ML20240A305
| ML20240A305 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 08/27/2020 |
| From: | Block J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00079, NRC-2018-0052 | |
| Download: ML20240A305 (8) | |
Text
PUBLIC SUBMISSION As of: 8/27/20 3:53 PM Received: August 27, 2020 Status: Pending_Post Tracking No. ked-65wk-w7mz Comments Due: September 22, 2020 Submission Type: Web Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0376 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0388 Comment on FR Doc # 2020-17536 Submitter Information Name: Jonathan Block Address:
Santa Fe, NM, 87508 Email: jblock41@gmail.com Phone: 505-984-1782 General Comment See attached file(s)
Attachments COMMENTS TO NRC ON HOL-TEC LICENSE Page 1 of 1 08/27/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484825c52&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (79)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
Jonathan Block 138 Verano Loop Santa Fe, New Mexico 87508 August 27, 2020 RE: Hol-tec license applications for long-term storage of high-level nuclear reactor waste at a site in the vicinity of Carlsbad, New Mexico To The Commission and its Delegated Staff in this matter:
I have some specific comments about deficiencies in the draft NEPA EIS, but first some objections to what I consider the violation of law of the NEPA statute, Council on Environmental Quality regulations,
and binding federal court decisionsthese are three, as follows:
(1) All of these meeting at supposed to be conducted in NMthe affected statethere is no pandemic exception in the laws, regulations or court decisions affecting application of NEPAmoreover, there is no rush to take this matter forward without adequate opportunities for public participation such as the law and regulations require; (2) Under the current pandemic circumstances, where the NRC is not holding public state location meetings, the NRC must extend the comment period for a reasonable time after the Public Health Emergency is over to allow commenting to take place
in a meaningful manner; (3) Public meetings should also include the NM Congressional Delegation or its members delegated representatives; As for my objections to deficiencies in the draft EIS for the Hol-tec license, I contend that the NRC failed to make an assessment of one of the most likely probabilities connected with this license.
That obvious consequence of granting the license at issue is that there is a considerable likelihood the site will take much of the nuclear reactor waste from around the United States and place it in casts for 120 years or more. As the NRC has only found a safe storage duration in the proposed manner of nuclear reactor waste
storage for 120 years, the license is, eo ipso, illegal to grantand, I also contend, under the Nuclear Waste Policy Act (NWPA),
unauthorized for consideration.
Given that the Hol-tec casks are not qualified for the 10,000 year protection from loss of contents that is required for storage at Yucca Mt., the only congressionally authorized (under NWPA) high-level nuclear waste long-term storage site, the NRC, under the NEPA, is required to fully analyze the potential consequences of cask failure over the probably duration of storage at the site in NM. Once the expense has been undertaken to move the waste to Carlsbad, NM, it is highly improbable the waste will ever leave that site. This is a reasonably foreseeable consequence of the action or project under NEPA.
Therefore, the NRC needs to undertake the same level of analysisincluding the occupational and public health consequences of the breaching of the casts at some time in the next 10,000 yearsas was undertaken to evaluate the consequences of storage at Yucca Mt.
Given that the New Mexico site is very likely to become the de facto high level waste storage facility for the nuclear reactor waste that was not contemplated (considered or selected) under existing federal law (NWPA) for controlling long-term high level nuclear reactor waste storage and disposal, it is also an underlying violation of federal law, beyond the inadequacy of the EIS, for the NRC to consider the license application at issue.
Unless and until the NRC undertakes a complete site evaluation pursuant to the direction and authorization of Congress through modifications to Nuclear Waste Policy Act and related laws, the creation of a de facto long-term high level nuclear reactor waste storage site anywhere will remain illegal. Additionally, the NRC cannot met the NEPA requirement for a consideration of reasonably foreseeable consequences of the project without prior congressional approval for such an analysis within the framework of a revised NWPA.
All activities on this application prior to a change in the NWPA are illegal under both NEPA and the NWPA and related laws.
Thank you for the opportunity to make this comment under protest of the violations
of law I described above.
Jonathan Block