ML19238A313

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Letter from NRC Acting Secretary to Richard Guldi of Dallas Sierra Club
ML19238A313
Person / Time
Site: Consolidated Interim Storage Facility
Issue date: 08/26/2019
From: Bavol R
NRC/SECY
To: Guldi R
Sierra Club, Dallas Group
SECY RAS
References
72-1050-ISFSI, ASLBP 19-959-01-ISFSI-BD01, RAS 55208
Download: ML19238A313 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 26, 2019 Mr. Richard L. Guidi Co-Chair*

Dallas Sierra Club RLGuldi77@gmail.com

Dear Mr. Guidi:

On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your email message of August 16, 2019, regarding the pending WCS Consolidated Interim Storage Facility application from Interim Storage Partners, LLC (ISP) (Docket No. 72-1050). Your message expresses opposition to the application.

Your message was sent to an email address managed by the NRC's Office of the Secretary.

The Office of the Secretary is comprised of "adjudicatory employees" who advise the Commission on various matters, including those such as the ISP proceeding. Because your message raises some of the same issues pending in the contested ISP adjudication, it would be inappropriate for the Office of the Secretary to comment on the matter at this time.

A copy of your email and this response will be served on the participants in the ISP proceeding.

Sincerely, Rochelle C. Bavol Acting Secretary

From: Richard Guidi To: RulemakjngComments Resource

Subject:

[External_Sender] The Dallas Sierra Club opposes expanding the proposed WCS nuclear waste storage sites in Texas and New Mexico Date: Friday, August 16, 2019 3:48:10 PM The Dallas Sierra Club opposes bringing high level radioactive waste into Texas and New Mexico.

It is extremely short sighted to even consider the WCS /ISP's application for Consolidated Interim Storage (CIS) which would allow the storage of 40,000 tons of high-level radioactive waste above ground at their existing Andrews County site. This facility is totally unsuitable for holding spent nuclear reactor core waste with very high curie counts Should this material get to the Texas and New Mexico sites, it will likely remain there for hundreds of years. Spent nuclear waste should not be stored above ground or even near the surface where it threatens aquifers. Rather, it should be stored in suitable underground caverns away from aquifers.

To make matters worse, the proposed sites lie within the Pecos Basin oilfields that hold more oil than all of Saudi Arabia. America will develop this oil and gas using fracking which creates low level earthquakes. Although these quakes are usually mitigated to sub-Mag3 status by limiting waste water injection, Mag2 quakes still occur and persist for unknown durations of even ten years or longer.

Recently, Fasken Oil and Ranch, a driller based in Midland, Texas, sent a note to the NRC saying that it was developing new fracking technologies and intends to dig "beneath and surrounding" Holtec's planned site in New Mexico, using some 20 million barrels of water and high-pressure sand. Other drillers will follow .

https://www.wsj.com/articles/battle-emerges-over-nuclear-waste-in-americas-oil-patch-11 s65775001 Texas citizens are also greatly concerned about transporting 40,000 tons of high-level waste through highly populated metropolises in Texas. The population of North Texas is approaching nine million and is growing rapidly. That will soon exceed the population of New York City or Long Island. You would not subject those populations to tlie transportation and storage risks from nuclear wastes, and Texans want.to be respected just like New Yorkers.

Please do not allow this waste to be brought into Texas or New Mexico.

Richard L Guldi., Co-Chair Conservation, Dallas Sierra Club

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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INTERIM STORAGE PARTNERS LLC ) Docket No. 72-1050-ISFSI

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(WCS Consolidated Interim Storage Facility) )

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Letter from NRC Acting Secretary to Richard Guldi of the Dallas Sierra Club have been served upon the following persons by the Electronic Information Exchange:

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the Secretary of the Commission Mail Stop: T-3F23 Mail Stop: O16-B33 Washington, DC 20555-0001 Washington, DC 20555-0001 Hearing Docket Paul S. Ryerson, Chair E-mail: Hearing.Docket@nrc.gov Administrative Judge E-mail: paul.ryerson@nrc.gov U.S. Nuclear Regulatory Commission Nicholas G. Trikouros Office of the General Counsel Administrative Judge Mail Stop - O-14A44 E-mail: nicholas.trikouros@nrc.gov Washington, DC 20555-0001 Joe Gillespie, Esq.

Dr. Gary S. Arnold Sara Kirkwood, Esq.

Administrative Judge Mauri Lemoncelli, Esq.

E-mail: gary.arnold@nrc.gov Patrick Moulding, Esq.

Carrie Safford, Esq.

Joseph McManus, Law Clerk Thomas Steinfeldt Taylor Mayhall, Law Clerk Alana Wase, Esq.

Molly Mattison, Law Clerk Brian Newell, Senior Paralegal E-mail: joseph.mcmanus@nrc.gov E-mail: joe.gillespie@nrc.gov taylor.mayhall@nrc.gov sara.kirkwood@nrc.gov molly.mattison@nrc.gov mauri.lemoncelli@nrc.gov patrick.moulding@nrc.gov carrie.safford@nrc.gov thomas.steinfeldt@nrc.gov U.S. Nuclear Regulatory Commission alana.wase@nrc.gov Office of Commission Appellate Adjudication Mail Stop: O16-B33 Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov

Docket No. 72-1050-ISFSI Letter from NRC Acting Secretary to Richard Guldi of the Dallas Sierra Club Counsel for Beyond Nuclear Karen D. Hadden Executive Director, Diane Curran, Esq. Sustainable Energy and Harmon, Curran, Spielberg and Eisenberg Economic Development (SEED) Coalition 1725 DeSales Street NW, Suite 500 605 Carismatic Lane Washington, DC 20036 Austin, TX 78748 E-mail: dcurran@harmoncurran.com E-mail: karendhadden@gmail.com Mindy Goldstein, Esq.

Emory University School of Law Counsel for Interim Storage Partners LLC Turner Environmental Law Clinic Morgan, Lewis & Bockius LLP 1301 Clifton Road 1111 Pennsylvania Avenue NW Atlanta, GA 30322 Washington, DC 20004 E-mail: magolds@emory.edu Timothy Matthews, Esq.

Ryan Lighty, Esq.

Paul Bessette, Esq.

Diane DArrigo E-mail: timothy.matthews@morganlewis.com Nuclear Information and ryan.lighty@morganlewis.com Resource Service (NIRS) paul.bessette@morganlewis.com 6930 Carroll Avenue Suite 340 Takoma Park, MD 20912 Email: dianed@nirs.org Chris Hebner, Esq. Counsel for Sierra Club City of San Antonio, TX Wallace Taylor P.O. Box 839966 4403 1st Avenue S.E.

San Antonio, TX 78283 Suite 402 E-mail: chris.hebner@sanantonio.gov Cedar Rapids, IA 52402 E-mail: wtaylorlaw@aol.com Counsel for Fasken Land and Oil and Counsel for Dont Waste Michigan, et al Permian Basin Land and Royalty Owners Terry Lodge, Esq.

Robert V. Eye Law Office, L.L.C. 316 N. Michigan Street Robert Eye, Esq. Suite 520 Timothy Laughlin Toledo, OH 43604 4840 Bob Billings Parkway, Suite 1010 Lawrence, KS 66049 E-mail: tjlodge50@yahoo.com E-mail: bob@kauffmaneye.com tijay1300@gmail.com

[Original signed by Herald M. Speiser ]

Office of the Secretary of the Commission Dated at Rockville, Maryland, this 26th day of August, 2019 2