ML20163A729
| ML20163A729 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/11/2020 |
| From: | Holtec |
| To: | NRC/OCM |
| SECY RAS | |
| References | |
| ASLBP 18-958-01-ISFSI-BD01, RAS 55706, Holtec International | |
| Download: ML20163A729 (2) | |
Text
Exhibit 1
Holtec SAR1 Holtec ER2 Holtec DEIS3 recent records (1998 through 2005) from the WIPP seismic monitoring network indicate the strongest events recorded annually in 1999, 2000, and 2002 through 2005 (typically of 2.5 to 4.0 magnitude) located about 50 miles west of the Site The Site is located in an area of low seismic hazard. (at 4-5); review of seismic riskbased on (USGS 2009) &
(Powers et al., 1978) closest earthquake to the proposed CISFoccurred on March 18, 2012magnitude of 3.1 (at 3-23)
MAGNITUDE 5.0 ON MARCH 26, 2020 OUTSTANDING NRC RAIS UNANSWERED BY HOLTEC Justify not incorporating site-specific subsurface geologic and geophysical properties through a site response analysis for development of the site-specific
[DBE][g]iven the lack of site-specific hazard development, [Holtecs] exceedance of [design basis earthquake (DBE)] should be justified4 potential future drilling on the Site, Holtec has an agreement with Intrepid Mining LLC (Intrepid) such that Holtec controls the mineral rights on the Site and Intrepid will not conduct any potash mining on the Site.
(at 2-12) potential future drilling on the Site, Holtec has an agreement with Intrepid Mining LLC (Intrepid) such that Holtec controls the mineral rights on the Site and Intrepid will not conduct any potash mining on the Site.
(at 3-2)
Holtec... is in discussions with the New Mexico State Land Office regarding an agreement to retire potash leasing and mining within the proposed CISF project area. (at 5-24)
OUTSTANDING NRC RAIS UNANSWERED BY HOLTEC The application should discuss the rationales for the conclusion that potash would not be extracted under and around the site during the licensed life of the project. (Id. RAI 2-12)
Subsidence from mining creates voids that cause collapse of strata above the mining level (at 2-9); a few brine wells in Eddy Countysuffered catastrophic collapse causing sinkhole development at the surface. (at 2-11); several examples in the Permian Basin of catastrophic subsidence as a result of oil field casing corrosion and dissolution of salt (at 2-9)
Risks from... subsidence...
are considered to be low (at 4-5).
areas of distinct subsidence the study identified are located approximately 16 km
[10mi] of the proposed CISF project (at 3-27).
thickness of alluvial material sitewide and the existence of groundwater within the alluvium, both laterally and temporally, is insufficiently described in the DEIS.principally due to.limited geotechnical characterization at the site; [Holtec] DEIS insufficiently characterizes the Chilne Formation situated within the upper portion of the Dockum Group and the probable importance of the Formation in monitoring the environmental impact of the CISF. 5 There are no active wells on the Site and there are no plans to use any of the plugged and abandoned wells on the Site (at 2-3)
There are no active wells on the Site and there are no plans to use any of the plugged and abandoned wells on the Site (at 4-2); Risks from... subsidence...are considered to be low (at 4-5)
There is one active oil/gas well on the southwest portion of Section 13 that operates at minimum production to maintain mineral rights. (at 3-7)
NO NEGATIVE EASEMENTS PRESENTLY ON LEASES BELOW OR SURROUNDING SITE 1 Holtec SAR, Rev. 0H, Docket No. 72-1051, (March 30, 2019) (ADAMS Accession No. ML19163A062) (emphasis added).
2 Holtec ER, Rev. 7, Docket No. 72-1051 (August 2019) (ADAMS Accession No. ML19309E337) (emphasis added).
3 Holtec DEIS, NUREG-2237 (March 2020) (ADAMS Accession No. ML20069G420), Holtec DEIS (emphasis added).
4 NRC Letter to Holtec, Request for Additional Information, Part 5 (Nov. 14, 2019), (ADAMS Accession No. ML193322C260) (emphasis added).
5 New Mexico Environment Dept Letter to N.R.C. Div. Rulemaking, Env.and Financial Support re Holtec - NRC DEIS - NMED Review and Comment (Dec. 16, 2019) at 2.1, 2.2 (emphasis added)..