ML20121A140

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Comment (33) of Martin Kral on Holtec International HI-STORE Consolidated Interim Storage Facility Project
ML20121A140
Person / Time
Site: HI-STORE
Issue date: 04/30/2020
From: Kral M
- No Known Affiliation
To:
Office of Administration
References
85FR16150 00033, NRC-2018-0052
Download: ML20121A140 (27)


Text

PUBLIC SUBMISSION As of: 4/30/20 12:13 PM Received: April 30, 2020 Status: Pending_Post Tracking No. 1k4-9gf1-bsjd Comments Due: July 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-0341 Comment on FR Doc # 2020-05690 Submitter Information Name: Martin Kral Address:

406 Viale Bond Roswell, 88201 Email: mkral@cableone.net General Comment NRC-2018-0052 Holtec's traveling presentation for New Mexico.

Ed Mayer, Program Director, for the Holtec HI-STORE CISF project has been traveling around Mew Mexico to present information in a formal setting for the movers, shakers, and influencers of the various counties and cities of New Mexico. Attached is the presentation that was used, minus the script notes because there were none. Ed Mayer followed the presentation with a lively questions and answer session. I for one got my questions answered.

(Attached Power Point Presentation)

Attachments HI-STORE CISF Committee Brief Page 1 of 1 04/30/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648451f814&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly COMMENT (33)

PUBLICATION DATE:

3/20/2020 CITATION 85 FR 16150

HI-STORE CISF:

A Consolidated Interim Storage Facility for Spent Nuclear Fuel in Southeast New Mexico September 2019

www.holtec.com l Page 2 Consolidated Interim Storage Topics Who is Holtec?

What is Spent Nuclear Fuel National Imperative Project Brief: Safety, Security, Transportation Why Not Status Quo?

Licensing & Regulating

www.holtec.com l Page 3 Holtec International Core Business Activities Safe & Secure Storage Used Nuclear Fuel Heat Transfer Equipment SMR-160 Delivery Decommissioning Nuclear Plants Consolidated Interim Storage Largest US exporter for capital equipment supporting the nuclear industry 116 nuclear plants worldwide: 65 domestic, 51 international Over 60,000 SNF assemblies loaded / 1,300+

Holtec systems loaded A vertically integrated turnkey supplier of goods and services to the power generation industry since in 1986

www.holtec.com l Page 4 Holtecs Worldwide Dry Storage and Transport Experience

www.holtec.com l Page 5 Nuclear Fuel & How it is Stored

www.holtec.com l Page 6 How Nuclear Fuel is Stored Wet Storage Dry Storage

www.holtec.com l Page 7 National Imperative NWPA 1982 Codified Repository as National Strategy 1 mill/kWhr

$12B Spent on Yucca Yucca Never Opened Jan 31, 1998: Contract Breach On-Site Storage 121 Facilities/39 States Each w/ security, operations, maintenance National Liability

$800M/yr

$1.3B/yr beginning 2022

$6.9B through 2017

$34.1B Total U.S. Treasury Judgement Fund Blue Ribbon Commission - 2012 Reaffirmed Repository as National Strategy CISF Compliments Repository

www.holtec.com l Page 8 Consolidated Interim Storage Safe: SNF storage system is designed and built to withstand natural and man-made events with no release of radioactivity Secure: SNF storage system and facility provide an impregnable fortress to protect SNF against attacks Retrievable : Allows removal of SNF canisters from facility in one shift for shipping to repository Temporary: Compliments repository, not competition. Canisters of SNF will be shipped to repository in the same manner they were shipped to site

www.holtec.com l Page 9 Stainless Steel Spent Fuel Canister Reinforced Concrete Top Pad Reinforced Concrete Base Mat Steel/

Concrete Lid Steel Liner Low Compressive Strength Concrete CISF Utilizes HI-STORM UMAX Technology HI-STORM UMAX:

Seal welded canisters Below grade vertical silos Requires no water or electric Produces no pollution, emissions, or noise Maximum Safety: Earthquakes, Oil & Gas Accidents, other postulated accidents Maximum Security: NRC DBT No Affect on Environment No minerals, aquifers, or ground water effected Radiation dose fraction of cosmic radiation No Negative Affect on State Economy Oil & Gas: Drilling, Fracking, Disposal Wells Ranchers & Farmers

www.holtec.com l Page 10 HI-STORM UMAX Construction 10

www.holtec.com l Page 11 11 Controlled Low-Strength Material

www.holtec.com l Page 12 12 Pours Complete

www.holtec.com l Page 13 Rebar for Top Pad 13

www.holtec.com l Page 14 HI-STORM UMAX Loaded 14

www.holtec.com l Page 15 Phase 1: 500 HI-STORM UMAXs

www.holtec.com l Page 16 HI-STORE Site Layout Initial Storage Capacity: 500 canisters Total Storage Capacity: 10,000 canisters Facility utilizes 300 of 1,000 acres available Operations could commence in 2024 Cask Transfer Building Admin Building HI-STORM UMAX Security Building

www.holtec.com l Page 17 Transport to HI-STORE Local area has well-developed rail infrastructure HI-STORE 3.8 miles west of BNSF spur - Intrepid North Casks move by rail and remain on rail car until on HI-STORE facility

www.holtec.com l Page 18 Transport to HI-STORE Transportation of radioactive material including Spent Nuclear Fuel is strictly regulated Nuclear Regulatory Commission and the U.S. Department of Transportation Two transport cask types will be used which were designed by Holtec and licensed with the NRC HI-STAR 190 and HI-STAR 100MB

www.holtec.com l Page 19 Transport to HI-STORE Transport Casks Safely confine fuel and shield workers and public from radiation Multiple layers of steel, lead, and other materials Inside cask SNF is contained in another sealed canister Fully loaded casks weigh 125 tons or more for rail shipments Holtec Transport Cask

www.holtec.com l Page 20 Cask Design Robust & Proven Safe Designed to protect public from releases of radioactive material in the unlikely event of an accident Must survive four successive accident conditions:

free drop, puncture, fire, and submersion in water

www.holtec.com l Page 21 Why Not Status Quo?

National Imperative:

Dispersed SNF Cost to Every Taxpayer SE New Mexico Excellent Location Land Characterized for GNEP Geologically Stable, Arid, Remote Robust scientific & nuclear workforce No Affect to General Public or State Economy:

Ranchers, Farmers, Oil & Gas Financial Benefits to New Mexico

$3B Capital Investment

$25M/yr Operating Costs

$15M-$25M/yr Revenue Sharing w/State 100 Operations & 100 Construction Jobs

www.holtec.com l Page 22 NRC Begins Safety Review (10 CFR Part 71, 72, 73)

NRC* Begins Environmental Review (NEPA)

NRC Issues Safety Evaluation Report (March 2021)

NRC Issues Environmental Impact Statement (10 CFR Part 51)

Draft March 2020/Final March 2021 NRC Adjudicatory Hearings (ASLBP)

(January 2019)

ASLBP Issues Findings; Potential NRC License Spring 2021 License Application Submittal (March 2017)

NRC Decides Whether to Accept Application for Review NRC Dockets License Application (March 2018)

NRC Licensing Process NRC*: BLM and NMED Coordinating Agencies ASLBP: Atomic Safety and Licensing Board Panel Operational Spring 2024 We Are Here

www.holtec.com l Page 23 NRC Facility Regulation

www.holtec.com l Page 24 Regulation At All Levels of Government Federal License Application: NRC (BLM & NM Coordinating Agencies for EIS), Submitted March 31, 2017 Land Use Permit (Rail Spur, Co Road 55): BLM, To be submitted September 2019 Endangered Species Act: USFWS, Surveys complete, No threatened or endangered species present Permitting Rail Spur: STB, Non-carrier private spur and not under STB jurisdiction State National Historic Preservation Act: NM SHPO, Surveys complete, avoidance primary mitigation tool NM Road 243 / Railroad Spur ROW Crossing: NMDOT, Apply once project approved and before construction begins Air Quality Permit: NMED, Apply once project is approved and before construction begins Groundwater Discharge Permit: NMED, Apply once project approved and before construction begins NPDES Construction & Industrial Stormwater Permit: NMED, Apply once project approved and before construction begins Hazardous Waste Generation and Storage Permit: NMED, Apply once project is approved and before construction begins EPA Notification of Hazardous Waste Activity: NMED, Apply for ID number prior to generation of waste during facility construction Petroleum Storage Tank Registration: NMED, Register storage tanks Local Co Road 55: Lea Co Road Dept., Road on private land. Landowners informed.

www.holtec.com l Page 25 Questions?

www.holtec.com Ed Mayer Program Director (856) 797-0900 Ext. 3671 (703) 401-7330 e.mayer@Holtec.com 1 Holtec Blvd.

Camden, NJ 08104