ML20268A003
| ML20268A003 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/22/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20268A003 (3) | |
Text
From: Tom Clements <srswatch@gmail.com>
Sent: Tuesday, September 22, 2020 1:18 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Comment for Docket ID NRC-2018-0052, Holtec spent fuel storage draft EIS
Dear NRC Staff,
I hereby submit this comment in response to the Draft Environmental Impact Statement (Docket ID NRC-2018-0052) regarding Holtec Internationals application for a license to build and operate a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste (NUREG-2237).
The proposed facility is unnecessary and would mean greater worker exposure and environmental risks due to increased handling of highly radioactive spent nuclear fuel. Spent fuel should be handled only once on its way to a geologic disposal facility and not more than once.
The Holtec facility would only amplify risks and exposure and not bring us any closer to a long-term spent fuel management plan. The EIS must fully explain why handling spent fuel twice is an acceptable approach and how consolidating spent fuel will further a comprehensive spent fuel disposal plan and not actually delay such a plan as spent fuel would be off many reactor sites.
I live in South Carolina, a state with seven operating commercial nuclear reactors and therefore a large amount of spent fuel. All the reactor sites here have dry cask storage facilities - Irradiated Fuel Storage Facilities (IFSFs) - adjacent to the reactors. That spent fuel is stored at the reactor sites has not impacted their operation and there is absolutely no clamoring by the public or nuclear industry here to remove the spent fuel from the reactor sites. Removal of that spent fuel at this premature point when a national spent fuel disposal strategy does not exist would mean additional worker exposure at the sites and additional and unneeded environmental and transport risks. These risks to us in South Carolina - and to other states with IFSFs - must be fully examined in the EIS. Likewise, lack of a public call for spent fuel removal from the many reactor sites must be discussed. And, that the Holtec projects adds nothing beneficial to safe operation of reactors must be discussed.
In short, it appears that creation of an interim storage facility is somehow being driven by financial interests of the proponents of the facility. This must be fully vetted in the EIS.
Ratepayers must not pay for spent fuel being moved twice and costs to ratepayers for needless movement of spent fuel to a Holtec facility must be reviewed in the EIS. If charges for moving spent fuel to a Holtec facility are requested by utilities to be included in monthly bills to ratepayers this will be opposed. The matter of opposition to requests by utilities to PSCs for redundant spent fuel management charges must be discussed in the EIS.
The proposed project violates the principle of consent-based siting, because New Mexico does not consent to it. A letter by public interest groups on the matter -
http://www.beyondnuclear.org/centralized-storage/2020/9/20/organizational-sign-on-letter-submitted-as-public-comment-on.html - lays out lack of consent: We join the All Pueblo
Council of Governors, New Mexico Governor Michelle Lujan Grisham, New Mexico State Land Commissioner Stephanie Garcia Richard, more than a dozen county and city governments, the Alliance for Environmental Strategies, the New Mexico Cattle Growers Association, the Permian Basin Coalition of Land & Royalty Owners and Operators, the Nuclear Issues Study Group, and the more than 30,000 residents who commented during the NRC's 2018 environmental scoping period in vehemently opposing bringing the nations high level radioactive waste from nuclear power plants through our communities to New Mexico. This lack of consent must be more fully discussed in the EIS.
That same letter points out the Holtec proposal also violates federal law: Under current U.S.
law, this project is illegal. The Nuclear Waste Policy Act of 1982, as Amended, does not allow the federal government to take title to the high-level radioactive waste (commercial irradiated nuclear fuel) a permanent geologic repository has opened. So the federal government cannot pay for transportation and storage of the waste as Holtec wants. Legally, the license cannot be issued until a permanent repository is operating. This legal matter and that no public funds can be spent on the facility must be fully discussed in the EIS.
Thank you for confirming receipt of this comment. Thank you for including it in the EIS record.
Sincerely, Tom Clements Director, Savannah River Site Watch 1112 Florence Street Columbia, SC 29201 srswatch@gmail.com https://srswatch.org/
Federal Register Notice: 85FR16150 Comment Number: 4389 Mail Envelope Properties (CAEbcavWfXN_MFTUZhu+277GaFHi6gq9Zob2Ta9BO=uHC1=LWNQ)
Subject:
[External_Sender] Comment for Docket ID NRC-2018-0052, Holtec spent fuel storage draft EIS Sent Date: 9/22/2020 1:18:06 PM Received Date: 9/22/2020 1:18:16 PM From: Tom Clements Created By: srswatch@gmail.com Recipients:
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