ML20143A000

Comment (46) of Susan Peirce Opposing to Holtec International HI-STORE Consolidated Interim Storage Facility Project

ML20143A000
Person / Time
Site:	HI-STORE
Issue date:	05/21/2020
From:	Peirce S - No Known Affiliation
To:	Office of Administration
References
85FR16150 00046, NRC-2018-0052
Download: ML20143A000 (1)

Text

Page 1 of 1 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 As of: 5/22/20 6:38 AM ADD: Jill Caverly Received: May 21, 2020 Status: Pending_Post PUBLIC SUBMISSION COMMENT (46)

PUBLICATION DATE: Tracking No. kah-h0s0-luds 3/20/2020 Comments Due: July 22, 2020 CITATION 85 FR 16150 Submission Type: Web Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0300 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0354 Comment on FR Doc # 2020-05690 Submitter Information Name: Susan Peirce Address:

Santa Fe, NM, 87506 Email: speirce@prodigy.net General Comment I am a New Mexicans who opposes this de facto permanent, surface storage, parking lot dump in my state.

NRC's time-limited focus on just 40 years of "temporary storage" is inappropriately, arbitrarily short, given Holtec's own admission in its license application to NRC that "interim storage" could persist for 120 years; in response to a Request for Information from DOE, Holtec admitted a CISF could operate for 300 years; and in NRC's own 2014 Continued Storage of Spent Nuclear Fuel Rule and Generic EIS, the agency acknowledged away-from-reactor ISFSIs (Independent Spent Fuel Storage Installations) could go on indefinitely (that is, forevermore). Institutional control could be lost over such long time periods. Failed containers could release catastrophic amounts of hazardous radioactivity directly into the surface environment, to blow downwind, flow downstream, bioconcentrate up the food chain, and harm people down the generations.

I protest NRC's woefully inadequate, to nearly non-existent, treatment of highly radioactive waste transport risks. This violates the long-established legal requirement under the National Environmental Policy Act (NEPA) that NRC take a "hard look" at the Holtec CISF proposal, including its inextricably linked high-risk transportation component, impacting most states in the Lower 48. (See the 2017 transportation route and shipment number documents posted online by the State of Nevada Agency for Nuclear Projects, its analysis of the same 2008 U.S. Department of Energy document that NRC itself cites as its excuse for not having to do a Holtec-specific transport analysis in 2020!)

https://www.fdms.gov/fdms/getcontent?objectId=09000064846693e1&format=xml&showorig=false 05/22/2020