ML20179A355
| ML20179A355 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/25/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20179A355 (6) | |
Text
From: Barney Magrath <barney.magrath@gmail.com>
Sent: Thursday, June 25, 2020 4:27 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] my written comments for the Draft EIS...
Attachments: Holtec - Draft EIS comments - ver 2 - 25jun2020.docx Hello Friends - I would like to provider written comments for the proposed Holtec/New Mexico project.
Specifically the Draft EIS. My comments document is attached.
Thank you for your time and consideration.
Peace Out Barney Magrath
>>808.937.3615<<
>>19 Encantado Loop<<
>>Santa Fe, New Mexico, USA<<
Your vote is your voice
Federal Register Notice: 85FR16150 Comment Number: 2095 Mail Envelope Properties (CAOvjA=XAEqmXkubjBW8T4zt2iORVJxM1qMpWLZ1n_cso1h0ZZA)
Subject:
[External_Sender] my written comments for the Draft EIS...
Sent Date: 6/25/2020 4:26:59 PM Received Date: 6/25/2020 4:27:12 PM From: Barney Magrath Created By: barney.magrath@gmail.com Recipients:
Post Office: mail.gmail.com Files Size Date & Time MESSAGE 363 6/25/2020 4:27:12 PM Holtec - Draft EIS comments - ver 2 - 25jun2020.docx 17297 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Comments on the Holtec Draft EIS 24 June, 2020 To: NRC From: Barney Magrath (Nuclear activist who Santa Fe County, New Mexico)
Hello Friends - Thank you for hosting a webinar yesterday, Tuesday 23 June 2020, on the Draft EIS for the Holtec CISF located near Carlsbad, New Mexico.
And thank you for all your hard work writing the EIS and putting it out there. I dont know how you do it.
I have been following this issue for years. In fact I testified at a NRC scoping meeting on this project, summer of 2018, in Albuquerque, in the convention center. My testimony relied on a study, by Alison McFarlane, that concluded that the high-level waste was safer where it was than it would be if transported to a repository.
(I know that a Safety review will be conducted separately so I expect this point to come up again and it is not relevant today for these comments.)
Today I am writing because I have a chance to comment on the Draft EIS and the webinar. Thanks in advance for this opportunity.
You know I was a little disappointed that speakers could not focus on the task at hand. Instead of commenting on, and referencing page numbers in the Draft EIS we heard business leaders promoting the project, and trashing outsiders, and activists who redundantly recited every gripe in the book. I did appreciate state level politicians chiming in. I did NOT appreciate our national level politicians being absent. Who do they think they are?
Some good stuff was brought up but when someone deviates from the subject the moderator needs to gently remind them Thats NOT relevant, back to the subject please.
You remind them what the subject is and what we are there for.
Effective time management nuff said Okay enough about the webinar on to my comments.
I have four items I want to comment on that are in the EIS:
- 1) The Title, 2) The NRC licensing process, 3) The Radiological impacts, 4) Mitigation of Greenhouse Gasses
- 1) The Title of the Draft EIS:
Firstly: The word interim, meaning temporary, appears. Really? In 40 years when the lease is up I will either be in diapers or dead. Ill be 104 and I will have seen Halleys comet twice! Im not gonna kick anything down the road past my death let alone this project!
Get real, its permanent!
Secondly: The last three words in the title are and High Level Waste. This is a red flag if I ever saw one. I never knew that a small quantity of mixed-oxide fuel,MOX (Executive Summary, page xxi, line 6), was included. What is a small quantity? There are 16 tons of this stuff at Savannah River. Is this the small amount?
- 2) The NRC licensing process:
On page 1-6, it states that the licensing process started 30 March 2017 with an application, for a license, from Holtec. About 3 months later, 7 July 2017 the NRC accepted the application. Obviously this project is being fast-tracked. Obviously its all about the current administrations love of business and everything that goes along with it, read money. Obviously this project needs to be approved before administrations change. It is NOT about a permanent solution to a national problem.
- 3) The Radiological Impacts:
The Executive summary at the beginning of the Draft EIS has a section titled: Public and Occupational Health p. xliii, lines 24-36, heading Operations that gives numbers in sieverts of projected exposure when handling the canisters SNF. The handling of MOX is not addressed so apparently we are to assume it can be
handled like SNF? This is not something anyone should assume.
The projected radiological exposure to MOX needs to be spelled out.
- 4) Mitigation of Greenhouse Gasses:
This issue is important as it is difficult to explain. The old saying applies if it were easy everyone would be doing it:
Section 6 is titled Mitigations. If one delves into this section one will encounter two (2) tables, one devised by Holtec p. 6-6 and one devised by NRC p. 6-10. Each table is comprised on identical sections like Groundwater Resources, Surface Water Resources, Ecology, etc. I am focusing on the section Air Quality because I want to know what mitigations are planned for greenhouse gasses.
Long story short NRC recommends considering electric vehicles Holtec recommends NOTHING. Basically they are ignoring the issue of greenhouse gasses.
What are they ignoring? If one looks at p. 2-11, table 2.2-2, and the table that immediately follows, one can see that the project has projections of emissions during transportation and operations.
Furthermore it divides each table into different categories. If I did the math right I see that over the life of the project we can expect the project to contribute 1,323,255 tonnes of CO2 to the atmosphere.
And Holtec has no plans to mitigate this staggering number! (In fact if they need two concrete batch plants instead of one the number will be significantly higher.) This is preposterous and completely irresponsible.
It is a perfect example of Holtecs complete disregard of the environmental consequences of their plan.
Thank you for your time and consideration.
Most Cordially Barney Magrath