ML18221A651

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Comment (3480) E-mail Regarding Holtec-CISF EIS Scoping
ML18221A651
Person / Time
Site: HI-STORE
Issue date: 07/30/2018
From: Public Commenter
Public Commenter
To:
Division of Fuel Cycle Safety, Safeguards, and Environmental Review
NRC/NMSS/DFCSE
References
83FR13802
Download: ML18221A651 (21)
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Text

1 Holtec-CISFEISCEm Resource From:

KarenD Hadden <karendhadden@gmail.com>

Sent:

Monday, July 30, 2018 11:20 PM To:

HOLTEC-CISEIS@nrc.gov; Holtec-CISFEIS Resource

Subject:

[External_Sender] Public Citizen and SEED Coalition Comments on HOLTEC-CIS Application Attachments:

Holtec Comments Final 7-30-18.docx

Dear NRC,

Please find our comments on the Holtec CIS application.

We have tried repeatedly to submit these comments online in a timely manner, but are getting a message saying that they cannot be received.

I'm attempting to send just the comments now, and will attempt to send related attachments later, in hopes of getting this email through.

Thank you, Tom "Smitty" Smith, Director of Special Projects and Adrian Shelley, Director of the Texas office

>\\Public Citizen Karen Hadden, Executive Director Sustainable Energy and Economic Development (SEED) Coalition 605 Carismatic Lane Austin, TX 78748

Federal Register Notice:

83FR13802 Comment Number:

3480 Mail Envelope Properties (CABBPgcvU0ksshfTWTtR_CTSrPDXMtH9ardXVmNWOD+fBWC6+nA)

Subject:

[External_Sender] Public Citizen and SEED Coalition Comments on HOLTEC-CIS Application Sent Date:

7/30/2018 11:20:18 PM Received Date:

7/30/2018 11:20:43 PM From:

KarenD Hadden Created By:

karendhadden@gmail.com Recipients:

Post Office:

mail.gmail.com Files Size Date & Time MESSAGE 648 7/30/2018 11:20:43 PM Holtec Comments Final 7-30-18.docx 4215812 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

Holtecs Radioactive Roulette:

Why High Level Radioactive Waste Should Not Be Stored in New Mexico Ref: USNRC Docket No. 72-1051 THE PROPOSED HI-STORE CIS FACILITY July 30, 2018 Public Citizen and the Sustainable Energy and Economic Development (SEED) Coalition appreciate the opportunity to submit the following comments to the NRC on Holtec Internationals application to build a consolidated interim waste storage site between Carlsbad and Hobbs, New Mexico. We are submitting these comments on behalf of 1,164 Public Citizen members in New Mexico and 5,000 members in Texas as well as 2,550 members of SEED Coalition who would be particularly affected by this proposed site either as neighbors or because they are live near the rail lines that would carry this risky radioactive cargo through their communities.

The questions raised in these comments and the issues discussed need to be explored more thoroughly in the Holtec License Application Environmental Report.

The Nuclear Regulatory Commission (NRC) held public meetings to take comments on Holtecs environmental impact statement in Roswell, Hobbs, Carlsbad, Albuquerque and Gallup.

Opponents outnumbered supporters at every one of the five hearings. Our informal count tabulated that opponents outnumbered supporters by more than 3-1 over the series of five NRC meetings. Supporters were typically people who are or would be employed in relation to the project. Opponents outnumbered supporters by at least a 2-to-1 margin at the two interim committee meetings held by the New Mexico State Legislatures Radioactive Waste and Hazardous Materials Committee. The New Mexico communities of Albuquerque, Las Cruces, Lake Arthur, and Jal have passed resolutions expressing their opposition to this site and transportation of high-level waste radioactive materials through their communities as have Nueces, Bexar, Dallas and Midland counties and the City of San Antonio in Texas. The number of opponents at each hearing and communities that have passed resolutions opposing this waste expose the fallacy of the assertion that New Mexicans and Texans support this type of facility and have given consent to the storage of high level radioactive waste in New Mexico.

Their comments raise serious questions about this application which we will summarize below:

1. What happens if a final repository is never permitted?
2. What are the transportation risks?
3. What happens if there is an accident?
4. What are the risks of a terrorist attack during transit?
5. What happens if a cask leaks and why is there no repackaging system proposed at the site?
6. What are the plans to deal with water incursion into the canisters at the site
7. Are the number of security personnel projected to be onsite and the wages that would be paid adequate to assure a topflight security force capable of protecting radioactive materials?
8. Shouldnt the nations sixtyyear history of broken federal promises to clean up leaking radioactive sites in past require special funds be set aside to assure for clean-up and remediation of this proposed project.1
9. The Holtec proposal and the agency should be revised to fully analyze the impact of this site and transportation leading to it on environmental justice communities.

What happens if a permanent repository is never designated? Would New Mexicans get stuck with the financial and health risks of storing this deadly and toxic waste?

The waste consists of fuel rods that have been inside operating nuclear reactors, and still contain most of the original uranium, plutonium, cesium and strontium. Some of the waste materials will remain deadly for one million years. Exposure to this radiation is known to cause cancer and birth defects.

Holtec Internationals controversial license application is to store over 100,000 tons of this dangerous nuclear reactor waste for as long as 120 years, (Holtec pg 197). This volume is large enough to include essentially all U.S. nuclear reactor waste. Recently, Holtec told New Mexico legislators at a Radioactive and Hazardous Materials Committee hearing on July 19th they are considering future amendments that would allow them to store as much as 173,000 tons--far 1 The Nuclear Waste Policy Act required the Secretary of Energy to issue guidelines for selection of sites for construction of two permanent, underground nuclear waste repositories. DOE was to study five potential sites, and then recommend three to the President by January 1, 1985. Five additional sites were to be studied and three of them recommended to the president by July 1, 1989 as possible locations for a second repository. A full environmental impact statement was required for any site recommended to the President.

Locations considered to be leading contenders for a permanent repository were basalt formations at the government's Hanford Nuclear Reservation in Washington; volcanic tuff formations at its Nevada nuclear test site, and several salt formations in Utah, Texas, Louisiana and Mississippi. Salt and granite formations in other states from Maine to Georgia had also been surveyed, but not evaluated in great detail.[4]

The President was required to review site recommendations and submit to Congress by March 31, 1987 his recommendation of one site for the first repository, and by March 31, 1990, his recommendation for a second repository. The amount of high-level waste or spent fuel that could be placed in the first repository was limited to the equivalent of 70,000 metric tons of heavy metal until a second repository was built. The Act required the national government to take ownership of all nuclear waste or spent fuel at the reactor site, transport it to the repository, and thereafter be responsible for its containment.[5]

more than the US reactors are anticipated to produce by the time all existing reactors are decommissioned. Who would this excess capacity be built for? Does Holtec have plans to import nuclear waste from other countries?

Furthermore, the Environmental Report is inadequate and must be revised since it analyzes storage of 100,000 MTUs, not 173,000 MTUs. If this is Holtecs intent then this is a massive difference should require a far different application.

The Federal Government has been searching for a site for spent nuclear fuel since the 1950s and has been required to find a site since the 1980s. 2The proposed Yucca Mountain permanent repository is unlikely to be reinvigorated and constructed.3 This consolidated interim waste site, if approved, would undermine federal efforts to develop a less risky location and storage systems for the permanent disposal of deadly radioactive waste by removing incentives for developing a viable permanent approach to our radioactive waste crisis. New Mexico could become an unsafe, inadequate de-facto nuclear waste dump for the country.

So what would happen if the Holtec site became a permanent site?

An interim storage site is not designed for and this process does not contemplate that nuclear waste might be present for a millennia let alone a million years. Yucca Mountain was required to be able to isolate waste for a million years. A process that only accounts for the consequences of storage for a few decades, or up to 120 years, is inadequate for a site that could become the de facto storage site for all time. Since there is not a permitted repository shouldnt this application process be redone based on an assumption that there will never be a final repository and using standards for evaluation established for repositories? There has been no evaluation of whether the Holtec site has the right geology for long-term storage or disposal.

Would the canisters and casks last a million years? This seems highly unlikely. How long are they expected to last before though wall cracks or other defects occur? Under what conditions could there be problems with the zirconium cladding?

2 The Nuclear Waste Policy Act of 1982 created a timetable and procedure for establishing a permanent, underground repository for high-level radioactive waste by the mid-1990s, and provided for some temporary federal storage of waste, including spent fuel from civilian nuclear reactors. State governments were authorized to veto a national government decision to place a waste repository within their borders, and the veto would stand unless both houses of Congress voted to override it. The Act also called for developing plans by 1985 to build monitored retrievable storage (MRS) facilities, where wastes could be kept for 50 to 100 years or more and then be removed for permanent disposal or for reprocessing.

3 Congress works to revive long-delayed plan to store nuclear waste in Yucca Mountain -

https://www.usatoday.com/story/news/politics/2018/06/03/yucca-mountain-congress-works-revive-dormant-nuclear-waste-dump/664153002/

If and when there are radiation releases, what financial guarantees are in place to assure that New Mexicans dont get stuck with the bill for cleanup and remediation? Who would pay to periodically repackage high level radioactive waste? Who would pay to guard it? Who would maintain it for decades? Who would pay to clean up the site in the event of an accident or if the site is not decommissioned by Holtec?

Over 10,000 Railcars of Radioactive Waste - A Train Wreck Waiting to Happen The transportation of radioactive waste is a train wreck waiting to happen.

More than 10,000 rail cars of this risky waste would rumble on New Mexico rails, in a process that would take 20 years, likely traveling rail lines along I-10, I-40, and I-25 to Clovis and thus Carlsbad and across Texas on the routes running along 1-10, 1-20, I-30, I-35 and I-27

https://www.google.com/search?q=holtec+hi-star+190&rlz Each loaded car would weigh 185 to 207 or more tons, far more that the 143 tons than the tracks are designed to carry per rail car according to testimony by railroad engineers at recent legislative hearings.

The Federal Railroad Commission has said A more robust track structure is required to handle these heavier cars. Many short lines did not have track and bridges capable of handling the heavier loads. Summary of needs of class II and III Railroads Federal Railroad Administration 2014 pg 5 4 When asked if the rail lines in New Mexico could safely handle cars of this weight-both Scott Palmer and Don Gallegos of the Brotherhood of Locomotive Engineers and Trainmen said they were not good enough at the July 19th Interim Committee meeting in Hobbs, NM.

Public Citizen has written about the danger and lack of oversight of transported radioactive material (some high-level and some low-level) going missing. See, http://www.texasvox.org/file-things-never-go-missing-category/.

Holtecs application says:

4 From documents filed with NRC by Holtec - https://www.nrc.gov/docs/ML1623/ML16238A215.pdf

Over the course of the operational life of the CIS Facility, Holtec would receive up to 100,000 MTUs of spent nuclear fuel (SNF) in approximately 10,000 canisters from decommissioned and operating reactor sites. (Holtec Pg 198).

From Holtecs application:

Two railroads service the area. One railroad company operates to the west of the site and the other to the east. Southwestern Railroad operates the Burlington Northern-Santa Fe (BNSF) Carlsbad Subdivision (Carlsbad to Clovis, New Mexico, plus industrial spurs serving potash mines east of Carlsbad and east of Loving, New Mexico) under a lease agreement The Carlsbad spur ends at the Intrepid Mining LLC North facility, which is 3.8 miles due west of the Site (ELEA 2007, Section 2.7.7.2). As discussed in Section 4.9 of this ER, a spur from this railroad would be constructed to serve the Site.

(Holtec Pg 157).

East of the Site, the Texas-New Mexico Railroad (TNMR) operates 104 miles of track near the Texas-New Mexico border from a Union Pacific connection at Monahans, Texas to Lovington, New Mexico. The railroad serves the oil fields of West Texas and Southeast New Mexico. The primary commodities hauled are oilfield chemicals and minerals, construction aggregates, industrial waste, and scrap (ELEA 2007, Section 2.7.7.2). Approximately 400 railroad cars per year travel on this rail (IIFP 2009, Section 3.2.1 Please evaluate the safety of the proposed transportation plan for this site based on the facts that there have been at least ten accidents on the railroads in New Mexico and Texas in the last three years, including a derailment near Roswell, NM and a train and truck collision in downtown Carlsbad, NM. Here are some references to those recent accidents.

  • A Southwestern Railroad engineer was killed and a second crew member was seriously was injured when their train struck a train parked on a siding 10 miles southeast of Roswell on April 28, 2015.5
  • On September 8, 2015, at 12:34 a.m. Central daylight time, westbound Union Pacific Railroad (UP) freight train AMNML-07 (striking train) collided into the side of northbound Union Pacific freight train ALDAS-06 (struck train) near Texarkana, Texas.6
  • On Tuesday, June 28, 2016, at 8:21 a.m. central daylight time, two BNSF Railway (BNSF) trains collided at milepost 525.4 on the BNSFs Panhandle Subdivision. 7
  • On September 22, 2017, at 11:06 a.m. central daylight time, Union Pacific Railroad (UP) train (Y-GW51R-22) derailed in the UP Great Southwestern Yard in Arlington, Texas.

8

  • January 30th 2017 train derailment on I-10 near Van Horn, Texas. 9
  • The train derailed off a railway that runs along Interstate 10 West in Luna County, New Mexico around noon May 30, 2017. 10 5 One Killed, One Injured in New Mexico Head-on Train Accident, CBS News -

https://www.cbsnews.com/news/1-killed-1-injured-in-new-mexico-head-on-train-accident/

6 NTSB Railroad Accident Brief: Collision of Two Union Pacific Railroad Freight Trains, Texarkana, Texas

- https://www.ntsb.gov/investigations/AccidentReports/Pages/RAB1708.aspx 7 NTSB Collision of BNSF Eastbound Train S-LACLPC1-26K and BNSF Westbound Train Q-CHISBD6-27L, Panhandle, Texas - https://www.ntsb.gov/investigations/AccidentReports/Reports/DCA16FR008-PreliminaryReport.pdf 8 CBS News DFW - Union Pacific Worker Killed By Train In Arlington -

https://dfw.cbslocal.com/2017/09/22/union-pacific-worker-killed-train/

9 KTSM.com - Train derails 40 miles east of Van Horn, TX - https://www.ktsm.com/news/local/el-paso-news/train-derails-about-40-miles-east-of-van-horn/647121099

  • May 1 2018 three cars derail near Odessa, Texas. 11
  • July 18th, 2018 - a semi and a train collide near Carlsbad, NM.12 There were two rail derailments over one weekend, July 21 and 22, 2018, along the Clovis - Carlsbad stretch of track. 13 http://www.kob.com/new-mexico-news/nm-senate-house-approve-funding-to-stabilize-giant-sinkhole-in-waiting/4785612/#.Ww8GwpSVXQ0.gmail The rail lines that would carry radioactive waste would run right along the edge and potentially over a mined out section of the Carlsbad sinkhole. Overweight radioactive waste trains alongside a sinkhole create a recipe for disaster. John Heaton, Holtecs spokesman, says that this concern is unfounded because the rail lines run to the north of Carlsbad, but Holtecs 10 Fox News -Cleanup underway for Mays train derailment in Luna County, officials say -

https://kfoxtv.com/news/local/diesel-fuel-spills-after-train-derails-in-luna-county-new-mexico 11 Odessa Advocate - Train cars carrying sand derail in Odessa -

https://www.oaoa.com/news/local/article_557a696c-4d91-11e8-8d96-8311b700b247.html 12 Carlbad Current - Train, semi collide at the intersection of Brantley and U.S. Highway 285 -

https://www.currentargus.com/story/news/local/2018/07/18/train-strikes-semi-near-brantley-rd/796456002/

13 KRQE - Two trains derail in SE New Mexico over the weekend - https://www.krqe.com/news/new-mexico/two-trains-derail-in-se-new-mexico-over-the-weekend/1317185887

application (page 157) and the above New Mexico State Rail map shows that line running along Highway 285 and then east along 62 to the Holtec site.

Cost of an Accident could be huge According to a 1999 study by the State of Nevada Nuclear Waste Project Office done regarding Yucca Mountain, even a small radiation release from a serious accident could contaminate 42 square miles of land. Clean up costs could exceed $620 million in a rural area, in an urban area, it could cost up to $9.5 billion to raze and rebuild the most heavily contaminated square mile.14 In a study of a proposed consolidated interim storage site for radioactive waste proposed for Andrews County, Texas, the Commission on Environmental Quality discussed a terrorist attack on radioactive waste during transport or at the site as a significant threat.15 The report cited a study entitled Centralized Interim Storage of Nuclear Waste and a National Interim Storage Strategy, included this reference:

With the presence of any potentially dangerous material, it is important to anticipate the possibility of malicious attack or theft. Due to the deliberate nature of such security threats, one cannot reasonably assign them a probability and calculate an expected cost. Because these attacks often target human lives and aim to create terror, it is important to actively safeguard against the negative consequences of such an attack.

Therefore, for interim spent fuel storage, spent fuel must be secured against malicious attack and its consequences at all times. For radioactive materials such as spent fuel, security threats fall into two general categories: sabotage and theft. In the former, the intent is to damage shielding and potentially disperse radioactive material, therefore exposing the environment and population to radiation. The latter involves stealing the material for future use in a radiological dispersal device or dirty bomb, or a potential nuclear device. In addition, each of these types of events may occur during storage, transportation, or fuel transfer. Pg 24 Transportation The transportation of spent fuel presents unique security vulnerabilities and challenges. Differences in risk between storage and transportation are due to a reduced number of security personnel guarding transport, fewer engineered barriers during transport, and potential proximity of transportation routes to population 14 Transportation of Spent Nuclear Fuel and High-Level Radioactive Waste to a Repository, May 20, 1999. - http://www.state.nv.us/nucwaste/trans/trfact03.htm 15 TCEQ 'Assessment of Texas' High Level Radioactive Waste Storage Options' -

https://www.documentcloud.org/documents/1100389-tceq-assessment-of-texas-high-level-radioactive.html

centers. Each of these factors make spent fuel in transit a more appealing and accessible target to attackers, thus increasing risk. Pg 26. 16 High level radioactive waste could be shipped through major urban areas with high value terrorist targets such as the petrochemical and refinery clusters around the Port of Houston and Corpus Christi. These wastes could also come through San Antonio, with its cluster of five military bases including one that houses the Strategic Air Command. A train car filled with radioactive material and passing near to these facilities could be an attractive target for terrorists A new generation of armor piercing weapons, cyber warfare technologies, robotic weapons and drones have been developed since 9/11 17 and more than half of the small arms were left left behind in hostile territories in the middle east making them easily obtained by terrorists.18 The NRC has not updated its studies on risk of terrorist attack since 9/11 and should do so.

How will the security force be trained and what are their qualifications?

  • The Holtec application says the operation of the CIS Facility would require an ongoing estimated work force of less than 40 personnel and less than 15 security Personnel (Holtec Pg 238)
  • The application says the mean annual salary for security guards is $29,880 (BLS 2016b). Or $14.31per hour (Holtec pg 195)

Using simple math: this means as few as 4 guards per shift:

  • 2,087 work hours per year (DOL/opm) /8760/15 = 4 guards per shift
  • This salary will not be competitive in SE new Mexico and may lead to underqualified, unfit and inexperienced security personnel.

What are the security force requirements?

16Petroski, Robert, Centralized Interim Storage of Nuclear Waste and a National Interim Storage Strategy, Journal of Engineering and Public Policy, vol. 9, (2005) - http://www.wise-intern.org/journal/2005/petroski.pdf 17 https://www.military.com/defensetech/2011/09/09/the-u-s-post-911-weapons-tech 18https://www.nytimes.com/2016/08/23/magazine/how-many-guns-did-the-us-lose-track-of-in-iraq-and-afghanistan-hundreds-of-thousands.html

  • Would they actively patrol and how often or just sit at gate or on monitors?
  • Would they be required to pass annual physicals and endurance tests in 100 degree heat?

Cask safety tests Most of the tests on canister safety were done prior to 9/11. Many of the tests were simulations that set artificial limits. For example: one test assumed a canister on a train running into an immovable object at 60 MPH would be unharmed-yet in a recent accident in West Texas two trains collided in a head on collision at 65 mph in West Texas, resulting in damage to both trains and three fatalities. 19 The resultant fire burned for more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (AP 8:56pm 6/28/16). The diesel fuel carried by the trains was still smoldering the next morning. (Mariah Medina, San Antonio Express-News Wednesday, June 29, 2016).

The 30 minute heat exposure tests were also flawed, according to Scott Palmer, chairman of the Oregon State legislative board of the Brotherhood of Locomotive Engineers and Trainmen.

19 NTSB Collision of BNSF Eastbound Train S-LACLPC1-26K and BNSF Westbound Train Q-CHISBD6-27L, Panhandle, Texas - https://www.ntsb.gov/investigations/AccidentReports/Reports/DCA16FR008-PreliminaryReport.pdf

Palmer testified at the July 19, 2018 New Mexico Radioactive and Hazardous Waste Committee hearing that although fire suppression equipment is available, rail accidents often occur hours away from that equipment.20 The application fails to provide a method for repackaging leaking canisters The irradiated fuel rods would be contained in thin steel canisters later surrounded by concrete These canisters arent designed for permanent storage. Metal fatigue, stress cracks or accidents could lead to radioactive leaks. The application does not propose or show any facilities for fixing or repackage a leaking container.

If Holtec consolidated interim storage facility is licensed, this dangerous waste will likely stay forever, at a site never designed for long-term disposal. The federal government has failed for decades to develop an underground permanent repository for this dangerous radioactive waste. We believe that waste stored at the Holtec site may never be removed.A new generation of armor piercing weapons, cyber warfare technologies and drones have been developed since 9/11 21 and many were left left behind in hostile territories in the middle east making them easily obtained by terrorists.22 What happens if the canisters crack or leak or are stored beyond their expected lifespan - how will they be monitored or repackaged? Why is there no plan to deal with a leaking canister in the permit? Why is it reasonable to assume that there will be no cracks or leaks in any of 10,000 shipments?

Once cracks in a canister start, they can grow through the wall in 16 years (NRC). The Holtec President admits that its canisters are not feasible to repair, even if the cracks were found. He said even a microscopic through-wall crack will release millions of curies of radionuclides into the environment.

Water incursion Radioactive waste needs to stay isolated and dry for a million years. The Holtec proposal would place the material near two playa lakes. Holtec acknowledges that the near surface water table appears to be 35-50 feet deep, where present, and is likely controlled by the water level in the 20 Presentation provided to committee at July 19, 2018 hearing -

https://www.nmlegis.gov/handouts/RHMC%20071918%20Item%202%20SNF%20Transportation%20Saf ety%20and%20Security%20Concerns.pdf 21 https://www.military.com/defensetech/2011/09/09/the-u-s-post-911-weapons-tech 22 https://www.nytimes.com/2016/08/23/magazine/how-many-guns-did-the-us-lose-track-of-in-iraq-and-afghanistan-hundreds-of-thousands.html

playa lakes. (Holtec pg 179) Given the location of the proposed site relative to the playa lakes and the presence of groundwater at 35 to 50 below the surface, isnt it probable that water will leak into the site?

The way its built is they excavate down 30 feet and then they put a 3 foot layer of reinforced concrete on the bottom of the excavation., Heaton said.23 Another 3-foot layer of reinforced concrete is added near the top of the silo so it is resistant to airplane crashes and rockets. The applications does not contain an adequate plan to is there not an adequate plan for remove the water from a canister?

If there are no drains in Holtecs canisters how will water be removed? Shouldnt the plans include a drainage system? At recent legislative hearings the possibility of using the waste heat at the storage site to purify brackish water was been raised.

Assuming the Holtec site is licensed, thought already has been given to using heat that comes off the storage casks to boil produced water from fracking operations, purify it, and either pipe it to nearby cities for their use, or reuse it in the oil field, Heaton said.It would 23 Holtecs site for used nuclear fuel could benefit oil, gas industry By Kathy Helms, July 28, 2018 Special correspondent cibola@gallupindependent.com Site

be a major, major change in how water is used in our part of the world. Its a concept that weve talked about for some time, he said, and Holtec has a patented process just waiting to be integrated. 24 How can that be done in ways that wont increase the risk that the waste will be exposed to water and imperil the waste?

What happens if there is a leak at the site? Most existing low-level radioactive waste sites have leaked, with remediation costs running into the billions of dollars. Congress has often failed to appropriate enough money to clean them up. What would happen to New Mexico if the federal government never approves a final site and never removes this waste, or wont adequately fund a cleanup?

Broken federal promises to clean up leaking radioactive sites bode ill for this site The following sites have had serious radiation leaks:

  • The Paducah Gaseous Diffusion Plant (PGDP) site in Kentucky listed as a Superfund site on the National Priorities List (NPL) in 1994.25
  • The Hanford Nuclear Reservation in Washington State is today Americas most contaminated nuclear site.26
  • The Waste Isolation Pilot Plant (WIPP) had a leak after 15 years of operation that took 3 years and $500 million to clean up.27
  • The Pantex Plant is the primary United States nuclear weapons assembly and disassembly facility. Since 2000, $171 million in compensation and medical bills has been disbursed to more than 1,300 workers and families since the energy employees compensation program began.28

Priorities List of Superfund Sites most in need of cleanup in 1989. The cleanup was completed after 28 years and cost $4.4 billion.29 Savannah River Site (SRS) produced tritium, plutonium and other special nuclear materials for national defense and the space program. Past disposal practices caused site contamination. Cleanup efforts have been underway since the 1980s. Site cleanup completion is currently scheduled for 2065.30 Beatty was the nations first federally licensed low-level radioactive waste dump. It opened in 1962 and closed in 1992. In October of 2015, that site caught fire. The commercial operator of the closed radioactive waste dump was troubled over the years by leaky shipments and oversight so lax that employees took contaminated tools and building materials home, according to state and federal records.31

  • West Valley Demonstration Project is a nuclear waste remediation project focusing on the cleanup and containment of radioactive waste left behind after the abandonment of a commercial nuclear fuel reprocessing plant in 1980. Despite over 30 years of cleanup efforts and billions of dollars having been spent at the site, the property has been described as New Yorks most toxic location in 2013.32i Impact on local employment Holtec says the total employment impact would include 80 construction workers, 40 professional staffers and 15 security guards for a total of 135 workers, 55 of them permanent--

just a 0.2 percent increase to regional employment (Holtec sec 4.8.2).

Eddy and Lea Counties are the two richest oil and gas producing counties in the country. The industry employs over 8,600 people. An accident at the Holtec site could jeopardize those existing jobs.

The New Mexico dairy industrys total economic impact exceeds $5 billion annually, second only to oil and gas revenues in state economic impact. The dairy industry employs nearly 6,000 people and generates over 17,000 related jobs. A radioactive release could destroy an entire local industry due to widespread consumer distrust over the safety of the local food stocks.

29 http://www.fluor.com/projects/fernald-environmental-remediation 30 https://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0403485 31 https://www.theguardian.com/us-news/2015/oct/25/radioactive-waste-dump-fire-reveals-nevada-troubled-past 32 https://en.wikipedia.org/wiki/West_Valley_Demonstration_Project

Local cattlemen and pecan farmers also expressed concerns at the July 19th interim legislative committee hearing about the impact of this waste on their industry and property values if their products were considered tainted.

Why risk existing jobs for 55 jobs at the proposed waste dump? Is all this risk worth it for a 0.2% increase in employment, especially considering risks to tens of thousands of existing jobs?

Environmental Justice Concerns The proposed site and the transport routes in New Mexico are located in predominantly low income communities of color--environmental justice communities. Holtect has not acted sufficiently to address or even document the disproportionate effect that this project would have on these vulnerable populations. Furthermore, the public engagement process has been discriminatory toward certain communities, particularly the non-English speaking population.

Notices were not provided in Spanish or other languages, predominantly spoken around meeting locations. Nor were the meetings translated. Various federal laws and executive orders require the NRC to document the potential effects of this project on environmental justice communities and seek to limit the impact of a proposed site on these communities.

Public Citizen used the EPA Environmental Justice screening tool EJSCREEN to conduct an analysis of all rail transport routes proposed for this project. (See attachments.) The following routes were considered:

  • BNSF from the state line to Vaughn; rail line from Raton to Belen; Southern line from Clovis to Carlsbad; and UP line from Gallup to Clovis. Within a 1/2 mile buffer of each of these lines, we found the following populations.33
  • BNSF from the state line to Vaughn: 10,629 people; 62% minority; per capita income

$17,854; 39% do not speak English at home; 26% with no high school diploma.

  • Rail line from Raton to Belen: 66,058 people; 74% minority; per capita income $21,690; 46% do not speak English at home; 20% with no high school diploma.
  • Southern line from Clovis to Carlsbad: 29,919 people; 61% minority; per capita income

$22,027; 37% do not speak English at home; 23% with no high school diploma.

33 See attachments. Data from the American Community Survey via EPA EJSCREEN.

  • UP line from Gallup to Clovis: 26,295 people; 74%% minority; per capita income

$16,565; 36% do not speak English at home; 23% with no high school diploma.

Public was excluded from government tour and project opponents cut off/pushed to end of a public meeting Wednesday, May 2, 2018, concerned members of the New Mexico communities, including local Hobbs residents, attempted to attend a government site tour to the proposed high-level nuclear waste dump in New Mexico. The Nuclear Regulatory Commission (NRC), Holtec International, and the Eddy-Lea Energy Alliance (ELEA) held a closed meeting without informing or inviting the public, violating its own Public Participation Policy. NRC claims they abide by their longstanding practice of providing the public with substantial information on its activities and of conducting business in an open manner. (Source: Enhancing Public Participation in NRC Meetings; Policy Statement.) NRCs 10-day advance-notification policy, which involves posting a notice of a meeting between a license applicant and the NRC, was not observed for the site tour. In addition, even with the provisions to give fewer than 10 days if the 10-day rule cannot be observed, nothing was posted on NRCs website. They also failed to cite any reason for not including the public, such as trade secrets or exchange of proprietary information.

Lorraine Villegas, Hobbs resident and member of the Alliance for Environmental Strategies, said, They want us to step up and take the nations waste, but we dont even deserve to participate in the tour of where this waste is going to be? Im confused. The NRC is a federal agency, a public body, and the public should have been included, not just ELEA salesmen. Also note that the green notice sign says FUTURE site, not potential, like its already a done deal.

Susan Schuurman of the Nuclear Issues Study Group said, We came to participate in this site visit to learn more about the proposed dump. It was a surprise when law enforcement prevented us from entering the site and hearing what was being said. If this project is as safe and transparent as they claim, what do they have to hide?

Eddy and Lea County Sheriffs officers informed the group that they were directed by tour organizers to keep the community members from attending the site tour, keeping them to the county road alongside the Holtec site.

Cody Slama, a University of New Mexico student, reported, The Nuclear Regulatory Commission disgraced themselves today as government officials because they failed to serve the public. As concerned citizens started to show up to tour the site, we were ignored by our government officials and separated from them by Eddy and Lea County Sheriff deputies. We

wanted to be a part of the tour, so we yelled from the county road, We want to join you!

Multiple concerned citizens attempted to get their attention, and every single time we were ignored. The people representing the NRC showed me one thing: they are completely capable of ignoring those who will be most impacted by the decisions that they make.

In addition to being excluded from the site visit, the final scheduled NRC Public Scoping meeting in Carlsbad, held on May 3, 2018 gave opponents of Holtecs waste site less time to speak than proponents. In addition, the order of speakers was not consistent with when speakers arrived or signed up to speak. The NRC facilitator, Francis Chip Cameron, called on elected officials first, many of whom are proponents of the project representing the Eddy-Lea Energy Alliance, as well as a Holtec staffer. Most of those who attended and who spoke at all five meetings opposed the site.

At the tail end of the meeting were a string of speakers from the public who all opposed the Holtec project in their statements. The facilitator told those who remained to make their comments shorter than previous speakers, and cut off Artesia resident Noel Marquez from finishing his prepared statement at a fraction of the time given to previous speakers.

Marquez started his statement in Spanish and continued in English, Its no wonder our communities hesitate to come to these badly designed meetings over two hours long and limited to a very short statement on such an extremely important issue, all while our lives are at stake. After Marquez was abruptly cut off, and audience members demanded the facilitator give Marquez one more minute to be allowed equal time as earlier supporters of the waste dump were given.

Conclusion New Mexicans have been burdened with more than their fair share of the nations radioactive poisons.34 Why should they become the pay toilet for risky waste they did not produce? This long-lived and dangerous waste could threaten existing jobs and risk human health today and for generations to come. If this waste is so safe in these containers why do the people who live near this waste want it gone?

Some reactors are located in precarious locations near the ocean, rivers, or fault lines where tjis waste clearly should not be stored. Material from these reactors could be moved to the nearest safe reactor site. This would be preferable to long distance transport and reduce the risk from transportation. This interim storage strategy--rather than a new centralized site--will assure 34 Albuquerque Journal - Nuclear Waste Plan is Too Dangerous for New Mexico -

https://www.abqjournal.com/1169517/plan-is-too-dangerous-for-nm.html

that the long-standing policy of finding a permanent repository for this waste is fulfilled.

Shipping material to a site where it will be out of site and out of mind to most people in the country and will likely result in the material remaining forever in an inadequate site never designed for nor evaluated for permanent use unless the NRC acts and requires a revision of this application as a long-term site.

Almost two hundred people have spoken in opposition to this proposal and raised many significant issues that were not addressed or inadequately in the application. 0ver 5,000 comments in opposition to this site have been filed. The people of New Mexico and their elected officials have spoken. It is up to the NRC now to reject this application as inadequate.

Public Citizen and SEED appreciate the opportunity to deliver these comments. If you wish to discuss them further, we can be reached at Smitty@citizen.org, Ashelley@citizen.org, or Karendhadden@gmail.com Respectfully Submitted, Tom Smitty Smith Director Of Special Projects Public Citizen Adrian Shelley Director of Public Citizens Texas Office Public Citizen Karen Hadden Director of the Sustainable Energy and Economic Development (SEED) Coalition

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