ML20211M197
| ML20211M197 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/27/2020 |
| From: | Small S - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00068, NRC-2018-0052 | |
| Download: ML20211M197 (4) | |
Text
PUBLIC SUBMISSION As of: 7/29/20 11:41 AM Received: July 27, 2020 Status: Pending_Post Tracking No. 1k4-9i1r-zo20 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-0377 Comment on FR Doc # 2020-05690 Submitter Information Name: Sue Small Address:
7 Arnold Court los lunas, NM, 87031 Email: to_suesmall@hotmail.com Organization: sue small General Comment See attached file(s)
Attachments holtec 7 27 2020 regdotgovonline Page 1 of 1 07/29/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064847abb17&format=xml&showorig=false SUNSI Review Complete Template =
ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (68)
PUBLICATION DATE: 3/20/2020 CITATION 85 FR 16150
July 27, 2020 NRC/Holtec New Mexico CISF NRC 2018-0052-0300 comments The NRC/BLM Consolidated Interim Storage Facility (CISF) project proposed for New Mexico is fraught with problems insufficiently addressed by the Draft EIS (NUREG-2237) and issues inappropriately excluded from this Draft EIS.
There is stalled progress toward a national long-term repository for spent nuclear fuel and high level nuclear waste. To propose the CISF as a 40 year short term (or 120 years with extensions) repository is providing a default permanent site for this national nuclear waste to be dumped in New Mexico.
Note the following quote:
Until there is an idea of a long-term repository, said Maria Korsnick, CEO of the Nuclear Energy Institute, at a recent Senate hearing, anybody that raises their hands for that consolidated interim storage [site] is, de facto, the long-term site.
(As reported:
https://www.latimes.com/california/story/2019-07-27/san-onofre-nuclear-waste-disposal )
The phased CISF project would start with a 40 year license for Phase I of 500 canisters, 8,680 metric tons of uranium with daily delivery via the United States railroad network of 1.4 shipments per day; then enlarging with 19 expansions to 10,000 canisters of spent nuclear fuel (SNF) and high level waste on privately owned acreage in southern New Mexico, currently owned by Eddy-Lea Energy Alliance (EIEA) with planned land sale and transfer to Holtec.
As the transport casks are not intended for long-term disposal in a repository, I have not found plans mentioned in the DEIS for their disposal in event of possible contamination from the SNF canisters they enclose. Rail shipping SNF from nuclear power plants through American communities occasions many possible incidents involving damage to the transport casks and storage canisters; and with the stated policy of return to sender any damaged goods, that just enlarges the problem. This return to sender policy is another example of the falsehoods within the DEIS, thus repository storage of damaged transport & storage devices must be anticipated and fully planned.
Upon arrival at the CISF site, SNF would be handled by personnel who will be exposed to radiation.
Unloading and transfer of the SNF canister from the transportation cask, placement into a transfer cask, and then SNF moving onto a transporter which will then move to yet another site where removal of the SNF from the transfer cask entails just one more occasion for accidents and exposure of personnel to unacceptable radiation exposure risks. It bears mention that DEIS 4.3.1.2.2.1 presents an incident free exposure associated with SNF transportation of an annual dose of 5mSv [500mrem] vrs a lower limit of 0.05 SV [5 rem]; however, rail traffic seldom runs on a timely basis without delays, derailments, or accidents, so all radiation exposure must account for occasions of intense exposure v annual exposure; and the lower exposure limit must be championed and used.
Additionally, within section 4 of the DEIS, exposure incidents and associated mitigation measures do not include events which can happen away from the storage units, at sites such as the rail spur, the
offloading areas, the cask & canister exchange areas, and the transfer process. This incomplete addressing of accident and mitigation invalidates the DEIS coverage of such an important topic of accident mitigation.
Proposing the NM Holtec CISF as an interim step while there is no chosen, sited, or licensed national permanent repository is a falsity that cannot be ignored just because the DEIS has stated it's not to be studied. Limiting the scope of this critical DEIS by choice is not a convenience the state or the nation can accept. The exclusion of this permanent repository topic invalidates the DEIS.
New Mexicans cannot accept the exclusion by this NRC DEIS of our history with nuclear energy and subsequent contamination. We have experienced the Church Rock tailings spill, continuing uranium mining and milling legacy land/water contamination; negative human and livestock radiological effects, downwinders, and more. This history will not be overlooked by a federal agency as it seeks to add to our state's challenges.
Most of our national rail network is in need of major infrastructure repair; nowhere is that more true than in New Mexico. The required improvements to the rail network cannot be excluded when considering the cost/benefit of this project. Foisting necessary infrastructure improvements onto states, communities, or other commercial entities cannot be used to give a false benefit boost to this Holtec CISF project. When one considers that states are statutorily responsible for protecting the public during radiological transportation accidents, rail transport is not a an economic boon for any entity beyond the NRC applicant for this CISF project. If the Holtec CISF functions as the purported temporary storage site, more of the same SNF handling, and more new rail traffic would then necessitate more movement of these deadly materials back across New Mexico and our nation to wherever permanence is found.
On the issue of cost benefit analysis, it appears the monetary analysis of SNF storage on site vrs CISF has been performed by Holtec, and the NRC has used this company's data to arrive at conclusions which may not be valid. Especially since the Hardened Onsite Storage System (HOSS) and the Hardened Extended-Life Local Monitored Surface Storage (HELMS) options were excluded from this NRC DEIS, the Holtec provided cost benefit calculations cannot be accepted.
Section 8 of the DEIS negates any attempt at estimating costs of accidents specific to the CISF since the NRC safety review has not identified what they consider credible accidents. So, naming no accidents means no safety review, thus no costs associated with accidents. This defies logic as well as invalidating the DEIS.
Holtec references on lines 13-16, page 8-6:
Holtec has proposed a license condition addressing liability and financial assurance arrangements with its customers that would be applicable to events occurring during CISF operations, which the NRC staff will consider in its safety review.
Since the nuclear industry liability is shifted to and paid for by taxpayers through the Price-Anderson Act, it's apparent that there's little to lose for Holtec as a private company in event of an accident.
Costing out of accidents must be included in any DEIS for the CISF.
Laguna Plata, Laguna Gatuna, and other playas in this major avian flyway and associated areas are
important for 300+ species of birds as documented by US Fish & Wildlife. There are areas Areas of Critical Environmental Concern (ACEC), animal species of Endangered, Threatened, and of Concern designations which will be affected by this facility, the increase of rail traffic, and the associated development on crucial habitat; and by any chemical or radiological exposure. Along with continuing climate change, loss of habitat and ephemeral water sources can spell extinction for many species.
Since the CISF would be on private land, the Lesser Prairie Chicken would lack any protection, although it's in precarious survival mode; even the limited BLM timing protections would not apply.
Consolidating so many nuclear related sites in this New Mexico corner is a poor strategy for preventing or allaying devastating radiologic impacts from either accidents, geologic events, or terrorism. As listed in section 5 of this DEIS, sited in the same area are the Waste Isolation Pilot Plant (WIPP), the National Enrichment Facility (NEF), and a projected depleted uranium plant (FEP/DUP). Holtec CISF would add to the target. Nearby, across the state line in Texas, are two radioactive waste storage and disposal sites operated by Waste Control Specialists (WCS), with its other NRC application for yet another CISF for SNF. The NRC is also entertaining a current application from Eden Radioisotopes for siting and construction of a 2 megawatt nuclear reactor in this same southeastern part of our state.
Glaring environmental justice issues arise in light of this apparent national sacrifice zone.
I would remind the NRC and others that the Governor of New Mexico, the New Mexico State Land Commissioner, the Cities of Albuquerque, Lake Arthur, Jal, Las Cruces, Gallup, Belen, San Antonio, Denton, Midland; the counties of Bernalillo, Santa Fe and McKinley, Bexar, Dallas, Midland, Nueces, El Paso; the Churchrock Chapter of the Navajo Nation, the Navajo Nation Dine' Uranium Remediation Advisory Commission, the All Pueblo Council of Governors, and the Midland Chamber of Commerce have resolved against this Holtec CISF.
The use of Holtec supplied data (Holtec, 2019) as referenced on lines 29-41, page 8-7 to arrive at the higher cost of on site storage of SNF through the No Action alternative compared to the Holtec CISF storage is prejudicial. Considering the No-Action alternative using independent costing data and methodology is necessary for informed decisions about the most economic way to deal with our nation's nuke waste. The No-Action alternative provides a reduction in occupational and public radiological exposure from SNF transportation to a CISF. The No-Action alternative eases the burden on New Mexico, a state already dealing with nuclear waste and nuclear legacy issues. The No-Action alternative provides an impetus for the nation to deal with its use of this energy source and its attendant disposal challenges. I urge the reconsideration of the HOSS, the HELMS, and the other alternatives listed in section 2 of the DEIS for on site SNF storage rather than transportation and storage at Holtec's New Mexico CISF. No-Action alternative is the most logical and economic choice at this time.