ML18277A229
| ML18277A229 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 10/02/2018 |
| From: | D'Arrigo D Nuclear Information & Resource Service (NIRS) |
| To: | Office of Administration |
| References | |
| 83FR44922 00025, NRC-2016-0231 | |
| Download: ML18277A229 (6) | |
Text
PUBLIC SUBMISSION As of: 10/4/18 10:26 AM Received: October 03, 2018 Status: Pending_Post Tracking No. 1k2-95rq-nbd5 Comments Due: October 19, 2018 Submission Type: Web Docket: NRC-2016-0231 Waste Control Specialists LLC's Consolidated Interim Spent Fuel Storage Facility Project Comment On: NRC-2016-0231-0187 Interim Storage Partners LLCs Consolidated Interim Spent Fuel Storage Facility Document: NRC-2016-0231-DRAFT-0205 Comment on FR Doc # 2018-19058 Submitter Information Name: Diane D'Arrigo Address:
NIRS, 6930 Carroll Ave., Suite 340 Takoma Park, MD, 20912 Email: dianed@nirs.org General Comment Please accept the attached request filed in Docket No. 72-1050 (NRC-2016-0231) for an extension of the intervention deadline, additional public meetings on environmental scoping, and publication of the license application documents in Spanish, on behalf of 41 parties.
Attachments 40+extension requests+ meetings+ Spanish WCS Dkt 72-1050 NRC 2016-0231 Page 1 of 1 10/04/2018 https://www.fdms.gov/fdms/getcontent?objectId=09000064837906aa&format=xml&showorig=false SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD= Antoinette Walker-Smith, James
- Park, Cinthya Cuevas Roman, Jenny Weil COMMENT (25)
PUBLICATION DATE:
9/4/2018 CITATION 83 FR 44922
1 TO:
May Ma, Office of Administration, Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Annette Vietti Cook, Secretary of the Commission U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Annette.Vietti-Cook@nrc.gov James Park, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 301-415-6954; James.Park@nrc.gov.
John-Chau Nguyen, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 301-415-0262; John-Chau Nguyen@nrc.gov Emailed to WCS_CISF_EIS@nrc.gov and submitted to the WCS hearing docket RE: Docket No. 72-1050; NRC-2016-0231 Waste Control Specialists LLCs / ISPs Consolidated Interim Spent Fuel Storage Facility Project Request for extension of comment and intervention deadlines, scoping meetings in Texas and across the US, provision of license application, public notices and materials in Spanish Date: October 2, 2018 FROM: 37 organizations and 4 individuals (listed at end)
This is a request from concerned and potentially affected organizations and individuals for additional time to comment on the Environmental Impact Statement Scoping and to seek leave to intervene (10 CFR 2.307) on the application of Interim Storage Partners/Waste Control Specialists/Orano (WCS) for a Consolidated Interim Storage Facility license in Andrews County, TX. We request that NRC and the applicant provide the application and related documents especially the public notices and fact sheets in Spanish and extend the comment and intervention period to 180 days from the date those documents are made publicly available and announced publicly. Finally, we ask that the NRC hold public scoping meetings in Texas (Andrews, Midland, El Paso, San Antonio, Houston and Dallas) and in communities along the likely transport routes across the country.
We seek 180 additional days beyond the posted deadlines and beyond provision of the application, notice and related documents in Spanish because the large, revised application requires more time for public review, technically, culturally, legally, economically and practically. Because the large portions of the communities that would be impacted by WCS are Hispanic and Spanish-speaking, we ask that the application and related materials be provided in Spanish and made readily available.
The effect of the license will be a massive shift in the current waste storage, transportation and management systems that have been in place for the past decades. This shift will bring much
2 more of the US population into closer proximity to high level radioactive waste on a regular basis for decades and once again when a final repository is opened and the waste is again moved.
Unanswered technical concerns about the environmental impacts, safety and security of irradiated/spent nuclear fuel over time under various conditions and at various levels of "burnup" need full evaluation and consideration, as well are concerns about liability and long term ownership of high level radioactive waste.
Our groups are reviewing the application materials with these questions in mind and need additional time to understand all the information available and to formulate our comments and contentions.
The NRC has two separate teams of employees evaluating the Holtec ELEA license application and Interim Storage Partners/Waste Control Specialists/Orano (WCS) application, which is similar but completely separate. Since both sites are so close to each other (~40 miles), the affected public is much the same--individuals, organizations, residents, travelers and communities. The mostly volunteer or nonprofit groups are neither funded nor staffed for such technical undertakings and are overloaded trying to do justice to both applications simultaneously. We seek a bit more time between the schedules of the two intense, massive licensing processes since they geographically affect the same general area.
We and our experts need time to evaluate the viability of casks and canisters for transport and storage in extreme desert climate conditions, the potential for earthquakes and water contamination, the cumulative impacts of hazardous waste storage and multiple nuclear facilities in the region and how damaged canisters would be handled since no dry cell or wet pool is included in the license application.
This is an unprecedented application because of the potential for terrorist attacks as waste is moved and while it is in consolidated storage, a vitally important national security issue.
We need additional time due to the need for translation between English and Spanish for both technical and cultural aspects of the project, for commenting and for consideration of legal intervention.
The application is still changing significantly. WCS has not completed its responses to NRC requests for additional information and plans to submit revisions to numerous chapters of the license application, all of which are significant for the safety and security of the proposed facility, some which are significant for environmental concerns.
Major unanswered questions remain about the ownership of and liability for the waste in the short term and for the long term legal, financial, technical and environmental disposition of the waste and the site. The EIS comment period and adjudicatory licensing hearing and intervention are the only opportunities the public will have to provide input on the granting of a 40 year license. Yet the clear potential exists for the site to become a de facto permanent storage facility.
If the waste does move again, there is the potential for repeat shipments back to the origin or to another temporary site or to a future permanent site.
3 We and our experts need time to examine the financial qualifications of Waste Control Specialists and its new owner, JF Lehman and the WCS role in NorthStar. We need to understand and integrate the financial and legal commitments and enforceability of short-term and long-term management requirements and responsibilities of NRC, DOE and the licensee.
There was a bit of confusion and correction in the federal register postings for the deadlines for both the WCS EIS Scoping comments and the WCS Opportunity to request a hearing and leave to intervene.
We ask that the application be provided in Spanish and that a clear extended deadline 180 days later be granted for both scoping and intervention submissions. This will allow for more thorough and informed public input, would allow the NRC more time to get answers to RAIs and would allow further progress by the NRC on high burnup fuel storage and transport guidance.
Individuals, organizations and governmental entities need additional time to consider whether they should intervene in order to protect local interests, including health, safety, financial and related impacts.
Thank you for your consideration of these requests. We would be most appreciative if you could inform us of your decisions in advance of the existing deadlines.
Very Sincerely, Karen Hadden Sustainable Energy and Economic Development Coalition, Texas karendhadden@gmail.com (POINT OF CONTACT)
Diane DArrigo Nuclear Information and Resource Service dianed@nirs.org Rose Gardner Alliance for Environmental Strategies AFES Eunice, NM Nmlady2000@hotmail.com Susan Corbett Sierra Club, Nuclear Free Campaign Reindeargirl@gmail.com Kevin Kamps Beyond Nuclear kevin@beyondnuclear.org Damon Moglen Friends of the Earth DMoglen@foe.org Denise Brown Nuclear Issues Study Group NISG Albuquerque, New Mexico protectnewmexico@gmail.com Mayor Harlan Crawford East Texas Sub-Regional Planning Commission Reklaw, Texas Tom Smitty Smith Public Citizen TX, Special Projects Citizen.smitty@gmail.com Aftab Siddiqui Dallas Peace and Justice Center, TX aftab.a.siddiqui@gmail.com Alice Canestaro Garcia Energia Mia San Antonio, Texas Joni Arends Concerned Citizens for Nuclear Safety Santa Fe, NM jarends@nuclearactive.org
4 Jay Coghlan Nuclear Watch New Mexico Santa Fe, NM jay@nukewatch.org Barbara Warren Citizens Environmental Coalition New York warrenba@msn.com Western New York Environmental Alliance Lynda Schneekloth Buffalo, NY lhs1@buffalo.edu Alice Hirt Don't Waste Michigan alicehirt@gmail.com Dave Kraft Nuclear Energy Information Service Illinois neis@neis.org Michael J. Keegan Coalition for a Nuclear Free Great Lakes Monroe, Michigan mkeeganj@comcast.net Manna Jo Greene Hudson River Sloop Clearwater, Inc.
Beacon, NY Mannajo@clearwater.org Mary Beth Brangan Ecological Options Network California mbbrangan@gmail.com Kelly Lundeen Nukewatch Luck, WI nukewatch1@lakeland.ws Glenn Carroll Nuclear Watch South Atlanta, GA atom.girl@nonukesyall.org Molly Johnson SLO Mothers for Peace San Luis Obispo, CA mollypj@yahoo.com Diane Turco Cape Downwinders Harwich, MA tturco@comcast.net Deb Katz Citizen Awareness Network New England deb@nukebusters.org Sarah Fields Uranium Watch Monticello, Utah sarah@uraniumwatch.org Tanya Keefe Great Lakes Environmental Alliance Port Huron, Michigan Chance Hunt Citizens for Alternatives to Chemical Contamination Lake Station, Michigan Laura Dewey Womens International League for Peace and Freedom, Detroit Branch Grosse Pointe Woods, Michigan Ruth Thomas Environmentalists Inc.
Columbus, North Carolina Ellen Thomas Proposition One Campaign for a Nuclear-Free Future, Washington D.C.
Vic Macks Michigan Stop the Nuclear Bombs Campaign St. Clair Shores, MI vicmacks3@gmail.com Stephen Brittle Dont Waste Arizona Phoenix, Arizona dwaz@fastq.com
5 Mike Carberry Green State Solutions Iowa mikecarberry@gmail.com Kerwin Olson Citizens Action Coalition Indiana www.citact.org Carol Izant Alliance to Halt Fermi 3 Southfield, MI cogknot@yahoo.com Marylia Kelley Tri-Valley CAREs Livermore, California marylia@earthlink.net Elizabeth Padilla Andrews, TX Marvin Lewis Pennsylvania Victor McManemy Michigan Linda Lewison Energy Policy Consultant Chicago, IL ljlewison1@gmail.com