ML18221A126
| ML18221A126 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/25/2018 |
| From: | Orr J - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 83FR13802 00187, NRC-2018-0052 | |
| Download: ML18221A126 (2) | |
Text
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~ay'Ma, Office of Administration Mail*Stop:TIA{FN-7-A60M.
u.s. Nuclear Regulatory Q>mmission Washington, DC 2~5-0001 Attn: Nuclear Regulatory Commission SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
COMMENT (287)
PUBLICATION DATE: 3/30/2018 CITATION # 83 FR 13802 RE:: Docket 10 *NRC-2018-0052; Holtec lriternational's Hl..:sTORE CIS Fae1lityfor 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 m 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. ldo not consent to the risk of contamination of our lands, aquifers, air, or the health of plants, Wlldlife and livestock.. l do not consent to endangering present and future generations to line the pockets of Holtec International.
The }1oltec project would lead to dangerous extensiVe transport of high--level t:adioactivewaste 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.
Here are a few concrete things* I urge yciu to consider:
- 1. This Hciltec Proposa1*1s Contrary to Current Law '
Current law only allows the U.S. Deparbnent of Energy to take title to commercial spent fuel "following commenc~ment of.operation of a repQsitory or at a DOE-owned and operated monitored retrievable storage.facility. The Holtec site* meets nett:her requirement, as it is a private facility.
- 2. Holtec Must Remove:Copyrights and All Redactions inthe Envitonmental Report NRC must requireHdltec to produce an ER that has no such cor.,yrif{ht ~ibn*and has no redactions.
- 3. The Impacts of Pernianel'lt Storage Must Be Anaiyzed The Environme'mal.Rt'!port (ER) is inadequate and incomplete'beca~ it does not analyze.the impacts of the spentfuel being Jeff at the Mtiltec 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. Thealtemative of consolidated storagE!'being done at an existing licensed Independent Spent Fuel S1.t>rage *Facility d*sFSi)'mustalso be analyzed.
- 5. The Environmeritaf*.Refiort inadequately discusses the Transportation Risks This* ERm~ includealltransportation.*routes and the potentialtmpacbQJaccideritsorterrorism incidents
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The ER is inadequate and i11comprete 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 lndiVidual 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 hot 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 WtPP 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 eleqric 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 inany 3.0 -4.0 tracking-induced earthquakes will have on the buried casks.
- 12. The impacts of *globa*1 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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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 reject~g Holtec's proposal and I fully support this.
Thank you for your consideration,
..