ML18221A128

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Comment (285) of Anahe Hernandez on Holtec Internationals HI-STORE Spent Fuel Waste Facility
ML18221A128
Person / Time
Site: HI-STORE
Issue date: 07/30/2018
From: Hernandez A
- No Known Affiliation
To: May Ma
Rules, Announcements, and Directives Branch
References
83FR13802 00285, NRC-2018-0052
Download: ML18221A128 (12)
v • d • e


Text

MayMa Office of Administration-Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001 SUNSI Review Complete Template= ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)

COMMENT (285)

PUBLICATION DATE: 3/30/2018 CITATION# 83 FR 13802 RE: Docket ID NRC-2018-0052; Holtec Intemational's HI-STORE Spent Fuel Waste Facility Nuclear Regulatory Commission.:

I respectfully submit these scoping comments on the Holtec Environmental Report (ER) 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 am submitting the following comments because I do not consent to New Mexico becoming a national radioactive waste dwnping ground. I do not consent to transporting up to 10,000 canisters of highly radioactive waste through thousands of c.om.munities 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.

I formally request a 60-day Extension Of Time For This Comment Period. A 60-day comment period places an undue burden on the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will.be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those present.

A thorough Environmental Justice analysis must be complete to consider all possible future impacts from this facility to the local communities and those along transport routes, including but not limited to: economic and health impacts. I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may adversely impacted at the site and along transportation routes.

This Holtec Proposaii Ii Co1mt1rairy To <Cmurrent L2w e

Current law only allows the U.S. Department of Energy 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 site meets neither requirement, as it is a private facility.

Holtec Must Remove Copyrilgllit1m Aill1dl AnlJRedlaal:!tio:ns m the Environmental Report NRC must require Holtec to piroduce an ER that has no such copyright restriction and has no redactions.

The Impacts Of Permmanentl: §toliStge M\\U!st JBe Al!ll3liyzedl

  • I>

The Environmental Report (ER) is inadequate and incomplete bedmse "it does not analyze the impacts of the spent :fuelbeing left at the Holtec site indefinitely. * *.

More Altern.aitives Must Be Alllla.Ay:;zedl tl Keeping the spent fuel casks in some form of Hardened On Si~~ Storage@OSS) on the reactor sites must be analyzed.

e The alternative of consolidated storage being done at an existing* licensed jridependent Spent Fuel Storage Fa~ility (ISP.SI) must.be analyzed.

The waste can and should remain on site for many more years and does not need to move until thorough analrses_ of alternatives are complete.

The Environmental Report inadequately discusses the transportation Risks

  • This ER must include aU transpo~tion routes and the potential impacts of accidents or*

terrorism incidents on pµblic health and safety along all th~ routes.

  • . The ER is incomplete because it does not discuss how rail shipments from reactors without rail access would be accomplished and the risks and impacts of such shipillents.

The Consequences To An Accident-Exposed Individual Must Be Analyzed Teqns like "collective dose risk" and ~'person-rem" are used.to" ignore the potential impacts to a single individual.

  • All possible exposures to humans from routine r:eleases from transport casks and site storage must be clearly defined in plain language, for individuals !).ear waste canisters on occasion and workers who are transporting or working at' the site long-term.

Cracked And. Leaking Ca~ters Must, Be Addressed*

  • The ER does not analyze exactly how radioactive waste *from a cracked and leaking' canister would be handled, since there i~ no wet pool *or hof cell*at the site.

I More Cumulative lmpac~ Must B~ Analyzed

  • The ER mentions tlte Waste Isolation Pilot Plant (WIPP) but doe~ not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
  • The impacts from the local oil and gas industry on the proposed*site need to b~ analyzed.

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Se~o,..tJfJ~i?,?~~.9,,,~!~l~4 {?,ilsks fylust Be S~~ed A.lthougb, tbe ER gives a statement on recent seismic activity in the area, there is no

  • analysis.of what many 3.0-4.0 fracking-µiduced earthquakes will have on the buried casks.

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Impacts Of Future Railro~ds And ~lectric Lines Must Be Analyzed

  • The. railroads_ ~d electric lines are not in place, but must be.analyzed:.

How mariy of the estimated 135 jo1>s*wn1*g~**fo loc~ and ~ow ~any,~*re' only temporary?

  • The total nuinber of annual workers at the site could total 'as many as 135 when short-term, construction jobs are combined with the operating* workforce. How inany of these jobs will create long-term careers for local commW1ities? How many jobs. and careers wiij benefit local residents?

Sincerely, D 1,~~...

Signature j\\Cl,._~ :/M: *..

Name (Print)kiiS~

.. Pate. 7-* :i)-'76.

City & State t),~~,Q>., {p"W\\.

s.:

MayMa Office of Administi:ation Mail Stop: TWFN--'7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-QOOI RE: Docket ID NRC-2018.,-0052; Holtec lnternationaPs HI;..8TORE Spent Fuel Waste*;Facility Nuclear Regulatory Commission:

I respectfully submit these scoping comments on the Holtec En,vironmental Report (ER) 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 am submitting the following-comments because 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 contaminatio1c1 of <?W: lands, aquifers, air, or the health of plants, wildlife, and livestock. I do not oohsentto endangering 1 present and niture
  • generations.
  • I formally req11:est a 60_-day Extension Of Time for This Comment Period.-A 60-day comment period places an undue burden on the public to respo11:d to this 543-page technic~ document. I.

formally request additional Public Scoping Meetings for other communitles in New Mexico and natio~wide that will be impacted by the transport and that any additional meetings have time for.

the public to make verbal comments to those present. '

A thorough Environmental Justice analysis m.ust he complete *10 consider all possib1e future*.

impacts from this facility to the local communities and those along transport routes,,including but.

not limited to: economic and health impacts.. I. also requ~st proper,Tribal Consultation for ~Y affected indigenous nations whose people, cultural risources, or sacr~d places.~ay adve.rsely impacted at the site and along transportation r.~utes.

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 "following 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.

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.

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.

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 be analyzed.

The waste can and should remain on site for many more years and does not need to move until thorough analyses of alternatives are complete.

I 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 incomplete because it does not discuss how rail shipm~nts fto~-reactors without rail access would be accomplished and the risks and impacts of such shipments.. *.

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.
  • All possible exposures to humans from routine releases from transport casks and site storage must be clearly defined in plain language, for individ:uals near waste canisters on occasion and workers who are transporting *or working at the site long-term.

Cracked And L~g Canisters Must *Be Addr~set:J

_

  • The ER does not analyze*exactly how* radioactive waste from a cracked and leaking canister would be handled, since there fa no wet p~Ql or hot cell at the site.

More Cumulative Impac(:8 Must Be analyzed*-'

1 *

.1

  • The ER mentions the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts*.

of a radiologic release from -WIPP* on the proposed CIS *site. * *

  • _.To~ impacts _from_theJucal oil and.gas.industry on the proposed.site need-to-be analyzed-. -

Seismic ID,lp*acts-On Stored**casks*Must B"Stated

~ "Aithollgb the ER gives a statement on recent seismic activity in _the area, there is no analysis of what many 3.0-4.0 fracking-in:a.uced earthquakes will have on the buried casks.

Impacts Of Future Railroads And Electric Lines M1,1st Be Analyzed.

  • The railroads ap.d electric lines are not in_pl~ce, but ~ust b~ ~alyzed.

H9w many 9fthe estilµat~_ l35jobs will go to locals and how many*are only temporary?*

  • The total number of annual workers at the site could total-as many as*.135 when shorta-term, construction jobs are combined.with the operating workforce. How many* of these jobs will create long-term careers for local communities? How many jobs and careers.will benefit local residents?

Sincerely, (J l

  • Signature ____..,,..(.),c__V\\.,_v.. __

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~_...,'. /.____* ___ Date*_-fl__.*. -~ _3_0_--_rJ_

Name (Print}..;...* ~.......:......:..;;.:'A..:.:...-'C'\\;;;;.,.'. _____._:+/-J4--I*

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City & State -d\\J-R < \\ q

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p,J C). -_; 2018 MayMa *

  • Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-:-0001 **.

RE: Docket ID NRC-2018-0052; Holtec lntemational's HI-STORE Spent Fuel Waste Facility

. Nuclear Regulatory Commission:

I respectfully submit these scoping comme_nts. o~ the Hol~~ Envi,ronmental Report (ER) to bring up to I 00,000 metric tons of spent fuel, high-level radioactive waste: from* nuclear reactors around*

the country to southeast New Mexico. I am submitting the following comments because 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 radioaciive w.aste through th0usands of...:...

communities nationwide. I do µot 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.

I formally request a 60-day Extension Of Ti~~ For Th.is Comment Period. A 60-day comment.

period places an undue burden on the public to* respond to this 543-page technical *document I formally request additional Public Scoping Meetings for ~ther commuajti~s in Ne~:Mexi~ and nationwide that will be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those present.

A thorough Environmental J~c~ analy~is rii~t be c~~~l~te* t~ c~nside~ all po;s-ibl~ future impacts from this facility to*the-IocaI*communities and those along transport.routes, including.but not limited to:.economic and health impacts. I also*requestproper Tribal Consultation for any affected indigenous. nations whose people, cultural resources; or sacred places may. adversely impacted at. the site arid along tr/lll5p.ortation routes~

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 "following 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.

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.

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.

More Alternatives Must Be Analyzed Ke_eping 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 be analyzed.

  • The waste can and should remain on site for many more years and does*not*need to move until thorough analyses of alternatives are complete.

The Environmental Report inadequately discusses the transportation Rjsks:

  • This ER must include all transportation routes and the potential impacts of accidents or terronsm inciden,ts on public health and safety along all the routes.
  • The ER is 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 Consequences To :An Accident-Exposed Individual Must Be Analyzed

  • Tenns like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual.
  • All possible exposures to h~s _from routin~ re~eases from transport casks and site storage must be clearly de.fined in plain language, for individuals near waste canisters on occasion and workers *who are transporting or working at the site long-tenn.

Cracked And Leaking Canisters Must Be Addressed

  • The ER does not ~yze 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.

More Cumulative lmpacts*Must*Be A.1.uilyzed

  • The ER mentions.the Waste Isolation Pilot Plant (WIPP) but does not analyz.e the impacts of a radiologic rele.ase from. WIPP on the pr~posed CIS site.
  • The impacts from the local oiLan:d gas,industry on the proposed site need to be;aµalyzed.

Seismic Impacts On Stored Casks Must Be Stated;.

.

  • Although the ER gives a statement on recent seis~c activity in the. area, there is no analysis of what many 3.0-4.0 fracking-induced earthquakes will have on the buried casks.

Impacts Of.Future Railroads ~d Electrie*LiJ;les Must Be Analyzed.

  • The railroads and eiectric li~es ~e not in place~ but must.*be analyzed.

How many of the estimated.-135 jobs*willgo to locals and how niany are only f~mporary?

  • The total number of annual workers at the site could total as many as 135 when short.:.term, construction jobs are combined with ~e op~~ating w:orkforce: H~w m~y of these jobs will create long-tenn careers for local ~ommunities? How many jobs *and careers wili benefit local residents?.

Sincerely, Signature c.i rt C1. s Cb

. e; z

-&:: 5:z~~,: :{~

-f-2--U 201s May Ma Office of Administration Mail Stop: TWFN-7....:.A60M U.S. Nuclear Regulatory Comiilission Washington, DC 20555-*000I.

RE: Docket ID NRC-2018-0052; Holtec)ntematiolllll's ffi.-:-STO~ Spent Fu~l Waste Facility Nuclear Regulatory Commission:

I respectfully submit these scoping comments pn the Holtec ~nvironmental

  • Report (ER) to bring up to 100,000 metric tons of spent fuel~ high-level radioactive waste, frolll nuclear re~tors around the country to southeast New Mexico. I am submitting the following comments because I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do not consent to transporting up to 101000 canist~rs.ofhighly radioactive waste threuglHhousands 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.

I formally request a 60-day Extension Of Time For This Comment Period. A 60-day" comment period places an undue burden on the public to respond to this 543-page technical document. I formally request additional Public Scoping Meetings for other comm~ities in New Mexico and nationwide that will be impact~d by the transport and that any additional meetings have time for the public to make verbal comments to *those preseD;t...

A thorough Environmental Justice analysis must be complete to consid~r all possible future impacts from this facility fo the local communities and those along transport routes, including but not limited to: economic and health impacts: I also request proper Tribal Consultation for any affected indigenous nations whose people, cultural resources, or sacred places may.advers~ly impacted at ~e site and along transportatipn routes..

~*~

'1:llilis HoRtec Propo8al I~ Co~trary To Currel!llt Laiw.

~

/ " Current law*only allows the U.8.Departm.ent of Energy 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 site meets neither requirement, as it is a private facility.

Hoitec Ml!llst Remove Copyrights And Allll Redlmdiiol!lls Ellll ttlhle Emrvilrollllmel!lltai Report

" NRC must require Holtec to produce an ER that has no such copyright restriction and has no redactions.

The Impacts Of Permainent Storage Must Be Amlrulyzedl e

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.

Mo!l"e A!ternaitiives Must Be Analyzed e

Keeping the spent fuel casks in some form* of Hardened On Site Storage (HOSS) on the reactor sites must be analyzed.

e The alternative of consolidated storage being done at an existing licensed Independent Spent Fuel Storage Facility (~SFSI) must be analyzed.

  • The waste,can and should remain on site for many more years and does not, ~ed to move until thorough analyses*ofaliematives are complete.

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 ro:u~s..
  • The ER is 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 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..
  • All possible exposures to humans from routine releases from-transport casks and site *

' storage must be clearly defined iii plain' language, fo,r individuals near waste canisters on occasion and workers who are transporting'or working_ai the*site long-term.

Cracked And Leaking Canisters Must Be Ad~ressed

  • The ER does.not analy~ exactly how,radioa~tive waste from a cracked and leaking canister would be handled; since th~re is no wet pool or hot cell at the site.

More Cumulative Impacts Must Be Analyzed

  • The ER mentions the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts of a radiologic release from -WIPP on the pr~posed CIS site...
  • The impacts ftorii. the 'l9bal oil and gas industry--on the proposed site need to be ~yzed.

Seismic Impacts 0~ Storei( Casks M:ust Be Stated.

Although the ER gives a statement on recent_se~~mic activity in ~e area,_there is no.

analysis of what many 3.0-4.0 fracking-induced earthquakes will have on the buried casks.

Impacts Qf Future Railroads And Electric I,.in~s.Must Be.Analyzed.

.

  • The railroads and electric l~es are not in place, but must be analyzed.

How many of the estimated 135 jobs will go *to locais_ and how many are only temporary?

  • The total number of annual workers at the site could total as many as 135 when short-term,.

construction jobs are combined with the oper~ting workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers wjll benefit' local residents?

  • re\\.

\\~.>

....... 2

__.. -~:l~ 2018 MayMa Office of Acimil)istration Mail Stop: TWFN-7-A60M U.~. Nuclear Regulatory Commission Washington, DC 2055:5-OOOl **

RE: Docket ID NRC-2018-0052;.Holtec International's HI~TORE Spent Fuel Waste Facility Nuclear Regulatory Commission:

I respe9tfully submit tb~se scoping comments on the-1:foltec 'Environmental Report (ER) to* bring up to 100,000 metric. tons.of sp~nt fuel, high-level radioactive waste, from nuclear reactors around the country to southeast New Mexico. I am S4bmitting the followµig comments because I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do not consent to transporting up to I 0,000 canisters of highly ra4io~ctive w~te through thousands of communities nationwide. I do not consent to the risk of contamination of our lands, aquifers, air, or th~ health of plants, wildlife, and livestock. I do not.consent to en~gering pr~sent and future generations.

I formally request a 60-day Extension Of Time For.This 'Comment*Period. A 60-day comment period places an undue.burden. on the public to respond to this 543-page technical document. I.

formally request additional Public Scoping Meetings for other communities in New Mexico and nationwide that will be impacted by the transport and that any additional meetings have time for the public to make verbal comments to those*present.

A thorough Envirorµnental Justice analy~is must be complete to consider all possible future impacts from this facility to the local communities* and those along t:ranspoit" routes, including but not limited to: economic and health impacts. I *also request.proper Tribal Consultation for any affected indigenous nations whose people, cul~ resources, or sacred pl~es may adversely impacted at the site and along transportation routes.

This Holtec Proposal Js Contrary To ~urrent Law

  • Current law only allows the U.S. Department of Energy to take titl<d9 commer~ial spent

. fuel "following 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.

Holtec Must Remove Copyrights And All Redactions in the Environmental Report

  • NRC must require Holtec to produce an ER that has i;io such copyright restriction and has no redactions.

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.

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 be analyzed.

.\\

The waste can and should remain on site for :many more years and does not need to move until thorough analyses of alternatives are complete.

The Environmental Report inadequately discu,sses the transportation Risks This ER must include all transportation routes and the potential impacts of ~ccidents or terrorism incidents on public health and safety along all the.rp~tes,:

The ER is incomplete because it does not discuss how rail shipments from reactors without n~il acc.~ss woul~ be accomplished and the risks and impacts of such shipments.

~

I

~

The Consequences.To An Accident-Exposed Individual Mult Be Analyzed*

Terms like "collective dose risk" and "person-rem" are used to ignore the potential impacts to a single individual.

  • All possibl~ exposures to hulilans from routine releases from transport casks and site storage must be clearly define~* in plam'Iariguage,'for individuals near waste canisters on occasion and workers who are transporting or working at the site long-term..

Cracked And Leaking Canisten 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.

More Cumulative Impacts Must Be Analy~ed The ER mentions the Waste Isolation.Pilot Pl~t (WIPP). but does not.analyze the impacts of a radiologic release from WIPP on the propos~d CIS site:.

  • ~tdmpac~ from the local oil and gas industry on the proposed site ne~d to be analyzed.

Seismic Impacts On Stored Casks Must Be Stated

  • Although the ER giyes a statement on recent seismic activity in the area, there is no analysis of what many '3.0-4.0 fracking-induced earthquajces will )laye on the buried casks.

Impacts Of Future Railroads i\\.iid Electric Lines Must Be Analyzed

.

  • The railroads and electric lin~~-ar~ ~ot in place~ but must be analy~d.

i' How many of the estimated 135 jobs will go to locals and how many are ~nly *.~~porary?

  • The total number of annual workers at the site could total as many as 135 when short-term, construction jobs are combined with the operating workforce. How many.of.these jobs will

. crea~e long-term careers. for local c~mmunities?'iiow many jobs and careers ~11 benefit local residents?

Sincerely, Si~ed~7l1~-

'r.j Name (Print) (. e C. /.{ leL rli U :11 tJ z.

  • City & Stat~~

?1.p-LA./ 22:t-~~

MayMa Office of Administration Mail Stop,: TWFN-7'-A60M U.S. Nuclear Regufato"ry Commission Washington, DC 20555- 0001 RE: Docket ID NRC-2018-005~; Hpltec International's HI-STORE' Spent Fuel'WasteFacility Nuclear Regulatory Commission:*

I respectfidly'*submitthese scoping.co~ents.o~ the Holtec ~nvironmental Report (ER) to bring up to l 00,000 metric tons of spent fuel, high-level radiqactive :w:~te, from.iniclear reactors around

  • the country to southeast New Mexico.. ! an,1 subµiit;ting the fo.~o'Ying comments because I do not consent to New Mexico becoming a national radioactive waste dumping ground. I do riot 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, ai:c, or the health of plants, wildlife, and livestock. I do not consent to endangering present and future

. generations..

I formally request a 60-day Extension Of Time For This Comment Period. A.qO-daypomµient.

. period places *111 undue burden on the public to respond to.this '543-page technical document. I formally request additional Public Scoping Meetings for other communities ~ New Mexico and natio~wide that will be impacted by the transport and that any additional meetings have time for the public to make verbal co~ents to those present A thorough Environmental Justice analysis must be complete to coDS,ider.all.possible future impacts from this facility to the lo~ communities and those along transport'routes*, inciuding but not limited to: economic and health impacts. I aiso request proper Tribal* Consultation for any affected indigenous nations whose people, cultiital resouI'ces; oi.sacred *places may adversely.

impacted'aithe site and along transportation rout~s..

This HoUec Proposal Is *~ontrary To ~ui:rep.t Law.. *.. :..

  • Current law only allows the U.S. Dep~ent ot:Enei:gy'fo take title to corinnercial spent fuel "following 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.

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.

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.

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 existip.g licensed Independent Spent Fuel Storage Facility (ISFSI) must be analyzed:*.

The waste can and should remain on site *for many more years and does not need to move until thorough analyses of alternatives are complete.

The Environmental J;{,eport inadequately discusses the transportation Risks *

  • Tb.is ER must in~lude all transportation routes and the potential impacts of acddents or terrorism incidents on public health and safety along all the routes. *
  • The ER is incomplete because it does no.t discuss how rail shipments from reactors without

' rail access would be accomplished and the risks and impacts of such shipments.

The Consequences ';('o -~*_Accident-Expos~d Individu~i *Must Be :An,alyzed.

  • Terms like "collective dose risk" and person-rem'~ are used to ignore the potential impacts

. to* a single indi,vidual.. *

  • . All possible exposures to humans from routine releases from transport casks and site storage n:nist be clearly defined in plain language, for individuals near waste canisters on.

oc.casion and workers who are transporting or working at the site long-term.

Cracked And Leaking Canisters 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.

More Cumulative Impacts Must Be Analyzed

  • The ER mentions the Waste Isolation Pilot Plant (WIPP) but does not analyze the impacts of a radiologic release from WIPP on the proposed CIS site.
  • The impacts from the local oil and gas industry on the proposed site need to be analyzed.

Seismic ~pa~ts On Stored C~slcs Must B.e S~ted

  • Althmigh the ER gives a 'statement on.recent seismic activity in the* area, there is no analysis of what many*J.04.0 fracking-indu<?Cd earthquakes will have on the buried casks.

Impacts Of :,!utur~ Railro;uls A.nd El~ctric Lines Must Be Analyzed

  • The railroads and electric lines are not in place, but must be analyzed.

How many of the estimated 135 jobs will go to locals and how many are only temporary?

  • The total number of annual workers at the site could total as many as 13 5 when short-temi, constructipn jobs are combined with the operating workforce. How many of these jobs will create long-term careers for local communities? How many jobs and careers will benefit local residents?

Sincerely,

"" (

Signaarre_U,.r ~*1, -

Name (Pnnt) ~::; o,... )/fl 7 (?U& 1..

City & State.,A.Yi e c, ~()..,

. ~J /VI e>(

,Date 7 3.0 - /~

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