ML20269A109

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Comment (4590) E-mail Regarding Holtec-CISF Draft EIS
ML20269A109
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: ML20269A109 (4)


Text

From: Protecting NM From All Things Nuclear

<protectnewmexico@gmail.com>

Sent: Tuesday, September 22, 2020 11:04 PM To: Holtec-CISFEIS Resource Cc: Diane D'Arrigo

Subject:

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

Dear NRC Staff,

The following comments were transcribed from the video recording of the Peoples Hearing held by the Nuclear Issues Study Group on Wednesday, September 16, 2020 (Available online: https://www.youtube.com/watch?v=CfCBsXCQyOU). These written comments are being submitted with the consent of the commenters. The transcription was made possible by the work of the Nuclear Issues Study Group volunteers.

Comment sent on behalf of:

DIANE DARRIGO Hi, I'm Diane DArrigo. Im with Nuclear Information and Resource Service. We're based in the Washington, D.C. area. And I'm originally from Western New York, which has one of the sites that already exists, that at one point concentrated high level commercial nuclear waste. There are places in Illinois, South Carolina, and New York that did that and the location at West Valley. This was done in the 1960s to 70s, and today in 2020, we are still groveling every year to the federal government to provide us money to help that site from getting worse. It was supposed to be a boon, jobs, progress, and roads.

And it ended up being a major nuclear waste mess with both high and low level commercial and weapons waste that threatens not only the immediate community, but in time, the site itself will erode into the streams that cut through it and into the Great Lakes and threaten Western New York and Canada and so forth. Thats where I learned about nuclear waste and I have learned now over the years, that the lessons that we learned as the general public are not learned by the powers that be. The Nuclear Regulatory Commission's job is to provide a license to any applicant who submits the license and meets the criteria that the Nuclear Regulatory Commission has set out. So the fact that it's illegal, and this Kevin Kamps earlier mentioned, the fact that it's illegal to even have such a dump because there's no permanent placethe law does not allow a temporary place if there isn't an operating permanent place. The fact that it's illegal has not stopped the Nuclear Regulatory Commission from proceeding to spend resources to process the application. So, this is the comment that you'll be providing to the NRC for me. What I would say to the NRC is once again, as we've said before, to back off, to suspend these licenses, both of these CIS consolidated supposedly interim" storage licenses, until such a facility is even is legal. At this point it is not legal, and they should not be proceeding with it. So that's some of the background. The whole purpose of this site is to facilitate nuclear power. Nuclear power threatens our health, our environment,

our economy, and our democracy. It threatens us in every way. It's also, as has been brought up before, a clear evidence of environmental racism and environmental injustice. The radioactivity that is created in nuclear power in the fuel rods in the core of a nuclear reactor after those reactors operate and the waste is generated, theres, 90%

of all of the radioactivity in the whole nuclear fuel chain is in those rods. So, we have uranium mining and milling and conversion and fuel fabrication and reactor operation and then waste management and storage, and all along that way, radioactive waste is generated. We also have that similar fuel chain to make nuclear weapons. We have mining and milling and processing of, creation of, fuel fabrication and reactors, and the nuclear weapons production. If you take all of that radioactivity, and you have in New Mexico several major nuclear facilities at Los Alamos, at Sandia, and the weapons that are near the airport, and the LES uranium enrichment facility, and other nuclear facilities in the state; the amount of radioactivity in those big nuclear centers, that amount of radioactivity is dwarfed by the amount of radioactivity that is targeted to come into New Mexico to this site. This site, it was mentioned earlier, it would be potentially the largest nuclear waste site in the world, most radioactivity. And, so what we are talking about is, even though there have been shipments in the past of nuclear waste on our roads, rails and waterways, there will be an exponential increase in the amount of radioactivity, in the concentration of radioactivity, in the amount of radioactivity per shipment. We're talking about thousands of shipments, regularly across this country, through potentially 44 states and the District of Columbia, coming in through Eunice largely, to the Holtec site, and it would be more than 90 percent of all the radioactivity that has been generated in the country, from all of the nuclear power and weapons processes. This is, far and away, the largest amount of radioactivity and movement of radioactivity that has ever happened in the world. And so its not to be sneezed at, its not to be dismissed as insignificant. Our concerns are very well warranted. There is no way that the potential consequences of this site are small" or moderate." That is a scientific fabrication, mis-fabrication of science, of supposedly scientific information. So New Mexico, even though it's a big nuclear state, this would be a lot more radioactivity coming in. The amount of transport, the amount of radioactivity in transport, in the whole country is dramatically increased. And then the other thing I wanted to share, which has come up in the previous Nuclear Regulatory Commission meetings on this, and then Ill close, is the corruption that's involved in making this site happen. There's the information that was provided to the New Mexico attorney, to the official office in New Mexico, that is not as we understand yet been processed about illegal interactions between the Eddy Lea Energy Alliance and Holtec, and that community on the local and state level. And then, there are problems and fraud in the Holtec companys interactions on the state level.

They have taken money from tax breaks in New Jersey that they got through lying on their application, about not having violated laws, and that money is potentially being used to proceed to get this application done. They are also allied with TetraTech which is a company that's been found in California to have provided misinformation on the amount of radioactivity at that site, sent nuclear waste to non-radioactive places, exposed workers, and done some of that intentionally. And then finally theyre in alliance with a company in Canada SNC Lavalin which has been forbidden from even bidding on contracts for ten years, because of their previous illegal misdoings. So we've got corruption and fraudulence and illegal actions on top of the dangers, the

misinformation. And last point is that the Nuclear Regulatory Commission is holding this Draft Environmental Impact Statement process to review the environmental impacts under the National Environmental Policy Act. The National Environmental Policy Act requires that a no-action alternative be looked at. So theyre supposed to look at what would happen if they didn't proceed and compare that, the impacts if they did proceed.

So the NRC did not look at what would happen if there was no CIS consolidated storage. All they looked at is different options for consolidated storage. They did not look at not proceeding with it, and holding the waste near or at its current sites until permanent management is developed. Thanks.

Nuclear Issues Study Group www.fb.com/NuclearIssuesStudyGroup

Federal Register Notice: 85FR16150 Comment Number: 4590 Mail Envelope Properties (E42B2A04-2102-49F7-BFBB-14950C792CB8)

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