ML20269A224
| ML20269A224 | |
| 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: ML20269A224 (7) | |
Text
From: Patricia Cardona <patriciacardona24@yahoo.com>
Sent: Tuesday, September 22, 2020 10:42 PM To: Holtec-CISFEIS Resource Cc: John Buchser
Subject:
[External_Sender] NUREG-2237, Docket ID NRC-2018-0052, Holtec DEIS Attachments: DEIS Response to NRC.docx
Federal Register Notice: 85FR16150 Comment Number: 4606 Mail Envelope Properties (E5DF3DCD-747D-46C8-9AAD-CBB302B941D5)
Subject:
[External_Sender] NUREG-2237, Docket ID NRC-2018-0052, Holtec DEIS Sent Date: 9/22/2020 10:42:22 PM Received Date: 9/22/2020 10:42:49 PM From: Patricia Cardona Created By: patriciacardona24@yahoo.com Recipients:
Post Office: yahoo.com Files Size Date & Time MESSAGE 2 9/22/2020 10:42:49 PM DEIS Response to NRC.docx 2206464 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
To: Nuclear Regulatory Commission Re: NUREG-2237, Docket ID NRC-2018-0052, Holtec DEIS I am a resident of New Mexico and I do not support the Proposal by HOLTEC, International for establishing a Consolidated Interim Storage Site in Southeastern New Mexico. The HOLTEC Storage Site is being marketed by NRC and HOLTEC as temporary and for use before transferring high-level waste to the Yucca Mountain Repository for permanent storage.
Yucca Mountain, has geological and socio-economic characteristics making it unsuitable as a permanent repository. Congress has not funded the repository for over ten years.
My major objections are:
- 1. New Mexico faces major economic impacts to our businesses and revenue for state services which are being ignored in Section 3.2 Land Use in the DEIS.
There are no mitigation measures proposed for the foreseeable losses to state revenues and individual jobs (with a fixed skill set) under Title 40 of the Code of Federal Regulations (CFR) 40 CFR 1508.20, for compensating for losses. NRC acknowledges all the industries in the area but without looking at the industries and the jobs provided residents and revenues for the state of New Mexico.
The DEIS ignores the split estate with the potash mine with the State Land Office revenues and federal tax revenue from the potash mines. Potash is used as a fertilizer by 80% of the United States. There is no provision for mitigating the loss of jobs and revenue from mineral rights near the proposed storage sight.
The HOLTEC Storage site seems to be a permanent economic liability for New Mexico as illustrated by the following the following rough estimate of risks to jobs and revenue:
Tourism: (Source: National Park Service Eddy- Lea County 2017)
Total Jobs: 12,221 Revenue: $416,600,000/year Agriculture /Crops (Source: Study by New Mexico State University 2013 Study)
Total Jobs: 4,042 Revenue: $840,845,110/year Agriculture/ Food Processing (Source: Study by New Mexico State University 2013 Study)
Total Jobs: 1,697 Revenue: $662,629,530/year
Potash Mine (excludes Federal Lands portion) (Department of Energy and Minerals and Natural Resources 2018)
Direct Jobs: 724 State Revenue: $283,353,622/year Oil and Gas (Eddy) (Source: Eddy County Finance Director 2018)
Eddy County Direct Jobs: 1,438 State Revenue: $1,443,038,911/year Oil and Gas (Lea County) (Lea County Economic Development Corporation 2018)
Direct Jobs: 980 State Revenue: $1,938,140,772/year Total Jobs at Risk 21,102 Total State Revenue/at Risk $ 5,584,607,991/year HOLTEC Jobs and Revenue Permanent Jobs 50 Temporary Jobs 100-200 Revenue Eddy /Lea County 15-25 million(split with HOLTEC)
State Revenue Loss NONE Jobs 50 ( 21,052 at Risk)
Transitioning an economy and jobs needs to be done in a planned logical manner by creating diversity in new businesses needed to support the current workforce in the area without damaging the environment. This is 2021 we need to use our technology to stabilize our natural resources.
Consolidated Interim Storage transfers pollution from 33 points of origin to an area where Hispanics comprise the majority of the population placing a heavy burden on one group. Transferring liabilities from 33 points of origin to one is equally alarming. The transfer of 173,000 metric tons of high-level radiation from 33 states to one area of New Mexico
/Texas border does not pass the sniff test for fairness for any of its residents, Hispanic, White, Black, Indigenous or Asian. Table 5.1-1 on Environmental Justice states that there is no disproportionate impacts the facts prove otherwise and the findings are disingenuous.
The DEIS and the label Consolidated Interim Storage erases the transfer of economic and health liabilities to New Mexico and Texas by omitting data on above normal radiation
levels from the other three radiation emitting business in the area; URENCO, WIPP and WCS.
Where is the data per reactor site, where is the data on URENCO, WIPP and WCS? This DEIS needs to be completed in a systematic scientific manner.
2 The Callan Institute 2019 audit of 2018 Decommissioning funds available found as of December 31, 2018 Investor owned utilities were 15-24 billion short of the decommissioning funds and the public power companies were 5-7 billion short of their decommissioning funds.
This shortage creates conditions for sacrificing public safety by avoiding the use of financial resources to purchase the best available technology for the Waste Containers and Facility. As the NRC staff should know by going on- line the Swiss build waste containers that can last at least 1000 years. In addition, the Swiss build their interim facilities to allow for inspection of the waste containers and can monitor for leaks. Their system is underground and the surface is unremarkable. See Photos below of their storage system.
The amounts for construction provided in C.3 at the end of the DEIS have little meaning without providing a detailed account of the materials being used for construction of the site.
HOLTEC has stated several times that it intends to share 15-25 million in revenue sharing with Eddy-Lea Alliance. The explanation of costs leaves out this exchange of profits Figure 3 - Holtecs mockup of its plan to store high-level nuclear fuel rods, partially underground and partially above ground. Photo courtesy Holtec
The DEIS has insufficient facts to determine whether there are safety features being left out of the design and construction of the building. It is also difficult to believe that ratepayers would accept the sharing of 15-25 million in revenue between Holtec and Eddy-Lea Alliance is prudent use of their money.
My comments cover only a few of the elements in the DEIS. I oppose this project and think that NRC needs to do a complete EIS on this proposed project in the areas I presented as well as those of other commenters.
In addition, there needs to be a full public in person hearing of this project in Eddy-Lea Counties, Albuquerque, Gallup and other cities in New Mexico and across the country where the routes will be placed if the proposed project is constructed once the COVID Emergency is fully abated. Common sense says transport this dangerous high level radiation only once. Use the best available technology for the waste containers and storage design, equip the facilities to be able to repair leaking canisters for the thousands of years required for isolating the dangerous material..
Sincerely, Patricia Cardona patriciacardona24@yahoo.com