ML20179A348
| ML20179A348 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/24/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20179A348 (5) | |
Text
From: Rebecca M Summer <becsummer@gmail.com>
Sent: Wednesday, June 24, 2020 6:19 PM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] `COMMENTS FOR THE CISF EIS To: Nuclear Regulator Commission From: Dr. Rebecca M Summer Date: June 24, 2020 Re: Holtec International has proposed HI-STORE Consolidated Interim Storage Facility (CISF) for spent nuclear fuel in Lea County, New Mexico.
I am a citizen of New Mexico and was part of the Expert Scientist Team for the Nuclear Regulatory Commission (NRC) at Sandia Labs in 1995. I also co-authored a paper for the NRC, Model Feasibility Study of Radioactive Pathways from Atmosphere to Surface Water.
The scientific investigation at Sandia Labs focused on the design of the Pre-Waste Isolation Pilot Plant (WIPP) in Eddy County, NM. The safety, stability, and health risks to humans, air, water and the earth at the proposed WIPP site were determined during assessments of the topographic, biologic, geologic and hydrologic data available for the proposed WIPP site and surrounding region. The materials that were planned to be stored here are defined by the US EPA as "Low-Activity" Radioactive Wastes (LARW) that "are informally defined as radioactive wastes that contain very small concentrations of radionuclides. The concentrations are small enough that protection of public health and the environment from these wastes may not require all of the radiation protection measures necessary to manage higher-activity radioactive material."
Our scientific team studying the proposed WIPP plan identified multiple problems of possible radioactive dangers to the public as well as the surrounding surface water, ground water, land use, wildlife, and air quality.
The team was not informed of the resulting final design, implementation and management of WIPP.
The NRC certified WIPP as a radioactive material storage facility for LARW in 1998 for 10,000 years. This type of radioactive material has been disposed (stored) at WIPP from 1999 until today except for several temporary closures.
Based on the team studies of WIPP, I have significant concerns about Holtec International's proposed HI-STORE Consolidated Interim Storage Facility (CISF) for high level spent nuclear fuel in Lea County, New Mexico, directly
east of the WIPP site in Eddy County, NM.
Beginning with a summary report from The Christian Science Monitor, 2017:
"In late 2013, operators at a Los Alamos nuclear lab stuffed the wrong kind of kitty litter into a waste drum and shipped it off to Carlsbad, N.M. Deep below the earth, at the Waste Isolation Pilot Plant, a chemical reaction popped open the drum and sent small amounts of radioactivity ascending to the surface." That now infamous accident contaminated nearly two dozen workers happened less than two weeks after a fire hospitalized six WIPP workers.
In April, 2015, the U.S. DOE reported in the U.S. DOE Accident Investigation Report Phase 2, Radiological Release at WIPP: "On February 14, 2014, there was a release of radioactive material from a transuranic (TRU) waste container emplaced in Panel 7 Room 7 of the Department of Energy (DOE)
Waste Isolation Pilot Plan (WIPP) underground (Figure ES-1) near Carlsbad, New Mexico. The release was detected by a continuous air monitor (CAM) monitoring the Panel and an alarm activated on the Central Monitoring System in the Central Monitoring Room on the WIPP surface, which initiated a shift to filtration of the underground ventilation....Conclusions and Judgments of Need. Based upon the evidence obtained during this accident investigation, the Board concluded that the release from the container(s) was preventable. If LANL had adequately developed and implemented repackaging and treatment procedures that incorporated suitable hazard controls and included a rigorous review and approval process, the release would have been preventable."
The report then listed forty Judgment of Needs directed to Los Alamos National Laboratory, Los Alamos National Security LLC (LANS), and others.
Later in February, 2019 Adrian Hedden, Carlsbad Current-Argus, reported that the accident radiological release in 2014 led to a three-year closure of the WIPP facility. The headlines were, "Ruined for good by kitty litter?"
Hedden noted that, according to the notice at the WIPP facility, employees in the underground nuclear waste repository were potentially "overexposed" to carbon tetrachloride, nitrogen dioxide and sulfur dioxide, including heat stroke between July and October, 2018.
These are serious incidents at WIPP. It is important to remember that WIPP does NOT provide storage for the following high activity materials:
Spent nuclear fuel: fuel that has been removed from a nuclear reactor
because it can no longer sustain power production for economic or other reasons.
Greater Than Class C waste: low-level radioactive waste that exceeds the concentration limits of radionuclides established for Class C waste in 10 CFR 61.55 Mixed Oxide Fuel ( "MOX"): contains plutonium oxide mixed with either natural or depleted uranium oxide, in ceramic pellet form. Using plutonium reduces the amount of highly enriched uranium needed to produce a controlled reaction in commercial light-water reactors.
These three classified materials are proposed to be stored at the HI-STORE CISF. Given the myriad of low activity radioactive problems at WIPP encountered by the managers, operators, nuclear waste 'handlers', waste transporters, and employees who suffered from debilitating ventilation and radioactive exposure, it is eerie and unnerving to image HI-STORE disposing high level radioactive wastes in the bordering county to WIPP. Does the current design include required radiation protection measures necessary to manage high activity radioactive material?
At the HI-STORE website it states that the "CISF will be located on a small and isolated portion of a thousand acres of undeveloped ELEA [Eddy Lea Energy Alliance LLC] land that is geographically stable, with a dry and arid climate that is ideal for the underground dry fuel storage system. The project will create jobs for local workers, boosting local incomes that will lead to an improvement in the local infrastructure." They forgot to mention that nuclear waste experts across the globe estimate that the land used to store high level radioactive wastes cannot be used by humans for 2-3 million years, i.e. radioactive decay requires 2-3 million years before it's safe for humans. HI-STORE also forgot to mention that the dry arid climate, land and vegetation provide a special ecosystem that is connected to all ecosystems within New Mexico.
My questions to the NRC are: would you like HI-STORE in your backyard?
Would you work there or allow your family to work there?
As many have said over the decades, leaving nuclear wastes at the location where they were generated is the best solution at this time. No more New Mexicans want to be exposed to radioactive waste materials from Los Alamos National Laboratory, Idaho, Colorado, Illinois, or any state in the U.S. or world.
Thank you for your consideration of my comments. We all realize that we
are in changing times, but the health of humans, our lands and our waters are critical to life on earth.
Rebecca M Summer, PhD Silver City, NM
Federal Register Notice: 85FR16150 Comment Number: 2088 Mail Envelope Properties (CACcvMqgqkP2kLY=LHoA4_vweK8rxYTNNp+CSfVrc2eLZYf2f_Q)
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