ML20266G397

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Comment (93) from Marcia Hart, Rn, on Holtec International HI-STORE Consolidated Interim Storage Facility Project
ML20266G397
Person / Time
Site: HI-STORE
Issue date: 09/22/2020
From: Hart M
- No Known Affiliation
To:
Office of Administration
References
85FR16150 00093, NRC-2019-0052
Download: ML20266G397 (2)


Text

PUBLIC SUBMISSION As of: 9/22/20 2:14 PM Received: September 21, 2020 Status: Pending_Post Tracking No. 1k4-9j3a-lz72 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-0402 Comment on FR Doc # 2020-17536 Submitter Information Name: Marcia Hart Address:

2 Fremont St Gloucester, MA, 01930 Email: marciahart@hotmail.com General Comment Sending abbrev. incase my email didn't arrive I am writing to submit a public comment on NRC Docket 2018-0052 in regards to the license application by Holtec International to build and operate a consolidated interim storage facility for spent nuclear fuel and high-level waste which has been proposed in New Mexico.

It appears the people of New Mexico do not want this storage facility in their state. The state of New Mexico has already received a disproportionate amount of the health and social costs of the nuclear legacy. The state demographics include extremely high poverty levels and fact that 60% of New Mexico's population is either Hispanic or Native American. This makes the siting of this facility in this state an environmental justice issue.

COVID has truly exposed the health effects of our practices of siting pollution sources and waste in poorer communities and communities of color. It is obvious that wealthier communities have the economic, social and educational resources to prevent their communities from even being considered for such a project. It is up to government regulation to enforce equity and to avoid jeopardizing the health and safety of our already more vulnerable populations, in such a disproportionate manner.

In fact, there is no safe site for consolidating the nation's nuclear plant waste. To accomplish this consolidation requires many years of transporting dangerous waste, across 44 states to arrive there. I am completely opposed to the transport of nuclear plant waste on our highways, railways and waterways. This Page 1 of 2 09/22/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648486d9de&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (93)

PUBLICATION DATE:

3/20/2020 CITATION 85 FR 16150

application does not adequately account for the extreme weather, natural disasters, potential terrorist activity or deteriorating national infrastructure that could potentially create devastating outcomes along these travel routes.

Our public process is inadequate for such serious decision-making. This is an example of the empty shell of what is supposed to be a robust public process and you are the overseers of this inadequate version of public inclusion. Many in New Mexico feel that the demographics of their area cannot fairly respond to a public process during COVID. I can offer that I was able to access the meeting by phone but was unable to access the online slides presented, despite having successfully utilized several online meeting platforms during COVID. This faceless process, fraught with dropped calls and the moderator being unable to identify the next caller did not instill confidence in the NRC's public commitment or in its choice of Holtec to containerize, transport and manage high level toxic waste.

During the hearing, the integrity and honesty and therefore the insured safety provided by Holtec was also questioned. I read more about this to verify the comments made against the Holtec company. I did not find this information search reassuring. I am concerned that the TVA has penalized them, that they failed to report this in their application, that the MA Governor and AG had to take measures to assure they operated responsibility regarding their Pilgrim contract and that they are in litigation with the State of New Jersey. I also read about a potential request for grand jury oversight of the land being sold for the disposal site and a possible bribery charge.

Two other items stood out as beyond the comprehension of a thoughtful person. First, that the evaluations that were conducted were done using normal operating conditions only and that climate change issues and age-related effects on the containment casks were not considered. The absurdity of this, given the projected time that radioactive waste is hazardous cannot be understated. The second issue, equally absurd, is that there is no on-site facility planned to re-containerize damaged casks and that casks arriving damaged to the site will be returned to their original location. Together, these issues, indicate an unreasonable lack of regard for public safety and an unrealistic outlook toward an array of toxic nuclear substances capable of having devastating public health consequences.

This site has two possible outcomes. It is temporary or it is permanent. If it is temporary then the waste will be moved at least twice, which makes no sense. If it is permanent then a different process and construction plan is needed. I have been hearing since the nineteen seventies, when I was in my twenties, that it wouldn't be long before the nuclear waste problem was solved. Now I am in my seventies and witness that not only has this problem remained unsolved, in a meaningful way but we are simply moving the problem out of sight, for another generation to deal with. The term intergenerational injustice, was used repeatedly to describe this.

I ask you to leave the waste where it is, make its care and containment a part of the operating cost of nuclear energy production and provide the nation with a process and plan that reflects the long-lived toxicity of the waste being contained.

Sincerely, Marcia F Hart RN Page 2 of 2 09/22/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648486d9de&format=xml&showorig=false