ML20269A414
| ML20269A414 | |
| 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: ML20269A414 (4) | |
Text
From:
Diane D'Arrigo <dianed@nirs.org>
Sent:
Wednesday, September 23, 2020 12:05 AM To:
Holtec-CISFEIS Resource
Subject:
[External_Sender] NIRS Comments on NRC 2018-0052 DEIS Holtec CISF Attachments:
Comments of Nuclear Information and Resource Service. Holtec CIS DEIS NRC 2018-0052docx.pdf
Federal Register Notice:
85FR16150 Comment Number:
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[External_Sender] NIRS Comments on NRC 2018-0052 DEIS Holtec CISF Sent Date:
9/23/2020 12:05:01 AM Received Date:
9/23/2020 12:05:16 AM From:
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9/23/2020 12:05:16 AM Comments of Nuclear Information and Resource Service. Holtec CIS DEIS NRC 2018-0052docx.pdf 621960 Options Priority:
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Comments of Nuclear Information and Resource Service on the Draft Environmental Impact Statement for the Application by Holtec International for a License to Construct and Operate a Consolidated "Interim" Storage Facility for Irradiated Nuclear Fuel and High Level Radioactive Waste Docket No. 72-1051 NRC-2018-0052 September 22, 2020 Holtec-CISFEIS@nrc.gov The proposed Holtec site would concentrate well over 90% of the radioactivity in the whole US nuclear power and weapons fuel chain--moving all of that radioactivity throughout the nation to a supposedly temporary site. It would be one of the largest nuclear facilities in the world, larger than the cancelled Yucca Mountain site and would bring orders of magnitude more nuclear radioactivity into NM than is already there at its many nuclear facilities. More time and more public participation are essential.
NIRS continues to call for more time for more of the affected public to learn and comment. The whole process should be suspended or extended until 6 months after the COVID-19 crisis ends to enable public meetings--in person--when safe--along all the transport routes as well as the promised meetings in New Mexico.
These comments summarize the NIRS comments made at the DEIS webinars regarding our objection to the illegality of NRC processing license applications for Consolidated "Interim" Storage sites in absence of an operating permanent repository and other provisions in the Nuclear Waste Policy Act and Amendments Act (We support Beyond Nuclear's specific comments on this.)
the inadequacy of the federal NRC licensing criteria for Type B transport containers which are being certified by NRC to standards clearly less than real road, rail and barge conditions (We support the comments of Dr Marvin Resnikoff, the State of Nevada Agency for Nuclear Projects and the Western Interstate Energy Board on this.)
the lack of analysis of additional challenges in transport and storage of high burn-up fuel and damaged fuel and preposterous plan for damaged or leading containers to be sent back to their origin over roads, rails and waterways rather than managed at the site failure to provide any shielded system or facility (wet or dry) to re-containerize or repair damaged, leaking and compromised casks and canisters such as a fuel pool or dry transfer facility (We support the comments of Attorney Terry Lodge on this point.)
failure to review and consider the fraud and corruption of Holtec itself and of its partner companies (SNC Lavalin, guilty of fraud, corruption and bribery and banned from international contracts for 10 years, and Tetratech, with its history of corruption including deliberate falsification of samples at Hunter's Point, California, and sending radioactive waste to unregulated places for years, upon whose data some of the Holtec NM Environmental Impact Statement is based) and apparently illegal interactions at the local/regional/state level with the Eddy Lea Energy Alliance as detailed by local residents (We support the comments of Beyond Nuclear and Nick Maxwell on this.)
I am also submitting a copy of letter from the Union at Indian Point questioning Holtec's capabilities.
denial and failure to consider in the DEIS the likelihood of the site becoming de-facto permanent--
NRC and Holtec incorrectly assume that the canceled Yucca Mountain site would be licensed as a final repository to which all the Holtec waste would eventually move--Yucca, cancelled over 10 years ago, was proposed to take 70,000 metric tons uranium (MTU) but the Holtec license with expansions would have 173,600 MTU failure to consider the likelihood of the site being used for reprocessing and the inevitable irreversible environmental contamination and damage that would result (based on every other reprocessing site in the world) failure to honestly and realistically analyze all of options required by the National Environmental Policy Act including massively improved at-and near reactor interim storage (We support Sierra Club's comments on this.)
incorrect information about the existence of the license for Private Fuel Storage (Goshute land, Utah) which never opened for consolidated "interim" storage or monitored retrievable storage at least partly due to conditions similar to this license--that nuclear waste owners will not utilize such a site if they must keep title and liability. DOE cannot take title and liability until a permanent site is operating.
failure to reassess potential impacts in New Mexico of the Holtec storage system in light of revelation of routine cask gouging and scratching (which will accelerate deterioration and loss of integrity) during insertion and removal of containers from the system at San Onofre and other Holtec storage facilities.
failure to fully assess the long term potential impacts on water and other natural resources of prolonged storage and even legal levels of leakage (We support New Mexico's comments on this.)
NRC's determinations of "Small" impacts ignore the risks of radiation, especially the disproportionately higher risks to females and youth, and rely on unjustified assumptions about probability and consequences. (We support the comments of Barbara Warren, Citizens' Environmental Coalition, on this including the NRC's denial of one of the laws of physics, entropy.)
In this era of facing the structural racism in our culture and our nation's history, it is time for NRC and the industry to do their parts. Do not send the worst nuclear power waste to minority communities with minimal if any use of nuclear energy. NRC's ASLB judges dismissed the interventions of the local group (Alliance for Environmental Strategies) based on environmental justice. The Environmental Impact Statement should not repeat that mistake.
We object to overall minimal time during major worldwide pandemic however the rush to finish before the end of the covid-19 major disruption to life as we know it is unacceptable. We reiterate the request for in-person meetings and suspension or extension of the process until 6 months after the end of the Covid-19 crisis.
Submitted 9-22-2020 via Diane D'Arrigo, Nuclear Information and Resource Service