ML20266G404
| ML20266G404 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 03/20/2020 |
| From: | Burling H League of Women Voters of New Mexico |
| To: | Office of Administration |
| References | |
| 85FR16150 00096, NRC-2019-0052 | |
| Download: ML20266G404 (10) | |
Text
LEAGUE oFWOMEN VOTERS DATE Office of Admi nistration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Holtec-CISFEIS@ nrc.gov ATTN: Program Management, Announcements and Editing Staff
Subject:
Environmental lmpact Statement for the HOLTEC lnternational's License Application for a Consolidated lnterim Storage Facility for Spent Nuclear Fuel and High Level Waste; Docket lD NRC-2018-0052 To Whom it may Concern:
The League of Women Voters of New Mexico (LWVNM) has reviewed the March 2020 Environmental lmpact Statement (ElS) for the HOLTEC Consolidated lnterim Storage Facility (CISF) License Application.
LWVNM has developed both general remarks regarding the adequacy of the Draft EIS as well as section-specific comments noting observations, inaccuracies, or omissions. LWVNM concerns extend from inaccurate representation of the hazards posed to public health and safetyand inadequate characterization of the surrounding environment, to underestimation of environmental impacts to NM resources.
Given the long list of concerns we found when our member experts (nuclear scientists and engineers, primarily) reviewed the Draft ElS, the League does not support this project. We ask that you not approve the Holtec application unless LWVNM concerns regarding the EIS can be adequately resolved.
LWVNM seeks to promote responsible government and inform the public on decisions impacting their health, safety, and sustainability of their quality of life as well as contributing to the well-being of those residents who may be disadvantaged or have insufficient resources to defend their interests. As a related concern voiced by numerous members of the public during both the 6/23/20 and7l9/2O US NRC Public lnvolvement Meetings for comments on the HOLTEC ElS, LWVNM echoes the request for in-person public meetings addressing the HOLTEC EIS (when Social Distancing precautions cease), thereby permitting those without internet access an equitable opportunity to record their concerns.
Please consider the concerns delineated in the attached LWVNM Comments addressing the HOLTEC EIS and contact me (hannahburllngl@gCIai1.cqtn) at your earliest convenience for any clarification or additional information. Thank you for the opportunity to provide comments to the Draft HOLTEC EIS and LWVNM looks forward to the US NRC response.
League of Women Voters of New Mexico SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (96)
PUBLICATION DATE: 3/20/2020 CITATION 85 FR 16150
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General Remarks/[ntroduction The U.S. Nuclear Regulatory Commission (NRC) prepared this draft environmental impact statement (ElS) as part of its environmental review of the Holtec lnternational 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 League's 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 lnterim Consolidated Waste Storage Facility.
Based upon thes: 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. ln particular, it did not address the possibility that the transfer of corroded casks and damaged fuel/fuel debris could League of Women Voters of New Mexico 3
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 3,20L8 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 anntral 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 site's safety is the concept of the word "interim". lt will be a logistical and political feat to move SNF from 'rarious NPPs across the country to this proposed storage site. lt is unlikely that the federal government wili 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 nation's 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 Government's 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 nation's 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.
lf the matters laid out above cannot be resolved the project should not go forward.
League of Women Voters of New Mexico
EIS SECTION SPECIFlC COMMENTS SECTION PAGE PAGES REMARKS 1,.1. - 1..4 There is a future difficulty with this program. The permit requested is to provide interim storage for waste for a 40-year time period. But no permanent storage place, or even plan, exists. Yucca Mountain is not finalized. The best estimate for the creation of an operating permanent facility is 45 years. However, regulations in place will be used if a permanent facility is not available when this permit runs out.
One of the main reasons given for trying so hard to get public comment was to make sure that all public's issues are addressed in some manner. Not all the public's issues were addressed in detail because some of the concerns raised were off topic or not related to this particular project. Nevertheless, a list of 16 specific issues is given here.
The complete list, including health and safety and ecology, appears on page 1.4 and is individually addressed in the body of the report.
Section 2.1.
Page 2-1; lines 32-34 The application considers the maximum canister capacity load of SNF in 500 canisters (8,680 MTUs) and the report extrapolates and claims to consider storage of 20,000 units.
With time I woulld presume canister design would be modified. For a surface storage location, it is important to know what types of canisters or casks are represented in the ElS, especially if one is extrapolating performance of the full 20,000 that will be emplaced at the site. lt is presumptuous to assume canister design beyond the first 500 emplaced will be known and if cask design is not fully known, how can there be a reasonable projection of 'safety' from 500 to the hypothesized 20,000 canister units?
The performance criteria need to be based on the current canister design, and not extrapolated out to the projected full capacity of 20,000.
Section 2.2.1..1 Site Location Page 2.2, lines 35-37 The application considers the maximum canister capacity load of SNF in 500 canisters (8,680 MTUs) and the report extrapolates and claims to consider storage of 20,000 units.
With time I would presume canister design would be modified. For a surface storage location, it is important to know what types of canisters or casks are represented in the ElS, especially if one is extrapolating performance of the full 20,000 that will be emplaced at the site. lt is presumptuous to assume canister design beyond the first 500 emplaced will be identical, however, LWVNM assumes all will be licensed by the NRC using the same rigorous criteria.
Section 2.2.1.1 Site Location Page 2.2, lines 35-37 The WIPP site is within the middle of a 4-mile square buffer zone (16 sq. miles or 10,240 acres), and the repository footprint itself is in the approximate center of this area (see figure below). The repository footprint itself is approximately 35 acres and fenced off.
Entering the WIPP site via Highway 128 one has to pass thru fencing and travel at least 2 miles to get to the actual operations area. These 16 square miles create a relatively large buffer/safety zone to assure no negative human or natural impacts will compromise the site.
ln contrast, HOLTEC's CISF site is located between L to less than 0.3 miles from Highway
- 62. The proposed fenced area is within -0.3 of the site boundary. This leaves a relatively small 'buffer' zone between the site boundary and the containment area. Taken together, the site boundary and relatively small buffer zone are very close to a highway League of Women Voters of New Mexico
that transports materials and wastewater from active oil producing and mineral extraction producing areas. The relatively small footprint of the proposed site and the small buffer zone from the site boundary to the emplacement area do not seem to be based on optimal public'safetv'. See map below.
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2.2 2-4 2-5 The HOLTEC Draft EIS states:
"Each canister is then surrounded by additional steel, concrete, or other material to provide radiation shielding to workers and members of the public."
"SNF waste at the proposed CISF would be stored in dry cask storage systems that the NRC previously approved. These cask systems include transportable dual-purpose (transportation/storage)or multi-purpose (transportation/storage/disposal)canister-based storage systems. Each of these systems is engineered to safely store SNF and is subject to rigorous inspections, aging management programs, maintenance, and relicensing "
The EIS indicates that intact SNF casks are adequate to shield workers and the public from radiation exposure exceeding the limits. However, canisters with corrosion or those containing high burnup fuel, damaged fuel or fuel debris are more likely to emit radiation which exceeds the limits. Corroded SNF canisters from the CA San Onofre Nuclear Generating Station (SONGS) owned by HOLTEC are destined for the NM HOLTEC CISF. Both aluminum and stainless steel canisters in lSFSls located at other sites near bodies of water have also exhibited corrosion including the 2010 Peach Bottom/PA, 2007 TMl2 lPA, & 2000 Surry/VA, which were exposed to rain water.
I
Reference:
NRC Regulation # NUREG/CR-7030 "Atmospheric Stress Corrosion Cracking Susceptibility of Welded and Unwelded 304, 3041, and 3l6lAustenitic Stainless Steels Commonly Used for Dry Cask Storage Containers Exposed to Marine Environments", US NRC Office of Nuclear Regulatory Research, October 20101. "For plants located near coastal areas, chloride stress corrosion cracking (SCC) is a potential degradation mode for dry storage system canisters made from austenitic stainless steels. Previous research on chloride SCC of austenitic stainless steels provides some insight on the effects of material composition and condition; however, limited information is available to determine the susceptibility of dry storage system canisters placed inside a ventilated concrete enclosure (e.g., HOLTEC UMAX CISF Storage System)."
League of Women Voters of New Mexico
IReference Regulations addressing SNF Storage [10 CFR 72.122(h)(1)]l states: "The spent fuel cladding must be protected during storage against degradation that leads to gross ruptures or the fuel must be otherwise confined such that degradation of the fuel during storage will not pose operational safety problems with respect to its removal from storage. This may be accomplished by canning of consolidated fuel rods or unconsolidated assemblies or other means as appropriate."
Section 2.2.1.2 Lines 2-6 For Phase 1 - There is risk every time a canister is loaded and unloaded from the reactor to a transport vehicle, then unloaded from the transport vehicle to the interim storage facility. Then, when a permanent repository is approved, the canisters would have to be removed from the CISF and placed back in a transport vehicle to be taken to a permanent repository. Because of all this handling (multiple loadings and unloading) it would seem prudent that all SNF and GTC material be loaded into one canlster design appropriate for both interim storage and final repository.
Section 2.2.1.3 Facility Cctnstru ct-ion Page 2-6; lines 9-12 Phase 1 - Volume excavated soil (135,517 m3 plus 80,500 m30). How is the soil disposed of and what type of airborne dust control will be put in place during construction? lf dust suppression is via sprinklers, then what is the daily volume of water used?
2.2.1.1 Page 2-'2 The EIS states that "there are no water wells within the proposed project area."
However, Figure 3.5-5 shows an abandoned water well in the northeast portion of the proposed CISF project area. This contradictory information should be reconciled.
2.2.1..1 Concrete fabrication -The volume of concrete produced for this facility begs the following question, 'What is the total volume of water to be used to make concrete for phase 1?' And for phase 2-2O how much additional water will be needed? ls this potable water, bought from Carlsbad municipality? The volume of water used to make concrete is not addressed.
Section 3.2.4 Page 3-7 New Mexico Oil Conservation Department maps (see below) indicate there is an active gas well on the site. The integrity of the plugs installed in shut in or abandoned wells has not been assessed. Plug designs have changed over time, and early on in Permian Basin development less rigorous plug designs were in effect. What is the integrity of the boreholes within and adjacent to the CISF footprint; how deep are these wells? How are the existing wells within and surrounding the site boundaries monitored? Additionally, based on current oil and gas exploration, it is likely that there future horizontal and
'frack' oil and gas wells will be drilled right up to the site boundary, as observed at the WIPP site. The potential impact of maximum oil and gas exploration on the site integrity needs to be addressed (see comment for Section 2.2.1,.11. What is the impact of any future wells drilled at the boundarv on overall site safetv? SEE MAP BELOW.
League of Women Voters of New Mexico
League of Women Voters of New Mexico
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I Section 3.4.5 Page 3-27 The site is surrounded by large mineral, oil and gas reserves. Past extraction of these resources has produced subsidence features and sinkholes. As reported in Land (2013) solution mining, traditional room and pillar mining have resulted in numerous sinkholes forming years after the extraction has taken place. The FEIS does not adequately address possible future subsidence within the area due to ongoing production of potash mining.
This is a significant omission.
9 League of Women Voters of New Mexico
Additionally, construction of the CISF will produce increased runoff, especially over a possible 100-year time period. What are the design safeguards to minimize run-off to roads or to prevent future preferential flow paths down minute fractures off-site that could produce sinkholes?
Section 3.4.5 Page 3-28 Zhang et al. 2018 indicates future subsidence events within the vicinity of the proposed site area are highly probable. The authors indicate their remote sensing tool reveals the presence of subsidence areas, but most likely underestimates a current or potentially future subsidence zone. They stale, " However, becoLtse the subsiding oreos voried spotially ond oppeored intermittently throughout our study period, this map con only give a glimpse of the unstable areos of the potash mine." ln section 4.2 of Zhang states the following, "A lack of significant incidents in the potosh mine since 207L (the lost year of ALOS PALSAR observotions) demonstrotes this may indeed be the cose, ond thot the surface ond underground stability of the mine may be well controlled by the operotor through the use of pillars ond other instruments in the mining coverns. However, the long-lasting, coreful manogement of o potosh mine is a much more diflicult task. lf the mining operotion were to be suspended or abondoned, the existing mining focility moy be vulneroble to continuous subsidence and possible collapse events without com p re he n sive mo n og e m e nt."
Furthermore, in Section 5.1.1.2 of the EIS report (page 5-2) it states that INTREPID is not likely to slow down their mining extractions. lt is predicted that INTREPID, along with 5 other nearby mining companies, will increase operations within the next 20 - 30 years.
Because the INTREPID mine has extensive mineral rights under and surrounding the interim storage area, and there is subsidence observed in the study area, there is a high probability that subsidence could occur close to or within the storage area causing erosion and shallow ground water flow within the vicinity of the HOLTEC site. What assurance is provided that this will not affect the proposed site integrity? SEE MAP BELOW.
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rhre map.an o.ly g,ve a 9lmry o{ th unslable drea! ol rh ptarh m.n From Zhang et al., 2018 Section 3.5.t.4 Floodpl ains Page 3-32 Related to capturing storm run-off at the Plata and Gatuna Laguna, HOLTEC states that both of these draina ges "would be able to accept runoff from o 24-hour/79 cm [7.5 inch]
rain event with excess freeboord spoce, ossuming 7 the Lagunos were dry prior to the start of the roin event." (HOLTEC, 20L9a) This assumes the lagunas would be dry prior to any and all precipitation events. The aerial photos of the two lagunas (included in Section 3.2.4 comment) indicate the laguna footprints are more than double in size in League of Women Voters of New Mexico 10