ML20189A547
| ML20189A547 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/04/2020 |
| From: | Kipen E, Kipen K - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00062, NRC-2018-0052 | |
| Download: ML20189A547 (2) | |
Text
PUBLIC SUBMISSION As of: 7/7/20 1:00 PM Received: July 04, 2020 Status: Pending_Post Tracking No. 1k4-9hmb-sg8c Comments Due: September 22, 2020 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-0371 Comment on FR Doc # 2020-05690 Submitter Information Name: Ken and Ethel Kipen General Comment We are strongly opposed to the Holtec storage proposal because the site is located near or on two lagunas or playa lakes:Laguna Gatuna and Laguna Plata. Lagune Plata is an archaeological district that has been extensively studied for decades. Two sites near Laguna Gatuna, where thenuclear waste is proposed to be stored, are listed on the National Register of HistoricPlaces. Archaeologists have found a plethora of evidence of the Jornada Mogollonpeople, dating from 200 AD, 700 AD, and 1200 AD. More than 200 archeological sitesare located within six miles of the proposed nuclear waste dump. Laguna Gatuna, whileoften dry, fills with water after monsoon rains, attracting a variety of wildlife and huntersfor millenia. The Hopi and Mescalero Apache nations have identified the area asculturally significant to them, and the Hopi nation has informed the NRC that traditionalcultural properties could be adversely affected if this project proceeds. The site whereHoltec wants to dump tens of thousands of tons of radioactive waste has profoundhistoric value and significance.5. Threats to Water & WildlifeThe impact of this forever deadly nuclear waste would have devastating consequenceson wildlife including threatened species that rely on the lagunas for drinking waterand surrounding area as a critical habitat, including the Lesser Prairie Chicken, and theDune Sagebrush Lizard. Agencies such as U.S. Fish & Wildlife, New Mexico Game &Fish, the Environmental Protection Agency (EPA) and New Mexico Environment Dept(NMED) have all gone on record attesting to the significance of Laguna Gatuna for migratory birds, and have argued that it should be designated permanently as a Waterof the United States (WOTUS), which would make it eligible for protection under theClean Water Act.6. Threats from Transporting Irradiated Nuclear FuelNot only New Mexico would be adversely impacted by the Holtec project: allcommunities along the transportation routes between nuclear power plants andthe Holtec proposed site would be threatened by radiation from the rail cars, andfrom the devastating financial and environmental damage if an accident or act of maliceshould occur. Studies have shown that one accident is likely to occur for every 10,000shipments. It is irresponsible and dangerous for NRC to avoid inclusion of Page 1 of 2 07/07/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064847265ce&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (62)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
thesemammoth risks and liability in its DEIS for Holtec's application.7. Holtec's Project is IllegalFinally, under current U.S. law, this project is illegal. The Nuclear Waste Policy Act of1982, as amended, does not allow the federal government to take title to the high levelradioactive waste until a permanent geologic repository is operating. So the federalgovernment cannot pay for transportation and storage of the waste as Holtec wants.The license cannot be issued until either a permanent repository is operating, or U.S.law is changed.For all the above reasons and more, I declare that the DEIS for Holtec's application isinadequate and further that the license for a high level radioactive waste storage facilityshould be denied. In conclusion, high level nuclear waste from nuclear power plantsaround the U.S. should not be brought to New Mexico-it should be isolated on or nearthe current site until there is an environmentally just and scientifically sound option is available.Sincerely, Ken and Ethel Kipen Ashfield MA USA Page 2 of 2 07/07/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064847265ce&format=xml&showorig=false