion routes and the p0tential impacts,,;,tacciden1sorteilrirism incidents
____.on publicheaftb.andsafety.alohg..ail.tbe.routes.......
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- The ER is inad~quate*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.
- 6. The Consequences to an Accident::exposed Individual Must Be Analyzed Terms like 1'collective dose risk" and "persor1.. rem0 are used to ignore the potential imp:acts to a single individual.
- 7. Cracked and Leaking casks Must Be Addressed The ER does hot analyze exactly how radioactive *waste from a* cracked and IE!aking canister would be handled, since there* is no wet pool or hot cell atthe site.
- 8. 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.
- 9. Impacts of Future Railroads and Electric Uries Must Be Analyzed The railroads and electric lines ate not in place but-must be analyzed.
- 10. How many ofthe 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 worldorce.
- 11. Seismic Impacts on Stored Casks Must Be Stated 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 fracking-induced earthquakes will have on the buried casks.
- 12. The irn_pacts of global warming on climate in the region and the resulting impacts on casks and canistersr in relation to their ratings, must be considered.
It is also unclear to me exactly how the town of )al or Lea County would benefit directly from this operation. lhe City of Jal government has written a resolution reject:iflg Holtet's proposal and I fully support this.
- Thank you for your.consideration,