ML20253A206
| ML20253A206 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/04/2020 |
| From: | Inoue M - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00081, NRC-2018-0052 | |
| Download: ML20253A206 (2) | |
Text
PUBLIC SUBMISSION As of: 9/9/20 1:25 PM Received: September 04, 2020 Status: Pending_Post Tracking No. 1k4-9irv-ew58 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-0390 Comment on FR Doc # 2020-17536 Submitter Information Name: Mari Inoue General Comment I oppose the Holtec plan, as do the Governor of New Mexico, the governors of 20 tribal nations, and the large majority of New Mexicans.
The history of nuclear and hazardous waste cleanup at sites around the United States has left populations further exposed to radiation and exorbitant costs that are not paid. New Mexico citizens have long been victim to cancer and disease from uranium tailings, nuclear weapons testing, radioactive contamination from Los Alamos National Laboratory and Sandia National Laboratories.
Members of local communities, including residents of the state of New Mexico and tribal nations, have a right to be heard to raise their concerns at publicly held in-person meetings, not at online meetings.
In regard to NRC's recent webinar hearings on this docket, the hearings:
(1) must be conducted in-person at site locations in New Mexico, as the NRC promised; (2) must extend the comment period until after the Public Health Emergency has ended and it is safe to have mass gatherings; and, (3) must include New Mexico's Congressional Delegation or staff so they can verify the validity of the hearing format.
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.
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.
Page 1 of 2 09/09/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484846d95&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (81)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
NRC's DEIS and Holtec's ER exclude the high risks of transporting highly radioactive waste, and not even being transparent about transport routes, represents segmentation. This is a violation of the National Environmental Policy Act (NEPA), as long ruled so by the federal courts.
Holtec and NRC assume that the Yucca Mountain dump in Nevada, targeting Western Shoshone Indian land, will open, allowing re-export of irradiated nuclear fuel from NM to NV for permanent disposal. It's how Holtec and NRC attempt to justify calling the CISF "interim" or temporary. But the Yucca dump should not, and will not, happen, for a long list of reasons. This includes the Yucca dump's illegality (it would violate the Treaty of Ruby Valley of 1863, signed by the U.S. government with the Western Shoshone Indians), as well as the environmental injustice of opening the national high-level radioactive waste dump in the same state that "hosted" nuclear weapons testing for several decades on end, resulting in disastrous radioactive fallout and health damage downwind. But it also includes Yucca's flagrant scientific unsuitability, as well as the fact that well over a thousand environmental groups have been actively opposing the scheme for 33 years. Holtec and NRC are entirely unjustified in assuming the Yucca dump will open someday, or year, or decade, or century.
In fact, NRC's doing so reveals its bias in the Yucca Mountain licensing proceeding, in which it is supposed to be a neutral safety regulator, only sitting in judgment of the Yucca site's capability of meeting regulations, not advocating for its opening even in the face of its clear unsuitability. For this reason, there is a very high risk that the Holtec CISF in NM will become de facto permanent surface storage, a parking lot dump, risking catastrophic releases of hazardous radioactivity directly into the environment when containers ultimately fail over a long enough period of time, due to loss of institutional control.
Page 2 of 2 09/09/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484846d95&format=xml&showorig=false