ML20267A619

Comment (4356) E-mail Regarding Holtec-CISF Draft EIS

ML20267A619
Person / Time
Site:	HI-STORE
Issue date:	09/21/2020
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
85FR16150
Download: ML20267A619 (6)

Text

From: Marlene Perrotte <marlenep@swcp.com>

Sent: Monday, September 21, 2020 11:52 PM To: Holtec-CISFEIS Resource; Marlene Perrotte; Joan Brown

Subject:

[External_Sender] Public Comments about Holtec Proposal NUREG-2237 Attachments: DEIS REVIEW TO TRANSPORTATION WORK GROUP version 1-1.docx To the NRC Review Board for report number NUREG-2237:

We, Sister Joan Brown, NM Interfaith Power and Light; and Sister Marlene Perrotte, Partnership for Earth Spirituality support the comments in response to the DEIS for Holtec International's request for a permit to build Consolidated Interim Storage in Lea County, New Mexico submitted by Petuuche Gilbert, Multicultural Alliance for a Safe Environment, Acoma, New Mexico Cynthia Weehler, Energía Mía, Santa Fe, New Mexico Rose Gardner, Alliance for Environmental Strategies, Eunice, New Mexico Scott Kovac, Nuke Watch, Santa Fe, New Mexico.

These comments are responses to the DEIS for Holtec International's request for a permit to build a Consolidated Interim Storage facility in Lea County, New Mexico. The Docket ID is NRC-2018-0052.

Federal Register Notice: 85FR16150 Comment Number: 4356 Mail Envelope Properties (46fb749f-b997-7cf4-ddaa-46c86bb2ec2f)

Subject:

[External_Sender] Public Comments about Holtec Proposal NUREG-2237 Sent Date: 9/21/2020 11:52:17 PM Received Date: 9/21/2020 11:52:31 PM From: Marlene Perrotte Created By: marlenep@swcp.com Recipients:

Post Office: swcp.com Files Size Date & Time MESSAGE 818 9/21/2020 11:52:31 PM DEIS REVIEW TO TRANSPORTATION WORK GROUP version 1-1.docx 21951 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

After close review of Sections 5, 6, 7, 8, & 9 of the DEIS, especially looking at transportation safety, we, the undersigned, submit these comments to the NRC, Docket ID NRC-2018-0052.

Section 5: Upon the review of Chapter 5 CUMULATIVE IMPACTS herein we provide the following comments:

• Cumulative impact analysis is limited only to a 50-mile area. It should be more because nuclear waste storage not only affects the onsite environment but also all transportation corridors bringing nuclear waste to the CISF.

• The cumulative impact analysis of transporting nuclear waste from sites around the nation and 44 through states has to be considered beyond the geographic limit of a 50-mile radius.

• Accidents of trains carrying nuclear waste would have large environmental, economic and health impacts. The DEIS does not evaluate present and future impacts of transportation accidents involving nuclear waste, which would likely be catastrophic. This must be included.

• We disagree that cumulative impacts of transportation to the CISF should be classified as SMALL (defined by the DEIS as having environmental effects that are not detectable, or are so minor they would neither destabilize nor noticeably alter any important attribute of the resource) as indicated under section 5.3.

• 5.3 Transportation timeframe analysis of 2017 to 2060 is too short for long-lived radioactive material hazards.

• Under Transportation 5-3 we question why The NRC staff do not anticipate transportation impacts on the main rail, because of SNF shipments to the proposed CISF. Why are railway conditions not assessed for transporting radioactive materials? The 2017 Infrastructure Report Card by the American Society of Civil Engineers grades US rail infrastructure as a D+. Since little work has been done since 2017, the grade may be lower.

• It is stated under Transportation 5.3 that radioactive doses from the CISF and nearby radioactive materials transportation activities are additive and therefore these could be harmful to human healthcausing latent cancer fatalities (LCF). We disagree that the potential cumulative public dose impacts would be SMALL.

• In the summary for 5.3 Transportation it is stated that radioactive effects resulting from facilities emitting radioactivity and any transportation, all in the geographic setting is SMALL. We disagree because of their overall cumulative impacts of radioactivity from facilities and transportation activity.

• The section on 5.7 Air Quality and Table 5.7-1 makes no mention of radioactive emissions into the air of the geographic area. We think it should be discussed since radioactive emissions are occurring within the area.

• Nuclear accidents could affect potash and salt mining and oil/gas production, both of which are huge industries in the area.

• Recreational activities, such as tourism at Carlsbad Caverns National Park, hunting, and fishing could be jeopardized by the CISF.

Section 6: Upon the review of Chapter 6 MITIGATION herein we provide the following comments. As stated at the introduction in Chapter 6 on Mitigations this involves reducing adverse impacts of the CISF during its construction, operation and decommissioning. Therefore, we ask the following:

• Under Table 6.3-1, Resource Area, describing Public Health and Occupational and Safety, what additional mitigation measures are planned during the return of any damaged cannisters?

• Under Table 6.3-1, Resource Area, describing Waste Management, what mitigation measures are planned if a storage and/or disposal facility is not ready?

Section 7: Upon the review of Section 7 ENVIRONMENTAL MEASURES AND MONITORING PROGRAMS we provide the following comments:

• Holtec says the NRC is the one who will conduct the Safety Evaluation Report (SER) for the final EIS. Why is the NRC doing this instead of the applicant? Does conduct mean the NRC will write the report? Needs clarification.

• Under RADIOLOGIC MONITORING AND REPORTING, the monitoring will be collected quarterly. This is insufficient and monitoring data should be collected at least daily.

• A yearly summary of releases with radiation types is too long for the public to wait to know if radiation has been released. This should be done weekly.

• We strongly feel that radiation monitors should be placed outside the facility based on wind patterns and between the site and towns and cities. When the WIPP release occurred there was no monitor between WIPP and Roswell so no way to know how it affected the city.

• This deadly material will travel through downtown Roswell and many other towns and cities. Anywhere the casks travel must have monitors so people who live on the routes have immediate feedback in the case of a leaking cask. This includes not only New Mexican communities, but all communities -rural and

urban- throughout the country. The DEIS is incomplete until this kind of monitoring is included.

• Holtec claims that because the casks are sealed and welded shut there will be no radiation exposure into the air. This is their reason for stating that no radiation exposure into the air will occur and continuous radiation monitors will not be used unless deemed necessary. We disagree: 1) radiation can escape casks, depending on the type of radiation it is and on the material that the cask is made of. 2) To wait on monitoring until something is deemed necessary is reckless.

When dealing with radioactive waste, setting up redundant safety systems before an incident is necessary and should never happen after the fact. 3) Holtec canisters are routinely scratched and cracked routinely every time they are moved, and they will be moved several times before they reach the site (NRC inspection Report & Notice of Violation, ML18332A357, pp. 8-9, 11/28/18).

Transporting the casks from the original power plant site to the CIS site requires at least 4 movements of canister to transport overpack casks; movement later to a permanent repository increases that to at least 8 times, and 4 of these after 40

+ years time to degrade. 4) The 1987 Amendment to the Waste Policy Act states that transported nuclear waste must be retrievable for inspection, which welded casks do not allow, meaning that radiation releases may not be known when there is time to correct them.

Section 8: Upon review of Section 8 COST BENEFITS OF SITE VERSUS NO ACTION ALTERNATIVE we submit the following comments:

• Holtec analyzes the potential for a second CISF as a reasonably foreseeable future action. Therefore, the cost-benefit analysis will also consider the potential presence of a second CISF as it pertains to impacts (i.e., changes) to the costs and benefits associated with the proposed Holtec CISF project. This is the first time a second repository has been mentioned and information about what kind, how much, and when waste will enter it needs to be indicated.

• The DEIS states that, at this time the safety analysis has not identified any credible accidents. Therefore this EIS will not estimate the cost of an accident specific to this proposed CISF. It defies logic to state that Holtec cant identify any credible accidents. All risks must be identified and assigned costs and it must be done before the license application is approved. To assume an accident will not happen when transporting and storing radioactive waste is the height of hubris on the part of Holtec and the NRC if it approves this. In Japan, no one thought a tsunami from an earthquake would cause a nuclear disaster. David Lochbaum, of the Union of Concerned Scientists, wrote a book asking why not?

He makes the case that it was lack of planning and preparation that caused the nuclear disaster, not the earthquake and tsunami. Japan is now reeling from the escalating costs of this lack of planning: In 2016 Japan predicted the cost of cleanup to be an unbelievable $188 BILLION. Since then the estimate had increased to 3 times that amount.

Section 9: Upon review of Section 9

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES we provide the following comments:

• Holtec completely fails to mention the transportation of 173,600 MT of high-level nuclear waste as having any environmental consequences. The DEIS is incomplete until this analysis is included.

• The DEIS states that soils will be replaced during decommissioning. Replacement soil, an essential resource that requires long time frames to form, will have to be taken from somewhere else. This is not a SMALL impact for the area where it is taken from.

• Holtec claims that they cannot predict the improvement to be expected from the decommissioning and reclamation work and also claim that new technologies may greatly improve reclamation. This is a ludicrous claim and shows the same reasoning that created the radioactive waste problem in the first place. The idea that new technology will somehow solve a problem in the future that we cant solve today is irresponsible. That may indeed come true, but to bet new generations of people on a guess should not be part of an EIS. Our parents generation, and now ours, has already promised future generations that somehow we will have a magical technology that will allow us to change the nature of radioactive decay and its effects on the environment. We should have learned from this illogical thinking and it should not be condoned in Holtecs rationalizations.

With the utmost respect, we would like to see responses to our concerns before the DEIS is approved.

Signatories:

Petuuche Gilbert, Multicultural Alliance for a Safe Environment, Acoma, New Mexico Cynthia Weehler, Energía Mía, Santa Fe, New Mexico Rose Gardner, Alliance for Environmental Strategies, Eunice, New Mexico Scott Kovac, Nuke Watch, Santa Fe, New Mexico