ML20269A398
| ML20269A398 | |
| 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: ML20269A398 (6) | |
Text
From: Laura Watchempino <5000wave@gmail.com>
Sent: Wednesday, September 23, 2020 2:04 AM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Docket ID NRC-2018-0052 Attachments: Holtec CIFS EIS.docx
Federal Register Notice: 85FR16150 Comment Number: 4642 Mail Envelope Properties (CAL8qOBEQMnNFQbt-imiWR-OVxzXgMqx3uZQR7wHQF2UpRiGEPA)
Subject:
[External_Sender] Docket ID NRC-2018-0052 Sent Date: 9/23/2020 2:04:26 AM Received Date: 9/23/2020 2:04:46 AM From: Laura Watchempino Created By: 5000wave@gmail.com Recipients:
Post Office: mail.gmail.com Files Size Date & Time MESSAGE 0 9/23/2020 2:04:46 AM Holtec CIFS EIS.docx 23217 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
September 20, 2020 Email: Holtec-CISFEIS@nrc.gov Re: Docket ID NRC-2018-0052 EIS for Holtec Internationals Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste, Draft Report for Comments, March 2020
Background:
The NRC analysis was limited to an initial phase of storage (500 canisters over a 40 year license period),
though bounding analysis assumes storage of up to 10,000 canisters of Spent Nuclear Fuel (SNF) without a corresponding license period for expanded storage.
The EIS should cover a total licensing period of at least 60 years, up to 120 years, with all anticipated renewals encompassed within the bounding analysis versus the operational life of the proposed project.
If the operational life of the project does not exceed 40 years, what will happen when that threshold is reached? Because the threat to human health from SNF and high level waste are expected to outlast even 120 years, Holtec International should be required to provide a plan for contingencies that will arise as the expected life of each operational phase is reached.
Purpose and Need for Project No need has been demonstrated at any of the reactor sites to put land to any particular use after the sites are decommissioned that would necessitate an immediate consolidation of all the nations high level nuclear waste at one interim storage site, only to be moved a second time once a permanent repository for the waste has been designated.
Holtec Internationals (Holtec) proposal for consolidated interim storage runs afoul of the Nuclear Waste Policy Act amendments of 1982 as amended, which mandate the operation of a permanent repository before the government can assume responsibility for the transportation and storage of SNF and other high level waste.
Holtec does not propose to assume any responsibility for accidental releases during transportation of SNF or during long-term storage of the waste.
Holtecs proposal interjects an unnecessary step, consolidated interim storage, on the road to the permanent deep geologic storage that is required to isolate this dangerous waste and the persistent risks it poses, from humans and the environment for eons.
Construction, Operations, and Decommissioning and Reclamation Although Holtec is required to submit a decommissioning plan in accordance with 10 CFR 72.54(d),
72.54(g), and 72.54(i), the NRC is not requiring Holtec to submit one until some unspecified future date, surmising that reclamation and decommissioning is likely to take place well into the future, and that technological changes that could improve the decommissioning and reclamation processes cannot be predicted. The NRC has limited its analysis of Holtecs project to a 40-year licensing period without a
decommissioning plan until well into the future, when it will undertake a separate NEPA review of Holtecs decommissioning and reclamation plan.
Exempting Holtec from the requirement to submit a Decommissioning and Reclamation Plan for this project at the outset, which can be amended if and when new technology becomes available, indicates that the NRC fully expects to grant future back-to-back license amendments for the operation of this CISF well into the future. Without a Decommissioning and Reclamation Plan, however, Holtec or another operator stepping into the shoes of Holtec should Holtec become insolvent or otherwise fail to carry out operations in compliance with its license, can leave the site unreclaimed.
Decommissioning activities, in accordance with 10 CFR Part 72 requirements that involve radiological surveys and decontamination, are an integral part of Holtecs radioactive materials license and cannot be jettisoned by the NRC. Failing to require a Decommissioning and Reclamation Plan as part of Holtecs license application may also involve an implicit recognition by the NRC that decontamination of a site storing the nations most dangerous high level nuclear waste for a prolonged period of time on the scale proposed in this EIS is simply not possible.
Transportation Impacts The EIS does not cover radiological exposures to the public from leaking canisters of SNF, only impacts to workers and the public associated with incident-free SNF transportation. At least one train derailment or other incidental accident with radiological impacts should have been analyzed in the EIS. Yet no special training programs for responding to radiation releases or coordinated plan of action for state, local and federal oversight has been offered for analysis.
Instead the EIS and Holtec's Environmental Report artificially excluded the high risks involved in transporting SNF and high level waste throughout a majority of states along major transportation hubs.
Yet the dangers posed during the loading and unloading of canisters containing SNF and high level nuclear waste from current interim disposal sites near reactors to transport vehicles and again during unloading of the transport vehicles in New Mexico and during placement at the new interim storage site in southeastern New Mexico exponentially magnifies the risks to a large segment of American population residing in both major urban centers and thousands of smaller communities along transportation corridors.
This is an example of segmentation (the dividing up of a major federal action into smaller parts to lessen the significance of a projects impacts). This is a violation of the National Environmental Policy Act of 1969, as amended, and has been ruled so by the federal courts.
The EIS analysis should have covered the projects entire footprint from interim reactor site to interim storage site and the entire period of storage, from an initial 40 years, with 19 additional phases over another 20 years, including:
Aging rail transport systems not designed for the heavy loads being proposed must be upgraded to safeguard the many communities through which they will pass for 60 years; and
Increased greenhouse gas emissions from transporting SNF and high level nuclear waste to the interim storage site in southeastern New Mexico will also have direct and significant impacts on climate change over a period of 40-120 years.
Environmental Justice The designation of New Mexico as a destination for more nuclear material without consent from the state, tribal governments, or disproportionately impacted communities that continue to experience legacy impacts from the Manhattan project, uranium production in the Grants Mining District, and the Trinity bomb test is not analyzed in the EIS.
Cultural impacts to Jornada Mogollon ancestral site with 200 archaeological sites, with affiliation to the Hopi and Mescalero Nations should have been analyzed with tribal consultation. Cultures cannot be viewed through the eyes of a dominant culture that does not recognize the importance of preservation and diversity.
The unique ecosystems in the project area must be viewed through the people and cultures who depend on them.
HOLTEC Canisters Holtecs thin walled canisters, in comparison to thick-walled ones used elsewhere, are prone to corrosion and cracking (San Onofre) during emplacement, removal, transport and re-interment.
Multiple transfers of these thin-walled canisters during transport could damage the canisters. Yet the NRC is not requiring Dry Transfer Systems (DTS), to deal with failed fuel, containers, or contamination.
While the use of DTS to repackage SNF carries significant risks and safety impacts to health and the environment, it could not be done without a DTS. The entire complex, high risk subject matter area is missing from the EIS, another violation of NEPA's "hard look" requirement.
No Action Alternative This alternative would leave SNF and high level waste at the reactor sites where it is generated and should remain the status quo until the nation makes a decision on permanent disposal. The need for a permanent waste disposal site continues to grow without a viable solution, putting all residents in the United States and our environment at risk. Interim disposal only adds to the scope and magnitude of the risk.
Removing the SNF and high level waste a second time to a permanent disposal site after 40 to 120 years will be foreclosed by the age and deterioration of the canisters from weathering and corrosion, along with all damages incurred during removal of the canisters from current interim storage sites near reactors, during transport, and during placement into the proposed new interim storage site.
No Action should be the Preferred Alternative due to the unmet need for permanent deep geologic disposal of SNF and high level waste. before transporting this lethal waste across the country on aging infrastructure that was not designed to move dangerous nuclear material in concert with other types of dangerous volatile waste and ordinary commercial goods in the EIS.
Holtec Internationals proposal for consolidating all the nations high level waste in New Mexico must be viewed with skepticism. Holtec International must be subjected to a background check to uncover all actual and potential violations of law. Especially important is its history of compliance with all applicable safety regulations and administrative regulations that bear upon its capacity to self-assess its weaknesses and take corrective action, all of which should be undertaken with public scrutiny.
Thank you for considering my comments, L. Watchempino P.O. Box 407 Acoma, NM 87034