ML20267A227
| ML20267A227 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/22/2020 |
| From: | Michael Lee Council on Intelligent Energy & Conservation Policy (CIECP), Promoting Health & Sustainable Energy (PHASE) |
| To: | Office of Administration |
| References | |
| 85FR16150 00117, NRC-2018-0052 | |
| Download: ML20267A227 (2) | |
Text
PUBLIC SUBMISSION As of: 9/23/20 9:28 AM Received: September 22, 2020 Status: Pending_Post Tracking No. 1k4-9j43-1afc Comments Due: September 22, 2020 Submission Type: API 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-0425 Comment on FR Doc # 2020-17536 Submitter Information Name: Michel Lee Address:
265 Madison Rd Scarsdale, NY, 10583 Email: ciecplee@verizon.net Submitter's Representative: Michel Lee Organization: Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE)
General Comment Promoting Health and Sustainable Energy (PHASE) and Council on Intelligent Energy & Conservation Policy (PHASE) strongly oppose Holtec's proposed CISF nuclear waste dump and have joined other public policy, civil society, and environmental groups in a submission to this docket. Here, we will not repeat arguments already raised, but focus, instead, on the fact that the NRC Draft Environmental Impact Statement (EIS) fails utterly to analyze:
(1) The medical and public health impacts upon vulnerable individuals and population subsets. Such persons include, persons of color, low income population subsets, persons with preexisting conditions, and persons at elevated risk of exposure to and health and economic impacts from the additional radioactivity and other pollutants the Holtec CISF will bring to New Mexico. Categories of such persons include babies developing in utero, infants, children, pubescents/and adolescents, girls and women. Such categories also include those who are already and will likely continue to be (absent vast changes in national policy and socioeconomic conditions) at heightened risk to other polluting and hazardous activities/facilities in the region as well as from COVID-19 and other pathogens, chemicals and/or illnesses.
(2) The evolving conditions and hazards presented by climate change, particularly drought, water stress, Page 1 of 2 09/23/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484871e63&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (117)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
wildfires, dust storms, and overall ecosystem deterioration. The fact that numerous other activities involving radioactive, toxic, and particulate pollution in the near and broad are region and in New Mexico overall have been occurring, are ongoing and are planned must be taken into consideration. The draft EIS notes climate change but engages in no evaluation of how climate phenomena and impacts may (indeed are likely to) interact with the CISF.
(3) The interactive dangers and risks presented by the regional mining and fossil industry activity, including pipeline explosions, exacerbation of fire risk, etc.
Page 2 of 2 09/23/2020 https://www.fdms.gov/fdms/getcontent?objectId=0900006484871e63&format=xml&showorig=false