ML18247A573
| ML18247A573 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/04/2018 |
| From: | - No Known Affiliation |
| To: | |
| References | |
| Download: ML18247A573 (6) | |
Text
1 Holtec-CISFEnvDocsPEm Resource From:
Kellermueller, Ronald, DGF <Ronald.Kellermueller@state.nm.us>
Sent:
Tuesday, September 4, 2018 1:43 PM To:
Caverly, Jill Cc:
Farmer, George, DGF; Beauprez, Grant, DGF; Pierce, Leland J., DGF; Duvuvuei, Erin, DGF; nmesfo@fws.gov; DGF-EEP-TG
Subject:
[External_Sender] RE: Holtec International HI-STORE Consolidated Interim Storage Facility Project. NMDGF Project #18390 Attachments:
18390_Holtec International HI-STORE Consolidated Interim Storage Facility.pdf
Dear Ms. Caverly,
Attached you should find NMDGFs comments on the proposed spent nuclear fuel Consolidated Interim Storage Facility Project. If you have any questions please feel free to contact me.
Yours Truly, Ron Ron Kellermueller Mining and Energy Habitat Specialist Ecological and Environmental Planning Division New Mexico Department of Game and Fish 1 Wildlife Way Santa Fe, NM 87507 (505) 476-8159 Ronald.Kellermueller@state.nm.us Conserving New Mexicos Wildlife for Future Generations CONFIDENTIALITY NOTICE: This e-mail, including all attachments is for the sole use of the intended recipient[s] and may contain confidential and/or privileged information. Any unauthorized review, use, copying, disclosure or distribution is prohibited, unless specifically provided under the New Mexico Inspection of Public Records Act. If you are not the intended recipient, please contact the sender at once and destroy all copies of this message.
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[External_Sender] RE: Holtec International HI-STORE Consolidated Interim Storage Facility Project. NMDGF Project #18390 Sent Date:
9/4/2018 1:43:01 PM Received Date:
9/4/2018 1:43:16 PM From:
Kellermueller, Ronald, DGF Created By:
Ronald.Kellermueller@state.nm.us Recipients:
"Farmer, George, DGF" <george.farmer@state.nm.us>
Tracking Status: None "Beauprez, Grant, DGF" <Grant.Beauprez@state.nm.us>
Tracking Status: None "Pierce, Leland J., DGF" <leland.pierce@state.nm.us>
Tracking Status: None "Duvuvuei, Erin, DGF" <Erin.Duvuvuei@state.nm.us>
Tracking Status: None "nmesfo@fws.gov" <nmesfo@fws.gov>
Tracking Status: None "DGF-EEP-TG" <DGF-EEP-TG@state.nm.us>
Tracking Status: None "Caverly, Jill" <Jill.Caverly@nrc.gov>
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MBXCAS005.nmes.lcl Files Size Date & Time MESSAGE 989 9/4/2018 1:43:16 PM image002.jpg 10204 18390_Holtec International HI-STORE Consolidated Interim Storage Facility.pdf 219426 Options Priority:
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GOVERNOR Susana Martinez STATE OF NEW MEXICO DEPARTMENT OF GAME & FISH One Wildlife Way, Santa Fe, NM 87507 Post Office Box 25112, Santa Fe, NM 87504 Tel: (505) 476-8000 l Fax: (505) 476-8123 For information call: (888) 248-6866 www.wildlife.state.nm.us STATE GAME COMMISSION PAUL M. KIENZLE III Chairman Albuquerque BILL MONTOYA Vice-Chairman Alto CRAIG PETERSON Farmington RALPH RAMOS Las Cruces BOB RICKLEFS Cimarron THOMAS DICK SALOPEK Las Cruces VACANT DIRECTOR AND SECRETARY TO THE COMMISSION Michael B. Sloane DEPUTY DIRECTOR Vacant 31 August 2018 Jill Caverly U.S. Nuclear Regulatory Commission (NRC)
Mail Stop: TWFN-7-A60M Washington, DC 20555 RE: Holtec International HI-STORE Consolidated Interim Storage Facility Project, Environmental Impact Statement (EIS), Public Scoping; NMDGF No. 18390
Dear Ms. Caverly,
The New Mexico Department of Game and Fish (Department) appreciates the opportunity to provide comments on the proposed HI-STORE Consolidated Interim Storage Facility Project (CIS Facility) located in Eddy County, New Mexico. On 2 May 2018, the NRC facilitated a meeting and site inspection that was attended by staff from the Department, NRC, Holtec International, Center for Nuclear Waste Regulatory Analyses, New Mexico Department of Transportation, and the New Mexico Environment Department.
The proposed CIS Facilitys project footprint is located approximately one-half mile north of Highway 62 in an area of existing land uses that have included oil and gas extraction, potash mining, and cattle grazing activities. The habitat in the area is heavily grazed desert scrub with honey mesquite (Prosopis glandulosa) and broom snakeweed (Gutierrezia sarothrae) being the dominant plant species observed during the site visit.
The project area is not suitable habitat for lesser-prairie chicken (Tympanuchus pallidicintus),
which is identified as a species of greatest conservation need (SGCN) in New Mexico, and is a currently under review for federal listing under the Endangered Species Act. However, the project area is adjacent to Crucial Habitat Category 3 (Modeled Habitat Zone) as identified in the Lesser Prairie-chicken Southern Great Plains Crucial Habitat Assessment Tool (http://kars.ku.edu/maps/sgpchat/). The EIS should address potential impacts to lesser prairie-chicken and its habitats surrounding the project footprint.
Important habitat for dunes sagebrush lizard (Sceloporus arenicolus) is located approximately four miles north of the proposed CIS Facility. The dunes sagebrush lizard is listed in New Mexico as a SGCN, and as endangered under the New Mexico Wildlife Conservation Act. While the Department does not anticipate any significant impacts to dunes sagebrush lizard, potential impacts should be addressed in the EIS.
Ms. Jill Caverly 31 August 2018 Page Tetra Tech, Inc., conducted a biological survey on 14 October 2016, in order to collect a biological representation of the area. The Department recommends that a more thorough biological survey of the project footprint (and a one-half mile buffer area) be conducted to better asses the range of wildlife species that may occur within the project area, and potential wildlife impacts from the proposed CIS Facility. For guidelines on conducting wildlife presence and diversity inventories at a proposed project site, please consult the Departments Baseline Wildlife Study Guidelines at: http://www.wildlife.state.nm.us/download/conservation/habitat-handbook/project-guidelines/Wildlife-Baseline-Study-Guidelines-and-Appendix.pdf.
Ephemeral saline lakes are rare features on the landscape and, when holding water, provide important shoreline habitat for some avian species. Saline lakes should be protected from disturbance and an adequate buffer zone should be established. There are two ephemeral saline lakes that are located near the project footprint, Laguna Plata and Laguna Gatuna.
Laguna Plata is located approximately three miles from the proposed CIS Facility and contains known nesting habitat for snowy plover (Charadrius nivosus), which is considered an SGCN in New Mexico. Laguna Plata is also under consideration by the Bureau of Land Management for designation as an Area of Critical Environmental Concern. Laguna Gatuna is located immediately east of the proposed CIS Facility, and a rectangular portion of the proposed project area boundary extends across the southern portion of the salt lake. The Department understands that proposed project does not include any disturbance to this area, but requests clarification regarding its inclusion within the project footprint. Laguna Gatuna has historically been utilized by the oil and gas industry for the disposal of produced brine fluids. The area contains contaminated sediments (USFWS 1999) associated with these land use activities, and migratory bird deaths have been documented there in the past. This important habitat area should be addressed for any potential effects from the proposed project. The Department also recommends that the NRC require appropriate remediation and restoration actions for Laguna Gatuna and Laguna Plata as part of the permitting process.
The EIS should include impacts to wildlife that could occur during the construction phase of the proposed project. This would include seasonal restrictions (1 March through 1 September) on ground disturbance and vegetation removal activities that would impact migratory bird nests, eggs or nestlings. It should also address potential trapping hazards to wildlife from open trenches and steep-sided pits. The Department is available for consultation regarding these matters, and can provide trenching guidelines in order to minimize impacts to wildlife.
Thank you for the opportunity to review and comment on the proposed HI-STORE Consolidated Interim Storage Facility Project. If you have any questions, please contact Ron Kellermueller, Mining and Energy Habitat Specialist, at (505) 476-8159 or ronald.kellermueller@state.nm.us.
Sincerely, Chuck Hayes, Assistant Chief Ecological and Environmental Planning Division cc: USFWS NMES Field Office George Farmer, NMDGF Southeast Regional Habitat Biologist Grant Beauprez, NMDGF Lesser Prairie-chicken Biologist Erin Duvuvuei, NMDGF Non-game Ornithologist Leland Pierce, NMDGF Herpetologist
Ms. Jill Caverly 31 August 2018 Page Literature Cited U.S. Fish and Wildlife Service [USFWS]. 1992. Environmental Contaminants in Water, Sediment, and Biological Samples from Playa Lakes in Southeastern New Mexico - 1992.
USFWS Region 2 Environmental Contaminants Program, Albuquerque, New Mexico.