ML20268A005
| ML20268A005 | |
| 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: ML20268A005 (8) | |
Text
From: Janet <contactus@cardnm.org>
Sent: Tuesday, September 22, 2020 1:22 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Comments Attachments: hlw,Introduction, comments NRC.docx
Federal Register Notice: 85FR16150 Comment Number: 4391 Mail Envelope Properties (4bd77dbe-3127-c61a-b316-99dfeabd8460)
Subject:
[External_Sender] Comments Sent Date: 9/22/2020 1:21:33 PM Received Date: 9/22/2020 1:21:34 PM From: Janet Created By: contactus@cardnm.org Recipients:
Post Office: cardnm.org Files Size Date & Time MESSAGE 2 9/22/2020 1:21:34 PM hlw,Introduction, comments NRC.docx 17442 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Submitted via: <Holtec-CISFEIS@nrc.gov>
Subject:
Docket ID NRC-2018-0052, Draft Environmental Impact Statement, Public Comment
Dear NRC Commissioners and Staff,
This public comment is 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 [CISF] for Spent Nuclear Fuel and High Level Waste (NUREG-2237).
Introduction At a February 2020 meeting of the Southwest Alliance to Save our Future, several groups of participants chose topics to comment on to the NRC concerning the proposal to bring high level nuclear waste to New Mexico for storage. We represent the group who agreed to summarize the New Mexico Environment Department's evaluation of the Draft Environmental Impact Statement by Holtec International.
Below is the summary. Please consider this summary as the comments of the Southwest Alliance to save our Future Water Issues Working Group to NRC.
Sincerely, Janet Greenwald, Citizens for Alternatives to Radioactive Dumping (CARD)
Dixon, New Mexico Karen Bonime CARD Albuquerque, New Mexico
G. Robin Seydel CARD Albuquerque, New Mexico Groundwater The DEIS insufficiently and contradictorily suggests that groundwater in the vicinity of the proposed CISF project area is not potable. Section 3.5,3.1; Section 3.5,3.1. Additionally, the DEIS provides no groundwater quality information for wells B 106, B107, and B101 and numerous other shallow wells in the area as identified on Figure 3.5-5. Our New Mexico Environment Department challenges the DEIS's assertion that there is an absence of potable water. A ground water monitoring program to monitor environmental impact need to be included in the DEIS.
The groundwater might be affected by surface water infiltration, Section 4.5.2.1.1.
The DEIS inappropriately neglects to discuss New Mexico groundwater protection standards listed at 20.62.3013 NMAC despite the fact that radionuclides are included in New Mexico groundwater standards at 20.6.2.3103.
The DEIS is inconsistent regarding the hydrologic relationship between the playas (Laguna Plata and Laguna Gatuna) and the area's shallow groundwater, Section 5.5.1, Section 3.5.4.2. The DEIS insufficiently describes the consequences of a significant storm event to the playas, 4.5.1, Section5.5.1. The DEIS needs to thoroughly address the possibility of the overtopping of the playas.
The DEIS insufficiently and inconsistently addresses the existence and implication of groundwater accumulating in the Cenozoic alluvium above the Dockum claystones, Application Section 3.5.2; Application Section 3.5.2; Section4.5.2. A full understanding of this zone of groundwater accumulation is important to understanding the environmental impact of the CISF.
The DEIS insufficiently addresses the need to mitigate or cease continued contamination of groundwater, Application Section 3.5.1.1. "Impacts on groundwater resources frompotential contamination due to improperly plugged or cased wells could impact groundwater quality through infiltration to near surface aquifers." Section 5.5.2.
The DEIS insufficiently acknowledges and challenges the Applicants assertion that shallow groundwater below the CISF can be under artesian pressure. Application Section 3.5.2.
The DEIS fails to acknowledge the necessity of establishing background constituent concentrations for the multiple aquifers below CISF. NMAC 20.6.2.7B(1). The DEIS insufficiently addresses long-term monitoring of environmental impacts of the CISF. At a minimum the DEIS needs to address the associated impact to groundwater, e.g. migration mechanisms both laterally and vertically, Application Section 3.5.2.
The existence and possible effect of collapsed substrate due to dissolution below the proposed CISF Project The DEIS insufficiently addresses, mischaracterizes, and is self- contradictory regarding the potential for groundwater recharge via hydrologic communications between the ground surface, ephemeral circular freshwater wetland depressions, deep and shallow subsurface geology, and perched and/or isolated groundwaters that are temporally or spatially present. Eddy and Lea Counties contain a large and diverse set of examples of surface and subsurface deformation that are the result of karst processes. The DEIS refers to outdated studies ignoring more recent information. In EIS Section 3.5.1.1 acknowledges that the water in Laguna Gatuna comes from precipitation events, then the DEIS contradicts itself and denies any potential for groundwater discharge.
Though it is well accepted that Nash draw is a karst formation, the DEIS does not acknowledge that fact. The DEIS disregards the subsurface geology when discussing the playas in the area. Underground subsidence can now be easily identified through geophysical survey techniques (e.g. electrical resistivity).
Deep drill islands are located approximately 10 miles west of the proposed project area. Though it is acknowledged that the area of the proposed repository should be free of significant seismic events, the DEIS does not define significant seismic events.
The DEIS inappropriately discounts the possibility of subsidence while acknowledging its existence: new sinkholes form almost annually Section 3.4.5.
Surface Water Once a federal permit is proposed, NMED reviews the permit and provides a Clean Water Act Section 401 Certification of the federal permit to ensure that it complies with state law. Currently, the nation is subject to the guidance issued in accordance with the 1986 rule (40 CFR Pat 230.3 (s), under which playa lakes are specifically included in the definition of WOTUS (Waters of the United States).
Monitoring requirements include monitoring of radionuclides addressed in 10 CFR 20, also those addressed in 20.6.4. The following substances must also be monitored: metals, oil and grease, pH, ammonia, alpha terpineol, aniline, benzoic acid, naphthalene, p-Cresol, phenol, pyridine, Chemical Oxygen Demand, Total Suspended Solids (TSS).
The playa lakes are surface waters of the state and subject to water quality standards at 20.6.4 NMAC. The DEIS should cover measures the Applicant would need to take to mitigate or treat contamination prior to discharge into these water bodies, Section 4.5.1.1.1.
The DEIS fails to address the necessity to accurately measure seasonal variations of playa water levels and resultant subsurface infiltration. Playa waters are the only source of surface water in the Eastern Plains and must be protected as such.
Satellite imagery shows a minimum of 20 circular playas within the proposed CISF project area. The circular playas that are located within the project area are potential pathways to groundwater. Playas are extremely important when wet to a variety of wildlife. Sandhill Cranes use saline lakes such as Laguna Gatuna from
October to March as winter habitat. Raptors such as Bald Eagles follow the cranes and other waterfowl to feed on these species during winter months as well. The DEIC does not adequately address the impacts on wintering birds at Laguna Gatuna.
Waste Materials and Mitigation The DEIS insufficiently addresses hazardous waste, in particular the processes generating this waste, its management and the identification of the potential circumstances that might result in its release to the environment. The NMED considers the possible mismanagement of hazardous waste to pose a substantial threat to the environment.
The DEIS insufficiently addresses sanitary waste. Groundwater protection associated with sanitary waste is regulated in New Mexico at 20.6.2NMAC.
The DEIS insufficiently addresses mixed waste, Section3.13.2.
The DEIS insufficiently addresses how NRC will be involved in the mitigation of environmental impacts.
The DEIS needs to more thoroughly identify "decontamination techniques" Table6.3.2 NMED requests the NRC share with NMED all anticipated license conditions resulting from the safety review that are relevant to possible environmental impacts.
The DEIS insufficiently addresses the radiological monitoring and reporting, particularly whether the monitoring is for radiation only or whether it includes monitoring for radiological elements or isotopes, and whether this monitoring pertains to groundwater, Section 7.2.
Regarding mixed waste, the DEIS references the generation of such waste, Section 3.13.2. The DEIS is inappropriately vague about how or why this waste would be generated.