ML20269A397
| ML20269A397 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/23/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20269A397 (5) | |
Text
From: Katrina@theNWSC.org Sent: Tuesday, September 22, 2020 7:53 PM To: Holtec-CISFEIS Resource Cc: Borges Roman, Jennifer; Kock, Andrea; Lubinski, John; Vietti-Cook, Annette; Caverly, Jill
Subject:
[External_Sender] NWSC Comments on the Holtec International HI-STORE Consolidated Interim Storage Facility Attachments: NWSC Comments re NRC Draft EIS on Holtec CIS 092220.pdf The Nuclear Waste Strategy Coalition (NWSC) appreciates the opportunity to provide the attached comments on the Nuclear Regulatory Commissions (NRC) Draft Environmental Impact Statement (DEIS) for the proposed Holtec Consolidated Interim Storage Facility (CIS) facility in southeast New Mexico.
Thank you for your consideration, Katrina Katrina McMurrian Executive Director Nuclear Waste Strategy Coalition (NWSC)
Katrina@theNWSC.org
Federal Register Notice: 85FR16150 Comment Number: 4641 Mail Envelope Properties (014001d6913b$8be05080$a3a0f180$)
Subject:
[External_Sender] NWSC Comments on the Holtec International HI-STORE Consolidated Interim Storage Facility Sent Date: 9/22/2020 7:53:17 PM Received Date: 9/23/2020 12:35:24 AM From: Katrina@theNWSC.org Created By: Katrina@theNWSC.org Recipients:
Post Office: theNWSC.org Files Size Date & Time MESSAGE 485 9/23/2020 12:35:24 AM NWSC Comments re NRC Draft EIS on Holtec CIS 092220.pdf 235721 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Sarah Hofmann, Chair Commissi oner, Vermont Publi c Utilit y Commi ssi on Julie I. Brown, Membership Officer Commissioner, Florida Publi c Service Commission Robert W. Capstick, Jr., Finance Officer Direct or of Regulatory Affairs, 3 Ya nkee Companies Jonathan Hirte, Communications Officer Federal Affai rs Specialist , DTE Energ y Mike Huebsch, Ex-Officio President, Huebsch Consulting Group LLC September 22, 2020 Office of Administration Mail Stop: TWFN-7-A60M ATTN: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via email to: Holtec-CISFEIS@nrc.gov Re: NWSC Comments on Holtec International HI-STORE Consolidated Interim Storage Facility Project Draft Environmental Impact Statement (85 FR 16150, published March 20, 2020)
Docket ID NRC-2018-0052
Dear Program Management,
Announcements and Editing Staff:
The Nuclear Waste Strategy Coalition (NWSC) 1 appreciates the opportunity to provide these comments on the Nuclear Regulatory Commissions (NRC) Draft Environmental Impact Statement (DEIS) for the proposed Holtec Consolidated Interim Storage Facility (CIS) facility in southeast New Mexico. The NWSC closely follows the issues relating to the NRCs review of license applications for proposed CIS facilities.
General While not taking a position on any specific CIS projects at this time, the NWSC is encouraged by this and other proposals to develop private CIS facilities in areas with substantial community support. We note that in all cases examined in the DEIS, the costs of the proposed action (Phase 1 of the project) were less than the costs of the No-Action alternative. Of course, the No-Action alternative reflects the status quo of federal government inaction on nuclear waste removal from both shutdown and operating reactor sites across our country.
1 The NWSC is an ad hoc organization representing the collective interests of member state utility regulators, consumer advocates, attorneys general, and radiation control officials; tribal governments; local governments; electric utilities with operating and/or shutdown nuclear reactors; and other experts on nuclear waste policy matters. Our mission is to ensure (i) the timely, safe, and cost-effective removal, transport, storage, and permanent disposal of spent nuclear fuel (SNF) and reactor-related Greater-Than-Class C (GTCC) waste stranded at numerous operating and shutdown commercial reactor sites in our states and communities; and (ii) sustainable access to the Nuclear Waste Fund (NWF)both the substantial payments by electric customers and accrued interestfor its intended purpose under the Nuclear Waste Policy Act (NWPA).
Public & private sector members collaborating to spur federal action to timely remove and dispose of nuclear waste and protect electric customers.
September 22, 2020 NWSC Comments Page 2 Need for Integrated Program (Removal, Transport, Storage & Permanent Disposal)
The NWSC continues to call on the federal government to end the decade-long de facto policy of indefinitely stranding spent nuclear fuel (SNF) and high-level radioactive waste (HLW) in states and communities without their consent, to deliver on what was promised to electric customers in return for billions of dollars in payments to the Nuclear Waste Fund (NWF), and to protect all U.S. taxpayers from billions of dollars of additional damage payments. The best way for the government to do that is to provide sustainable annual access to the NWF and simultaneously reestablish a national integrated nuclear waste management program containing the following three critical elements:
x Completion of the Yucca Mountain Licensing Review. The NRC and U.S. Department of Energy (DOE) should proceed with the adjudicatory process outlined in the Nuclear Waste Policy Act (NWPA) for evaluating scientific and technical evidence and determining whether the license application for the proposed repository should be granted. Failure to move forward on permanent disposal in parallel with interim storage could prove detrimental to CIS projects because interim host communities repeatedly express an unwillingness to becomeand, based on the lack of progress on a permanent solution, a fear of becomingde facto permanent hosts.
x Implementation of Pilot CIS with Priority for SNF from Shutdown Reactors. A pilot CIS facility with priority for SNF and reactor-related Greater-Than-Class C (GTCC) waste stranded at shutdown sites would (i) enable the government to begin meeting its obligations sooner; (ii) allow for other use of decommissioned reactor sites; and (iii) develop and exercise the countrys SNF transportation infrastructure. While not considered a pilot facility, Phase 1 of the proposed CIS facility is expected to address these objectives.
x Preparation for SNF Transportation. SNF transportation infrastructure and proper coordination with all levels of government will be necessary regardless of destination. Thus, the NWSC supports (i) testing, certification, and procurement of rail cars and licensed transportation casks and components (using the private sector to the maximum extent practicable); and (ii) increasing financial and technical assistance to tribal, state, and local governments for transportation and related emergency preparedness activities.
Benefits of CIS as Part of Integrated Program CIS for SNF stranded at shutdown sites is necessary because of the governments inaction, but CIS is not an alternative to disposal. A geologic repository is the necessary national solution for SNF disposal. However, CIS offers potential benefits as part of an integrated waste management program, including:
x Beginning to fulfill the federal governments statutory and contractual obligation to remove SNF from nuclear power reactor sites in return for substantial electric customer payments and thereby demonstrating progress in SNF management.
x Reducing federal government liabilities to utilities for extended SNF storage (thus, also reducing the U.S.
taxpayer burden and the federal deficit).
x Eliminating SNF at shutdown reactor sites, thus allowing complete decommissioning and land reuse for host communities now storing this stranded material.
x Developing and exercising a national SNF transportation infrastructure.
x Precluding or minimizing the need to begin or expand SNF storage at reactor sites.
x Providing a buffer and staging area for other facilities, such as a geologic repository.
Public & private sector members collaborating to spur federal action to timely remove and dispose of nuclear waste and protect electric customers.
September 22, 2020 NWSC Comments Page 3 Transportation Transportation of nuclear waste from reactor sites will be necessary regardless of whether SNF is sent to a CIS facility for temporary storage before permanent disposalor directly to permanent disposal. Provided that transportation is conducted in accordance with relevant regulations, transportation should not serve as an impediment to CIS or disposal projects.
In addition to NRC and other federal oversight, we also note the important roles of state, tribal, and local governments regarding nuclear waste transportation, public safety, and emergency preparedness and response.
To provide the public greater assurance that the health, safety, and welfare of communities will be preserved as SNF is transported, the NWSC encourages SNF licensees/shippers to coordinate with state, tribal, and local officials.
Finally, we highlight the established safety record of SNF transportation as documented in the following resources that we hope are useful to the NRC and the public:
x A Historical Review of the Safe Transport of Spent Nuclear Fuel. Kevin J. Connolly (Oak Ridge National Lab) and Ronald B. Pope (Argonne National Lab) for U.S. Department of Energy. August 31, 2016:
https://www.energy.gov/sites/prod/files/2017/03/f34/Enhanced%20safety%20record%20report%20-
%20final%20public%20release_0.pdf.
x 5 Common Myths About Transporting Spent Nuclear Fuel. U.S. Department of Energy Office of Nuclear Energy. May 26, 2020: https://www.energy.gov/ne/articles/5-common-myths-about-transporting-spent-nuclear-fuel.
x Going the Distance?: The Safe Transport of Spent Nuclear Fuel and High-Level Radioactive Waste in the United States. Transportation Research Board and National Research Council. 2006. Washington, DC:
The National Academies Press: https://doi.org/10.17226/11538.
x Safety of Spent Fuel Transportation. NUREG/BR-0292, Rev. 2. U.S. Nuclear Regulatory Commission.
February 2017: https://www.nrc.gov/docs/ML1703/ML17038A460.pdf.
In its 5 Common Myths About Transporting Spent Nuclear Fuel, DOE notably states, More than 2,500 SNF shipments have been transported around the country without any radiological incidents over the past 55 years.
Thank you for your consideration of our comments and for your considerable outreach efforts and opportunities for public comment. Should you need additional information, please contact me at katrina@theNWSC.org.
Sincerely, Katrina J. McMurrian NWSC Executive Director Public & private sector members collaborating to spur federal action to timely remove and dispose of nuclear waste and protect electric customers.