ML18219A720
| ML18219A720 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/25/2018 |
| From: | Ellison J - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00272, NRC-2018-0052 | |
| Download: ML18219A720 (2) | |
Text
July 25, 2018 May Ma, Office of Administration Mail Stop: TWFN-7-AGOM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Nuclear Regulatory Commission SUNS! Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (272)
PUBLICATION DATE: 3/30/2018 CITATION# 83 FR 13802 RE:: Docket ID NRC-2018-0052; Holtec lnternational's HI-STORE CIS Facility for Spent Nuclear Fuel, Lea County, New Mexico As a citizen of Jal, New Mexico and 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 c<>nsent to transporting up to 10,000 canisters of highly radioactive waste through thousands of communities nationwide. I do ~ot 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 ~cke~s of~~!!_ec_ lnt~ational.~ ~iJS) Tii-1-,.6 g lSt,f\\~S I JJ f Av~.
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 acros_s Tribal and agricultural lands. Without routes that are designated, the public cannot adequately comment on the impacts of thi~ massive project.
Here are a few con~rete things I urge you to consider:
- 1. This Holtec Proposal Is Contrary to Current Law Current law only allows the U.S. Department of Energy to take title to commercial spent fuel "fol~owing commencement 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 facility.
- 2. Holtec Must Remove Copyrights and All Redactions in the Environmental Report NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions.
- 3. 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 spent fuel being left at the Holtec site indefinitely.
- 4. 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 Independent Spent Fuel Storage Facility (ISFSI) must also be analyzed.
- 5. The Environmental Report 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.
- 6. 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.
- 7. 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.
- 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 Lines Must Be Analyzed The railroads and electric lines are not in place but must be analyzed.
- 10. 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.
- 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 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.
It is also unclear to me exactly how the town of Jal or Lea County would benefit directly from this operation. The City of Jal government has written a resolution rejecting Holtec's proposal a.nd I fully support this.
Thank you for your consideration,