ML23023A255

Limited Appearance Statement from Ted V. Jackson in the Matter of Nuclear Fuel Services, Inc. License Amendment Application

ML23023A255
Person / Time
Site:	Erwin
Issue date:	01/23/2023
From:	Todd Jackson - No Known Affiliation
To:	Sue Abreu, Bollwerk G, William Froehlich Atomic Safety and Licensing Board Panel
References
70-143-LA
Download: ML23023A255 (1)

Text

From: tvjackson@bellsouth.net To: Docket, Hearing; Paul Bollwerk; William Froehlich; Sue Abreu

Subject:

[External_Sender] Proposed NFS License (SNM-124) Amendment Request, Nuclear Fuel Services, Docket No. 70-143-LA Date: Monday, January 23, 2023 11:28:20 AM Hon. Paul Bollwerk, Hon. William Froehlich, Hon. Sue Abreau, Judges Atomic Safety and Licensing Board Rockville, MD Via email only to hearing.docket@nrc.gov, paul.bollwerk@nrc.gov, william.froehlich@nrc.gov, sue.abreu@

nrc.gov RE: Proposed NFS License (SNM-124) Amendment Request, Nuclear Fuel Services, Docket No. 70-143-LA Honorable ASLB Judges:

The Atomic Safety and Licensing Board has a special responsibility and obligation to many parties when hearing proposed licensing actions, whether for commercial power generation facilities, academic or medical licensees, or the production of special nuclear materials. As an ex parte, independent judge, the exercise of impartial deliberations as to who and what is presented to the ASLB is crucial to your role and responsibilities to the Commission, Licensees, and the public.

I am writing to request the allowance of non-parties to this licensing amendment proceeding to provide comments. NRC regulations at 10 CFR § 2.315(a) state, "A person who is not a party . . . may, in the discretion of the presiding officer, be permitted to make a limited appearance by making an oral or written statement of his or her position on the issues at any session of the hearing or any prehearing conference within the limits and on the conditions fixed by the presiding officer." I request that the Board place my below comments into the record of this proceeding and be deemed properly submitted pursuant to 10 CFR § 2.315(a).

The proposed licensing amendment from Nuclear Fuel Services (currently licensed, SNM-124) requests that the Commission grant an amendment to their Special Nuclear Materials license to purify and enrich uranium for weapons-grade material under contract with the Department of Energys National Nuclear Security Agency. Though the basic chemical/mechanical Ames process will be employed, the licensing process should encompass a full evaluation of site safety, emergency preparedness, quality assurance, environmental impacts, and site redress issues. This full evaluation should be required by the Commission, just as NRC has done for new pressurized water reactor generation units employing a differing set of technologies (e.g., AP-1000).

Under 10 CFR §§ 50, 52, and 100, the Commission is obligated to require a comprehensive and acceptable Site Safety Analyses Report, which incorporates site safety, safeguards, emergency preparedness and response, environmental effects (past, present and potential), and how this part of the NFS site dedicated to uranium enrichment and processing will be redressed after operations cease. Unlike the federally operated counterparts doing similar activities (e.g., Oak Ridge, Savannah River, Hanford), a privately-operated facility does not have the opportunity to engage and partner with local and state governmental entities to conduct offsite monitoring and emergency preparedness and response. Any accident analysis should incorporate any potential environmental impacts of postulated accident scenarios (both onsite and offsite). Thus, it is more important that the Commission thoroughly review and assess this licensing amendment.

Thank you, in advance, for allowing these comments be placed into the licensing docket and for your future considered deliberations.

/s/ Ted V. Jackson, Shady Valley, Tennessee