ML20197A175

Comment (2158) E-mail Regarding Holtec-CISF Draft EIS

ML20197A175
Person / Time
Site:	HI-STORE
Issue date:	07/14/2020
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR16150
Download: ML20197A175 (8)

Text

From:

Joan Brown,osf <joankansas@swcp.com>

Sent:

Tuesday, July 14, 2020 3:57 PM To:

Holtec-CISFEIS Resource Cc:

joan m brown

Subject:

[External_Sender] ID NRC-2018-0052, Attachments:

NRC Holtec faith letter(1)-j.docx Blessings this day, I submit a letter from faith leaders who do not support the transportation and storage of high level nuclear waste to the proposed Holtec site in South East New Mexico.

Please accept this letter and we welcome any response.

Peace and good, Sr. Joan Brown,osf Joan Brown,osf Executive Director New Mexico Interfaith Power and Light (NMIPL)

New Mexico Interfaith Power and Light PO Box 27162 Albuquerque, NM 87125 505-266-6966 www.nm-ipl.org info@nm-ipl.org 1004 Major Ave. NW.

Albuquerque, NM 87107 joanbrown@nm-ipl.org There is no inner world without the outer world. Thomas Berry, Author of The Great Work This email has been checked for viruses by Avast antivirus software.

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Federal Register Notice:

85FR16150 Comment Number:

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New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125 www.nm-ipl.org**info@nm-ipl.org**505-266-6966 June 2020 Office of Administration Mail Stop: TWFN-7-A60N ATTN: Program Management Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE:

Docket ID NRC-2018-0052, Holtec Internationals Application to Construct and Operate a Consolidated Interim Storage Facility (CISF) for Spent Nuclear fuel in New Mexico NRC:

As faith leaders in communities of New Mexico, we are committed to promoting and safeguarding life and wellbeing for all people, communities, wildlife and the natural environment. The gifts of creation are sacred trusts, intended for the wellbeing of the entire life community and held thus within all religious traditions. We also take seriously the science of Climate Change, evident in record breaking temperatures, wild fires, flooding, sea level rise, extreme weather events and changes in the surface processes of the planet. Human choices and actions, done without regard for the common good and care of Earth, will have devastating consequences for generations to come.

With this enhanced sense of urgency and responsibility, we strongly oppose NRCs licensing of Holtecs proposed consolidated interim storage facility in South Eastern New Mexico, for the most lethal, high level radioactive waste generated by nuclear reactors. We do not want the death-dealing radioactive contamination of our land, aquifers, air, endangering the health of communities, vegetation, wildlife, livestock, and the life of present and future generations.

While solutions to this problem are needed, we understand that leaving spent fuel rods from nuclear power plants in place where they are currently safely stored is the correct action until the United States government can responsibly address another solution. In addition, we believe there are large environmental justice concerns in placing this site in South Eastern New Mexico and initiating train travel with nuclear hazardous waste that travels on railways mostly through economically poor communities of color.

We offer the other following concerns which include factual reasons for our opposition to the Consolidated Interim Storage Facility:

1) Holtec Thin-Wall Canisters, containing high level radioactive waste, have serious engineering design flaws.

Holtec HI-STORM UMAX canister storage and all other thin-wall ( 1/2 - 5/8) canister storage systems have significant defective engineering design flaws. These thin-wall canisters are:

-vulnerable to short-term cracking and major radioactive leaks

-cannot be inspected inside or out

-cannot be repaired or replaced: millions of curies of radiation would be released from even a microscopic crack

-cannot be monitored or maintained to prevent radioactive leaks: no warning before radiation leaks from thin canisters

-There is no plan for failing canisters.

NRC admitted in their November 28, 2018 Inspection Report that at the San Onofre nuclear plant Holtecs thin wall canisters are all damaged.

At the Koeberg nuclear plant in South Africa Holtecs thin-wall canisters cracked and leaked in 17 years.

2) Overweight, untested nuclear fuel casks transported by rail pose dangerous threats to millions of people, thousands of communities and the natural environment.

Loaded US railway car maximum weight in the U.S. is 286,000 lbs (143 US tons, 130 metric tons) for 4 axle cars.

Holtec HI-STAR 190 transport cask is heavier than all other cask systems with bounding loaded weight of 450,000 lbs (225 US tons, 204 metric tons).

Given the poor condition of roads, rail and bridge infrastructure, the national transportation risks endangering every community along the route, posing threats to millions of people, thousands of communities and scores of major cities near railways in 44 states.

There is no assurance of incident-free transportation for 10,000 railway car shipments passing communities during a 20 year period. Each thin-wall canister contains spent fuel rods and as much highly radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.

The DOE found that a severe accident involving one radioactive waste cask would contaminate a 42 square mile area, with cleanup costs exceeding $620 million in a rural area; up to $9.5 billion in an urban area.

NRC Management approved Holtecs transport cask by ignoring NRC engineers critical safety concerns, NRCs own evidence and NRCs transport regulations.

On May 19, 2018 in Alexandria, VA, 30 freight cars of the CSX train came off the tracks and crashed to the ground below after a partial railway bridge collapse. Fortunately, the 167-car freight train was not carrying hazardous cargo.

3) Holtecs HI-STORM CIS storage systems flawed design is not safe in New Mexico environment.

The HI-STORM CIS Storage Systems above-ground concrete lid requires air vents for convection cooling of the nuclear fuel waste. Water, corrosive particles and small creatures can enter through air vents and initiate microscopic cracks on the canisters. Particles continue to build up, increasing corrosion cracking risks.

The concrete structure cannot be adequately inspected for structural problems, yet is subject to higher corrosion from moisture, corrosive soils and aging.

There are no drains in the bottom of the concrete holes. Water, soil and other materials can build up and block the air vent pipe opening near the bottom of the concrete hole. If this opening is blocked, canister and nuclear fuel can overheat. The NRC admits that if water enters the canister, a nuclear chain reaction can occur.

Annual monsoon precipitation in southern New Mexico from June to September causes forceful,

concentrated rainfall, potential flash flooding, and lightning that challenge the integrity of the storage system. Increasingly high temperatures in New Mexico due to climate change add to dry air environments that can trigger stress corrosion cracks in thin-wall canisters.

A canister breach, causing a nuclear explosion in New Mexico, would impact and contaminate the Ogallala aquifer, underground vital water source for eight states.

The proposed Holtec plan would consolidate up to 100,000 metric tons from all US nuclear power reactors and temporarily store 10,000 nuclear fuel canisters in southeastern New Mexico for 20 to 200 years. The waste would allegedly move again, but if no future permanent site is found, it could remain in the interim storage site indefinitely, though it is not designed for permanent isolation.

4) The proposed Holtec CIS site threatens to contaminate and undermine the agricultural, ranching and dairy industries of Southeastern New Mexico.

To face challenges of increasing Climate Change, promotion of local sustainable food production is essential for all communities. Viewing land as valueless and disposable for a nuclear waste dump site is morally and ethically unacceptable.

Holtecs proposed CIS site in this region of economically successful dairy and agricultural production would undermine and destroy the environmental health, safety and protection necessary for continuation of these sectors vital to New Mexicos economy. The publics trust in the safety of products will be undermined by possible contamination of soil, water and air from the radioactive storage site in the area.

Agriculture, ranching and dairy production are major industries in Lea, Eddy and Chavez counties as reported in 2018:

Lea County - 555 farms with 1,938,231 acres devoted to farms, ranches and dairies.

Eddy County - 507 farms with 1,087,902 acres given over to farms, ranches and dairies.

Chavez County - 560 farms with 2,318, 413 acres comprised in farms, ranches and dairies.

In these three counties, over 5 million acres are devoted to farms, ranches, dairies, livestock, field crops and vegetable growing.

New Mexicos total value of agriculture sector production in 2018 was $3.17 billion. The dairy industry, which is the leading commodity in the state, was $1.21 billion in milk sales in 2018.

Thousands of jobs and small businesses are dependent on the agriculture, ranching and dairy sectors in the region. All this revenue would be threatened if southeastern New Mexico becomes the nations high level radioactive waste dump site.

In Lea, Eddy and Chaves counties, the primary water supply source is from the Underground Water Basin, drawing from the Ogallala Aquifer. Any potential radioactive release accident could result in a disaster similar to Chernobyl or Fukushima, threatening all life in the region, including contamination of the Ogallala Aquifer, the major water source for eight states.

5) Holtecs proposed interim storage site is a non-solution, postponing long term strategies and wasting resources needed for permanent safe storage of high level radioactive waste.

The Holtec Plan is an ill-fated experiment, a temporary, stop-gap measure that does nothing toward a long-term strategy for safe storage of the nations high-level nuclear waste that will protect public safety and the natural environment. A stop-gap, temporary plan is not a solution to the real challenge. It does not provide the required long-term solution of verifiably safe, permanent storage of lethal radioactive waste from 98 nuclear power reactors in the U.S.

According to government statistics, 36 nuclear power plants in the U.S. have been or are in process of being decommissioned. Two unfinished nuclear reactor plants in South Carolina have been abandoned, after an investment of $9 billion dollars. Alternative, long term strategies are needed to utilize extensive, fenced-in sites at shuttered, high-security nuclear power plants and two uncompleted nuclear power plants for permanent safe storage of the nations lethal nuclear waste.

Potential threats from Holtecs Consolidated Interim Storage Facility to the life, health, and wellbeing of thousands of communities, as well as the natural environment across the United States urge us to raise moral, ethical and environmental justice issues, underscored by Pope Francis urgent appeal:

Each year hundreds of millions of tons of waste are generated, much of it non-biodegradable, highly toxic and radioactive. The earth, our home, is beginning to look more and more like an immense pile of filth. Frequently no measures are taken until after peoples health has been irreversibly affected. Here we see how environmental deterioration and human and ethical degradation are closely linked. As a result, whatever is fragile, like the environment, is defenseless before the interests of a deified market, which become the only rule.

(Laudato Si 21;56)

Within the larger context of global climate change, we urge serious reflection and consideration of the proposed Holtec project. Please take action to ensure that all the concerns for the risks of this project are included in open public hearings and decision making.

Thank you for consideration of our concerns on this ethical and moral challenge.

Faith Leaders Archbishop John Wester, Archbishop of the Catholic Archdiocese of Santa Fe, New Mexico Bishop James Wall, Bishop of Gallup, New Mexico Diocese Bishop Peter Baldaccino, Bishop of Catholic Diocese of Las Cruces, New Mexico Rev. Bill Lyons, Southwest Conference of the United Church of Christ Sr. Joan Brown,osf, Executive Director, New Mexico Interfaith Power and Light, Albuquerque, NM Sr. Rose Marie Cecchini, mm Director, Office Life, Peace, Justice and Creation-Catholic Charities, Gallup Vicki Trujillo, Executive Director, Catholic Charities of Gallup, Inc, Gallup, NM Brooks Berndt, Minister of Environmental Justice, United Church of Christ Cheryll Felder, President - NM Conference United Methodist Women, New Mexico Rabbi Harry Rosenfeld, Congregation Albert, Albuquerque, NM Reverend Gary Kowalski, Unitarian Congregation, Taos, NM Sr. Geneal Kramer OP, Adrian Dominican, Spritual Director/Retreat Leader, St. Therese, Albuquerque Rev. Carolyn W. Metzler, Spiritual Director, Living School for Action and Contemplation, Albuquerque Rev. Anne Morawski, Global Mission Associate, Evang. Lutheran Church in America, Albuquerque, NM.

Rabbi Nahum Ward-Lev, Santa Fe, NM.

Rev. Dr. Stephen J. Miller, retired Disciples of Christ pastor, Albuquerque, NM Rev. Dr. David Wasserman, HR, Presbyterian Church (USA), Albuquerque, NM Rev. Erica Lea-Simka. Pastor, Albuquerque Mennonite Church, Albuquerque, NM

Rev. Roger Scott Powers, Pastor, St. Andrew Presbyterian Church, Albuquerque, NM Rev Sue Joiner, First Congregational United Church of Christ, Albuquerque, NM Marlene Perrotte, rsm, Sister of Mercy of the Americas, Albuquerque, NM Rev. Nicholas King, Mennonite Pastor, Carlsbad, NM Rev. Anita Amstutz, Mountain States Mennonite Conference, Albuquerque, NM Rev. H. Blaine Wimberly, Zia Methodist Church, Santa Fe NM Leland H. Bowen, PE (Earth Care Fellowship, former chair, Las Placitas Presbyterian, Placitas, NM Rev. Jean Siegfried Darling, Min. Emerita, Peoples Church Chicago, Co-Chair, UU Santa Fe Enviro. Justice Patricia Sheely, lay leader, United Methodist Church, Gallup, NM Rev. Dr. G. F. Schott, Ph.D., Min. of Word & Sacrament, Evan. Lutheran Church America, Santa Fe, NM Sr. Elizabeth Racko, DC, Prison Chaplain, Gallup Diocese Gallup, NM Charlotte Smith, Bahai leader/Board Representative NM Interfaith Power and Light, Albuquerque, NM Rev. Greg Kennedy, Sr. Pastor, Central UMC, Albuquerque, NM Rev. Edward Barlow, Ret. UMC clergy, Community UMC in Ruidoso, NM Rev. Talitha Arnold, Senior Minister, The United Church of Santa Fe, Santa Fe, NM Sister Marlene Kochert, Pastoral Ministries, St. Mary Mission, Tohatchi, NM Kathleen Mezoff M.D., Presbyterian Elder, Gallup, NM Rev. Elizabeth McMaster, ret., Unitarian Universalist, Albuquerque, NM Rev. Lee Walters, interim co pastor, Westminster Presbyterian Church, Santa Fe, NM Reverend Tiffany Curtis, Minister, First Christian Church, Santa Fe, NM Ann Porter, Morning Light Sangha, Gallup, NM Fr. Jeremiah C. Griffin, Rector of St. Chad's Episcopal Church, Albuquerque, NM Fr. Warren Broussard, SJ, Pastor, Immaculate Conception Church, Albuquerque, NM Fr. Larry Bernard, O.F.M., Pastor, San Diego Mission, Jemez Pueblo, NM Rev. Karen Bash, United Church of Christ, Albuquerque, NM Anner-Bolieu, Deacon (Ret.), Good Shepherd Mission Church, Episcopal Church of Navajoland Joan Rieck, Teacher, Sanbo Zen Zendo, Albuquerque, NM Rev. Loreli Kay, Pastor, Westminster Presbyterian Church, Gallup, NM Betsy Windisch, Facilitator, Gallup Interfaith Community, Gallup, NM Henry Shukman, guiding teacher at Mountain Cloud Zen Center in Santa Fe, NM Rev. Harry W. Eberts, Pastor, First Presbyterian Church of Santa Fe, Santa Fe, NM Rabbi Neil Amseych, Congregation Beth Shalom, Santa Fe, NM Rev. Pamela Shepherd, Taos United Community Church, Taos, NM Rev. Judith Marshall, Unity Spiritual Center Albuquerque, Albuquerque, NM Rt. Rev. Joel P. Garner. O.Praem., Abbot.Santa Maria de la Vid Abbey, Albuquerque, NM Rev. Debra Jimenez, Pastor, Trinity Lutheran Church, Hobbs, NM Sr. Rene Backe, CSA, Delegate for Religious, Gallup Diocese, Gallup, NM Judy Traeger, Lay Leader, St. John the XXII Parish, Albuquerque, NM Rev. Martha Singleterry, Pastor, St. Peter Lutheran Church, Carlsbad, NM Rev. Dr. Bert Scott, United Methodist, Albuquerque, NM Kevin Bean, Chair, Creation Care Com., Saint John the XXIII Catholic Community, Albuquerque, NM

Sr. Maria Isabel Galbe, Assumption Sister, Chaparral, NM Rev. Gene Harbaugh, Presbyterian, Carlsbad, NM Linda Popelish, member Morning Light Sangha, Gallup, NM Rabbi Neil Amswych, Temple Beth Shalom, Santa Fe, NM