ML18218A677
| ML18218A677 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 07/26/2018 |
| From: | Public Commenter Public Commenter |
| To: | Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| NRC/NMSS/DFCSE | |
| References | |
| 83FR13802 | |
| Download: ML18218A677 (11) | |
Text
1 Holtec-CISFEISCEm Resource From:
Joan Brown,osf <joankansas@swcp.com>
Sent:
Thursday, July 26, 2018 5:30 PM To:
Holtec-CISFEIS Resource; joan m brown
Subject:
[External_Sender] High Level Radio Active Waste Comment Period---New Mexico Attachments:
faith leader holtec letter to NRC and legis March 19, 2018 reformatted.pdf; Faith letter Catholic Sisters.pdf Please see the attached letters and comments regarding the High Level Nuclear Waste Storage Facility Comment Period that ends July 30. Please let me know that you have received these comments.
Peace and good, Sr. Joan Brown,osf Joan Brown,osf Executive Director New Mexico Interfaith Power and Light (NMIPL)
New Mexico Interfaith Power and Light PO Box 27162 Albuquerque, NM 87125 505-266-6966 www.nm-ipl.org info@nm-ipl.org 1004 Major Ave. NW.
Albuquerque, NM 87107 joanbrown@nm-ipl.org There is no inner world without the outer world. Thomas Berry, Author of The Great Work This email has been checked for viruses by Avast antivirus software.
https://www.avast.com/antivirus
Federal Register Notice:
83FR13802 Comment Number:
2492 Mail Envelope Properties (07d2ebec-a5f0-23a9-653a-cd632e3a975b)
Subject:
[External_Sender] High Level Radio Active Waste Comment Period---New Mexico Sent Date:
7/26/2018 5:30:11 PM Received Date:
7/26/2018 5:30:24 PM From:
Joan Brown,osf Created By:
joankansas@swcp.com Recipients:
Post Office:
swcp.com Files Size Date & Time MESSAGE 738 7/26/2018 5:30:24 PM faith leader holtec letter to NRC and legis March 19, 2018 reformatted.pdf 200255 Faith letter Catholic Sisters.pdf 86367 Options Priority:
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1 New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nm-ipl.org**505-266-6966 July 2018 To:
Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation
Dear Mr. Secretary,
Madam Chairperson, and Members of Congress:
We are faith leaders from many religious traditions, and from many diverse communities in New Mexico. 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, 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 (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 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 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.
2
- 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 religions have ancient roots, and this ancient 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: 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 Faith Leaders and Organizations:
Rev. Susan Quass, Executive Director New Mexico Conference of Churches Bishop David Bailey, Epicopal Church Navajoland Farmington, NM Sr. Joan Brown,osf, Executive Director, NM Interfaith Power & Light Albuquerque, NM Sr. Rose Marie Cecchini, MM, Director, Office of Life, Peace, Justice &
Creation,Catholic Charities of Gallup Diocese, Gallup, NM Rev. Dr. William M. Lyons, SouthWest Conference Minister United Church of Christ Rev. Nick King, Mennonite Pastor Carlsbad, NM Rev. Stephanie Harmon, Methodist Chaplain Carlsbad, NM
3 Rev. Marty Singleterry, Pastor, St Peter Lutheran Retired Methodist Superintendent, Carlsbad, NM Rev. Gene and Ellen Harbaugh, Retired Presbyterian Minister Carlsbad, NM Rev. Stephen A. Gaertner, O. Praem., Associate Pastor, Holy Rosary Parish Albuquerque, NM Betty Jo Nye, President, Albuquerque District United Methodist Women Fr. Tom Smith OFM Conv., Director, Holy Cross Retreat Center Mesilla Park, NM Fr.Richard Rohr,O.F.M., Center for Action and Contemplation Albuquerque, NM Fr. Gene Gries, O. Praem, Maria de la Vid Norbertine Abbey Albuquerque, NM The Rev. Holly Beaumont, D. Min., Organizing Director Interfaith Worker Justice - NM Fr. Warren, J Broussard, S.J., Immaculate Conception Church Albuquerque, NM Linda Popelish, Gallup's Morning Light Sangha Jamestown, NM Sister Catherine Clemons Gallup, NM Rev. Virginia Bairby, Pastor, First Presbyterian Church Taos, NM Rabbi Paul J. Citrin Albuquerque, NM Sr. Marlene Perrotte, rsm, Legal Immigration/Assylum Ministry Albuquerque, NM Lynn R. Anner-Bolieu, Deacon (Ret.), Episcopal Church of Navajoland Reside in McKinley County, NM Rev. Pamela Shepherd, Pastor, Taos UCC Taos, NM
4 Judy Traeger, JustFaith Facilitator, St. John XXIII Catholic Community, Albuquerque, NM Rev. Larry Bernard, ofm, Pastor, San Diego Mission Jemez Pueblo, NM Kathleen Mezoff, Elder, Westminster Presbyterian Church Gallup, NM 87301 Sr. Diana Wauters,Sisters of the Assumption Chaparral, NM Rabbi Harry Rosenfeld, Congregation Albert Albuquerque, NM Rev. Jean Siegfried Darling, Minister Emerita, Peoples Church of Chicago Cerrillos, NM Rev. Harry Ebert, Pastor, First Presbyterian Santa Fe, NM Rev. Andrew Black, Pastor, First Presbyterian Santa Fe, NM Rev. Sarah TevisTownes, Pastor and Teacher, Church of the Good Shepherd UCC, Albuquerque, NM Rev. Gail Marriner, Pastor, Unitarian Universalist Santa Fe, NM Rev. Tiffany Curtis, Pastor, First Christian Church Santa Fe, NM Rev. Sue Joiner, Pastor, First Congregational United Church of Christ, Albuquerque, NM Rev. Erica Lea-Simka, Albuquerque Mennonite Church Albuquerque, NM Pastor Anne Morawski, Evangelical Lutheran Church in America Associate in Global Mission Jutta Stonawski, Teacher of the Gifted Gallup, NM Rev. John
Dear Santa Fe,
NM
5 Fr. Frank A Quintana, Pastor of Bl. Oscar Romero Catholic Comm.
Albuquerque, NM Rabbi Nahum Ward-Lev, Temple Beth Shalom Santa Fe, NM Mary Ellen Gonzales, Board of Trustees, Unitarian Universalist Congregation of Santa Fe Rev. Jeremiah Griffin, Pastor, St. Chad Episcopal Church Albuquerque, NM Rev. Dr. Stephen J. Miller, Disciples of Christ pastor, retired Albuquerque, NM Rev. Anita Amstutz, Anabaptist Fellowship of Alamosa Mountain States Mennonite Conference Rev. Joan Jiko Halifax, Abbot, Upaya Zen Center Santa Fe, NM Rev. Kenneth Cuthbertson, PhD, Presbyterian (USA)
Albuquerque, NM Rabbi Neil Amswych, Temple Beth Shalom Santa Fe, NM The Rev. Angela Herrera, Senior Minister, First Unitarian Church Albuquerque, NM The Rev. Ryan W. Roberts, n/OLF Albuquerque, NM Rev. Dr. Bert Scott, United Methodist Church Albuquerque, NM Rev. Sarah Tevis Townes, Pastor and Teacher, Church of the Good Shepherd UCC, Albuquerque, NM Lilly B. Irvin-Vitela, Children Youth & Family Ministries First Congregational United Church of Christ, Albuquerque, NM Mirakhel Windsong, Lay leader, Westminster Presbyterian Gallup, NM Rev. Janet Norden, Pastor, University Heights United Methodist Albuquerque, NM
6 Rev. H. Blaine Wimberly Santa Fe, NM Janet Gildea, SC, Sisters of Charity Anthony, NM Rev Sharon Littrell-Marsh, Ph.D, United Church of Christ Southwest Conference Peggy Deneweth, SC, Sisters of Charity Anthony, NM Carol Wirtz, SC, Sisters of Charity Anthony, NM Rev. Karen Bash, Retired United Church of Christ Minister Albuquerque, NM Rev. Allen Bash, Retired United Church of Christ Minister Albuquerque, NM Rev. Alexander Lenzo+, Priest, St. Francis Episcopal Church Rio Rancho, NM Donna Illerbrun, Principal, St. Therese Catholic School Albuquerque, NM Rev. Talitha Arnold, Senior Pastor, United Church of Santa Fe United Church of Christ, Santa Fe, NM Rev. Jeremiah Griffin, Pastor, St. Chad Episcopal Church Albuquerque, NM Ani Jamgyal, Monastic at Mangala Shri Bhuti Albuquerque, NM
New Mexico Interfaith Power and Light PO Box 27162, Albuquerque, New Mexico 87125**www.nm-ipl.org**info@nm-ipl.org**505-266-6966 July 2018 To:
Rick Perry, Secretary, Department of Energy Kristine L. Svinick, Chairperson, Nuclear Regulatory Commission Members of the New Mexico Congressional Delegation
Dear Mr. Secretary,
Madam Chairperson, and Members of Congress:
We are Catholic Sisters who are community 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, 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 (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 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 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 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 Judeo-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:
Sr. Marlys Jax, osf Rochester Minnesota Franciscans Rochester, MN Sr. Joyce Stemmper, osf Rochester Minnesota Franciscans Minneapolis, MN Sr. Pat Keefe, osf Rochester Minnesota Franciscans Rochester, MN Sr. Kate Minar, osf Rochester Minnesota Franciscans Rochester, MN Sr. Judy Chiodo, osf Rochester Minnesota Franciscans Minneapolis Minnesota Carol Warren Co-member Rochester Franciscans Sacramento, CA Marion Kaple Co-member Rochester Franciscans Atlanta, GA Mary Kay Flannigan, osf Rochester Minnesota Franciscans Chicago, Ill