ML20254A367
| ML20254A367 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/10/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20254A367 (5) | |
Text
From:
Tonya Kleuskens <tonyak@midplains.coop>
Sent:
Thursday, September 10, 2020 11:27 AM To:
Holtec-CISFEIS Resource Cc:
sonya letson
Subject:
[External_Sender] DEIS HOLTEC License Application September 10, 2020 Office of Administration Mail Stop: TWFN-7-A60M Attn: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Holtec-CISFEIS@nrc.gov ATTN: Program Management, Announcements and Editing Staff
Subject:
Environmental Impact Statement for the HOLTEC Internationals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste; Docket ID NRC-2018-0052 To Whom It May Concern:
Given the long list of concerns that the League of Women Voters New Mexico (LWVNM) found when member experts (nuclear scientists and engineers, primarily) reviewed the March 2020 Environmental Impact Statement (EIS) for the HOLTEC Consolidated Interim Storage Facility (CISF) License Application, we join them in asking you not to approve the Holtec application for license to operate Interim Storage for Spent Nuclear Fuel and High Level Waste.
Storage at any interim facility produces the risk of creating a dangerous de facto permanent site, which should never happen because the risk outweighs the benefits of temporary storage. Also, this license may prove politically unpalatable to a public that was told the storage would be temporary and a permanent site would be found elsewhere. This again undermines the 1987 Nuclear Waste Policy Act, by the federal government shirking its duty to find and license a permanent facility to house the nations SNF.
Reclassifying this radioactive waste to accommodate the site is a disastrous plan that would allow very hot Greater-Than-Class C and TRU waste to go into shallow burial pits instead of deep underground in a geologic repository, the less risky approach currently required for safety and public protection. This proposal would set in motion the plan to send the nations inventory of this waste stream to Texas and New Mexico. The amount of waste analyzed in the Generic Environmental Impact Statement was 420,000 pounds and 161 million curies. This massive amount of curies is more than 28 times the full licensed capacity of WCS huge federal waste pit and 41 times the full capacity of the adjacent Compact Waste pit and more than any one repository was intended to house in the NWPA.
Transport of this massive poisonous waste stream through our communities for the unjustified purpose of shallow burial should be prevented. At least 33,700 truck shipments or 11,800 rail shipments of highly radioactive waste would occur, but the public cant comment effectively since routes have not been set.
Plus the details of transportation and storage are substantially overlooked in the DEIS by not discussing a plan for cask repackaging. This is a considerable problem since leakage from ageing or cracked containment could cause a release of radioactivity at any point during the process.
It is important to promote responsible government and inform the public on decisions impacting their health, safety, and sustainability of their quality of life, even when English is not their first language. It is for this reason that we echo the request for in-person public meeting, coordinated with an extension of the comment deadline, addressing the HOLTEC EIS (when Social Distancing precautions cease) thereby permitting those without internet or telephone access an equitable opportunity to record their concerns.
In support of the League of Women Voters of New Mexico, we are attaching their General Remarks and list of concerns to reiterate their importance to the potential licensing of Holtec for Storage of Spent Nuclear Fuel and High Level Waste and because these are concerns that we share.
Respectfully, Tonya Kleuskens Tonya Kleuskens League of Women Voters of Amarillo Texas Environmental Affairs Committee tonyak@midplains.coop General Remarks/Introduction League of Women Voters of New Mexico The U.S. Nuclear Regulatory Commission (NRC) prepared this draft environmental impact statement (EIS) as part of its environmental review of the Holtec International license application to construct and operate a consolidated interim storage facility (CISF) for spent nuclear fuel (SNF) and Greater-Than-Class C waste, along with a small quantity of mixed oxide fuel (MOX). The NRC stated that the evaluation of the program is independent of HOLTEC - a concrete example of this effort is the NRC recalculation of the radiation to which workers in the facility will be exposed. The NRC calculation result was twice that of HOLTEC, but still low.
It would be very useful if the reasons for rejecting the second alternative, no action or permitting the spent nuclear fuel to remain at nuclear reactors and independent spent nuclear fuel storage installations were listed in prominent fashion.
These are the assumptions that guide the Leagues recommendations:
- 1. The proposed site is truly an interim facility (i.e.40-100 years of site usage).
- 2. Recommendations are based on information provided in the NRC EIS and the provided SARs for proposed Holtec LLC Lea County, NM Interim Consolidated Waste Storage Facility.
Based upon these assumptions, LWVNM anticipates that the canister design and site design laid out in the EIS have a low probability of damage severe enough to cause radiological release due to a seismic
event or natural disaster at this proposed site. With respect to the type of SNF to be sent to this proposed site, radiological diffusion into the ground and groundwater via seismic activity, or a natural disaster also has a low probability. With regards to the chemical embrittlement of the canisters while stored at the HOLTEC CISF via ground water or flooding, LWVNM expects the probability would be low based upon the past, current, and projected meteorology and climate of the proposed site and the surveyed groundwater tables in this area.
However, many of these conclusions are contingent upon no mining under or on the proposed storage site. Holtec LLC has stated in the EIS that they would buy the land for the proposed storage site.
However, the mineral rights are owned by the State of New Mexico and could potentially be leased to mining companies.
Mining on or under the site could cause a substantive safety risk and would most certainly cause an increased perceived safety risk to the proposed storage facility. Therefore, it is of paramount importance to the public safety and trust for Holtec LLC to follow through on their disclosed desire to buy the mineral and mining rights of the proposed storage site, and to retain these rights without leasing them to outside mining companies or exercising the use of these mining rights themselves. The purchase must be completed before the CISF is approved, as the outcome is by no means certain.
LWVNM assumes that Holtec LLC and the US NRC will use this site truly as an interim storage facility and the mineral rights of the proposed Lea County, NM site are retained by Holtec LLC and not exercised by Holtec LLC, and the information provided in the multiple SARs and the NRC EIS is as accurate and exhaustive as possible.
The EIS did not adequately evaluate conditions impacting public and occupational health. In particular, it did not address the possibility that the transfer of corroded casks and damaged fuel/fuel debris could cause radiation exposure. Cask transfer was presented as a routine, well-controlled operation with no inherent risks. However, the cask drop incident occurring at the San Onofre Nuclear Generating Station (SONGS) on August 3, 2018 demonstrates that the complexity of the cask transfer operation can result in unforeseen accidents. There is currently no plan for a hot cell facility on the HOLTEC site. Therefore, repackaging defective casks upon receipt will not be possible. This means that they will need to be returned to their place of origin, doubling the radiation exposure. Also, without a hot cell facility, there would be no way to handle casks exhibiting degradation after extended storage at HOLTEC CISF when a permanent geological repository becomes available.
Occupational radiation exposure was underestimated for other CISF operations. Cask inspection, a routine recurring task, has previously resulted in inspection team exposure of 4 Rems for a single cask (5 Rems is the annual occupational limit). Discussion of potential radiation exposure from nearby facilities neglected to include the extent of SNF and GTCC waste storage operations planned for the TX/ISP CISF, under concurrent NRC licensing review, which will pose similar hazards as the HOLTEC CISF. The NEF/URENCO facility continues to expand its uranium enrichment capacity but only current operations were evaluated.
Outside the direct scope of the specific proposed sites safety is the concept of the word interim. It will be a logistical and political feat to move SNF from various NPPs across the country to this proposed storage site. It is unlikely that the federal government will want to put in the political, logistical, and financial capital to do this again in 40 years. Therefore, license extensions will be granted. The question is how many license extensions would jeopardize the safety of the storage facility? Also, this continual license extension may prove politically unpalatable to a public that was told the storage would be
temporary and a permanent site would be found elsewhere. This again undermines the 1987 Nuclear Waste Policy Act, by the federal government shirking its duty to find and license a permanent facility to house the nations SNF.
One of the more abstracted concerns is, does the use of a private company for the stewardship of SNF undermine the precedent of the 1987 Nuclear Waste Policy Act in that it delays the US Federal Governments legal obligation to find and license a permanent waste storage facility? The addition of profit to the stewardship of SNF creates the potential of lobbying for the continual delay of the licensing of a permanent facility. This would not be in the best interest of the general public and would enable the federal government to shirk its duty to provide a permanent solution to the SNF problem. Therefore, LWVNM recommends any interim storage solution, if one is deemed necessary, be operated by the US DOE, so as to not blur the lines between the duties of the federal government and the private steward.
The nation needs to address the growing number of canisters of SNF that are crowding our nations NPPs. With sea levels rising at NPP sites, these canisters safety comes into question. Having SNF scattered throughout the country at sites not specifically designed for such a number of canisters is a security and safety issue and thus a financial issue for the federal government. Consolidation at a storage site designed for nuclear waste is urgently needed, otherwise disposal at current storage sites should be undertaken.
The main question, whether the current risk posed by the SNF is great enough and the probability of licensing a permanent site is low enough to warrant the licensing of an interim storage site, is unresolved and needs further consultation with policy experts.
If the matters laid out above cannot be resolved the project should not go forward.
Federal Register Notice:
85FR16150 Comment Number:
3887 Mail Envelope Properties (00dd01d68786$d22277d0$76676770$)
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