Hey Stock, my NRC "Waste Confidence" comment tracking number is 1jx-89es-c4ou. Thanks for the "push". Your encouragement here on Enenews and petition on NukePro was especially helpful. FYI, all comments can be viewed at: http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=NRC-2012-0246;refD=NRC-2012-0246-0456
We had over 1000 visitors, I wonder how many provided testimony to the NRC?
Quite a few at ENENEWS did confirm to me that they provided testimony.
Rulemaking1CEm Resource
From: RulemakingComments Resource
Sent: Wednesday, December 04, 2013 4:47 PM
To: Rulemaking1CEm Resource
Subject: FW: Docket ID NRC-2012-0246 - NUCLEAR WASTE CONFIDENC
DOCKETED BY USNRC—OFFICE OF THE SECRETARY
SECY-067
PR#: PR-51
FRN#: 78FR56775
NRC DOCKET#: NRC-2012-0246
SECY DOCKET DATE: 12/4/13
TITLE: Waste Confidence—Continued Storage of Spent Nuclear Fuel
COMMENT#: 00330
From: peteowl@aol.com [mailto:peteowl@aol.com]
Sent: Wednesday, December 04, 2013 11:08 AM
To: RulemakingComments Resource
Subject: Docket ID NRC-2012-0246 - NUCLEAR WASTE CONFIDENC
TO: rulemaking.comments@nrc.gov
Comments for the NRC regarding "NUCLEAR WASTE CONFIDENCE"
To: Rulemakings and Adjudications Staff
Re: Docket ID NRC-2012-0246
Comments on NRC Waste Confidence
In seventy years of producing nuclear weapons and nuclear energy we have found no way
to dispose of the resultant radioactive waste that will not threaten life on earth.
There is no permanent waste repository. The Yucca Mountain team consisted of the best
people we have with unlimited resources, yet they failed. They didn't fail due to
incompetent management, they failed because they were given an impossible task.
Were there to be a repository available, the transportation of waste to it would be
vulnerable to accidents and to terrorism. One only has to cite the many truck, train and
ocean vessel accidents associated with the transportation of chemicals and fossil fuels to
understand comparable risks.
Failing a national repository, the NRC has not studied the issue of waste storage for each
individual reactor (age, type, site location, ownership, history of problems, accidents,
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violations) but instead has created a generic wish list for waste storage, lacking workable
specifics. Each reactor must be considered on its own.
In the case of Entergy's Pilgrim Nuclear Power Station (PNPS) in Plymouth, which is of
special concern to we the undersigned, shutdowns and malfunctions have been so
numerous that the NRC itself has flagged the plant for intensive oversight.
Presently on-site storage in dry casks is the only solution, but it is only a relatively shortterm
fix for a problem requiring containment for hundreds of thousands of years. So far the
design for the Interim Spent Fuel Storage Installation (ISFSI) is underfunded, and its
location is vulnerable to sea level rise, flooding and terrorism. The casks would not be
separated by protective berms although that would obviously lessen the impact of an
aircraft attack.
Although it never agreed to do so, Massachusetts is forced to host a high-level nuclear
waste dump for up to 380 years - if the industry's and regulator's promises are kept. But
past promises (40 years of reactor operations and no waste dump) were not kept. Given
this history, NRC confidence in a waste plan does not give us any confidence.
The NRC has estimated the risk of a core melt with containment breach at a GE Mark 1
Boiling Water Reactor such as Pilgrim at 1 in 1 million reactor-years. Actual reality has
proven the risk to be 1 in 352 reactor-years, 2,841 times more likely than NRC prediction.
At Pilgrim, nearly 3300 bundles of irradiated fuel are stored in an attic pool designed for
880.The NRC's probabilistic risk assessment (PRA) assures us that a high level radwaste
pool can't be drained by an aircraft carrying C4. The PNPS in Plymouth is a Mark 1
reactor that's on a flight path for a major airport - and there are no airspace restrictions.
Even a partial drain down is likely to result in an inextinguishable uranium and plutonium
fire. The only thing between a 747 and the SFP is a thin sheet metal roof. It's not safe
now, and claiming that it will remain safe until 2092 is only wishful thinking.
With climate change, the likelihood of extreme weather events is
increasing along with the potential for catastrophic results affecting
any waste storage facility, especially those near the coast. We are
concerned that seismic risks also have been underestimated.
Could people be evacuated safely if there's a fire at a waste fuel pool? Past experience
with comparatively minor accidents like Windscale, Three Mile Island, Chernobyl and
Fukushima says no. But in order to maximize the externalization of radwaste costs, within
just a couple of years of final reactor shutdown the NRC will not require evacuation
planning. This is altogether unacceptable.
There is nothing scientific about NRC claims that it can guarantee the safe storage of
nuclear waste for a million years. This waste contains plutonium & uranium with half-lives
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of 24,000 years and ten billion years, respectively. You needn't have any expertise, just a
little commonsense to realize how insane this is. One million years takes us to the
Calabrian stage of the Pleistocene era, a period of which we know very little, hundreds of
thousands of years prior to the emergence of the Neanderthal. But going forward in time,
we know little if anything about events a decade from now, and we have no way to know
anything about conditions ten thousand centuries from now. That the word 'confidence' is
used by the NRC when talking about safeguarding radwaste for a period of time five
hundred times greater than the Christian era is preposterous!
There is no proven technology to displace something for a million years. Not for 100,000
years, not even for 10,000 years. The longest lived man-made structures are the
pyramids. They've been around for 5,000 years and they failed at their intended purpose.
Entropy isn't addressed by the NRC waste document. The NRC concludes in Section
4.1.3 that the impact of indefinite storage on land use will be small. How does that jive with
real world engineering experience? Real world data says that every 25 years we will have
a major leak of high-level nuclear waste that will render about 250 square kilometers
unusable for millennia. That works out to be 5 million square kilometers or about onethirtieth
of the land area of the entire world.
Petitioners and intervenors have called attention to what is wrong with the NRC Draft
Waste Confidence Generic Environmental Impact Statement (DWC GEIS) and backed up
their criticism with numerous examples of failing to comply with federal laws, faulty
decision-making practices, and poor operating histories. But many of these concerns and
facts have been ignored.
The NRC fails to abide by the intent, language, and provisions of the Atomic Energy Act
(AEA) and the National Environmental Policy Act (NEPA).
We endorse Principles for Safeguarding Nuclear Waste at Reactors from the Institute for
Energy and Environmental Research.
We agree with those who ask the NRC to stop building new nuclear facilities, stop
extending the licenses of existing nuclear power plants, to not expose the nuclear workers
and the public by transporting nuclear waste.
In concluding, one elephant in the room stands: the NRC's failure to understand the very
real, well documented, science of radioactive substances which waste produces. A
fingernail of plutonium could kill off, conservatively a large city. Cesium, strontium, and
other radionuclides contained in waste, are some of the most toxic substances on earth,
creating slow and long term illness and well as mutating genes.
The NRC has a duty to protect children and grandchildren for generations to come from
substances which contaminate human beings, the biosphere and the environment and
which can create lasting, adverse, multi-generational changes in the genome. We believe
the DWC GEIS shows that the NRC does not take that duty seriously.
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Rather than generating more waste, we believe that the prudent approach is to stop
producing nuclear waste.
I request a receipt for this letter, please, be emailed to peteowl@aol.com.
Sincerely Yours,
Lee Roscoe
14 D Frederick Ct.
Brewster, MA. 02631
508 896 3510
peteowl@aol.com
P.S. I am a Woods Hole Ocean Science Journalism Fellow and an EPA award winning
environmentalist.
I want to note that literally thousands of us in Barnstable County from all of its towns voted to shut
Pilgrim Nuclear Station, in large part because of concerns over waste.
I am also a part of Capedownwinders.org on whose behalf in part I send this letter.
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