ML19345E987
| ML19345E987 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 12/11/2019 |
| From: | Annette Vietti-Cook NRC/SECY |
| To: | Mayer A Green Century Exploration & Production |
| SECY RAS | |
| References | |
| 72-1050-ISFSI, ASLBP 19-959-01-ISFSI-BD01, RAS 55460 | |
| Download: ML19345E987 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SECRETARY December 11, 2019 A. James Mayer Founder & CEO Green Century Exploration
& Production, LLC 505 North Big Spring St., Ste. 402 Midland, TX 79701
Dear Mr. Mayer:
On behalf of the U.S. Nuclear Regulatory Commission (NRG), I am responding to the comment you submitted via e-mail on November 19, 2019, regarding a Draft Regulatory Basis for the Disposal of Greater-than-Class-C Waste (GTCC): Your message was sent to an email address managed by the NRC's Office of the Secretary. .Accordingly, your comment has been added to the NRC's rulemaking docket (NRC-2017-0081) and the GTCC aspects of your message will be considered during that process.
In addition to your comment on the GTCC rulemaking, your e-mail references subjects raised during adjudication of the license applications of both Holtec International and Interim Storage PartnersANCS for consolidated interim storage facilities (CISF). Some of these subjects are currently before the Commission on appeal. The Office of the Secretary is comprised of "adjudicatory employees" who advise the Commission on various adjudicatory matters, thus, it would be inappropriate for the Office of the Secretary to comment on any references in your message to the CISF application proceedings.
A copy of your e-mail and this response will be served on the participants in both the Holtec CISF and ISPANCS CISF proceedings.
Sincerely,
From: James Mayer To: RulemakingComments Resource
Subject:
[External_Sender] Docket ID NRC-2017-0081 Comments Date: Tuesday, November 19, 2019 11:48:02 AM To Whom It May Concern, I am responding to your request for comments regarding a draft regulation to allow the long-term storage/disposal of greater-than-Class-C (GTCC) waste in low-level radioactive waste land disposal facilities. My response is general in nature as well as being specific to the permit applications by WCS for a GTCC facility in Andrews County, Texas, and by Holtec for a GTCC facility in Lea County, New Mexico.
We at Green Century are supporters of nuclear energy as one of the many (all) domestic energy sources needed to power American Energy Security and Independence. But allowing the placement of high level nuclear waste in the heart of the Permian Basin oil fields is reckless and negligent in our opinion. We are especially concerned that these sites will become terrorist targets.
Taking out some Permian oil production would not only harm America but would benefit organizations funded by Middle East oil money. The US depends on the Permian Basin to keep energy costs down for consumers, the economy strong, and the nation energy dominant and secure. A terrorist attack on these sites, or another event causing a major contamination incident, could result in the shut-down of needed Permian Basin production.
Title to the GTCC nuclear waste should only be transferred to the U.S. Federal Government as only the U.S. government has the financial wherewithal to handle a serious radioactive release and can generally provide the perpetual institutional security required.
Sites having substantial strategic natural resources such as oil & gas under and nearby should not qualify and in fact should never be considered for licensing.
Areas that have limited freshwater resources such as the Permian Basin should not be candidates for GTCC waste as a release could cause groundwater contamination that would be catastrophic to the region.
Approval by the governor and the legislature of a state should be required to approve a GTCC site.
Sites that cannot be adequately protected by the U.S. military against terrorist attacks should not qualify.
Any site designated for accepting spent fuel must be on Federal land under Federal authority to assure the long-term (500 hundred year) security of the site and regulation by the U.S. Nuclear Regulatory Commission.
Any off-site storage of spent nuclear fuel should be located in East of Mississippi River, the region that has the vast majority of the nuclear plants, to minimize transportation of this dangerous
material.
Thank you, A. James Mayer Founder & CEO Green Century Exploration & Production, LLC 505 North Big Spring Street, Suite 402 Midland, Texas 79701
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
INTERIM STORAGE PARTNERS LLC ) Docket No. 72-1050-ISFSI
)
(WCS Consolidated Interim Storage Facility) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Letter from NRC Secretary, Annette Vietti-Cook, to A. James Mayer of Green Century Exploration & Production have been served upon the following persons by the Electronic Information Exchange:
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O16-B33 Mail Stop: O16-B33 Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov Hearing Docket E-mail: Hearing.Docket@nrc.gov U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Mail Stop: T-3F23 Mail Stop - O-14A44 Washington, DC 20555-0001 Washington, DC 20555-0001 Joe Gillespie, Esq.
Paul S. Ryerson, Chair Sara Kirkwood, Esq.
Administrative Judge Mauri Lemoncelli, Esq.
E-mail: paul.ryerson@nrc.gov Patrick Moulding, Esq.
Kevin Roach, Esq.
Nicholas G. Trikouros Carrie Safford, Esq.
Administrative Judge Thomas Steinfeldt E-mail: nicholas.trikouros@nrc.gov Alana Wase, Esq.
Brian Newell, Senior Paralegal Dr. Gary S. Arnold Nicholas Moran, Legal Intern Administrative Judge E-mail: joe.gillespie@nrc.gov E-mail: gary.arnold@nrc.gov sara.kirkwood@nrc.gov mauri.lemoncelli@nrc.gov Ian Curry, Law Clerk patrick.moulding@nrc.gov Stephanie Fishman, Law Clerk kevin.roach@nrc.gov Molly Mattison, Law Clerk carrie.safford@nrc.gov Taylor Mayhall, Law Clerk thomas.steinfeldt@nrc.gov E-mail: ian.curry@nrc.gov alana.wase@nrc.gov stephanie.fishman@nrc.gov brian.newell@nrc.gov molly.mattison@nrc.gov nicholas.moran@nrc.gov taylor.mayhall@nrc.gov
WCS CISF - Docket No. 72-1050-ISFSI Letter from NRC Secretary, Annette Vietti-Cook, to A. James Mayer of Green Century Exploration & Production Counsel for Beyond Nuclear Sustainable Energy and Economic Development (SEED) Coalition Diane Curran, Esq. Karen D. Hadden Harmon, Curran, Spielberg and Eisenberg Executive Director, 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 Grant Eskelsen, Esq.
Timothy Matthews, Esq.
Nuclear Information and Ryan Lighty, Esq.
Resource Service (NIRS) Paul Bessette, Esq.
Diane DArrigo E-mail: grant.eskelsen@morganlewis.com 6930 Carroll Avenue timothy.matthews@morganlewis.com Suite 340 ryan.lighty@morganlewis.com Takoma Park, MD 20912 paul.bessette@morganlewis.com Email: dianed@nirs.org Chris Hebner, Esq. Counsel for Fasken Land and Oil and City of San Antonio, TX Permian Basin Land and Royalty Owners P.O. Box 839966 San Antonio, TX 78283 Robert V. Eye Law Office, L.L.C.
E-mail: chris.hebner@sanantonio.gov 4840 Bob Billings Parkway, Suite 1010 Lawrence, KS 66049 Timothy Laughlin, Esq.
Counsel for Sierra Club E-mail: tijay1300@gmail.com Wallace Taylor 4403 1st Avenue S.E. Kanner & Whiteley, LLC Suite 402 701 Camp Street Cedar Rapids, IA 52402 New Orleans, LA 70130 E-mail: wtaylorlaw@aol.com Allan Kanner, Esq.
Elizabeth Petersen, Esq.
Cynthia St. Amant, Esq Counsel for Dont Waste Michigan, et al Conlee Whiteley, Esq .
Terry Lodge, Esq. E-mail: a.kanner@kanner-law.com 316 N. Michigan Street e.petersen@kanner-law.com Suite 520 c.stamant@kanner-law.com Toledo, OH 43604 c.whiteley@kanner-law.com E-mail: tjlodge50@yahoo.com
[Original signed by Herald M. Speiser ]
Dated at Rockville, Maryland, Office of the Secretary of the Commission this 11th day of December 2019 2