ML20268C276

Comment (4469) E-mail Regarding Holtec-CISF Draft EIS

ML20268C276
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: ML20268C276 (7)

Text

From:

dave mccoy <dave@radfreenm.org>

Sent:

Tuesday, September 22, 2020 4:47 PM To:

Holtec-CISFEIS Resource; Caverly, Jill

Subject:

[External_Sender] Holtec 2d Set of Citizen Action Comments Attachments:

Holtec.CA.Comments.9.22.2020.Second.Set.docx Please see attached.

Dave McCoy

Federal Register Notice:

85FR16150 Comment Number:

4469 Mail Envelope Properties (CAKhVgZawXML6Qj3nWhQ3EP_5WfW5TkEnzT0dhoi5Z1n05a68bA)

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[External_Sender] Holtec 2d Set of Citizen Action Comments Sent Date:

9/22/2020 4:46:32 PM Received Date:

9/22/2020 4:46:48 PM From:

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Sent by email to: Holtec-CISFEIS@nrc.gov September 22, 2020 Jill Caverly U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Re:

Draft Environmental Impact Statement Holtec Consolidated Interim Spent Fuel Storage Facility Project (CISFSF)

CITIZEN ACTION COMMENTS SECOND SET The Draft Environmental Impact Statement (DEIS) for a license to store irradiated nuclear fuel from commercial nuclear power plants at their Holtec, Inc. dump site in New Mexico is wholly deficient.

The back end of the fuel cycle so far is a problem without a solution. Yucca Mountain has been a failure to date. The Waste Isolation Pilot Plant (WIPP) experienced fire and explosion(s) spreading a cloud of Plutonium and Americium over several states and injuring workers with contamination and resulting in a three year shutdown. The Department of Energy low-level radioactive waste dump at Beatty, Nevada erupted in explosions and fires raging for a day shutting down major highways and sending a radioactive cloud over Las Vegas, St. George, Utah and into Idaho. We have genius at making nuclear waste and idiocy when it comes to cleanup.

The Nuclear Regulatory Commission is so irresponsible toward New Mexico that it refused to take jurisdiction or do anything about the more than 70 spent fuel elements irresponsibly dumped in the Sandia National Laboratories Mixed Waste Landfill (an unlined dump) that has no license for shallow waste disposal of spent fuel and Transuranic waste. Many of the disposed MWL spent fuel pins/rods are from nuclear reactor meltdown tests performed by Sandia Labs for the NRC severe accident program (nuclear reactor meltdown experiments), performed after the 3MI accident. MWL waste experiment canisters hold irradiated fuel melted together with metallic sodium. Metallic sodium was the source of the explosions at Beatty, Nevada. NRC refuses to accept responsibility for the unlicensed, illegal disposal of the MWL spent fuel and Transuranic waste. NRC cant be bothered to enforce its own regulations against unlicensed disposal. Why should NRC be trusted to license and regulate interim storage of 170,000 tons of commercial spent fuel from around the U.S.? There is no plan for where it should go next after New Mexico.

DEIS Deficiencies

1. Holtec has not provided the meaning of interim. Holtec has not demonstrated the existence of a detailed quality assurance program which would effectively detect and prevent defective work by contractors and manufacturers of the Holtec proposed spent fuel

storage facility for an extended period of time. The following quality assurance program elements are wholly inadequate:

(1) program; (2) organization; (3) design control; (4) procurement document control; (5) instructions, procedures, and drawings; (6) document control; (7) control of purchased material, equipment, and services; (8) identification of materials, parts, and components; (9) control of special processes; (10) inspection; (11) test control; (12) control of measuring and testing equipment; (13) handling, storage, and shipping; (14) inspection, test, and operating status; (15) nonconforming items; (16) corrective actions; (17) quality assurance records; and (18) audits (19) waste acceptance criteria

2. Long-term Storage: The Licensees have failed to demonstrate that utilization of the interim storage, associated systems, and storage system, as proposed pursuant to the requested permit, is adequate to accommodate storage of spent fuel elements safely either for the length of time contemplated by its analysis or in the event of what is reasonably likely to be a substantially longer period of time. This failure precludes a conclusion that issuance of the proposed license is not inimical to the public health and safety. Holtec has not assessed the effect of increased corrosion, the need for chemistry and material controls, and the need for surveillance of equipment, and ongoing inspections for leakage. There is no provision for inspection or monitoring of leakage.

3. Holtec has not adequately analyzed corrosion and radiation damage to the fuel elements, the assemblies, and the concrete walls and flooring of the storage facility due to: (a) increased radioactivity from fuel assemblies with deterioration of cladding and concrete containers deterioration from gamma radiation making them not transportable to any other location. (b) increased and uninterrupted spent fuel assembly residence time including possible residence beyond 10,000 years; (c) increased temperatures resulting from high burnup fuel.

4. Holtec has not determined how it will analyze the long term damage to the fuel assemblies and the effect of moving them from spent fuel pools, dry storage, transporting them from reactor sites around the country and then removing and repackaging the containers once again (perhaps thousands of years later) from the interim site to a permanent repository. Such a move even in 100 years may be doubtful to achieve. Holtec should be required to meet the safety requirements for what would be a permanent repository.

5. The Holtec study of dry storage risks omitted accidents involving canister leakage from chloride-induced stress corrosion cracking. The Licensees have failed to adequately demonstrate that the storage of greater amounts of irradiated fuel for longer periods of time than ever anticipated and the attendant increased fission product inventory, heat load, will not: (b) result in breakage, leakage, unacceptable radioactivity and heat-induced acceleration of corrosion of the separation system for the fuel elements racks, the seismic restraint system, and the Zircaloy cladding on the stored fuel elements. There has been acknowledgement by the NRC that canisters will leak. There just has not been an estimate of how many canisters will leak. The DEIS is not valid without estimating the number of canisters expected to leak over the facility life? The proposed Holtec facility is not providing any means

for replacing a faulty canister. In fact, Holtec doesnt even have the technology in place to detect crack development.

6. The proposed seismic design and analyses for collapse from mining activities for the Interim Site is inadequate.

7. Holtec has not demonstrated that the design of the spent fuel storage provides a structural integrity sufficient to maintain the spent fuel onsite in a condition to allow transport of all spent fuel from a reactor site to Holtec and from Holtec to a permanent repository. This will create orphan spent fuel remaining at reactor sites so that Holtec cannot achieve full temporary storage. The cost of additional storage at reactor sites for untransportable fuel has not been analyzed for the extreme period that may be required.

This failure precludes the conclusion that issuance of the proposed license is not inimical to the public health and safety.

8. The drop test for transport does not accurately reflect the internal condition of the containment in the event of an accident and whether the container and spent fuel will be in a condition to be sent to the site after an accident. Passage over drops of over 30 ft may damage containers irreparably with severe accident consequences. Acceptance criteria for container drops are not presented. Will the container be returned to sender or allowed to proceed to Holtec?

9. Accidental dropping of the containers during loading and unloading has not been adequately analyzed. Repeated droppings may occur over a period of time of containers and fuel assemblies or other similar large objects into or upon the expanded storage areas prior to loading in containers. Measuring internal damage to fuel assemblies is inadequate or nonexistent.

10. Speed of rail travel, condition of tracks and other infrastructure, terrorism and the damage to tracks either accidentally or intentionally has not been adequately analyzed.

11. Holtec analysis of potential accidents during and after loading and transport is deficient, and therefore cannot be used to support a conclusion that issuance of the proposed license would not be inimical to the public health and safety and environment.

The Applicants did not adequately discuss what provisions have been made to recover from accidents or from the longer term effects of spent fuel storage for damaged spent fuel and degradation of containment, the fuel cooling systems, or storage racks. Specifically, the Applicants have failed to demonstrate that (1) leakage can be repaired, and (2) sufficient numbers of casks are available for or can be obtained in the event of accidents to allow removal of fuel from damaged containment if such removal is necessary.

12. The Applicants analysis of potential accidents is deficient, and therefore cannot be used to support a conclusion that issuance of the proposed facility would not be inimical to the public health and safety. Specifically (a) the Licensees did not accurately address either the increased risks of or consequences from releases of radioactivity from or criticality that may occur due to an accident resulting from (1) the transport of spent fuel casks and other

heavy objects alongside, over, and near the spent fuel pool if one is utilized; (2) projectiles generated by natural events, such as earthquakes or tornados, or by mechanical failure.

13. Holtec analysis of the effect of the spent fuel configuration upon criticality is deficient.

14. Holtec has failed to demonstrate that the amount of spent fuel and high burnup fuel proposed to be stored will not become critical some time during the period of storage permitted under the proposed amendment or in the absence of a geological repository.

15. A terrorist attack on a storage site could result in the release of radioactive material.

There is no assurance Holtec has adequate resources and attention for devotion to maintaining the storage facilities free from attack or sabotage.

16. There is sufficient space at all operating nuclear reactors to accommodate all spent nuclear fuel for the duration of the plant licenses. By the time consolidated storage could be established almost all U.S. reactor sites will have installed dry storage systems. So it does not make sense to impose the extra costs of moving the waste twice before a permanent repository is established.

17. Holtec has provided no rigorous cost estimates showing that consolidated interim storage is an economically attractive option in the face of significant delays in opening the repository.

18. Construction and the costs of interim storage will deplete funding and delay the siting and development of one or more permanent repositories as required by the Nuclear Waste Policy Act. Consolidated interim storage will illegally become the de facto permanent solution for managing the nation's growing inventories of commercial spent fuel. Siting requirements and cost for permanent disposal in New Mexico that used interim storage may not be met. Adequate sites for permanent geological disposal elsewhere may not be available. This could result in leakage of wastes from the Holtec site that was only considered for temporary storage.

19. Given the long-term storage, Holtec has not provided assurance that underground aquifers and groundwater will be protected from deterioration and/or breakage of containers and leakage.

20. Prevention of potential episodes of criticality and emergency procedures for criticality events must be presented. Water may enter containment and cause criticality.

21. Applicants have not explained what provision will be used for containers with damaged fuel, details of construction and what water and other requirements would be necessary for cooling. The handling of damaged containers and any repackaging operations is not presented.

22. The HOLTEC site is located above one of the largest karst lands in the world where water runs underground since the surface is too porous to hold the run off. Holtec has not

analyzed the risk of aquifer contamination due to the karst formation. The site lies over a shallow perched aquifer that rises and falls inexplicably (New Mexico Environment Department). Monitoring wells are often saturated.

23. NRC is requested hold face-to-face public hearing on the draft Environmental Impact Statement in Albuquerque.

Respectfully submitted, David B. McCoy, Executive Director Citizen Action New Mexico PO Box 4276 Albuquerque, NM 87196 505 262-1862