ML20266G399
| ML20266G399 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/22/2020 |
| From: | Barish R - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00094, NRC-2019-0052 | |
| Download: ML20266G399 (2) | |
Text
Page 1 of 2 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly As of: 9/22/20 2:16 PM Received: September 22, 2020 COMMENT (94)
Status: Pending_Post PUBLIC SUBMISSION PUBLICATION DATE:
3/20/2020 Tracking No. 1k4-9j3h-uwzj CITATION 85 FR 16150 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-0403 Comment on FR Doc # 2020-17536 Submitter Information Name: Richard Barish Address:
3935 Anderson Ave. SE Albuquerque, NM, 87108 Email: richard.barish@gmail.com General Comment The recommendation to approval of Holtec's application is misguided, and I oppose that recommendation.
The DEIS leading to that recommendation is inadequate for the following reasons:
- 1. There is no permanent repository and no prospect for a permanent repository for the waste in coming years.
We have been trying to solve the problem of a permanent site for nuclear waste for decades, but this has proved to be a difficult problem to solve for both technical and political reasons. I am not aware of any present efforts to find a permanent place to store the waste. There is a substantial likelihood that an "interim" facility would end up as a de facto permanent waste dump. However, since the facility is not designed to contain the waste for thousands of years, there would be leaks and radiation releases, endangering the residents of the region. The DEIS should address the substantial risk that a permanent repository will not be found and that waste could be stored on the site for hundreds or thousands of years. If should evaluate whether the cannisters and site will be adequate to contain the waste if this is what transpires.
- 2. I am concerned that Holtec's casks are inadequate. Even if the casks can withstand a fall of 30 feet, it is possible that they could be subject to greater stresses in some kinds of accidents. Moreover, they are only designed to last up to 120 years. It is my understanding that high-burnup fuel has to be cooled for 200 years before it can be placed underground in a permanent repository! There is no plan for what will happen to the the waste so that it could remain for another 80 years. The casks should be sufficient to contain the waste for the entire time necessary for it to cool before placement in a permanent repository, and the DEIS should evaluate the casks based on the assumption that they will be required to retain the waste for this period plus a comfortable cushion.
https://www.fdms.gov/fdms/getcontent?objectId=090000648486e2e4&format=xml&showorig=false 09/22/2020
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- 3. The Holtec application is for a 40-year license. However, as noted above, recent science suggests that the waste needs to remain on site for 200 years. Holtec should be required to demonstrate that their storage plan is adequate to retain the waste for this 200 year period.
- 3. Holtec does not have an adequate plan to deal with leaking casks. It is foolhardy to assume that none of the casks will ever leak. Where human endeavor is involved, accidents will inevitably happen, as at WIPP. We are not perfect. Any storage plan must be required to have a means to deal with leaks. Astonishingly, Holtec's plan to deal with a cask that is leaking when it arrivals is to send it - a cask leaking radiation or highly radioactive material - back to where it came from! That is no plan at all. In assessing the adequacy of Holtec's plan, the DEIS should discuss and consider the absence of a plan for dealing with leaking casks.
- 4. Waste will have to be transported from locations around the country to Lea County. The American Society of Civil Engineers in 2017 rated the overall condition of rail lines in the country as a "D+." Accidents may happen and inevitably will happen over such a long period on rail lines in such poor condition. There were seven train accidents in New Mexico last year alone. Even if the risk of an accident is low, the affects if there is an accident could be catastrophic, especially if the accident occurred while the casks were being transported through a densely populated region. We should avoid having to transport the waste twice and undergo that risk of catastrophe twice, once to an interim facility and once to a permanent repository, if one is ever constructed. The DEIS should more thoroughly consider the risks of accidents and what could happen if the accident occurs in a densely populated region.
- 5. I am not aware of any guarantee of the security of this site. This is a sparsely populated area where terrorist activity could go unnoticed and be successfully carried out. Although sparsely populated, it does, nonetheless, have people who live there, as well as substantial oil and gas activity. A successful terrorist attack could render this entire area uninhabitable. The DEIS should consider and factor in the risk of a terrorist attack.
- 6. Southeast New Mexico/West Texas should not be a national sacrifice zone. Residents of that area already bear risk from existing facilities; they should not be made to bear the additional risk from the Holtec facility.
- 7. The DEIS fails to adequately consider other options, in particular, Hardened On-Site Storage. The DEIS frequently just states conclusions without any citing any evidence and without analysis. This is not an adequate consideration of impacts, In sum, this project seems to be more about Holtec's profits that actually finding a solution that constitutes good public policy and that simply works to address the nuclear waste problem.
Thank you for considering these comments.
https://www.fdms.gov/fdms/getcontent?objectId=090000648486e2e4&format=xml&showorig=false 09/22/2020