ML20268C354
| ML20268C354 | |
| 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: ML20268C354 (3) | |
Text
From: Paige Murphy-Young <pmurphyyoung@gmail.com>
Sent: Tuesday, September 22, 2020 7:06 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Comments concerning CISF, NUREG-2237
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).
Surface and Groundwater Concerns New Mexico Environment Departments comments regarding the surface and groundwater impacts of proposed action are comprehensive, compelling, and fully supported by scientific authorities. Please address the issues raised in NMEDs 23 page comments with written responses NRC makes to it public comments. In any event, satisfaction of NMEDs concerns will be necessary before any required NMED permit can be issued. See Comments submitted to John Tappert, Director, Division of Rulemaking, Environmental and Financial Support, U.S. Nuclear Regulatory Commission, from Rebecca Roose (Dec. 16, 2019) https://www.env.nm.gov/wp- content/uploads/2020/05/2019-12-16-NMED-comments-to-NRC-on-Holtec-DEIS_FINAL.pdf Meeting of the Minds?
Assent to terms of a contract (including an NRC license) requires a clear and full statement of its terms. Unambiguous and enforceable commitments seem to be lacking in Holtecs current proposal (at least as it is reflected in the DEIS). The parties rights and responsibilities both financial and operational at the end of this 40-year license remain particularly hazy. That NRC states that the CISF may be extended with a new NEPA proceeding does not obviate the for the currently considered license to contain clear commitments for closure at the end of its 40-year term. When NRC actually can approve an extension, the 2020 closure requirements can be modified accordingly.
Another unacceptably vague response is Holtecs position re transportation routes (basically, that they are unknowable at this time. Considering the risks to cities, agricultural and other vulnerable and valuable populations and properties involved, Holtec could easily outline routes from existing nuclear facilities storing wastes on site.
Additionally, NRC should evaluate transportation routes increased vulnerability due to infrastructure: generally over-strained, under-funded and increasingly subject to extreme weather events experienced with global climate change.
Holtecs Financial and Criminal Background Most federal and state environmental statutes require permit/license applicants to demonstrate that they have the technical competence and financial resources necessary to fulfill the requirements of the permit being sought.
Here, the public has access to less financial and operational information about Holtec than it does about any publicly traded stock. With billions of taxpayer dollars, possible liabilities for environmental and public health damages at stake, we still know virtually nothing about Holtecs corporate organization or its financial resources. Holtec International is a privately held company comprised of trusts controlled by Holtec CEO Signh, all obscure.
Of great concern is Holtecs record of bribery fraud and nonfeasance:
Bribery, TVA (60-day debarment and administrative fee of two million dollars);
Tax fraud , New Jersey (false certification re prior debarment);
Failure to fulfill commitments made for tax break program (Ohio).
Can the NRC legitimately expect Holtec to change course for the CISF proposed for southeastern New Mexico? Does Holtec meet the standards generally apply to federal contractors? If not, how can NRC justify relying on Holtec for a project with the grave responsibility and extensive risks inherent with a CISF?
No Action. . . or no action on Holtec, with better action for nuclear power plants?
Under Holtecs plan, billions of dollars will committed to construction, operation and decommissioning of the spent nuclear fuel produced by the nations nuclear power plants. Funds for insurance, Holtec profit margins (yet undisclosed to the public) and other expenses will continue for at least 40 years.
Major unknowns exist with the promised yet necessary repackaging of spent nuclear fuels before they are ultimately sent (via 40-years older transportation routes) to their final repository where it is hoped they will safely remain for the thousands of years the high-level nuclear wastes remain hazardous.
Happily, possible alternatives exist. (The DEIS seemed to present a pretty all-or-nothing scenario.)
For example, federal funds could be provided to the nuclear power plants currently maintaining their wastes on-site. NRC and/or DOE would reimburse these plants for all the liabilities, costs and uncertainty resulting from the federal governments failure to find a permanent repository. Additionally, financial and technical support could be provided to emplace the wastes in dry storage casks. (These thick casks are successfully being used by most other countries and some states. Thus secured, the nuclear plants waste could be maintained on site for the 40 years as safely if not more safely considering the track record Holtecs thin canisters (discussed by other commenters). With not the need to add additional cladding/casking, the thick casts could more safely be transported to a permanent repository. Additionally, the nuclear wastes would have to be transferred once, not the two-transfer solution required by the Holtec plan.
I look forward to seeing new NRC plans for the long-accumulating nuclear wastes now reposed in nuclear power plants around the country.
Respectfully submitted, Paige Murphy-Young
Federal Register Notice: 85FR16150 Comment Number: 4518 Mail Envelope Properties (738F55C1-0BE2-4132-94A8-BD397C2C7A5C)
Subject:
[External_Sender] Comments concerning CISF, NUREG-2237 Sent Date: 9/22/2020 7:05:38 PM Received Date: 9/22/2020 7:05:50 PM From: Paige Murphy-Young Created By: pmurphyyoung@gmail.com Recipients:
Post Office: gmail.com Files Size Date & Time MESSAGE 5783 9/22/2020 7:05:50 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: