ML18219A715
| ML18219A715 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 05/12/2018 |
| From: | Bean K, Duran M, Traeger J St. John XXIII Catholic Community |
| To: | Perry R, Kristine Svinicki Rules, Announcements, and Directives Branch, NRC/Chairman, State of NM, US Congress, US Dept of Energy (DOE) |
| References | |
| 83FR13802 00267, NRC-2018-0052 | |
| Download: ML18219A715 (4) | |
Text
To: **Rick Perry, Secretary, Department o.f Energy Kristine L. Svinick, Chairperson, Nuclet:ir Regulatory Commission
- Members of the New Mexico Congressional Delegation
Dear Mr. Secretary,
Madam Chairperson, and Members of Congress:
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Saturday, May.12, 2018 As faithful Christians, we are greatly concerned, about an issue that'will affect our communities,. our future generations, and the wonderful st~te we call "home.". As Pope. Francis stated in his 2015 encyclical addressing climate change and the economy, "As followers of Christ we*take seriously the responsibility to help discern.wh~t is equitable, just,,and for the common good;of Ol:Jr-Common Home."
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Our concern is aboµt 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.
.1 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 atthe 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 c;tisposal 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 pos~ potential failure risk.. Our citizens, many of whom are Hispanic, bear a disproportional amount of risk as SUNSI Review Complete COMMENT (267)
Template= ADM-013 PUBLICATION DATE: 3/30/2018 E-RIDS=ADM-03 CITATION# 83 FR 13802 ADD= Antoinette Walker-Smith, Jill Caverly (JSCl)
f, ' - 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 pre~ence: in New Mexico.
- 8. W~ste 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 o.f this project since ia competitor is already started..
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Our religion has ancient roots, and this ancient wisdom calls us to protect and care for Creation and Community. One pas$age.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.~
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~ i Please take action to ensure that all concerns for the risk of this -project are in the.op~n. receive public scrutiny, and_ recetve du!! con;;ideration.
Thank you for the consideration of our request.
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Undersigned members of,St,... '1ohn XXIII Catholic Community, Albuqu~rque,,NM: **
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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:
Saturday, May 12, 2018 As faithful Christians, 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 followers of Christ 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 MexiC().
- 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 religion has ancient roots, and this ancient 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.
0 Please take action to ensure that all concerns for the risk of this project are in the open, receive public scrutiny, and receive due consi_deration. :..
Thank you for the consideration of our request.
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