ML20112F460
| ML20112F460 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 04/19/2020 |
| From: | Birnbaum E - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR16150 00018, NRC-2018-0052 | |
| Download: ML20112F460 (2) | |
Text
PUBLIC SUBMISSION As of: 4/21/20 10:59 AM Received: April 19, 2020 Status: Pending_Post Tracking No. 1k4-9g7v-vdgz Comments Due: May 22, 2020 Submission Type: Web Docket: NRC-2018-0052 Holtec International HI-STORE Consolidated Interim Storage Facility Project Comment On: NRC-2018-0052-0300 Holtec International HI-STORE Consolidated Interim Storage Facility Project Document: NRC-2018-0052-DRAFT-0326 Comment on FR Doc # 2020-05690 Submitter Information Name: Edward Birnbaum Address:
926 Circle Drive Los Alamos, NM, 87544 Email: ed@chelsea.net General Comment I would like to express my opposition to the Holtec project as currently configured. Although the Holtec proposal to store nuclear fuel rods in a ground-level facility in SE New Mexico will solve a lot of problems for the nuclear energy industry, the benefits to the citizens of New Mexico appear to be small compared to the potentially large risks associated with such a facility. Although Holtec has addressed a variety of the potential hazards regarding cask storage and transportation, there are other issues for which solutions remain obscure.
First, it isn't clear to me how Holtec will be able to move the casks stored at their facility to a not yet constructed long-term facility, such as the proposed Yucca Mountain nuclear waste repository. After 40 years or so, do they expect they will be able to just pull the casks out of the ground without leaks occurring? How will they deal with leaks of such highly radioactive waste during such a move, and what kind of a physical plant will be needed at the Holtec facility to handle radioactive waste spills?
Second, there is no specific plan on how to deal with the situation where a long-term high-level nuclear waste repository is not constructed within the maximum lifetime of the casks, estimated to be between 40 and 100 years. Will the radioactive waste remain at the Holtec facility indefinitely?
Third, what is the plan to deal with casks that fail, as they will eventually, regardless of how well constructed.
Are we prepared for a period of wet years where the Holtec storage site is inundated with water or if there is enough earthquake activity to shift the positions of the casks, or even crack a cask open? Will we end up with Page 1 of 2 04/21/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064844b732c&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (18)
PUBLICATION DATE:
3/20/2020 CITATION 85 FR 16150
a situation similar to what DOE currently faces with the million-gallon, single-and double-wall radioactive storage tanks at the Hanford site?
Fourth, I am very disturbed by the suggestion that if a Yucca Mountain-type repository is not available when needed, Holtec will just move the casks to WIPP. However, WIPP was never designed to hold fuel rods from nuclear reactors and other forms of concentrated, highly radioactive waste.
Fifth, there is the issue of human error, as occurred at WIPP in 2014, which ultimately resulted in the rupture of a storage cask, putting WIPP out of operation for three years and requiring an expenditure of more than one billion dollars to get it back in operation. Who is to say that human error won't strike again? A bad weld or improperly packaged fuel rods resulting in cask rupture would likely expose far more people to very high levels of radiation.
Finally, there are the financial considerations, which in some ways are the most disturbing. Los Alamos, Hanford and Oakridge still have enormous legacy waste issues, the resolution of which are estimated to cost in the trillions of dollars, and as far as I know, that doesn't include the development cost for a Yucca Mountain-type repository. It is unreasonable to expect a private company, such as Holtec, to be financially responsible for the myriad of large potential costs associated with this facility if things don't go as planned.
For such a project to go forward, the Federal government needs to indemnify the State against: (1) the cost of moving and/or repackaging the waste stored in any temporary storage facility in the event that a Yucca Mountain-type permanent repository isn't built within the projected lifetime of any Holtec-type temporary storage facility; (2) the cost of moving the waste to a final repository; (3) the cost of clean-up and remediation in the event of a leak of radioactive waste from any transport or storage cask; (4) any costs that a private entity responsible for such a facility cannot cover due to inadequate resources or bankruptcy.
Finally, it should be recognized that the cost of nuclear waste storage is not a one-time cost, but rather creates ongoing risks and expenses required to deal with security, leaks, and repackaging of waste. One approach would be to impose an annual royalty charge paid to the State based on the amount of waste stored at the site until completely remediated, analogous to what the oil and gas industry is now charged. It is ludicrous to think that the usual taxes received by the State for such a waste storage facility, including property taxes, income taxes on the small number of employees, GRT taxes, etc., will be large enough to justify accepting the risks associated with such a facility.
Although some may think that the Holtec proposal is similar to the Facebook facility near Los Lunas, the reality is that if Facebook goes away and their facility is mothballed, the worst case scenario is that we may have an ugly reminder of a failed enterprise on the landscape, but not a radioactive disaster waiting to happen, as is possible with any nuclear power plant or nuclear waste storage facility.
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