ML20309B135
| ML20309B135 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 11/04/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR27447 | |
| Download: ML20309B135 (4) | |
Text
From:
Kerster, Courtney, GOV <Courtney.Kerster@state.nm.us>
Sent:
Wednesday, November 4, 2020 10:10 AM To:
WCS_CISFEIS Resource
Subject:
[External_Sender] RE: Comments from Gov Lujan Grisham Attachments:
CISF ISP Letter MLG.pdf Apologies, here is the correct format.
From: Kerster, Courtney, GOV Sent: Wednesday, November 4, 2020 10:09 AM To: WCS_CISF_EIS@nrc.gov
Subject:
Comments from Gov Lujan Grisham Please see the attached letter from Governor Michelle Lujan Grisham.
Thank you, Courtney Courtney Kerster Director of Federal Affairs Office of Governor Michelle Lujan Grisham 444 North Capitol St NW, Suite 411 Washington DC 20001 Office: 202-624-3667 Cell: 505-690-7964 courtney.kerster@state.nm.us
Federal Register Notice:
85FR27447 Comment Number:
10392 Mail Envelope Properties (e199eeef6dca4142be9f1a436f2ab71e)
Subject:
[External_Sender] RE: Comments from Gov Lujan Grisham Sent Date:
11/4/2020 10:10:09 AM Received Date:
11/4/2020 10:10:19 AM From:
Kerster, Courtney, GOV Created By:
Courtney.Kerster@state.nm.us Recipients:
Post Office:
MBXCAS002.nmes.lcl Files Size Date & Time MESSAGE 558 11/4/2020 10:10:19 AM CISF ISP Letter MLG.pdf 65065 Options Priority:
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Recipients Received:
State Capitol
- Room 400
- Santa Fe, New Mexico 87501
- 505-476-2200 Michelle Lujan Grisham Governor State of New Mexico November 3, 2020 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Submitted by email to: WCS_CISF_EIS@nrc.gov
Dear Sir or Madam,
As the Governor of the State of New Mexico, I write to express my opposition to the proposed action to issue a license in response to the Interim Storage Partners (ISP) LLCs License Application for a Consolidated Interim Storage Facility (CISF) for Spent Nuclear Fuel (SNF) in Andrews County, Texas. The May 2020 draft Environmental Impact Statement (EIS) is significantly flawed and does not adequately address significant threats to the health and safety of New Mexicans, impacts to our economy, and protection of our environment.
The U.S. Nuclear Regulatory Commission (NRC) proposed approval of the ISP license application to construct and operate a CISF for SNF and Greater-Than-Class C waste and spent mixed oxide fuel at the existing Waste Control Specialists (WCS) site in Andrews County, Texas. If licensed, the facility could store up to 5,000 metric tons of uranium (MTUs) for a license period of 40 years. ISP has indicated that they will seek amendments and extensions of the license to store an additional 5,000 MTUs for each of seven expansion phases over 20 years, resulting in an expanded facility with total storage of up to 40,000 MTUs of spent nuclear fuel.
New Mexicans have a vested interest in this proposed action due to the proximity of the site to the Texas-New Mexico border; the facility is located just.37 miles east of the border and five miles east of Eunice, New Mexico. Additionally, the New Mexico side of the border is more densely populated, meaning that the proposed action would disproportionately impact New Mexicans in the immediate area.
The draft EIS does not adequately address the many safety concerns that siting a CISF in Andrews County, Texas raises. With no active planning for a permanent repository for SNF underway, there is significant risk that this and other facilities proposed as interim storage
State Capitol
- Room 400
- Santa Fe, New Mexico 87501
- 505-476-2200 facilities become de facto permanent repositories. Over time, it is likely that the casks storing spent nuclear fuel and high-level waste will lose integrity and will require repackaging. Any repackaging of spent nuclear fuel and high-level waste increases the risk of accidents and radiological health risks. The consequences of a release of radiation due to accidental events (such as fire, flood, earthquakes, ruptures of fuel rods, explosion, lightning, extreme temperatures and more), potential acts of terrorism or sabotage, and the risks associated with aging spent nuclear fuel canisters all pose unacceptable health, safety, and environmental risks that the draft EIS fails to address.
Further, the ISP project would place unfunded safety mandates on local communities.
Transporting spent nuclear fuel across the nation is complex and extremely dangerous. Safe transportation of spent nuclear fuel requires both well-maintained infrastructure and highly specialized emergency response equipment and personnel that can respond quickly to an incident at the facility or on transit routes. New Mexico residents cannot afford and should not be expected to bear the costs associated with transporting material to the proposed CISF or responding to an accident on transport routes or near the facility.
The proposed CISF also poses unacceptable economic risk to New Mexicans, who look to southeastern New Mexico as a driver of economic growth in our state. New Mexicos agricultural industry contributes approximately $3 billion per year to the states economy, $300 million of which is generated in Eddy and Lea Counties, adjacent to the West Texas site. Further, the site is located in the Permian Basin, which is the largest inland oil and gas reservoir and the most prolific oil and gas producing region in the world. New Mexicos oil and natural gas industry contributed approximately $2 billion to the state last year, driven by production in Lea and Eddy County. Any disruption of agricultural or oil and gas activities as a result of a perceived or actual nuclear incident would be catastrophic to New Mexico, and even taking steps toward siting a CISF in the area could cause a decrease in investment in two of our states biggest industries.
Recognizing the risks outlined above, a broad range of businesses, state, local, and tribal leaders have expressed their opposition to this project and to a similar project in New Mexico proposed by Holtec International. That opposition includes both myself and Governor Abbott of Texas, who similarly recognizes the risk a CISF in this region poses to Texas residents.
The ISP proposal poses unacceptable risk to New Mexicos citizens, communities, and economy, and I urge you to deny the ISP license application.
Sincerely, Michelle Lujan Grisham Governor