ML20268C302
| ML20268C302 | |
| 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: ML20268C302 (5) | |
Text
From:
Henkels, Max <mhenkels@nmda.nmsu.edu>
Sent:
Tuesday, September 22, 2020 5:23 PM To:
Holtec-CISFEIS Resource Cc:
Maitland, Julie
Subject:
[External_Sender] Comment Letter for Holtec International CISF Project, Docket No. NRC-2018-0052 Attachments:
09222020_NMDA Holtec Letter-Final.pdf To Whom it May Concern:
New Mexico Department of Agriculture submits the following comment letter (see attachment) in response to the U.S. Nuclear Regulatory Commissions Draft Environmental Impact Statement for the Holtec International HI-STORE Consolidated Interim Storage Facility (CISF) Project, Docket No. NRC-2018-0052-0300.
If there is any issue, please contact Max Henkels at mhenkels@nmda.nmsu.edu or 575-339-5052.
Thank you for the opportunity to comment, Max Henkels Natural Resource Policy/Planning Analyst New Mexico Department of Agriculture Work Cell: 575.339.5052 Confidentiality Notice: New Mexico has a very broad public records law. Most written communications to or from state employees are public records. Your e-mail communications may therefore be subject to public disclosure. This e-mail, including all attachments is for the sole use of the intended recipients. Any unauthorized review, use, disclosure or distribution is prohibited unless specifically provided under the New Mexico Inspection of Public Records Act.
Federal Register Notice:
85FR16150 Comment Number:
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DEPARTMENT OF AGRICULTURE STATE OF NEW MEXICO MSC 3189, Box 30005 Las Cruces, New Mexico 88003-8005 Telephone (575) 646-3007 MICHELLE LUJAN GRISHAM JEFF M. WITTE Governor Secretary September 22, 2020 John Tappert, Director Division of Rulemaking, Environmental and Financial Support U.S. Nuclear Regulatory Commission Mail Stop T4-B72 11545 Rockville Pike Rockville, MD 20852 To Director Tappert:
New Mexico Department of Agriculture (NMDA) submits the following comments in response to the U.S. Nuclear Regulatory Commissions (NRC) Draft Environmental Impact Statement (EIS) for the Holtec International HI-STORE Consolidated Interim Storage Facility (CISF)
Project, Docket No. NRC-2018-0052-0300.
Part of NMDAs role is to advocate proactively on behalf of New Mexicos agricultural communities and the natural resources that sustain them. The agricultural sector contributes over
$3.7 billion to the New Mexicos economy and supports over 40,000 individual farmers and ranchers.1 These producers livelihoods depend on the protection and wise stewardship of New Mexicos land and water.
The establishment of the CISF would have a profound impact on agricultural producers in southeastern New Mexico. Lea and Eddy Counties contain over 3 million acres of farm and ranch land, which contribute nearly 300 million dollars to the local economy each year.1 The 1 New Mexico Agricultural Statistics 2018 Annual Bulletin. USDA, National Agricultural Statistics Service.
John Tappert, Director CISF Project Draft EIS September 22, 2020 Page 2 local human population may be low, but the two counties are home to nearly 140,000 head of beef and dairy cattle.
The CISF location is surrounded by productive rangeland. While the proposed projects footprint may seem minor to outside planners, it places a major burden on local producers impacted by the construction of the CISF and the accompanying transportation infrastructure.
Construction would disrupt grazing operations on neighboring public lands and reduce forage through the spread of noxious weeds. In addition, a spent nuclear fuel storage facility will reduce property values in the vicinity, instantly devaluing one of agricultural producers main assets. This draft EIS fails to address this economic factor in the analysis and offers no compensation or even consideration of these costs to local farmers and ranchers.
Concerns have also been raised related to collaborative land management work in the state on the Restore New Mexico initiative, which has treated over 41,000 acres for noxious weeds in southeastern New Mexico. The Restore New Mexico Initiative has applied approximately $12 million for conservation practices on federal, state and private property in the state overall2,3.
Work such as this could be undone as a result of the installation a CISF.
Access to adequate water is critically important to farmers and ranchers in an arid state like New Mexico. The presence of a CISF in New Mexico and associated shipments would result in a greater risk of radioactive contamination to the water table. Such an event could put local agriculture out of business. Southeastern New Mexico has scarce water resources and the loss of any wells for stock watering would be irreplaceable for individual producers. Even if an accidental release of radiation were contained by emergency protocols, the perception of contamination would devastate the value of local agricultural products. Again, the draft EIS fails to address this economic factor in the analysis and offers no discussion on the potential impacts to agriculture from contamination of the water table. Finally, agriculture across New Mexico would be impacted by the frequent conveyance of waste to the CISF from across the United States. These regular deliveries would not only strain New Mexicos transportation infrastructure but also increase the risk of a contamination event to rural communities around the state.
Given these serious risks to the farmers and ranchers of New Mexico, NMDA urges the NRC to select the No-Action alternative. As it stands, the proposed action has no plan in place beyond 2 https://www.techlinenews.com/articles/blm-and-partners-restore-southeastern-new-mexico 3 http://www.nmacd.org/restore-new-mexico
John Tappert, Director CISF Project Draft EIS September 22, 2020 Page 3 forty years of interim storage. New Mexicos rural communities should not bear the burden of such a short-sighted approach to a long-term national challenge.
NMDA appreciates the ability to participate in the NRCs public comment process. If you have questions related to these comments, please contact Mr. Max Henkels at (575) 339-5052 or mhenkels@nmda.nmsu.edu.
Sincerely, Jeff M. Witte JMW/mh/ya