ML20268C348

Comment (4512) E-mail Regarding Holtec-CISF Draft EIS

ML20268C348
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: ML20268C348 (3)

Text

From: Catherine Skopic <catherineskopic@yahoo.com>

Sent: Tuesday, September 22, 2020 6:51 PM To: Holtec-CISFEIS Resource

Subject:

[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Greetings NRC Staff.

You must be very busy these days. I hope you are well and safe.

I'm writing about multiple concerns regarding Holtec's application to you for a license for their proposed project, a Consolidated Interim Storage Facility (CISF) in New Mexico that has problems of legality from beginning to end -

from the right to the land of the proposed site to Indigenous Rights; Environmental Racism; potentially contaminating waters that serve wildlife, endangered species, migrating birds and people; to the State of New Mexico not consenting to this project; threats to Cultural Properties and Historic Sites; threats to our Nation from the transporting of irradiated nuclear fuel to the heavy burden of the cumulative impact of nuclear radiation people of New Mexico carry.

In fact, it has been shown that the whole of Holtec's CISF project is illegal.

Looking at Sierra Club Guidance on Implementing Sierra Club Policy on the Management of High-Level Nuclear Waste, I see there are other problems.

"Essential Information is not Transparent - Unfortunately, there is little transparency regarding the relationships and responsibilities of the owners/

operators of the CIS facilities and other controlling or involved entities....

Fundamental details regarding these relationships and which entities are responsible for what are largely unknown, and the public is left in the dark.

The legal agreements associated with the principals involved should be made known, so the public clearly understands how various responsibilities are being handled including financial responsibility for damages or health impacts. NRC has instead allowed much of this information to be deemed proprietary, and therefore, the arrangements have not been disclosed to the public.. .......

Holtec appears to rely on local government expertise to handle emergency responses (based on its responses to NRC) when local governments are ill-equipped financially and technically to do so, thus jeopardizing public safety. In the past, almost all privately owned nuclear waste sites have been abandoned by their owners, defaulting to public ownership, with costs of long-term clean-up and management falling on local and state taxpayers as well as the federal government."

No state or locality wants to be left "holding the bag" - especially when it comes to cleaning up nuclear waste - potentially, metric tons of it. Relationship questions regarding the involved principals have not been answered. The public has not been openly, transparently informed on essential details - this raises red flags on the project.

In looking at the reliability of the private company, Holtec, I discovered many facts and implications of wrong-doing, including one statement that Holtec has a criminal record and should not be allowed to do business. There have been faults and mistakes in the making of their fuel casks violating NRC regulations, as noted in the Brattleboro Reformer April 29, 2019. Holtec was found to have violated two federal regulations for the design changes it made to their casks that are in wide use at nuclear power sites all over the country. This one incident - and there are others - raises the issue of integrity.

Is this a private company with which one would want to do business? I don't think so.

I closing, I ask the NRC to reject this Holtec Consolidated Interim Storage Facility.

Thank you.

PEACE, Catherine Skopic

Federal Register Notice: 85FR16150 Comment Number: 4512 Mail Envelope Properties (772201390.4976160.1600815030398)

Subject:

[External_Sender] Docket ID NRC-2018-0052 Draft Environmental Impact Statement Comment Sent Date: 9/22/2020 6:50:30 PM Received Date: 9/22/2020 6:50:56 PM From: Catherine Skopic Created By: catherineskopic@yahoo.com Recipients:

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