ML20252A222
| ML20252A222 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/04/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20252A222 (3) | |
Text
From:
elizabeth schwartz <lizschwartz5@gmail.com>
Sent:
Friday, September 4, 2020 2:38 PM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Holtec CISF Proposal To Whom It May Concern:
Grassroots New Mexicans oppose this de facto permanent, surface storage, parking lot dump in their state. See Laura Watchempino of Multicultural Alliance for a Safe Environment's, and Albuquerque resident Sam Weisberg's, op-eds, and Janet Greenwald of Citizens for Alternatives to Radioactive Dumping's letter to the editor, recently published in the Albuquerque Journal.
NRC's time-limited focus on just 40 years of "temporary storage" is inappropriately, arbitrarily short, given Holtec's own admission in its license application to NRC that "interim storage" could persist for 120 years; in response to a Request for Information from DOE, Holtec admitted a CISF could operate for 300 years; and in NRC's own 2014 Continued Storage of Spent Nuclear Fuel Rule and Generic EIS, the agency acknowledged away-from-reactor ISFSIs (Independent Spent Fuel Storage Installations) could go on indefinitely (that is, forevermore). Institutional control could be lost over such long time periods. Failed containers could release catastrophic amounts of hazardous radioactivity directly into the surface environment, to blow downwind, flow downstream, bioconcentrate up the food chain, and harm people down the generations.
I also protest NRC's woefully inadequate, to nearly non-existent, treatment of highly radioactive waste transport risks. This
violates the long-established legal requirement under the National Environmental Policy Act (NEPA) that NRC take a "hard look" at the Holtec CISF proposal, including its inextricably linked high-risk transportation component, impacting most states in the Lower 48. (See the 2017 transportation route and shipment number documents posted online by the State of Nevada Agency for Nuclear Projects, its analysis of the same 2008 U.S. Department of Energy document that NRC itself cites as its excuse for not having to do a Holtec-specific transport analysis in 2020!)
Sincerely, Elizabeth Schwartz
Federal Register Notice:
85FR16150 Comment Number:
3878 Mail Envelope Properties (CA+x67OuGczq3d55uKzLrJS60pTmq2OrnzmYB5p9tJF7Xbys2Qg)
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