ML20179A012
| ML20179A012 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/20/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20179A012 (4) | |
Text
From:
Judy Lukasiewicz <jsteel@cruzio.com>
Sent:
Saturday, June 20, 2020 1:04 AM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Comment against Holtec CIS Docket ID NRC-2018-0052 U.S. Nuclear Regulatory Commission (Holtec CIS)
RE: Comment against Holtec CIS Docket ID NRC-2018-0052
Dear,
Comment to US NRC on proposed HOLTEC Consolidated "Interim" Storage Facility Docket ID NRC-2018-0052 Extend the Comment Period//Hold Public Meetings ALL along transport routes Over 80 organizations are asking NRC to suspend all activities involving public input until the COVID-19 crisis is over and then allow 6 months for public comment or other interactions. I ask that the comment period on the proposed Holtec nuclear waste site be extended 6 months due to the continuing COVID-19 disruptions. I ask that public DEIS meetings be held in communities along the potential transport routes in New Mexico and Texas and other corridor states, especially in large urban areas including but not limited to Atlanta, Chicago, Cleveland, Dallas/Fort Worth, Detroit, Nashville, Minneapolis/St Paul, New York/Newark, Omaha, Philadelphia, Pittsburgh, San Antonio, and Saint Louis.
DEIS Violates National Environmental Policy Act by segmenting and not including Transport impacts The DEIS does not show all the potential routes through which waste would travel to get to the Holtec site in southeast New Mexico and dismisses the risks from transport even though this is essential to get waste to proposed temporary storage sites. The analyses done are completely inadequate relative to the substantial risks of these shipments through most states, over decades.
Thousands of shipments, each with more highly radioactive cesium than released from Chernobyl and more plutonium than released in the Nagasaki bomb would move on our roads, rails, waterways through most of the states and Congressional districts for DECADES. Each shipment has the capability of destroying the regions through which they move with radioactive contamination due to unavoidable accident or possible deliberate acts of terrorism and/or sabotage. Absent those threats, containers will continue to emit radioactivity because compete radioactive emission shielding would make the containers too heavy to move. Additionally, there will be more radioactive waste shipment transport miles, years and subsequent risks to move waste to a final site, which is not considered in the DEIS.
Violates Environmental Justice In light of the heightened awareness of institutional racism and the plight of impoverished communities in this country, I object to bringing the most deadly nuclear waste generated (i.e., more than 90% of the radioactivity in nuclear power and weapons waste) in the US to and through communities of color and
impoverished communities or "sacrifice zones." The trunk rail lines that will deliver most of the high level radioactive waste to Holtec are routed through older neighborhoods and core areas of American cities. Routine radioactive "shine," accidents or deliberate attacks would disproportionately impact poorer, minority communities. The Holtec/Eddy Lea area is largely Hispanic and has numerous other industrial facilities in the area with highly radioactive and other toxic chemical emissions, which exacerbate the impacts.
I support requests for providing all documents in Spanish.
Failure to Assess the Full Environmental Impacts if the Site lasts longer than 40 years or becomes permanent:
Analyzing the application for a 40 year license ignores the possibility of the waste staying there for much longer or indefinitely. 40 years is inappropriately and arbitrarily short, given Holtec's own admission in its application that "interim storage" could persist for 120 years and a statement by Holtec staff that it could be 300 years. This discrepancy in the application and the actual range of use projection is unacceptable and irresponsible.
Failure to Meaningfully Consider Alternatives, as required by law Rather than consider alternatives to moving waste across the country to a consolidated location, NRC only considered other consolidated locations. NRC did not analyze the option of NOT proceeding with consolidated storage and providing safer nuclear waste management at or near the generation sites, dismissing on and near-site storage options because they are not consolidated storage. This is especially remiss in that the consolidated storage on alternative sites, as well as at or near the generation sites, is illegal under federal law. This is double talk and avoidance of legalities is unacceptable. It is clear that safe radioactive nuclear waste storage is not foreseeable and not possible.
Failure to protect Water The DEIS fails to adequately assess the radioactive threats to water at and near the proposed site and during transport on and near water bodies across the country including the Great Lakes, Chesapeake Bay, rivers and oceans.
Inadequate Storage and Transport Containers Although NRC "certifies" containers, the irradiated fuel cannot be monitored, inspected, repaired or maintained. No containers will last for as long as high level waste fuel stays dangerous. There is no plan at the Holtec NM site for recontainerizing damaged and worn out containers, even though the site could inadvertently become the de facto permanent storage site. In absence of hazardous fuel pools, NRC must require dry transfer facilities so the irradiated fuel can be remotely moved to new containers as needed.
The inconsistent predicted lengths for interim storage period, from several decades, to a century, or centuries, or even de facto permanently (forevermore), timeframes would dangerously exceed the design and service life of all the containers.
Do not curtail the EIS process due to June 4, 2020 Executive Order
I do not believe that any emergency circumstances exist, which justify NRC gutting or bypassing NEPA, 42 U.S.C. § 4321 et seq. I oppose any NRC attempt to curtail or limit in any way a thorough, deliberative inquiry under NEPA into all environmental impacts likely to be caused by licensing, construction and operation of the Holtec Consolidated "Interim" Storage facility.
Sincerely, Sincerely, Ms. Judy Lukasiewicz 701 Happy Valley Rd Santa Cruz, CA 95065 (831) 423-4606
Federal Register Notice:
85FR16150 Comment Number:
2003 Mail Envelope Properties (1188937860.7519.1592629451450.JavaMail.tomcat)
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[External_Sender] Comment against Holtec CIS Docket ID NRC-2018-0052 Sent Date:
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