ML20162A262
| ML20162A262 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/10/2020 |
| From: | Singh K Holtec |
| To: | Andrea Kock Division of Fuel Management |
| Caverly J | |
| References | |
| 5025055 | |
| Download: ML20162A262 (3) | |
Text
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 5025055 P a g e l 1 June 10, 2020 Ms. Andrea Kock andrea.kock@nrc.gov Director, Division of Fuel Management U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Reference:
HI-STORE CIS Environmental Impact Statement Docket #:
72-1051 Holtec Project:
5025
Dear Ms. Kock:
We are thankful to the NRC for performing a rigorous review of our application and for running a sound public consultation process to ensure that the proposed HI-STORE Consolidated Interim Storage (CIS) facility would not have an adverse impact on the environment. We staunchly support public engagement in nuclear issues and have supported NRCs decision last May to extend the public comment period by 60 days. Holtec International would like to provide input on the matter of granting a second extension of the current ongoing public comment period on the Draft Environmental Impact Statement (DEIS) for the HI-STORE CIS prepared by the Commission.
Holtec opposes a second extension because it is highly unlikely to yield any enlightening input to the discourse on environmental impact and it would cause damaging delay to HI-STORE CISs licensing schedule. We present corroborative facts in support of our opposition in the following:
- 1.
Draft EIS Comment Process:
The draft EIS evaluates a wide variety of environmental impacts that might occur from the HI-STORE facility and concludes that it is recommended to issue an NRC license to Holtec to construct and operate a CISF for SNF at the proposed location. The draft EIS was made available for public comment on March 20, 2020 and was originally scheduled to close May 22 (60 days).
An extension has already been granted to extend the comment period an additional 60 days to July 22 (120 days total). The goal of the public comment period is to allow for interested stakeholders to provide the NRC any additional information that may be factually relevant to the environmental
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 5025055 P a g e l 2 impacts of the facility. Holtec believes that a further extension is unlikely to yield any enlightening input to the discourse on environmental impact. We note that, at this writing, the Commission has received 344 comments from private citizens and groups. Unfortunately, it seems that none of the comments point to any environmental consideration that the Staff may have overlooked. Recalling that 7,000 comments were received by the NRC in the environmental scoping process in 2018, virtually all submitted on a standard template, it is evident that the activists are capable of mobilizing large number of participants by savvy use of mass media. They are evidently using marginally interested citizens to bolster the decibel level of their noise. Their ability to mobilize evidently does not rely on having people travel from across the country. Therefore, we respectfully posit that the COVID-19 pandemic has not impaired their ability to provide comments. One round of extension granted to the process was a magnanimous gesture, the second extension, in our opinion, would only serve to facilitate the submission of emotionally charged opinion based comments rather than comments that are factually relevant to the environmental impacts of the facility. We also support conducting a web-based public discourse to facilitate the objective consultation that NRCs process contemplates. The unfortunate disruption to businesses that the COVID-19 virus has caused has highlighted the efficiency of meetings held on virtual platforms.
- 2.
Damage to the licensing schedule:
The proposed extension would delay the EIS completion period by three more months on a project which is widely viewed to bear upon our national interest. As you know, Holtec presently owns and is slated to acquire several nuclear power plant sites that are scheduled to be decommissioned and returned to unrestricted industrial use on the earliest possible date. These sites, most of them located in the populous northeast, have hosted carbon-free energy generation plants for many decades before being retired. Holtec is committed to the residents surrounding the nuclear plants it owns to perform the safe decommissioning of the site so it can be returned to productive use as soon as possible leading to economic development including tax ratables and jobs for the local community. We should recall that removing the used fuel from some 75 scattered sites across the country and to aggregate it into few manageable consolidated interim storage facilities has been the U.S. Governments announced goal since the days of the Obama Administration. Believing in our governments sincerity of purpose, we began the HI-STORE CIS to build on the arid plateau of New Mexico that will use our incomparably safe and below-the-ground storage system (HI STORM UMAX). To ensure that storage of used nuclear fuel and the facility itself is truly non-permanent (i.e., an avowedly interim installation), it has been configured to enable the stored canisters to be removed from the site with little effort.
Holtec Technology Campus, 1 Holtec Blvd, Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Document ID: 5025055 P a g e l 3 To fulfill the commitment to the host communities around nuclear plants the development of the interim storage facility on the earliest possible date is critical to them. Accordingly, the ability to repurpose the land at the decommissioned site without any radiological hindrance or limitation has been a core mission for our company. We have repeatedly reassured residents of our unwavering commitment to render the plant site in their midst free of used nuclear fuel and other unwanted nuclear waste. To fulfill our commitment, we have carried on with the HI STORE CIS project shouldering the entire financial burden ourselves (without any financial support thus far from the US Government). We believe it is our solemn responsibility to make every effort within our power to remove the fuel from the well-populated communities and bring it to the secure state-of-the-art HI-STORE CIS so that America keeps its long-standing promise to its citizens. Any delay in licensing of the project undermines our governments publicly stated position and our representations to the public. Therefore, we urge the NRC to consider time to be of the essence in this licensing evolution.
In closing, we should observe that remote consultation via the web already scheduled by the NRC is a much more suitable platform for public consultation because it eliminates the opportunity to potentially spread COVID-19 and provides a means for the public to comment directly to the NRC Staff. Embracing modern technology would be good for all of us.
Very truly yours, Kris Singh, President & CEO HOLTEC INTERNATIONAL cc:
John Tappert, NRC Pierre Oneid (Holtec)
Joy Russell (Holtec)
John McKirgan, NRC Stefan Anton (Holtec)
Jill Caverly, NRC Kim Manzione (Holtec)
Jose Cuadrado-Caraballo, NRC Ed Mayer (Holtec)
Chris Regan, NRC