From: Hannah Burling Sent ... · fuel cladding must be protected during storage against degradation that leads to gross ruptures or the fuel must be

From: Hannah Burling <[email protected]> Sent: Friday, July 31, 2020 7:37 PM To: Holtec-CISFEIS Resource Subject: [External_Sender] League of Women Voters of New Mexico comments

on Holtec EIS Attachments: HOLTEC EIS compiled3.pdf

Please see the attachment for our comments. Thank you, Hannah Burling President League of Women Voters of New Mexico

Federal Register Notice: 85FR16150 Comment Number: 2184 Mail Envelope Properties (CAKz-UHaRsj3CX1HKxoWci7o+K2FwJ2dGeJW=3dE-74bf1rZdSg) Subject: [External_Sender] League of Women Voters of New Mexico comments on Holtec EIS Sent Date: 7/31/2020 7:37:21 PM Received Date: 7/31/2020 7:37:44 PM From: Hannah Burling Created By: [email protected] Recipients: Post Office: mail.gmail.com Files Size Date & Time MESSAGE 132 7/31/2020 7:37:44 PM LWVNM logo.jpg 28241 HOLTEC EIS compiled3.pdf 1152398 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

League of Women Voters of New Mexico

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DATE

Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 [email protected]

ATTN: Program Management, Announcements and Editing Staff

Subject: Environmental Impact Statement for the HOLTEC International’s License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel and High Level Waste; Docket ID NRC-2018-0052

To Whom it may Concern:

The League of Women Voters of New Mexico (LWVNM) has reviewed the March 2020 Environmental Impact Statement (EIS) for the HOLTEC Consolidated Interim Storage Facility (CISF) License Application. LWVNM has developed both general remarks regarding the adequacy of the Draft EIS as well as section-specific comments noting observations, inaccuracies, or omissions. LWVNM concerns extend from inaccurate representation of the hazards posed to public health and safety and inadequate characterization of the surrounding environment, to underestimation of environmental impacts to NM resources.

Given the long list of concerns we found when our member experts (nuclear scientists and engineers, primarily) reviewed the Draft EIS, the League does not support this project. We ask that you not approve the Holtec application unless LWVNM concerns regarding the EIS can be adequately resolved.

LWVNM seeks to promote responsible government and inform the public on decisions impacting their health, safety, and sustainability of their quality of life as well as contributing to the well-being of those residents who may be disadvantaged or have insufficient resources to defend their interests. As a related concern voiced by numerous members of the public during both the 6/23/20 and 7/9/20 US NRC Public Involvement Meetings for comments on the HOLTEC EIS, LWVNM echoes the request for in-person public meetings addressing the HOLTEC EIS (when Social Distancing precautions cease), thereby permitting those without internet access an equitable opportunity to record their concerns.

Please consider the concerns delineated in the attached LWVNM Comments addressing the HOLTEC EIS and contact me ([email protected]) at your earliest convenience for any clarification or additional information. Thank you for the opportunity to provide comments to the Draft HOLTEC EIS and LWVNM looks forward to the US NRC response.


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Respectfully,

Hannah Burling, President League of Women Voters of New Mexico


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General Remarks/Introduction

The U.S. Nuclear Regulatory Commission (NRC) prepared this draft environmental impact statement (EIS) as part of its environmental review of the Holtec International license application to construct and operate a consolidated interim storage facility (CISF) for spent nuclear fuel (SNF) and Greater-Than-Class C waste, along with a small quantity of mixed oxide fuel (MOX). The NRC stated that the evaluation of the program is independent of HOLTEC - a concrete example of this effort is the NRC recalculation of the radiation to which workers in the facility will be exposed. The NRC calculation result was twice that of HOLTEC, but still low. It would be very useful if the reasons for rejecting the second alternative, no action or permitting the spent nuclear fuel to remain at nuclear reactors and independent spent nuclear fuel storage installations, were listed in prominent fashion.

These are the assumptions that guide the League’s recommendations:

1. The proposed site is truly an interim facility (i.e. 40-100 years of site usage). 2. Recommendations are based on information provided in the NRC EIS and the provided SARs for

proposed Holtec LLC Lea County, NM Interim Consolidated Waste Storage Facility.

Based upon these assumptions, LWVNM anticipates that the canister design and site design laid out in the EIS have a low probability of damage severe enough to cause radiological release due to a seismic event or natural disaster at this proposed site. With respect to the type of SNF to be sent to this proposed site, radiological diffusion into the ground and groundwater via seismic activity, or a natural disaster also has a low probability. With regards to the chemical embrittlement of the canisters while stored at the HOLTEC CISF via ground water or flooding, LWVNM expects the probability would be low based upon the past, current, and projected meteorology and climate of the proposed site and the surveyed groundwater tables in this area.

However, many of these conclusions are contingent upon no mining under or on the proposed storage site. Holtec LLC has stated in the EIS that they would buy the land for the proposed storage site. However, the mineral rights are owned by the State of New Mexico and could potentially be leased to mining companies.

Mining on or under the site could cause a substantive safety risk and would most certainly cause an increased perceived safety risk to the proposed storage facility. Therefore, it is of paramount importance to the public safety and trust for Holtec LLC to follow through on their disclosed desire to buy the mineral and mining rights of the proposed storage site, and to retain these rights without leasing them to outside mining companies or exercising the use of these mining rights themselves. The purchase must be completed before the CISF is approved, as the outcome is by no means certain.

LWVNM assumes that Holtec LLC and the US NRC will use this site truly as an interim storage facility and the mineral rights of the proposed Lea County, NM site are retained by Holtec LLC and not exercised by Holtec LLC, and the information provided in the multiple SARs and the NRC EIS is as accurate and exhaustive as possible.

The EIS did not adequately evaluate conditions impacting public and occupational health. In particular, it did not address the possibility that the transfer of corroded casks and damaged fuel/fuel debris could


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cause radiation exposure. Cask transfer was presented as a routine, well-controlled operation with no inherent risks. However, the cask drop incident occurring at the San Onofre Nuclear Generating Station (SONGS) on August 3, 2018 demonstrates that the complexity of the cask transfer operation can result in unforeseen accidents. There is currently no plan for a hot cell facility on the HOLTEC site. Therefore, repackaging defective casks upon receipt will not be possible. This means that they will need to be returned to their place of origin, doubling the radiation exposure. Also, without a hot cell facility, there would be no way to handle casks exhibiting degradation after extended storage at HOLTEC CISF when a permanent geological repository becomes available.

Occupational radiation exposure was underestimated for other CISF operations. Cask inspection, a routine recurring task, has previously resulted in inspection team exposure of 4 Rems for a single cask (5 Rems is the annual occupational limit). Discussion of potential radiation exposure from nearby facilities neglected to include the extent of SNF and GTCC waste storage operations planned for the TX/ISP CISF, under concurrent NRC licensing review, which will pose similar hazards as the HOLTEC CISF. The NEF/URENCO facility continues to expand its uranium enrichment capacity but only current operations were evaluated.

Outside the direct scope of the specific proposed site’s safety is the concept of the word “interim”. It will be a logistical and political feat to move SNF from various NPPs across the country to this proposed storage site. It is unlikely that the federal government will want to put in the political, logistical, and financial capital to do this again in 40 years. Therefore, license extensions will be granted. The question is how many license extensions would jeopardize the safety of the storage facility? Also, this continual license extension may prove politically unpalatable to a public that was told the storage would be temporary and a permanent site would be found elsewhere. This again undermines the 1987 Nuclear Waste Policy Act, by the federal government shirking its duty to find and license a permanent facility to house the nation’s SNF.

One of the more abstracted concerns is, does the use of a private company for the stewardship of SNF undermine the precedent of the 1987 Nuclear Waste Policy Act in that it delays the US Federal Government’s legal obligation to find and license a permanent waste storage facility? The addition of profit to the stewardship of SNF creates the potential of lobbying for the continual delay of the licensing of a permanent facility. This would not be in the best interest of the general public and would enable the federal government to shirk its duty to provide a permanent solution to the SNF problem. Therefore, LWVNM recommends any interim storage solution, if one is deemed necessary, be operated by the US DOE, so as to not blur the lines between the duties of the federal government and the private steward.

The nation needs to address the growing number of canisters of SNF that are crowding our nation’s NPPs. With sea levels rising at NPP sites, these canisters’ safety comes into question. Having SNF scattered throughout the country at sites not specifically designed for such a number of canisters is a security and safety issue and thus a financial issue for the federal government. Consolidation at a storage site designed for nuclear waste is urgently needed, otherwise disposal at current storage sites should be undertaken.

The main question, whether the current risk posed by the SNF is great enough and the probability of licensing a permanent site is low enough to warrant the licensing of an interim storage site, is unresolved and needs further consultation with policy experts.

If the matters laid out above cannot be resolved the project should not go forward.


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EIS SECTION SPECIFIC COMMENTS SECTION/ PAGE

PAGES REMARKS

1.1 – 1.4 There is a future difficulty with this program. The permit requested is to provide interim storage for waste for a 40-year time period. But no permanent storage place, or even plan, exists. Yucca Mountain is not finalized. The best estimate for the creation of an operating permanent facility is 45 years. However, regulations in place will be used if a permanent facility is not available when this permit runs out. One of the main reasons given for trying so hard to get public comment was to make sure that all public’s issues are addressed in some manner. Not all the public’s issues were addressed in detail because some of the concerns raised were off topic or not related to this particular project. Nevertheless, a list of 16 specific issues is given here. The complete list, including health and safety and ecology, appears on page 1.4 and is individually addressed in the body of the report.

Section 2.1

Page 2-1; lines 32 – 34

The application considers the maximum canister capacity load of SNF in 500 canisters (8,680 MTUs) and the report extrapolates and claims to consider storage of 20,000 units. With time I would presume canister design would be modified. For a surface storage location, it is important to know what types of canisters or casks are represented in the EIS, especially if one is extrapolating performance of the full 20,000 that will be emplaced at the site. It is presumptuous to assume canister design beyond the first 500 emplaced will be known and if cask design is not fully known, how can there be a reasonable projection of ‘safety’ from 500 to the hypothesized 20,000 canister units? The performance criteria need to be based on the current canister design, and not extrapolated out to the projected full capacity of 20,000.

Section 2.2.1.1 Site Location

Page 2.2, lines 35-37

The application considers the maximum canister capacity load of SNF in 500 canisters (8,680 MTUs) and the report extrapolates and claims to consider storage of 20,000 units. With time I would presume canister design would be modified. For a surface storage location, it is important to know what types of canisters or casks are represented in the EIS, especially if one is extrapolating performance of the full 20,000 that will be emplaced at the site. It is presumptuous to assume canister design beyond the first 500 emplaced will be identical, however, LWVNM assumes all will be licensed by the NRC using the same rigorous criteria.

Section 2.2.1.1 Site Location

Page 2.2, lines 35-37

The WIPP site is within the middle of a 4-mile square buffer zone (16 sq. miles or 10,240 acres), and the repository footprint itself is in the approximate center of this area (see figure below). The repository footprint itself is approximately 35 acres and fenced off. Entering the WIPP site via Highway 128 one has to pass thru fencing and travel at least 2 miles to get to the actual operations area. These 16 square miles create a relatively large buffer/safety zone to assure no negative human or natural impacts will compromise the site. In contrast, HOLTEC’s CISF site is located between 1 to less than 0.3 miles from Highway 62. The proposed fenced area is within ~0.3 of the site boundary. This leaves a relatively small ‘buffer’ zone between the site boundary and the containment area. Taken together, the site boundary and relatively small buffer zone are very close to a highway


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that transports materials and wastewater from active oil producing and mineral extraction producing areas. The relatively small footprint of the proposed site and the small buffer zone from the site boundary to the emplacement area do not seem to be based on optimal public ‘safety’. See map below.

2.2 2-4 2-5

The HOLTEC Draft EIS states: “Each canister is then surrounded by additional steel, concrete, or other material to provide radiation shielding to workers and members of the public.” “SNF waste at the proposed CISF would be stored in dry cask storage systems that the NRC previously approved. These cask systems include transportable dual-purpose (transportation/storage) or multi-purpose (transportation/storage/disposal) canister-based storage systems. Each of these systems is engineered to safely store SNF and is subject to rigorous inspections, aging management programs, maintenance, and relicensing “ The EIS indicates that intact SNF casks are adequate to shield workers and the public from radiation exposure exceeding the limits. However, canisters with corrosion or those containing high burnup fuel, damaged fuel or fuel debris are more likely to emit radiation which exceeds the limits. Corroded SNF canisters from the CA San Onofre Nuclear Generating Station (SONGS), owned by HOLTEC, are destined for the NM HOLTEC CISF. Both aluminum and stainless steel canisters in ISFSIs located at other sites near bodies of water have also exhibited corrosion, including the 2010 Peach Bottom/PA, 2007 TMI2 /PA, & 2000 Surry/VA, which were exposed to rain water. [Reference: NRC Regulation # NUREG/CR-7030 “Atmospheric Stress Corrosion Cracking Susceptibility of Welded and Unwelded 304, 304L, and 316LAustenitic Stainless Steels Commonly Used for Dry Cask Storage Containers Exposed to Marine Environments”, US NRC Office of Nuclear Regulatory Research, October 2010]. “For plants located near coastal areas, chloride stress corrosion cracking (SCC) is a potential degradation mode for dry storage system canisters made from austenitic stainless steels. Previous research on chloride SCC of austenitic stainless steels provides some insight on the effects of material composition and condition; however, limited information is available to determine the susceptibility of dry storage system canisters placed inside a ventilated concrete enclosure (e.g., HOLTEC UMAX CISF Storage System).”


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[Reference Regulations addressing SNF Storage [10 CFR 72.122(h)(1)]] states: “The spent fuel cladding must be protected during storage against degradation that leads to gross ruptures or the fuel must be otherwise confined such that degradation of the fuel during storage will not pose operational safety problems with respect to its removal from storage. This may be accomplished by canning of consolidated fuel rods or unconsolidated assemblies or other means as appropriate.”

Section 2.2.1.2

Lines 2-6

For Phase 1 - There is risk every time a canister is loaded and unloaded from the reactor to a transport vehicle, then unloaded from the transport vehicle to the interim storage facility. Then, when a permanent repository is approved, the canisters would have to be removed from the CISF and placed back in a transport vehicle to be taken to a permanent repository. Because of all this handling (multiple loadings and unloading) it would seem prudent that all SNF and GTC material be loaded into one canister design appropriate for both interim storage and final repository.

Section 2.2.1.3 Facility Construct-ion

Page 2-6; lines 9-12

Phase 1 - Volume excavated soil (135,517 m3 plus 80,500 m30). How is the soil disposed of and what type of airborne dust control will be put in place during construction? If dust suppression is via sprinklers, then what is the daily volume of water used?

2.2.1.1 Page 2-2

The EIS states that “there are no water wells within the proposed project area.” However, Figure 3.5-5 shows an abandoned water well in the northeast portion of the proposed CISF project area. This contradictory information should be reconciled.

2.2.1.1 Concrete fabrication –The volume of concrete produced for this facility begs the following question, ‘What is the total volume of water to be used to make concrete for phase 1?’ And for phase 2-20 how much additional water will be needed? Is this potable water, bought from Carlsbad municipality? The volume of water used to make concrete is not addressed.

Section 3.2.4

Page 3-7

New Mexico Oil Conservation Department maps (see below) indicate there is an active gas well on the site. The integrity of the plugs installed in shut in or abandoned wells has not been assessed. Plug designs have changed over time, and early on in Permian Basin development less rigorous plug designs were in effect. What is the integrity of the boreholes within and adjacent to the CISF footprint; how deep are these wells? How are the existing wells within and surrounding the site boundaries monitored? Additionally, based on current oil and gas exploration, it is likely that there future horizontal and ‘frack’ oil and gas wells will be drilled right up to the site boundary, as observed at the WIPP site. The potential impact of maximum oil and gas exploration on the site integrity needs to be addressed (see comment for Section 2.2.1.1). What is the impact of any future wells drilled at the boundary on overall site safety? SEE MAP BELOW.


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3.4.2 Page

3-21, lines 17-22

In-situ permeability tests of the Santa Rosa Formation reported by GEI (2017) indicated values ranging from 3.4 x 10-7 to 9.2 x 10-7 cm/s. These values seem to be unrealistically low for the reported lithology of “fine- to coarse-grained sandstone, with minor reddish-brown siltstones and conglomerates” and especially for a formation described in the EIS as a “major aquifer” (p. 3-32, l. 28). Was there an effort to verify the typical permeability of the Santa Rosa Fm. in the area of the proposed CISF as reported in scientific literature?

Section 3.4.5

Page 3-24, Line 12-13

INTREPID mine owns the mineral (potash) leases under the HOLTEC area. The company has an investment portfolio that indicates ownership of all mineral rights under and surrounding the proposed CISF property. INTREPID’s annual report shows a map of their mineral leases extending under the proposed site. Even if they agree not to mine under this area, they could mine up to the site boundaries and impact and/or compromise the integrity and stability of the site. SEE MAP BELOW.


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Section 3.4.5

Page 3-27

The site is surrounded by large mineral, oil and gas reserves. Past extraction of these resources has produced subsidence features and sinkholes. As reported in Land (2013) solution mining, traditional room and pillar mining have resulted in numerous sinkholes forming years after the extraction has taken place. The FEIS does not adequately address possible future subsidence within the area due to ongoing production of potash mining. This is a significant omission.


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Additionally, construction of the CISF will produce increased runoff, especially over a possible 100-year time period. What are the design safeguards to minimize run-off to roads or to prevent future preferential flow paths down minute fractures off-site that could produce sinkholes?

Section 3.4.5

Page 3-28

Zhang et al. 2018 indicates future subsidence events within the vicinity of the proposed site area are highly probable. The authors indicate their remote sensing tool reveals the presence of subsidence areas, but most likely underestimates a current or potentially future subsidence zone. They state, “However, because the subsiding areas varied spatially and appeared intermittently throughout our study period, this map can only give a glimpse of the unstable areas of the potash mine.” In section 4.2 of Zhang states the following, “A lack of significant incidents in the potash mine since 2011 (the last year of ALOS PALSAR observations) demonstrates this may indeed be the case, and that the surface and underground stability of the mine may be well controlled by the operator through the use of pillars and other instruments in the mining caverns. However, the long-lasting, careful management of a potash mine is a much more difficult task. If the mining operation were to be suspended or abandoned, the existing mining facility may be vulnerable to continuous subsidence and possible collapse events without comprehensive management.” Furthermore, in Section 5.1.1.2 of the EIS report (page 5-2) it states that INTREPID is not likely to slow down their mining extractions. It is predicted that INTREPID, along with 6 other nearby mining companies, will increase operations within the next 20 – 30 years. Because the INTREPID mine has extensive mineral rights under and surrounding the interim storage area, and there is subsidence observed in the study area, there is a high probability that subsidence could occur close to or within the storage area causing erosion and shallow ground water flow within the vicinity of the HOLTEC site. What assurance is provided that this will not affect the proposed site integrity? SEE MAP BELOW.

From Zhang et al., 2018

Section 3.5.1.4 Floodplains

Page 3-32

Related to capturing storm run-off at the Plata and Gatuna Laguna, HOLTEC states that both of these drainages “would be able to accept runoff from a 24-hour/19 cm [7.5 inch] rain event with excess freeboard space, assuming 7 the Lagunas were dry prior to the start of the rain event.” (HOLTEC, 2019a) This assumes the lagunas would be dry prior to any and all precipitation events. The aerial photos of the two lagunas (included in Section 3.2.4 comment) indicate the laguna footprints are more than double in size in


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comparison to the water levels at the time of the photo. The construction of the CISF could affect drainage patterns to these lagunas, causing them to enlarge and perhaps encroach onto the CISF site and/or flood the highway.

3.5 Pages 3-28 through 3-42

The authors of the EIS rely heavily on two dated references, Nicholson and Clebesch (1961) and Bjorklund and Motts (1959) for their analysis of aquifer conditions, groundwater occurrence, and groundwater quality. Although these are solid references to the geological knowledge extant at the time they were published, more current data should be researched and presented in the EIS, especially with regard to more transient conditions including groundwater occurrence, quality and development.

3.5.1.1 Page 3-31, lines 10-12

The EIS text references a spring that feeds Laguna Plata. However, EIS Figure 3.4-7 shows two springs, one feeding Laguna Plata and another, much closer to the proposed CISF Project site, feeding Laguna Gatuna. The potentiometric information presented on this figure suggests that both springs could be fed by Quarternary alluvium groundwater discharging from the proposed CISF site. The potential water quality impacts of the CISF on these springs and the wetlands of Laguna Plata and Laguna Gatuna should be addressed in the EIS. These springs could also be included as environmental monitoring points for an operating CISF.

3.5.1.4 Page 3-32, lines 2-8

The EIS references Holtec 2019b to conclude that no floodplains are located within or in the vicinity of the proposed CISF project area. This conclusion is an obvious contradiction to the presence of the ephemeral playas Laguna Plata and Laguna Gatuna. Cursory review of the USGS topographic map (EIS Figure 3.4-5) and the soil survey aerial photograph (EIS Figure 3.4-8) reveals the current and historical shorelines of Playa Gatuna exist within the Proposed CISF Project Area. Further, soil types mapped as “mixed alluvial lands” represent ephemeral drainage features tributary to the two playas. Review of the FEMA Interactive National Flood Hazard Map referenced in the Holtec Environmental Report indicates that the Proposed CISF Project Area is categorized as “Zone D” which is defined as “area of undetermined but possible flood hazard.” The proximity of the proposed storage facility to ephemeral drainage features, and especially the design for subgrade storage of radioactive wastes, warrant a more thorough assessment of potential flooding hazards.

Section 3.5.2.1 Regional Groundwater Resources

Page 3-33

Capitan Aquifer – HOLTECs EIS cites Bjorklund and Motts, 1959 for the recharge to the Capitan aquifer. This is a very old reference and much research has been conducted on recharge and within the Capitan reef complex NM and west TX more recently. The credibility of this report is diminished by citing numerous old reports such as this. Why are HOLTEC and NRC not looking at more recent studies and reports related to hydrogeology in the area? For example, the Texas Water Development Report (TWDB, Jones 2016) refutes the Bjorklund and Jones assessment and indicates recharge. The TWDB investigations indicated flow occurs within the Capitan reef complex itself (see TWDB, Figure 4.2.3) and refute claims by Bjorklund and Motts that there is flow between the interior of the Delaware Basin and Capitan Reef.

3.12 Section 3.12 deals with health issues caused by radiation, chemicals, and accidents. Because this facility deals with radioactive material, more attention than usual is given to radiation. There are three facilities, with an additional one planned, in the area. Much information is given about each. In particular, it is stated how much each contributes to the background radiation outside the confined area of the facility. In all cases, it is a negligible amount. This proposed facility is located in a section of the state that has a vibrant oil and gas industry. Active mining is also going on. The result is that there is a large number of industrial accidents. The rate in this region is well above the state average.


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Unfortunately, in this section no information is given as to what estimated contribution to this average can be expected from this facility or what special efforts, if any, are going to be made to keep this contribution low.

3.12.1.2 3-95

Other Sources of Radiation Exposure This Draft HOLTEC EIS section overlooked multiple sources of nearby radiation from both existing and proposed facilities that could impact public & occupational health. The HOLTEC EIS sections discussing background radiation from nearby sites only address normal operations. The Nuclear Safety Analysis reports and other licensing submissions for these sites specify a much higher radiation release and provide the probability for potential accidents: The proposed ISP CISF located 40 Mi SE of HOLTEC CISF is under concurrent NRC

Draft EIS Public Comment. Not only will this facility, if approved, receive SNF from commercial nuclear reactors and ISFSIs, this is also the proposed storage location for Greater than Class C (GTCC) Waste from all US Operating and Shutdown Reactors as published in 2019 Federal Register public notices and distributed by the US NRC during the July 2019 NRC Rulemaking process (Ref Nov 2016 NRC GTCC Presentation to International Conference on the Safety of Radioactive Waste Management). GTCC is considered intermediate level waste and is too radioactive to permit near surface burial used for other LLW at adjacent WCS site. “GTCC includes:

Activated metals - irradiated metal components as well as filters and resins from reactor operations and decommissioning

Common radionuclides include Ni-63, Ni-59, C-14, Tc-99, and Pu-239 Sealed sources - radioactive material that is sealed in a capsule ranging in size from a

few millimeters to tens of centimeters Common radionuclides include Cs-137, Am-241, Pu-238, and Pu-239 Other waste – wide range of physical forms and radionuclides from a wide range of

sources (e.g., scrap metal, filters, rubble, sludges) Can include Pu-239, Pu-240, Pu-238, Am-241, Cs-137, Sr-99 All GTCC LLRW created from NRC licensed activities (commercial Nuclear Reactors),

i.e., commercially generated GTCC waste, must be disposed of in an NRC licensed facility.

DOE owns or generates non-commercial LLRW which have characteristics similar to those of GTCC LLRW and has described this waste as GTCC-like waste -NRC does not have regulatory authority over GTCC-like waste.”

(Reference: “Greater than Class C Low Level Radioactive Waste Characteristics and Disposal Aspects,” International Conference on the Safety of Radioactive Waste Management, Hans D. Arlt, November 23, 2016)

The 2020 NRC Rule may permit all US GTCC burial at ISP located on the NM/TX border 5 miles from Eunice, NM and would increase the radiation exposure level above the 2.7 mR stated in the Draft HOLTEC EIS. All Spent Nuclear Fuel transport, receipt, transfer, inspection, and storage activities (including potential accidents) considered for the HOLTEC CISF, with resultant radiation exposure, would also be factors for the adjacent ISP CISF.


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WIPP 16 mi SW, 3.2 M ft3 contributing 1X10-4 mR at fence-line. However, NRC should consider the 2/14/14 WIPP Accident and resultant Radiation Release, although not exposing the public or the workforce to dangerous radiation levels, this accident was never previously envisioned and not addressed in the WIPP Accident Analysis used as the justification for safe operation – the possibility of never previously envisioned occurrences should be considered as a factor which could also affect HOLTEC CISF and other facilities’ nuclear operations.

NEF (Uranium Enrichment Facility) 38 mi SE contributes 19 mR annually. In 2006, Louisiana Energy Services (also known as Urenco USA) received a license to construct and operate the National Enrichment Facility in Eunice, N.M. This plant opened in 2010 (www.nrc.gov) and the site occupies 50 acres. The NRC has licensed three gas centrifuge plants. NRC nuclear Safety Evaluation Report 2014 License Amendment (Phase adding additional Separation Building Modules) instituted significant training and administrative controls supplementing structures, systems, and components to prevent nuclear criticality; however, criticality is a potential issue which would result in massive radiation doses to both the URENCO workforce and community, extending to the HOLTEC facility. Also, training and administrative controls are dependent on personnel actions that are more frequently subject to error than SSCs. Note that the NRC SER 2014 License Amendment covered the phase adding additional Separation Building Modules, but the NEF/URENCO facility is not evaluated in the HOLTEC EIS for potential expansion. As indicated above, Uranium Separation Building modules continue to be added, with each increasing radiation exposure above the estimates identified in the HOLTEC CISF Draft EIS.

FEP/DUP to be built 23 mi NE and contribute 21.8 mR annually 3.12.3 3-97 HOLTEC EIS States: “The NRC has a statutory responsibility, pursuant to the Atomic

Energy Act of 1954, as amended, to protect worker and public health and safety. The NRC’s regulations in 10 CFR Part 20 specify annual worker dose limits, including 0.05 Sv [5 rem] total effective dose equivalent (TEDE) and dose limits to members of the public, including 1 mSv [100 mrem] TEDE with no more than 0.02 mSv [2 mrem] in any 1-hour period from any external sources.” Additionally, 10 CFR Part 72 includes an annual public dose limit of 0.25 mSv [25 mrem] committed dose equivalent to the whole body. These public dose limits from NRC-licensed activities are a fraction of the background radiation dose, as discussed in EIS Section 3.12.1.1. However, radiation exposure to workers at the HOLTEC CISF could greatly exceed these levels for damaged fuel and fuel debris. Also, routine cask inspection may also expose workers daily to radiation levels exceeding annual limits. [Reference Dry Storage Canister Inspections, EPRI, J Renshaw, NRC REGCON meeting, DFSM September 2019] >3000 Dry Cask Storage systems (variations to cask type/ISFSI & storage geometry) are in US alone; 200 systems are added annually and all will exceed their original licensed period – Aging Management Programs are required to extend the licenses for current storage locations at 78 US ISFSIs in 34 states. Cask and peak fuel cladding temperature, fuel stability (some is damaged or fuel debris), radiation exposure to workers (occupational) and the public, nuclear criticality and other characteristics are measured and monitored. “


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“Non-Destructive Examinations of the SNF are now being tested and incorporate Robotics for remote examinations. The inspection team checking the outside temperature of a 16 year-old SNF Cask received a 4 Rem radiation dose. “ (5 Rem is the annual 10CFR20 limitation for radiation dose and these teams monitor multiple casks daily. Additionally, the NRC may approve multiple 40-year license extensions for HOLTEC CISF, each increasing the number of required Cask Inspections.) (Occupational Exposure Reference: www.nei.org (US nuclear utility industry) “The annual limit for occupational exposure is 5,000 mrem. The average nuclear energy facility worker receives 101 mrem. The average member of the public receives less than 0.5 mrem per year from the entire nuclear energy fuel cycle combined, including uranium mining, fuel fabrication, and nuclear power generation and waste disposal. No harmful effects have been detected as a result of exposure to low levels of radiation—in the range of 5,000 to 10,000 millirem (mrem)—depending on whether the exposure occurs in a short period or over a longer time,…, A typical medical X-ray (single exposure) provides a dose of 10 mrem, while a single CT scan typically provides a dose of 1,000 mrem”)

4.2.1 Page 4-4, lines 17-31 Paul

Potash mining activities in the vicinity of the proposed project are described. Potash resources beneath the proposed project area are leased to Intrepid Mining LLC, while potash resources surrounding the proposed project area are leased to “various potash production companies, including Intrepid, Mosaic Potash, and Western Ag-Minerals.” The closest mined potash is approximately 2 miles from the proposed CISF project area (EIS page 3-9, lines 4-5). Given the subsidence impacts associated with underground mining of potash in the region (documented within 10 miles of the proposed CISF project area), as discussed in Section 3.4.5 of the EIS, a safe exclusion zone should be established as a mitigation measure in which no potash mining is permissible (e.g., through retirement of leases or other administrative process). Potash mining beneath or in proximity to the proposed CISF would risk future compromise of the integrity of the facility. Section 5.4, lines 33-37 describe an agreement with Intrepid Mining and “discussions” with the NM State Land Office to retire potash leasing and mining within the CISF project area. However, the footprint of the proposed CISF project area is small relative to potential land subsidence that could be induced outside its boundaries and the assurances offered in this section are not particularly reassuring. An engineering analysis could be conducted to determine a safe exclusion zone for prohibition of potash mining and a legal means of enforcement established.

4.2.1 Page 4-4, lines 32-42 Paul

Active oil and gas exploration and development in the vicinity of the proposed project are documented, including the presence of an operating gas well within the project area. Given the potential for anthropogenic sinkhole development related to oil and gas well construction, operation and abandonment, as described in Section 3.4.5 of the EIS, as well as seismic risks and other potential hazards of gas well construction and operation, these activities should be prohibited on the proposed project site and within some safe exclusion zone surrounding the proposed project site established as a mitigation measure.

4.3.1.2 4-11

Regarding operation impacts from transportation, the HOLTEC EIS states: “Similar to the construction stage, during operation of the proposed CISF, Holtec would continue to use roadways for supply and waste shipments in addition to workforce commuting. Additionally, Holtec proposes using the national rail network for transportation of SNF


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from nuclear power plants and ISFSIs to the proposed CISF and eventually from the CISF to a geologic repository, when one becomes available. The regional and local transportation infrastructure that would serve the proposed CISF is described in EIS Section 3.3. The operations impacts the NRC staff evaluated include traffic impacts from shipping equipment, supplies, and produced wastes, and from workers commuting during CISF operations. Other impacts evaluated included the radiological and non-radiological health and safety impacts to workers and the public under normal and accident conditions from the proposed nationwide rail transportation of SNF to and from the proposed CISF.” However, the EIS fails to discuss the impacts from SNF shipments with suspected breached canisters as indicated by higher radiation levels. HOLTEC SAR 3.1.4.1” When the transportation cask arrives at the HI-STORE CIS facility, the transportation cask is visually inspected for any outward indications of damage or degradation prior to entry into the Protected Area (PA). Additionally, a review of the transportation documentation package, which includes verification that a pre-shipment inspection was performed and acceptable, is mandatory prior to receiving and accepting a transportation cask - the radiation dose rate from the cask on arrival at the HI-STORE CIS facility must be in reasonable accord with the measured dose rate at the originating plant.” The Holtec Nuclear Safety Analysis Report section 5.5 also addresses acceptance of multi-purpose canisters (MPCs) and states that “after passing the Krypton-85 test, each canister shall be subjected to a helium leak test in accordance with ANSI N14.5-2014. Canisters that fail to meet the acceptance criteria shall not be stored at HI-STORE and are shipped to the nuclear plant of origin or other facility licensed to perform fuel-loading procedures.” This return of SNF to its origin doubles radiation exposure impact to material handlers (both at HOLTEC receipt and at original source nuclear power plant and transportation exposure to railroad workers. “Canister records are reviewed to certify that the canister meets the material considerations of Chapter 17 and the receipt inspection requirements of Chapter 9 to ensure the canister continues to meet the no-credible-leakage criteria to which it has been certified in the HI-STORM UMAX docket [1.0.6]. Various welding techniques, non-metallic repair and other options are under evaluation for correcting cask defects” but no final recommendations were available in September 2019.

4.4.1.2 Page 4-26, lines 24-43

The EIS recognizes the potential hazards posed by improperly abandoned oil, gas and water wells, but offers no assurance that the 18 abandoned and active oil and gas wells, and the one abandoned water well on the proposed CISF project area were properly constructed or properly abandoned. The risk is minimized by the suggestion that none of the wells are located within the proposed storage area (but none are more than 5,000 ft.) and that the geologic conditions are not conducive to karst development because no thick sections of soluble rocks are present at or near the land surface. It is stated that the shallowest formation of thick soluble materials is the Rustler Formation at over 1,000 ft. below the proposed CISF facility. Ironically, at least two of the local examples cited in the EIS involved dissolution of soluble formations at depths of 1,000 ft. or more below the surface. The Jal Sinkhole was the result of dissolution of the Rustler Formation and the Wink Sinkhole formed due to dissolution in the Salado Formation, in


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both cases at depths greater than 1,500 ft. below the surface. The integrity of the 18 oil and gas wells, and the one water well, present at the proposed CISF project area should be thoroughly evaluated and an engineering determination of the potential for sinkhole development at the site included in the EIS.

4.5 Water Resource Impacts

Potable water for construction, operations, and decommissioning/reclamation are to be supplied by the City of Carlsbad Water Department mostly through existing pipelines. This water is pumped from the Ogallala Aquifer. Water requirements during construction (Phase I) are almost 50 Acre-feet per year (AFY). Phases 2-20 plus ongoing operations have a peak water demand of 30 gpm - which also translates to slightly less than 50 AFY, small compared to the roughly 15,000 AFY pumped by the City of Carlsbad. Threats to surface and groundwater supplies would only arise as a consequence of major flooding events. There is quite adequate drainage to regional playas and area groundwater is unlikely to be adversely affected by runoff. It is important to note that the SNF canisters do not contain any material in liquid form.

4.7.1.1.2

4-58, lines 36-37

The EIS looks at the project in isolation and does not consider cumulative air quality impact in conjunction with the already operating oil well on the site. Combined impact would be more representative of actual human exposure to PM2.5 particles. Normally in air quality permits cumulative impact is considered.

4.11.1.2 Benefits to Eddy and Lea Counties

Section 4.11.1.2: Holtec states that during the operations stage they would expect to make annuity payments in the range of $15 million to $25 million to Lea County, Eddy County, and the cities of Hobbs and Carlsbad (Holtec, 2019c). Based on the NRC staff’s comparison of county financial reports against the tax values in the counties in the ROI in fiscal year 2018, the proposed action (Phase 1) operations stage would generate a 0.2 percent increase in local revenues. The addition of the annuity payments to Lea County, Eddy County, and the cities of Hobbs and 13 Carlsbad would result in an increase up to 0.38 percent. They don’t provide the basis for the annuity payments.

4.11.1.1 Employment Impacts

The peak number of onsite workers (80 construction workers, 40 operations personnel, 15 security guards)*, totals 135. The range of indirect jobs resulting from construction workers is from 5 to 14. They do not state whether these are permanent jobs. The construction is supposed to take 2 years, so 80 construction workers would be employed for two years. The range of indirect jobs resulting from non-construction workers is from 12 to 18. These are not significant numbers of new jobs. Costs: Table C-4: Phase 1 annual operating costs (2019) range from a higher cost scenario $27,892,625 to a lower cost scenario $4,709,983. Table C-5: Phase 1 construction cost $116,859,908 for each of the two years. Subsequent phases: $103,399,272 per year for the next 19 years to finish all phases. They do not state how many workers would be needed to build the additional phases. Holtec estimates they need 40 operations personnel and 15 security guards to operate the Phase 1. According to tables C-5 and C-6, Holtec’s annual operating costs do not


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increase as new phases are added. This seems unrealistic but from this we assume subsequent phases will not increase the numbers of jobs. Benefits to New Mexico This is not addressed in the EIS. During the Radioactive and Hazardous Waste committee meeting of November 4-5, 2019 it was said that there were some discussions about sharing part of the revenue with the state. In the absence of that, the main benefit to the state is the GRT during construction. We estimated this to be $5,989,000 for each of the two years to build Phase 1, assuming the state GRT tax rate of 5.125%. We assume there would be some GRT for materials during operations but the costs are not broken down by category. There could be minor income tax benefits if the jobs that are added aren’t replacing other jobs.

44.11.1.1

4-73, lines 29-32 4-73, lines 46-47

“A lease agreement between Holtec and Intrepid could be established that restricts potash mining beneath the footprint of the proposed CISF project area and a 305-m (1,000-ft) buffer…” “If no agreement is made then Intrepid could potentially expand mining operations under the proposed CISF project area.” These two statements inject a major uncertainty factor into the potential long-term physical stability of the CISF. It should be resolved before the EIS is completed.

4.162 4-74, lines 37-38

The EIS estimates Holtec International will buy 10% of its construction materials locally and extrapolates that guess into an estimate of tax revenue for Lea County. But there is no evidence in the EIS that Holtec International has made a commitment to buy any construction material locally, so the basis of the estimated tax impact is questionable.

4.11.1.2 4-78, lines 40-44 4-79, lines 5-7 4-79, lines 11-13

The EIS says there are eight Department of Energy funded Federal Regional Coordinating offices throughout the U.S. with personnel on 24-hour call. The office for New Mexico is located in Albuquerque, several hours away from the site by motor vehicle. The EIS notes “significant additional costs to States would likely not be incurred related to unique or different training to respond to potential transportation accidents involving SNF as compared to existing radioactive materials commerce.” The EIS goes on to note “Because needs of individual municipalities along transportation routes and the costs of training and equipment vary widely, quantification of such would be speculative.” There is inconsistency in these two statements. Either the EIS should eliminate speculation about potential cost of training and equipment or do an actual analysis of the cost. Until this is resolved, it seems premature to declare the annual socioeconomic impacts associated with operations of CISF to be SMALL.

4.13.1.2 4.15

4-89 4-101

The HOLTEC EIS states: “Operational activities at the proposed CISF would include the receipt, transfer, handling, and storage of canistered SNF. During these activities, the radiological impacts would include expected occupational and public exposures to low levels of radiation. The nonradiological impacts would include the potential for typical occupational injuries and fatalities during the proposed CISF operations.” The HOLTEC EIS also states: “Numerous features combine to reduce the risk associated with accidents involving SNF storage at the proposed CISF project.” The NRC staff’s safety review states that Holtec has incorporated safety features into the design, construction, and operation of the proposed CISF project as a first line of defense to prevent the release of radioactive materials.” The NRC staff also says that additional measures are designed to mitigate the consequences of failures in the first line of defense.


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However, cask transfer is the most challenging operation at Hi-STORE. (Reference: HOLTEC CIS Nuclear Safety Analysis Report, Rev 0A October 6, 2017) “The Canister Transfer Facility (CTF) is a below-grade placement location where the transport cask is temporarily placed to effectuate vertical canister transfer between the transport cask and the HI-TRAC CS Transfer Cask. Canister Transfer means transfer operations necessary to translocate a loaded canister between a transport cask, HI-TRAC CS and/or the HI-STORM UMAX storage system. The Cask Crane is the gantry crane installed in the Cask Transfer Building for heavy load handling activities.” The August 2018 Cask Drop incident using Hi-TRAC Transfer Cask (same as NM HOLTEC CISF Design) occurred at the HOLTEC-operated San Onofre Nuclear Generating Station (SONGS) in CA during Decommissioning operations. The Multi-Purpose Canister (MPC) containing SNF assemblies being downloaded at SONGS into the storage vault lodged on the shielding ring in the receiving Cask. Obstructions in the loading path were identified among causes of this incident. Remote monitoring with cameras were among the SONGS corrective actions implemented. [reference “SONGS Recent Dry Storage Operating Experience”, Randall Granaas, REGCON 2019, NRC Division of Spent Fuel Management (DSFM) September 2019]. Similar Cask drops could occur during handling at the HOLTEC CISF proposed for SE NM. SNF stored in a humid environment may also have a greater probability of radiation release during cask transfer. Damaged MPCs (e.g., those exhibiting Stress Corrosion Cracking from ISFSI storage in humid environments) may also have a greater probability of radiation release during cask transfer. MPCs of concern may include those from the San Onofre Nuclear Generating Station (CTF) as discussed in canister corrosion remarks (EIS 2.2) above. HOLTEC Nuclear Safety Analysis Report Section 3.1.4.2 addresses cask transfer and indicates that “temporary radiation shielding during cask transfer may be positioned as required to maintain worker dose as low as reasonably achievable (ALARA);” however, each SNF handling operation increases the potential for radiation exposure.

4.15 Accidents

This section addresses only accidents that could occur at the CISF site, and only those that might result in “potential offsite doses.” Specifics are practically non-existent. Possible failures of storage canisters, ruptures of fuel rods within canisters, and accidents in handling spent nuclear fuels are briefly mentioned. On Site Accidental Releases The main “local” human safety concern should be for an incident that results in airborne material. Prevailing winds are mainly from the south, almost all from between WSW and ESE (See Figure 3.7-1). What are the populations living “downwind”? (See figure 2.2-1): Downwind Populations: Maljamar (2010 pop. 39 )is about 25 miles to the North of the site Loco Hills (pop. 89) is about 28 miles to the NNW Lovington (pop. 11,009) is about 38 miles to the NE Hobbs (pop. 38,277 (pop. 11,009) is about 40 miles to the ENE. Artesia (pop. 12,268) is about 50 miles to the NW Upwind Populations:


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Eunice (pop. 2,987) is about 40 miles to the ESE Carlsbad (pop. 29,331) is about 35 miles to the WSW Malaga (pop.147) and Loving (pop.1,390) are about 35 miles to the SW Other Populations:

Reference is made to a “… large transient population of employees in the area at nearby potash mines, oil fields, an oilfield waste treatment facility, and an industrial landfill. (2-3)

The surrounding population is heavily Hispanic and relatively low-income.

This raises concerns about environmental justice for this vulnerable population.

Where is the analysis of off-site impacts?

Is it clear that all deliveries are to be by rail? To what does the rail spur connect? To what railroads? Do those railroads have lines (rights-of-way, tracks & rolling stock) capable

of handling the loads? (Are there agreements in place?) Locations of present storage sites needed.

Decommissioning?

Are there any guarantees that the facility will be decommissioned by a certain date?

Where does the “storage” go if no permanent storage site is provided? Does the “interim” site become a permanent one?

Section 5

General Comment

Given the facility’s close proximity to a major highway, that it contains a very small ‘buffer zone’, and is located in areas where significant mineral, oil and gas extraction activities are currently taking place, this site does not appear to be suitable for interim spent nuclear fuel storage. Some of a few specific issues of concern are given below.

1. The site location seems to be based on available land rather than being a location that would minimize the risks due to the significant mineral, oil and gas extraction taking place in the near vicinity. There are relatively open areas where oil and gas wells are less dense than the proposed site and would seem better suited for this type of site (see map below).

2. The site has a relatively small footprint with a very narrow buffer zone making it more susceptible to subsidence, sinkhole formation, and seismic activity due to nearby oil and gas extraction, salt water disposal, and mining.

3. The report minimizes the INTREPID potash mine that underlies the proposed site location and possible subsidence that may occur from potash extraction.

4. There are numerous old references cited in the report (e.g. Bjorklund and Motts), and conclusions based on biased interpretations of future activity in the area.

5. Past and active potash extraction are approximately 2 and 4 miles south of the proposed site boundary. Surface subsidence due to subsurface potash mining is common and occurs long after mining operations have ceased as reported by Zhang et. al. 2017 upon an analysis of satellite images within the vicinity of the site. Subsidence can and does change surface water flow patterns and, consequently, could alter the integrity of proposed site. At the time of the HOLTEC’s EIS there is no potash mining below the proposed CISF. However,


20

INTREPID mine corporation has potash mineral rights below the proposed site boundary. HOLTEC states an agreement has been formed between INTREPID mining and the State of New Mexico to ‘relinquish or retire’ any potash mining below the site, thus circumventing any potential subsidence within site boundary. It is presumptuous of HOLTEC (and NRC) to assume that there will be no future potash mining below the site boundary based on this ‘proposed’ agreement. Additionally, any mining adjacent to the boundary can potentially alter surface water flow patterns and undermine the integrity of the site itself. HOLTEC should not presume INTREPED mining will not extract potash below the proposed CISF based on this anticipated agreement nor presume mining up to the boundary will not affect groundwater flow patterns within the CISF.

SEE MAP BELOW.

5.4 Page

5-24 Lines 14-16

The EIS recognizes the potential hazards posed by improperly abandoned oil, gas and water wells, but offers no assurance that the 18 abandoned and active oil and gas wells, and the one abandoned water well on the proposed CISF project area were properly constructed or properly abandoned. The risk is minimized by the suggestion that none of the wells are located within the proposed storage area (but none are more than 5,000 ft.) and that the geologic conditions are not conducive to karst development because no thick sections of soluble rocks are present at or near the land surface. It is stated that the shallowest formation of thick soluble materials is the Rustler Formation at over 1,000 ft. below the proposed CISF facility. Ironically, at least two of the local examples cited in the EIS involved dissolution of soluble formations at depths of 1,000 ft. or more below the surface. The Jal Sinkhole was the result of dissolution of the Rustler Formation and the Wink Sinkhole formed due to dissolution in the Salado Formation, in both cases at depths greater than 1,500 ft. below the surface. The integrity of the 18 oil and gas wells, and the one water, present at the proposed CISF project area should be


21

thoroughly evaluated and an engineering determination of the potential for sinkhole development at the site included in the EIS.

5.8 Noise

(This is a somewhat abbreviated version of Sections 4.8) “Geographic scope” is 10 Km (6 mi). No estimate is provided for noise levels during operations. These are probably dominated by rail operations and the use of cranes etc., to handle the unloading and transfer of casks.

5.9 Historic & Cultural Resources

(This is a somewhat abbreviated version of Sections 4.9) “Geographic radius” is 16 km (10 miles ).

5.10 Visual and Scenic

(A slightly abbreviated version of Sections 4.10 ) “Geographic scope” is 10 km (6 mi). Dust would probably be the major adverse impact during construction, light pollution would be the major visual impact during night operations. Site lighting, e.g., “Security Lighting”, even if downward-directed would probably be visible as skyglow for considerable distances.

5.11 Socio-economics

(A much abbreviated version of Sections 4.11 ) The “Region of Interest (ROI)” for this topic is 80 km (50 mi) and consists of parts of Lea and Eddy Counties in New Mexico plus Andrews and Gaines Counties in Texas. It is, at least, recognized that any sort of demographic or economic forecasting for this region, subject to the boom and bust cycles of the oil and gas industry, is difficult.

5.12 Environ-mental Justice

(A very brief summary of the materials in Section 4.12 and APPENDIX B ) The “geographic scope” is 80 km (50 mi). The concern is the possibility of disproportionately high adverse effects upon the health or physical environment of low-income or minority populations. (Note emphasis.) The conclusion that these effects are SMALL on low-income and minority populations follows from the conclusion (see the following Section) that the adverse effects on all populations in this ROI will be SMALL. See above comments on the disproportionate impact on low-income Hispanic populations. NOTE: The Summary of Section 5.12 , 5.12.1 says that the impacts are found to be “… SMALL to MODERATE for ecological resources and socioeconomics, and SMALL to LARGE for historic and cultural resources.” This seems to be somewhat at variance with the preceding material and the material in Table 5.1-1 which indicates Environmental Impacts are SMALL for all categories except Moderate for Vegetation, and SMALL to MODERATE (and beneficial) for local finance.

5.13 Public and Occupa-tional Health

( A 1-page summary of the 8 pages of Section 4.13 ) The “geographic scope” is an 80 km (50 mi) radius. The 0.122 mSv exposure the fence in 2,000 hours scales to an annual dose of 0.535 mSv at the 100 meter “fence line”- an order of magnitude smaller than the 6.2 mSv level of background radiation supposedly characterizing ROI. This has the potential for a major impact on public health. But Section 5.13, despite its title, doesn’t address occupational health which, presumably, would refer to personnel who work at the site and their families.


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Section 4.13, on the other hand, deals extensively with the non-radiological hazards associated with construction and operation but does address worker exposure in Section 14.13.1.2. The NRC estimated that the annual worker exposure associated with cask handling would be 25 mSv (i.e. 0.025 Sv or 2.5 rem). This is half of the NRC dose limit.

5.14 Waste Manage-ment

( A somewhat shortened version of Section 4.14 ) The geographic scope is an 80 km (50 mile) radius. The Low Level Radioactive Waste (LLRW) produced over the full lifetime of the project, including decommissioning (through 2060?), amounts to about 27.21 metric tons ( 39 short tons), which is very small (0.2%) compared to that currently disposed at (relatively) nearby facilities. The nature of this waste (tools, gloves, cleaning supplies?) is not given. Non-hazardous waste would go to a pair of identified municipal landfills prior to decommissioning. The volume produced during decommissioning would be problematic, requiring the creation of new landfills. Sanitary waste would go to underground digestion tanks and collection tanks and then be shipped to an offsite treatment facility.

5.15 References

This does not correspond to Section 4.15 Accidents .

Table 6.3.1

6-2 The EIS statement that HOLTEC CISF does not place additional burden on public services or community infrastructure due to commuting or transitory workforce, as well as well as economic impact assumptions, may be erroneous. The URENCO facility utilizes community resources and the workforce commutes via NM infrastructure to facility. In addition, Emergency Response efforts for URENCO draw from NM communities and impact first responders and hospitals.

7.2 7-1 The HOLTEC EIS states: “Radiation monitoring requirements are met by using area radiation monitors in the cask transfer building for monitoring general area dose rates from the casks and canisters during canister transfer operations, and with thermoluminescent dosimeters (TLDs) along the perimeters of the restricted and controlled areas (Holtec, 2019b). TLDs provide a passive means for continuous monitoring of radiation levels and provide a basis for assessing the potential impact on the environment. Monitoring is expected to include the following:

Continuous radiation monitoring at the project boundary fence (via TLDs) Continuous monitoring (via TLDs) on the outside of all buildings Continuous monitoring (via TLDs) at strategic work locations, as backup for

personnel radiation exposure monitoring Each TLD location will have a backup (i.e., two TLDs) with quarterly retrieval and

processing Local radiation monitors with audible alarms to be placed in the canister transfer

building “


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Thermoluminescent Dosimeters (TLDs) are used for radiation monitoring in most CISF operations. TLDs provide continuous passive monitoring and backup TLDs are processed to obtain radiation readings that have accumulated and are recorded quarterly. Damaged Fuel Assemblies and Fuel Debris resulting more frequently from High Burnup Fuel will release more radiation than intact fuel and releases may be short bursts of radiation (acute exposure) rather than the longer-term exposure, so TLDs may not be acceptable. Accurate measurement of acute radiation doses requires an electric dosimeter, e.g., pocket Geiger-Mueller (GM) detector, to measure real time levels. Neutron radiation from SNF for the Holtec application should also employ neutron detectors throughout the facility (fission chamber detectors) for Cask Transfer, Cask Transportation, and other high risk SNF handling applications. More rigorous radiation measurement techniques including pocket GM detectors with real-time feedback and appropriately placed neutron detectors should be employed where warranted.

Table 6.3.2

6-8 Table 6.3.2 lists NRC-recommended mitigations. However, LWVNM Recommendations to NRC could be added as comments to the Mitigation Measures Section of HOLTEC EIS.

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From: Hannah Burling Sent ... · fuel cladding must be protected during storage against degradation that leads to gross ruptures or the fuel must be