ML18143B453

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Comment (75) of New Mexico Interfaith Power & Light on License Application by Holtec International for the Consolidated Interim Storage of High-level Radioactive Waste
ML18143B453
Person / Time
Site: HI-STORE
Issue date: 05/03/2018
From:
New Mexico Interfaith Power & Light (NMIPL)
To: Kristine Svinicki
Rules, Announcements, and Directives Branch, NRC/Chairman
References
83FR13802 00075
Download: ML18143B453 (35)
v • d • e


Text

NewiMexico Interfaith Power and Lighf PO Box 27162, Albuquerque, New Mexico 87125**www.nm""ipl.org-info@nm-ipl.org-505-266-6966 May2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr. $. *cretary, Madam Chairperson, and Members of Congress:

We are -'~~~h~ ;isterA~1:%~munity and religious* leaders. We are greatly concerned about an issue that will aff~dt~~;mmunities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "A'!, faith leade_rs we take seriously the responsibility to help discern what is equitable, just,, and for the common good of Our Common Home."

Our concern is about, a license application by Holtec International for the Consolidated lnter;im Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider., As stated in.the license application, this proposed projej::t would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in,35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currer:rtly at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to apprvve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways, and railroads through communities. Also, since this is a "storageD sit_e and.not a "disposal siteD like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during *construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and Mure clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC; a Umited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory-requirements, safety performance, and financial responsibility in their existing. ope~ons. Holtec has no current presence in New Mexico so their corporate ethics are unknown.

SUNSI Review Complete Template= ADM-013 COMMENT #75 E-RIDS=ADM-03 PUBLICATION DATE: 3/30/2018 ADD= Anntoinette Walker-Smith Jill Caverly (jSCl)

CITATION: 83 FR 13802

5. When the people of New Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" *here wtll become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial aclivmes*which can pollute our air, land, and water and pose
  • potential failure risk. Our citizf!ns, many of whom are Hispanic, bear a-disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in *southeast New Mexico. The wtPP site is overseen by the Department of Energy.(DOE) which has decades of presence in New Mexico.
  • .a. Waste Control Specialists, LLC has already startecHhe development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic. if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judeo-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

. "T~ay, I have set before you life and death, biessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

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New 'Mexico Interfaith Power and Light ft

. PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org-info@nm-ipl.org**505-266-I 6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation Dei;lr Mr. Secretary, Madam Chairperson, and Members of Congress:

We are ~st;~~

co~munity and religious* leaders. We are greatly concerned about an issue that will a~~

7,~r communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing-climate change and the economy, "As faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home."

Our concern is about a license application by Holtec International for the Consolidated lr:iterim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.- As stated in*the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad* and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways. and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and Mure clean-up and decommissioning of the *site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information trom*the NRC regarding Holtec Government Services, LLC compliance with regulatory-requirements, safety performance, and financial responsibility in their existing ope~ions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.

J

5. When the people of New Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" *here will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRG does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen -by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alread_y started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage iri these issues:.

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

'I I

New Mexico Interfaith Power and Lig~t" PO aox 27162, Albuquerque, New Mexico 87125-WWW.nm-,ipl.org**info@nm-ipl.org**505-266-6966 May2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr. Secretary, Madam Chairperson, and Members of Congress:

We are C~e~~~~munity and religious* leaders. We are greatly concerned about an issue that will a;;~r-~~-~mmunities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "A~ faith leaders.we take seriously the responsibility to help discern what is equitable, just, and for the common good of Our Common Home."

Our concern is about a license applica~ion by Holtec tnternational for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.- As stated in*the license application, this proposed projept would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currer:ttly at the power plants as well as the spent fuel from what is currently in use -and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways_ and railroads through communities. Also, since this is a '"storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to. a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more ~adioactive than the waste disposed of at WJPP.

3. Assurance that The State of New Mexico wiU not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the *site. The operating entity is likely to be Holtec Government Services, LLC; a limited Liability Corporation (LLC) and.as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck:with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory-requirements, safety performance, and financial r.esponsibility in their existing. ope~tions. Holtec has no current presence in Ne\\fY Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has.

been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facilityn here will become a de-facto disposal location.

6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollµte our air, land, and water and pose potential failure risk. Our citizens, many of whom.are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alreaqy started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live. n Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

New.Mexico Interfaith Power and Light" I

PO Box 27162, Albuquerque, New Mexico 87125**www_nm-ipl.org**info@nm-ipl.org**505-266-6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation Dec;ir Mr. 8fcre~ Madam Chairperson, and Members of Congress:

We are ~t~

l~co~munity and religious* leaders. We are greatly concerned about an issue that will affe~ ""J;r' communities,* our future generations, and the wonderful state we call "home.* As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "A~ faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home.*

Our concern is about a license applica~ion by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRG) will consider.- As stated in.the license application, this proposed projept: would allow the storage of 110,000 tons of spent nuclear-reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years*.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities_ Also.. since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP_

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation arid recovery, and future clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial _responsibility in their ex1sting operations. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed.to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that histol)' we are concerned that the ustorage facility" here will become a de-facto disposal location.
6. There-is also an environmental justice concern for this project. We.already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has already startecHhe development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability* of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the rlsk of this project are in the open, receive public scrutiny-, and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

.. * * * *.
  • y*

PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org-info@nm-ipl.org-505-266-6966 May2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr. ecretary, Madam Chairperson, and Members of Congress:

We are * *.~~h~i;c Sis~,~

community and religious* leaders. We are greatly concerned_

about an issue that will aff~d Tur communities, our future generations, and the wonderful state we call "home. n As Pope Francis stated in his 2015 e_ncyclical addressing.climate change and the economy, "A~ faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home. n OLJr concern is about a license application _by Holtec tnternational for.the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power ~nts in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel curreAtly*at the power pla.nts as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storageD site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and
  • decommissioning of the-site. The operating entity is likely to be Holtec Government Services, LLC; a limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck *with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory-requirements, safety performance, and financial responsibility in their existing oper~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown..
5. When the people of New Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facilttyn here will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are. concerned that the NRC does not have th.e resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy.(DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alread.Y started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in propheti'c, if not popular roles. Our ancient *roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live. n Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

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  • . New.Mexico Interfaith Power and Ughf
  • PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nm-ipl.org**505-266-6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congre*ssional Delegation De~r M~

Madam Chairpe~on, and Members ~f Congress:

We are Catholic Sist'5.,W~community and religious leaders. We are greatly concerned about an issue that will a7/~~t~r~communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing ciimate change and the economy, "A~ faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home. n Our concern is about a license application by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed proje~ would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in-35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant {WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves; who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain-information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requfrements, safety performance, and financial responsibility in their existing operations. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New-Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here will become a de-facto disposal location. *
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does _not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alreaqy startec:Uhe development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and *Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live. D Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny. and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

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New Mexico Interfaith Power and Light" PO Box 27162, Albuquerque, New Mexico 87125*"www.nm-ipl.org**info@nm-ipl.org**505-266-6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr~

Madam Chairpe~on, and Members ~f Congress:

We are Catholic SisterRw~~mmunity and religious leaders. We are greatly concerned about an issue that will affect~~rk~mmunities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "A~ faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home."

Our concern is about a license applica\\ion by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission {NRC) will consider.- As stated in*the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and* Hobbs. This facility would store the spent fuel currently*at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities, Also, since this is a "storage" site and not a "disposal siten like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC; a limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial responsibility in their existing oper~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to th~ WIPP Sit~ they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raise$ the question of the economic viability of this project since a competitor is already
started, Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular rotes. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

I u
  • .New Mexico Interfaith Power *and Ligtlt" PO Box 27162, Albuque,que, *New*Mexico 87125-www.nnHpl.ofiJ**info@nm.;pt.org-505-266-6966 May2018 To:

Rick Perry, Secretary, Department-of Energy Kristine L. Svinick, Chairperson, *Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr. Secretary, Madam Chairperson, and Members. of Congress:

We are ~Zli~mmunity and religious*.leaders. We are greatly concerned about an issue that will affect ~~~mmunities, our future generations. and the wonderful state we call "home." As Pope Frati~s stated in his 2015.encyclieal add~ng-climate change and the economy, "As faith leaders we take seriously-the responsibility to help discern what is equitable, just, and for the common Q(>od of Our Common H9me.~

Our concern is about a license applicaijon.by Holtec 1nternational for the Consolidated Interim storage of high-level radioactive waste that the Nuclear.Regulatory Commission (NRC) will consider.. As stated in.the llcense application, this proposed pr~ would allow the storage of 110,000 tons of spent n_uclear.~actor ~

.from nuclear power ~ts in-35 states. The proposal is for a shallow sub-surface burial system in Lea County between* Carlsbad,and Hobbs.* This facility would store the spent fuel. currently:at the power plants: as ~I.as :the spent fuel from what is currently in use and projectecffor future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand*the project and voice their concerns. Some of the iss1.1es are:

1. The safety.of the transportation of the spent fuel on highways_ and railroads through communities. Also, since this. is* a "storage" site and not a "disposal site" *like the Waste Isolation Pilot Plant (WIPP), at -some future point-the spent fuel will need to be removed and sent to.a disposal site, thus doubling-the transportation risk.
2. The safety of the operations at ttie site during construction and operation.

Spent fuel is many thousands of times more radioactive-than the waste disposed of at WIPP.

3. Assurance that The state of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future ciean-up and decommissioning of the *site. The operating entity. is tikely to be-Holtec Go¥emment Services, LLC, a limited Liability Corporation (UC) and as such is protected from many of the financial consequences of. failure. If their corporation dissolves, who *is stuck *with the-bill? New Mexico does not have the resources:for this. *
4. The public has been unable to obtain information from*the NRC reg&rQing* Holtec Govemment Services, LLC compliance with-regulatory-requirements, safety performance, and financial J~sponsibility in their-existing operaJions. Holtec-has no current presence in New Mexico so their corporate ethics are :unknown.
5. When the people. of New-Mexico agreed to ~-WJPP*Sit~.they were p:omised that New Mexico wouki:not store high-level nudear waste. The Federal government has been unable to agree on a disposal site for the pennanent disposal of spent nuclear fuel, and given that history we are concerned that the astorage facility' here will become a de-fado disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities-which can pollute our air, land, and water and pose potential failure risk. Our *ens. many of whom are Hispanic, bear a-disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have th.e resources or presence to adequately monitor or regulEJte the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The Wf PP site is overseen by the Department of-Energy.(DOE) which has decades.of presence in New Mexico.
8. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nu.clear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already
started, Our lives are committed to service of the Common Good and.high ethical and moral principles that lead us to stand in prophetic, if not popular roles.. Our ancient roots, and wisdom calls us to prated and care for Creation and Community. One passage*in *the Judeo-Christian tradition from the Book of Deuteronomy caHs us to-.be respon$ibte and to engage in these issues:
  • Today, I have set before you life-and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our. request.

Undersigned Catholic Women Religious and Organizations:

R-qpniA q;r"lv ah~

d)'n~~ ~Mo...~ ~

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New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125*'""www.nm-ipl.org**info@nm-ipl.org**505-266-6966 May 2018 To:

  • Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation Dec;tr Mr. ~adam Chairperson, and Me"!lbers ~f Congress:

We are Catholic Sisterlhtfr~munity and religious leaders. We are greatly concerned about an issue that will affect ~~r fu~munities, our future generations, and the wonderful state we caU "home." As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "As faith leaders we take seriously the responsibility to help discern what is equitable, just, and for the common good of Our Common Home."

Our concern is about a license application by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRG) will consider.- As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs.- This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are: -

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1. The safety of the transportation of the spent fuel on highways_ and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant {WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.

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  • ..- c**, 2. The safety of the operations at the site during construction and operation.
* :.;.. _*. )'. Spent fuel is many thousands of times more rad.ioactive than the waste disposed of at

' *.. ;. "'.', '.Wll?P.

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.. :3'.:' Assurance that The State of New Mexico will not have to shoulder the cost of

  • frS{i~ays; ro-=1ds, accident mitigation and recovery, and future clean-up and

_ *. :ae~rtj.rnissioning of the *site. The operating entity is likely to be Holtec Government

- *..,.. ::<.. >iServices; LLC; a Limited Liability Corporation (LLC) and as such is protected from many

  • . * *-*~ ""* *\\Qf:~~ financial consequences of failure. If their corporation dissolves, who is stuck-with

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  • the,-bill? New Mexico does not have the resources for this.

'A\\/ft,e public has been unable to obtain information from*the NRC regarding Holtec

  • G6V~mment Services, LLC compliance with regulatory requirements, safety perf~nna~ce, and financial responsibility in their existing operations. Holtec has no curr~ presence in New Mexico so their corporate ethics are unknown.

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5. When the people of New Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here will become a de-facto disposal l~ion.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities.which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional*

amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.

7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico. *
8. Waste Control Specialists, LLC has alreaqy started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and. high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live. m C

  • Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

,Thank you for the consideration of our request.

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  • ' Ur:idersigned Catholic Women Religjous and Organizations:

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New Mexico Interfaith Power and Light I

PO Box 27162; Albuquerque, New Mexico 87125**www.nm-ipl.org-info@nm-ipl.org**505-266-6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation Dec;1r Mr. Secretary, Madam Chairperson, and Members of Congress:

We are ~tls

~~ommunity and religious.leaders. We are greatly concerned about an issue that will affe~t'~Z/'communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing *climate change and the economy, "As faith leaders we take seriously the responsibility to help discern what is equitable, just, and for the common good of Our Common Home."

Our concern is about a license applica~ion by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.- As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currently at the power plants as well.as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need tc>be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC, a limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial responsibility in their existing oper~tions: Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility 0 here will become a d~

facto disposal location.

6. There is also.an environmental justice concern for this project. We already have a large number of industrial activities-which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy.(DOE} which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

New Mexico Interfaith Power and Light"

  • 1*

PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nrn-ipl.org**505-266-

. 6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico. Congressional Delegation Dec;1r Mr.. Secretary, Madam Chairperson, and Members of Congress:

We are ~te'Z'.:MJ ~~munity and religious* leaders. We are greatly concerned about an issue that wifi aff~tt our/communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing 'Climate change and the economy, "A~ faith leaders *we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home."

Our concern is about a license applica\\ion by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Cartsbad and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" sit.e and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at

  • WIPP.
3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the *site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck*with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial r:esponsibility in their existing oper~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New-Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here will become a de-facto disposal location_.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities.which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alread_y starte<Hhe development of a storage facility for spent nuclear fuel near the Texas/New Mex1co border near Eunice; NM. This raises the question of the economic viability of this project since a competitor is already
  • started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roJes. Our ancient roots, and *wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage, in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

I New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org-info@nm-ipl.org-505-266-6966 May 2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico. Congressional Delegation De:;ir Mr. Secretary, Madam Chairperson, and Members of Congress:

We are ~elww~~munity and religious* leaders. We are greatly concerned about an issue that will a~::r.. ~~/;c;mmunities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing climate change and the economy, "A~ faith leaders* we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home."

Our concern is about a license application by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed proje!=t would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currentty*at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel:\\l(,iill need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WtPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the *site: The operating entity is likely to be Holtec Government Services, LLC; a limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the.bill? *New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory.requirements, safety performance, and financial_ responsibility in their existing ope~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here Will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities *which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.

8-Waste Control Specialists, LLC has alread_y started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roJes. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

I.

New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nm-ipl.org**505-266-

. 6966 May2018 To:

Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members ofthe New Mexico Congressional Delegation

Dear Mr. recr~.ry,

Madam Chairperson, and Members of Congress:

We are *~~Zrs>>f~ community.and religious* leaders. We are greatly concerned about an issue that will iah~ctb~r communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclieal addressing climate change and the economy, "A?, faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home."

Our concern is about a license applica~ion by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.- As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface buriat system in Lea County between Carisbad and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issl)es are:

1. The safety of the transportation of the spent fuel on highways_ and railroads through communities. Also, since this is a ustorage" s~e and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico wiU not have to shoulder the cost of railways, roads, accident mitigation and recovery, and Mure clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck-with the-bill? New Mexico does not have the resources for this.
4. The pu~lic has been unable to obtair, information from-the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial responsibility in their existing operations. Holtec has no current presence in New Mexico so their corporate ethics are *unknown.
5. When the people of New Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" here will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has alread_y startecHhe development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

I New, M~xico lnterfaittl.;Power and. Light" 1 PO Box 27162, Albuquerque, -New*Mexico -87125**www.nRHptorg**info@nm-ipl.org... 505-266-

... 6966 May2018 To:

Rick Perry, Secretary, Department -of Energy Kristine L Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr.. Secretary, Madam Chairperson, and Members of Congress:

We are Cath~ lo ~unity and religious: leaders. We are greatly concerned about an issue that will affect our communities, our future generations, and the wonderful state we call "home." As Pope Francis stated-in his 2015 encyclical addressing -climate change and the economy, "A'!, faith leaders we take seriously*.the responsibility to help discern what is

  • equitable, just, and for the common good of Our Common Home.~

Our concern is about a license applica~ion.by Holtec International for the Consolidated Interim Storage of high-level radioactive waste that the_ Nuclear.Regulatory Commission (NRC) will consider.. As stated in*the license application, this proposed*projept would allow the storage of 110,000 tons of spent nuclear reactor fue.1 from nuclear power~ *in-35 states. The-proposal is for a shallow sub-surface burial system in Lea County betvveen Cai1sbad.and Hobbs. This.

facility would store the spent fuel. curremty at the power ptants: as well,as,1he* spent fuel from what is currently in use and projected for future years.

We ar.e concerned that the decisions.to approve this.project will be made without adequate time for communities to understand*the projeet and Yoice their. concerns.. Some of the iss&JeS are:

1. The safety of the transportation of-the spent fuel on highways_ and railroads through communities. Also, since this is*a *storage" site and not a "disposal sii:eD *like the Waste Isolation Pilot Plant (WIPP), at -some future point-the speot *fuel will* need to be removed and sent to.a disposal site, thus.dotibling the transportation risk.
2. The safety of the operations at the site during. construction and operation.

Spent fuel is many thousands of times more radioactive-.than the. waste disposed of at

~~-

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the *site. The operating entity. is likely to be*Holtec Government Services, LLC, a Limited Liability Corporation (tLC) and as such is protected from many of the financial consequences of failure. If.their corporation "dissolves, who is stuck *with the-bill? New Mexico does not have the resource~rfor this.
4. The public has been unable to obtain infonnation trom*the NRC regard.ing Holtec Government Services, LLC compliance with-regulatory-requirements, safety performance, and financial ~sponsibility in their existing. operations. Holtec has no current presence in New Mexico so.their corporate-ethics are:unknown.

5_ When the people of NewMelGCO agreed to ~WIPP*~~ they were ~m~

that New Mexico would*not store high-revel nuciear waste; The Federal* government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facifity" here will become a de-facto disposal location.

6. There is also an environmental justice concern for this project. We already have a large number of industrial activities *which can poHute our air, land, and water and pose
  • potential failure risk. Our citizens, many of whom are Hispanic, bear a* disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are concerned that the NRC does not have th_e resources or presence to adequately monitor or regulate the construction or operatiQn of this facility. The NRC has no current presence in Southeast New Mexico. Toe WlPP site is overseen by the Department of-Energy.(DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability* of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and.high ethical and moral principles that lead us to stand in prophetic, if not. popular roles. Our ancient -roots, and wisdom calls us to*

protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to-be respon$ible and to engage in these issues:

"Today, I have set before you life and death, blessing and cwse. Therefore, choose life that you and your children may live."

Please take action to ensure that all. concerns for the risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

i New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nm-ipl.org**505-266-

. 6966 May2018 To:

Rick Perry, Secretary, Department of Energy

. Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr.~

Ma~am Chairpe~on, and Members ~f Congress:

We are Catholic SisterAh~~munity and religious leaders. We are greatly concerned about an issue that will affect o~r ~~munities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 e_ncyclical addressing *climate change and the economy, "As faith leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home. n Our concern is about a license application.by Holtec *International for the Consolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.- As stated in.the license application, this proposed project would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in lea County between Carlsbad and Hobbs. This facility would store the spent fuel currently at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their. concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" site and not a "disposal siten like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico wiU not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the*site. The operating entity. is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck*with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information.from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial responsibility in their existing oper~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to the WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility~ here will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in Southeast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.

f3. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico.border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started..

Our.lives are committed to service of the Common Good and high ethical and moral principles that_.lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse~ Therefore, choose life that you and your children may live.u Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

New Mexico Interfaith Power and Light"

    • o*

PO Box 27162, Albuquerque, New Mexico s112s-www.nm-ipJ.cxg-in!o@nm-ipl.org-so&-266-

  • _.. 6966 May2018 To:

Rick Perry, Secretary, Department of Energy Kristine l. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation De~r Mr. Secretary, Madam Chairperson, and Members of Congress:

-~ij)')/~

We are Catholic Sisten:fwtto &ire corflmunity and religigus leaders. We are greatly concerned about an issue that will affect our communities, our future generations, and the wonderful state we call "home." As Pope Francis stated in his 2015 encyclical addressing dimate change and the economy, "A'!, faith.leaders we take seriously the responsibility to help discern what is equitable, just,* and for the common good of Our Common Home. n Our concern is about a license applica~ion by Holtec International for the *c.t>nsolidated Interim Storage of high-level radioactive waste that the Nuclear Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed proje~ would allow the storage of 110,000 tons of spent* nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a *shallow sub-surface burial system *in.Lea County between Carlsbad and Hobbs. This facility would store the spent fuel currer:itly at the power plants as well as the spent fuel from what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways and railroads through communities. Also, since this is a "storage" site and not a "disposal site" like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to.a disposal site, thus doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radioactive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico will not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and decommissioning of the site. The operating entity is likely to be Holtec Government Services, *LLC; a Limited Liability Corporation (LLC) and as such is protected from many.

of the financial consequences of failure. If their corporation dissolves, who is stuck *with the-bill? New Mexico does not have the resources for this.

4. The public has been unable to obtain information from*the NRC regarding Holtec Govemment Services, LLC compliance with regulatory requirements, safety performance, and financial _responsibility in their existing oper!=ltions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
5. When the people of New Mexico agreed to th~ WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned, that the "storage facility" here Will become a de-facto disposal location.
6. There is also an environmental justice concern for this project. We already have a large number of industrial activities *which can pollute our air, land, and water and pose
  • potential failure iisk. Our citizens, many of whom are Hispanic; bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.
7. We are-concerned that the NRC does not have the resources or presence to adequately monitor or regulate the construction or operation of this facility. The NRC has no current presence in South~ast New Mexico. The WIPP site is overseen by the Department of Energy (DOE) which has decades of presence in New Mexico.
8. Waste Control Specialists, LLC has already started*the development of a storage facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

"Today, I have set before you life and death, blessing and curse. Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the*risk of this project are in the open, receive public scrutiny, and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

'D I

I New Nlexico Interfaith Power and Light" PO Box 27162, Albuquerque, New Mexico a112s-www_nm-ipl.org**info@nm-ipl.org-505-266-6966 May2018 To:

Rick Perry, Secretary, Department.of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation Dei;lr Mr_ Secretary, Madam Chairperson, and Members of Congress:

We are Cat~ ~o~~unity and religious-leaders. We are greatly concerned about an issue that will affect o~r ~~~unities, our future generations, and the wonderful state we call "home." As Pope Francis stated.in his 2015 e_ncyclical addressing-climate change and the economy, "A~ faith leaders we take seriously the responsibility to help discern what is

-equitable, just,* and for the common good of Our Common Home.D Our concern is about a license application by Holtec International for the ConsQlidatedtlnterim Storage,of high-level radioactive waste that the Nuclear"Regulatory Commission (NRC) will consider.. As stated in.the license application, this proposed proj~ would allow the storage of 110,000 tons of spent nuclear reactor fuel from nuclear power plants in 35 states. The proposal is for a shallow sub-surface burial system in Lea County between Carlsbad and *Hobbs.- This facility would store the spent fuel currently at the power plants as well as the spent fuel from

  • what is currently in use and projected for future years.

We are concerned that the decisions to approve this project will be made without adequate time for communities to understand the project and :voice their concerns. Some of the issues are:

1. The safety of the transportation of the spent fuel on highways_ and railroads through communities. Also, since this is a "storage" site and not a "disposal siten *like the Waste Isolation Pilot Plant (WIPP), at some future point the spent fuel will need to be removed and sent to. a disposal site, thus* doubling the transportation risk.
2. The safety of the operations at the site during construction and operation.

Spent fuel is many thousands of times more radio~ctive than the waste disposed of at WIPP.

3. Assurance that The State of New Mexico wiU not have to shoulder the cost of railways, roads, accident mitigation and recovery, and future clean-up and
decommissioning of the *site. The operating entity is likely to be Holtec Government Services, LLC; a Limited Liability Corporation (LLC) and as such is protected from many of the financial consequences of failure. If their corporation dissolves, who is stuck*with the-bill? New Mexico does not have the resources for this.
4. The public has been unable to obtain information from*the NRC regarding Holtec Government Services, LLC compliance with regulatory requirements, safety performance, and financial_r:esponsibility in their existing ope~tions. Holtec has no current presence in New Mexico so their corporate ethics are unknown.
  • 5. When the people of New Mexico agreed to ttie WIPP Site they were promised that New Mexico would not store high-level nuclear waste. The Federal government has been unable to agree on a disposal site for the permanent disposal of spent nuclear fuel, and given that history we are concerned that the "storage facility" *here will become a de-facto disposal location.
6. There is also an environmental justice concern for this. project. We already have a large number of industrial activities*which can pollute our air, land, and water and pose*

potential failure risk. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as citizens.of New Mexico living in the communities where environmentally risky operations take place.

7. We are. concerned that the NRC does not have the resources or presence to,

adequately monitor or regulate the constructi-on or operation of this facility. The NRC has no current presen~ in Southeast New Mexico. The WIPP site is overseen by the Department of Energy.(DOE) which has decades of presence in New Mexico.

8. Waste Control Specialists, LLC has already started-the development of a storage

_facility for spent nuclear fuel near the Texas/New Mexico border near Eunice, NM. This raises the question of the economic viability of this project since a competitor is already started.-

Our lives are committed to service of the Common Good and high ethical and moral principles that lead us to stand in prophetic, if not popular roles. Our ancient roots, and wisdom calls us to protect and care for Creation and Community. One passage in the Judea-Christian tradition from the Book of Deuteronomy calls us to be responsible and to engage in these issues:

'Today, I have set before you life and death, blessing and curse~ Therefore, choose life that you and your children may live."

Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny., and receive due consideration.

Thank you for the consideration of our request.

Undersigned Catholic Women Religjous and Organizations:

(~)

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