ML18235A193
| ML18235A193 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/28/2018 |
| From: | Public Commenter Public Commenter |
| To: | Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| NRC/NMSS/DFCSE | |
| References | |
| 83FR13802 | |
| Download: ML18235A193 (3) | |
Text
1 Holtec-CISFEISCEm Resource From:
Natalie Houghton <tallyho4617@hotmail.com>
Sent:
Saturday, July 28, 2018 2:32 PM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] COMMENT TO the NRC on Docket ID NRC-2018-0052: Holtec Internationals HI-STORE Consolidated Interim Storage Facility Project
Dear Nuclear Regulatory Commission Staff:
Reject Holtec Internationals application for a Consolidated Interim Storage Facility (CISF) for high level nuclear waste:
first, because centralized or consolidated interim storage sites are NOT allowed under US federal laws, to the extent the Department of Energy and US taxpayers are expected to own and transport the waste. It is an ILLEGAL DUMP.
Reject, and do not rely on, the Environmental Report done by Tetra Tech for Holtec: this fraudulent contractor should NOT be doing the environmental analysis. For 20 years Tetra Tech has been falsifying radiation monitoring data, deliberately spreading radioactive soil and waste to previously clean places on and offsite, using unqualified workers to supervise radioactive scanning and cleanup efforts, and suppressing and firing whistleblowers at the Navys huge Hunters Point nuclear site in San Francisco, which is being converted to high-end housing. This is according to the US Navy, EPA and California Health Department. Based on this track record, Tetra Tech cannot be trusted to assess environmental impacts of the proposed Holtec dump.
The Holtec site VIOLATES environmental and economic jusstice. The proposed area has valuable industries including pecan, cattle ranches, dairy, and other local farming interests that would be threatened by the site. Even some hazardous and extractive industries that are part of the local economy oppose the dump. New Mexico has suffered enough as a national sacrifice zone at the hands of the nuclear industry, including abandoned uranium mines, the Manhattan Project, Trinity Test, plutonium contamination in the rivers downstream from Los Alamos, uranium enrichment, and hosting the nations transuranic waste at the Waste Isolation Pilot Plant. As one of the poorest states and a majority minority state, New Mexico has experienced environmental racism for decades. People of color continue to be disproportionately impacted by hazardous and toxic wastes. (Samia Assed, Chair of the New Mexico Poor Peoples Campaign; see: www.nonuclearwaste.org). NRC should re-assess the multiple stresses on New Mexicans, and failures to compensate them over the history of the atomic age.
CASK DANGERS. NONE of todays certified waste containers are designed for real world transport conditions (temperatures, crash speeds, submersion in deep water), nor have they been physically tested, despite dump-promoters misuse of 40 year-old crash-test videos on totally different casks. The storage containers cannot be monitored for potential cracks and leaks, inspected, repaired or replaced, even though we know the waste will be dangerous for far longer than the casks will last. The technology is in the future according to NRC staff. Nuclear Regulatory Commission (NRC) should include evaluation of transporting 10s of 1000s of shipments of the most deadly radioactive waste in super-heavy, inadequate containers over deteriorating railroad tracks, roads and bridges, including the impacts from many thousands of shipments on infrastructure, people, businesses, communities, and resources along all the proposed routes.
HOTTER HIGH LEVEL WASTE. NRC should include full evaluation of high burn-up fuel, which is a significant portion of the waste that would go to Holtec.
2 EMERGENCY RESPONSE. Assess and report on the reliability and capability of volunteer and distantly-located emergency response personnel upon whom the site will rely. Include availability, training, equipping and notification of emergency responders along all the routes.
HARSH ENVIRONMENT. Consider the decades of high temperatures, salty dry climate, potential flash floods, lightning, burrowing animals, sand, blocked vents, wind, rain, and fire on the casks and waste. Assume increased earthquake risks and impacts from fracking (which is not prohibited) near and under the site!
CONSOLIDATED INTERIM STORAGE (CIS) COULD BECOME PERMANENT. NRC must analyze the consequences of the waste remaining indefinitely at the sitenever moving to another location. Holtec proposes to consolidate up to 173,600 metric tons of high-level waste from all US nuclear power reactors to New Mexico, near the famous Carlsbad Caverns, to temporarily store for 40-120 years. (It could take 40+ years to move it there!) The waste would allegedly be moved again--but, if no permanent site is found or money to move it again never appears, it could stay forever, despite not being designed for permanent isolation.
REPROCESSING + PROLIFERATION DANGER. NRC, analyze the possibility of the waste being reprocessed at the site, since consolidating waste is the first step to dangerous reprocessing to extract plutonium, increasing nuclear weapons proliferation, massive water use (in land with very little water) and intense, irreversible environmental contamination.
Reprocessing was proposed at this same site before and must be addressed in the EIS.
Ms Natalie Houghton 1887 Wood Trail Prescott, AZ 86305 9285419601
Federal Register Notice:
83FR13802 Comment Number:
5001 Mail Envelope Properties (248878841.3281.1532802737194.JavaMail.tomcat)
Subject:
[External_Sender] COMMENT TO the NRC on Docket ID NRC-2018-0052:
Holtec Internationals HI-STORE Consolidated Interim Storage Facility Project Sent Date:
7/28/2018 2:32:17 PM Received Date:
7/28/2018 2:32:19 PM From:
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