ML20265A091
| ML20265A091 | |
| 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: ML20265A091 (5) | |
Text
From:
Diane TURCO <tturco@comcast.net>
Sent:
Sunday, September 20, 2020 1:36 PM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Public comment regarding the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec International's application for a license to construct and operate a "Consolidated Interim Storage Facility Installation for Spent Nuclear Fuel and High Level Waste" (NUREG-2)
Submitted by Diane Turco, Director, for Cape Downwinders, a nuclear watchdog group with members and affiliates across the state of Massachusetts, working to protect the people and the environment from the failed oversight of the Nuclear Regulatory Commission and the corrupt corporation, Holtec International, and its subsidiaries decommissioning Holtec Pilgrim and ISFSI management in Plymouth, MA.
WE DO NOT CONSENT.
Cape Downwinders is strongly opposed to the NRC licensing Holtec International's planned CISFI. We stand in support of our New Mexican neighbors and colleagues across the U.S. who are demanding the NRC reject the Holtec license application process until it is safe to hold in-person public meetings in NM. We also support the demand for the NRC to hold pubic meetings in TX and the 44 impacted states, including our home state of Massachusetts where Holtec Pilgrim is located.
This proposed Holtec CISF is no better solution for storing nuclear waste than what is already in place at every nuclear power site in the U.S. It's a shell game that highlights the fact that there is no solution to the nuclear waste disaster. The NRC has incredulously concluded that impacts from transportation accidents assumes there would be no release of radioactive materials and the public is safe. This determination is completely irresponsible. The NRC is just kicking the nuclear waste can down American highways and rails to dump this most toxic substance known to humankind in a minority community. This is unacceptable and clearly social and environmental racism.The NRC continues to work for the benefit of the nuclear industry at the cost to our communities and the environment. But the government must work with the consent of the people.
YOU DO NOT HAVE OUR CONSENT to proceed with this license application.
- 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, Cape Downwinders, 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 their communities.
We do not consent to New Mexico 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. Environmental Racism Its no coincidence that the United States wants to make New Mexico a nuclear wasteland. It ranks as one of the poorest states and is a majority minority state, with more Black, Indigenous, People of Color (BIPOC) residents than white residents. For the NRC to determine that nuclear waste which will threaten life for millions of years would have small or no environmental impact is a blatant violation of environmental justice principles and is environmental racism in action. We do not give our own government license to allow a private corporation to further contaminate NM or to expand the massive nuclear burden they already bear.
- 4. Threats to Cultural Properties & Historic Sites Holtec International and the NRC would have us believe that the site is a desolate, uninhabited place with no historic value or significance. This statement is completely false and without merit. The site is located near or on two lagunas or playa lakes:
Laguna Gatuna and Laguna Plata. Lagune Plata is an archaeological district that has been extensively studied for decades. Two sites near Laguna Gatuna, where the nuclear waste is proposed to be stored, are listed on the National Register of Historic Places. Archaeologists have
found a plethora of evidence of the Jornada Mogollon people, dating from 200 AD, 700 AD, and 1200 AD. More than 200 archeological sites are located within six miles of the proposed nuclear waste dump. Laguna Gatuna, while often dry, fills with water after monsoon rains, attracting a variety of wildlife and hunters for millenia. The Hopi and Mescalero Apache nations have identified the area as culturally significant to them, and the Hopi nation has informed the NRC that traditional cultural properties could be adversely affected if this project proceeds. The site where Holtec wants to dump tens of thousands of tons of radioactive waste has profound historic value and significance.
- 5. Threats to Water & Wildlife The impact of this forever deadly nuclear waste would have devastating consequences on wildlife including threatened species that rely on the lagunas for drinking water and surrounding area as a critical habitat, including the Lesser Prairie Chicken, and the Dune Sagebrush Lizard. Agencies such as U.S. Fish & Wildlife, New Mexico Game &
Fish, the Environmental Protection Agency (EPA) and New Mexico Environment Dept (NMED) have all gone on record attesting to the significance of Laguna Gatuna for migratory birds, and have argued that it should be designated permanently as a Water of the United States (WOTUS), which would make it eligible for protection under the Clean Water Act.
6.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 tremendous risks and liability in its DEIS for Holtecs application.
- 7. 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.
Here in Massachusetts, Holtec presented a slide show on waste management at the November 2019 Nuclear Decommissioning Citizens Advisory Panel meeting. One Holtec slide stated that, if all goes as planned, the waste could be leaving Plymouth by 2024. This left the impression that the waste onsite is only temporary, so the community could interpret that the waste issue will be resolved shortly. Is this license already a
done deal? Is this comment period just another NRC platform to ignore real public concerns?
NRC has determined the waste may remain at local sites for decades to come.
Thus, we need safe and secure ISFSIs onsite today. In Plymouth, the waste must be in the safest canisters available, not the current thin-walled Holtec Hi-Storm 100 canisters. My Yeti coffee mug is only 1/4' thicker than those cans holding high level nuclear waste. What is available on site if a canister leaks? Nothing. There must be real security 24/7 and the casks must be in a secure building away from the open environment.
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 is available. And the government needs to provide better safety and security at current ISFSI sites across the U.S. NOW.
Sincerely, Diane Turco, Director Cape Downwinders PO Box 303 South Harwich, MA 02661 tturco@comcast.net
Federal Register Notice:
85FR16150 Comment Number:
3960 Mail Envelope Properties (360901347.39972.1600623346846)
Subject:
[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Sent Date:
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