Exhibit to Fasken and Pblro Combined Reply to NRC Staff'S and Holtec International'S Oppositions to Motion for Leave to File Amended Contention and Motion to Reopen the Record| ML20163A729 |
| Person / Time |
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| Site: |
HI-STORE |
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| Issue date: |
06/11/2020 |
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| From: |
Holtec |
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| To: |
NRC/OCM |
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| SECY RAS |
| References |
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| ASLBP 18-958-01-ISFSI-BD01, RAS 55706, Holtec International |
| Download: ML20163A729 (2) |
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Category:Legal-Pleading
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Exhibit to Fasken and Pblro Combined Reply to NRC Staff'S and Holtec International'S Oppositions to Motion for Leave to File Amended Contention and Motion to Reopen the Record
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2020-08-07
[Table view] |
Text
Exhibit 1 Holtec SAR1 Holtec ER2 Holtec DEIS3 ---------- -
recent records (1998 through 2005) from The Site is located in an area closest earthquake to MAGNITUDE 5.0 ON MARCH 26, 2020 the WIPP seismic monitoring network of low seismic hazard. (at 4- the proposed indicate the strongest events recorded 5); review of seismic CISFoccurred on OUTSTANDING NRC RAIS UNANSWERED BY annually in 1999, 2000, and 2002 through riskbased on (USGS 2009) & March 18, HOLTEC 2005 (typically of 2.5 to 4.0 magnitude) (Powers et al., 1978) 2012magnitude of 3.1 Justify not incorporating site-specific subsurface located about 50 miles west of the Site (at 3-23) geologic and geophysical properties through a site response analysis for development of the site-specific
[DBE][g]iven the lack of site-specific hazard development, [Holtecs] exceedance of [design basis earthquake (DBE)] should be justified4 potential future drilling on the Site, Holtec potential future drilling on the Holtec . . . is in OUTSTANDING NRC RAIS UNANSWERED BY has an agreement with Intrepid Mining LLC Site, Holtec has an agreement discussions with the New HOLTEC (Intrepid) such that Holtec controls the with Intrepid Mining LLC Mexico State Land Office mineral rights on the Site and Intrepid will (Intrepid) such that Holtec regarding an agreement The application should discuss the rationales for the not conduct any potash mining on the Site. controls the mineral rights on the to retire potash leasing conclusion that potash would not be extracted under (at 2-12) Site and Intrepid will not conduct and mining within the and around the site during the licensed life of the any potash mining on the Site. proposed CISF project project. (Id. RAI 2-12)
(at 3-2) area. (at 5-24)
Subsidence from mining creates voids that Risks from . . . subsidence. . . areas of distinct thickness of alluvial material sitewide and the cause collapse of strata above the mining are considered to be low (at subsidence the study existence of groundwater within the alluvium, both level (at 2-9); a few brine wells in Eddy 4-5). identified are located laterally and temporally, is insufficiently described in Countysuffered catastrophic collapse approximately 16 km the DEIS.principally due to.limited geotechnical causing sinkhole development at the [10mi] of the proposed characterization at the site; [Holtec] DEIS surface. (at 2-11); several examples in the CISF project (at 3-27). insufficiently characterizes the Chilne Formation Permian Basin of catastrophic subsidence as situated within the upper portion of the Dockum Group a result of oil field casing corrosion and and the probable importance of the Formation in dissolution of salt (at 2-9) monitoring the environmental impact of the CISF. 5 There are no active wells on the Site and There are no active wells on the There is one active there are no plans to use any of the plugged Site and there are no plans to use oil/gas well on the NO NEGATIVE EASEMENTS PRESENTLY ON and abandoned wells on the Site (at 2-3) any of the plugged and abandoned southwest portion of LEASES BELOW OR SURROUNDING SITE wells on the Site (at 4-2); Risks Section 13 that operates from. . . subsidence. . .are at minimum production considered to be low (at 4-5) to maintain mineral rights. (at 3-7) 1 Holtec SAR, Rev. 0H, Docket No. 72-1051, (March 30, 2019) (ADAMS Accession No. ML19163A062) (emphasis added).
2 Holtec ER, Rev. 7, Docket No. 72-1051 (August 2019) (ADAMS Accession No. ML19309E337) (emphasis added).
3 Holtec DEIS, NUREG-2237 (March 2020) (ADAMS Accession No. ML20069G420), Holtec DEIS (emphasis added).
4 NRC Letter to Holtec, Request for Additional Information, Part 5 (Nov. 14, 2019), (ADAMS Accession No. ML193322C260) (emphasis added).
5 New Mexico Environment Dept Letter to N.R.C. Div. Rulemaking, Env.and Financial Support re Holtec - NRC DEIS - NMED Review and Comment (Dec. 16, 2019) at 2.1, 2.2 (emphasis added)..