ML20265A088
| ML20265A088 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/20/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20265A088 (4) | |
Text
From: David Rosen <info@sg.actionnetwork.org>
Sent: Sunday, September 20, 2020 12:09 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Commissioners and Staff,
Dear NRC Commissioners and Staff,
This public comment is in response to the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec Internationals application for a license to build and operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste (NUREG-2237).
I oppose Holtecs proposal and ask that the NRC halt its licensing in order to protect public health and safety, the environment and our economy. It appears from Draft Environmental Impact Statement and other license documents that there would be no dry cask transfer facility at the proposed site, which means there would be no way to repackage waste. As you can see, this is designed to be a PERMANENT DISPOSAL SITE not an interim storage site.
Its design belies its' purpose.
Furthermore, given the number of transports planned to this site, accidents must be expected. Yet the final 200 miles is likely to be through on of the nation's most prolific oil producing regions. Oil and gas are essential for our nations' defense; or at least until tanks, trucks, planes and ships are all designed to move and work on a fuel other than petroleum.
By threatening US petroleum production with accidents you are endangering US defense needs. And if you don't foresee any accidents occurring you are not living in the real world.
- 1) New Mexico Does Not Consent The motto of the Nuclear Regulatory Commission is Protecting People and the Environment, yet the NRCs Draft Environmental Impact Statement (DEIS) on the Holtec project does neither. Instead, the NRCs inadequate draft EIS puts people, wildlife and
precious water resources at significant and potentially, deadly risk by failing to heed the concerns of the community. We join the All Pueblo Council of Governors, New Mexico Governor Michelle Lujan Grisham, New Mexico State Land Commissioner Stephanie Garcia Richard, more than a dozen county and city governments, the Alliance for Environmental Strategies, the New Mexico Cattle Growers Association, the Permian Basin Coalition of Land
& Royalty Owners and Operators, the Nuclear Issues Study Group, and the more than 30,000 residents who commented during the 2018 scoping period in vehemently opposing bringing the nations high level radioactive waste from nuclear power plants to our communities. We do not consent to becoming a nuclear wasteland for millions of years.
- 2) Cumulative Impacts The DEIS is inadequate because it fails to consider cumulative impacts from the damage the nuclear industry has already inflicted on New Mexicans for the past 75 years: uranium mining and milling in the northwest on indigenous Diné and Pueblo lands, including the 1979 Churchrock Disaster; radioactive contamination to Tewa lands and people from the Manhattan project in the Los Alamos area; fallout on downwinders from the Trinity Test in the Tularosa basin; the Waste Isolation Pilot Plant, which has already accidentally released dangerous amounts of radiation and now wants to expand; the URENCO uranium enrichment plant in Eunice; the worlds largest nuclear warhead stockpile on the edge of Albuquerque; and the toxic threat to Albuquerques aquifer by the Mixed Waste Landfill.
Rather than adding 173,600 metric tons of high level radioactive waste to a state that has already been grossly overburdened, the United States should be directing its resources towards cleaning up the contamination already present in our communities, just compensation, and holistic community health studies. The DEIS also fails to account for cumulative impacts from the other proposal for Consolidated Interim Storage, approximately forty miles east at the current Waste Control Specialists low-level radioactive waste site.
- 3. Threats from Transporting Irradiated Nuclear Fuel Not only New Mexico would be adversely impacted by the Holtec project: all communities
along the transportation routes between nuclear power plants and the Holtec proposed site would be threatened by radiation from the rail cars, and from the devastating financial and environmental damage if an accident or act of malice should occur. Studies have shown that one accident is likely to occur for every 10,000 shipments. It is irresponsible and dangerous for NRC to avoid inclusion of these mammoth risks and liability in its DEIS for Holtecs application.
- 4. Holtecs Project is Illegal Finally, under current U.S. law, this project is illegal. The Nuclear Waste Policy Act of 1982, as amended, does not allow the federal government to take title to the high level radioactive waste until a permanent geologic repository is operating. So the federal government cannot pay for transportation and storage of the waste as Holtec wants. The license cannot be issued until either a permanent repository is operating, or U.S. law is changed. For all the above reasons and more, I declare that the DEIS for Holtecs application is inadequate and further that the license for a high level radioactive waste storage facility should be denied. In conclusion, high level nuclear waste from nuclear power plants around the U.S. should not be brought to New Mexico-it should be isolated on or near the current site until there is an environmentally just and scientifically sound option available.
Sincerely yours, David Rosen, Certified Petroleum Geologist 2662 David Rosen dr5002@yahoo.com 5002 Thames Ct.
Midland, Texas 79705
Federal Register Notice: 85FR16150 Comment Number: 3959 Mail Envelope Properties (5f677e995056d_c5f43fa4d59cfa406484c)
Subject:
[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Sent Date: 9/20/2020 12:08:57 PM Received Date: 9/20/2020 12:09:03 PM From: David Rosen Created By: info@sg.actionnetwork.org Recipients:
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