Submit public comments to NRC on Nuke Waste Con Game environmental scoping before Jan. 2, 2013!
SUGGESTED ENVIRONMENTAL SCOPING TALKING POINTS WITH WHICH TO MAKE PUBLIC COMMENT ON NRC’S “NUCLEAR WASTE CONFIDENCE” (before NRC's Jan. 2, 2013 deadline)
Please use the suggested process and substance points below to fashion your own for submission to NRC.
Environmental scoping comments can be submitted electronically to www.regulations.gov, using Docket ID NRC-2012-0246 (despite repeated demands, NRC has yet to provide a simple email address for the submission of comments!). Comments can also be snail mailed to: Cindy Bladey, Chief; Rules, Announcements, and Directives Branch; Office of Administration; Mail Stop: TWB-05-B01M; U.S. Nuclear Regulatory Commission; Washington, D.C. 20555-0001. Comments can also be faxed to Cindy Bladey/NRC, at (301) 492-3446. Comments are currently due by Jan. 2, 2013, although repeated demands for an extension to this absurdly short deadline have been made.
PROCESS POINTS
NRC’s Oct. 26, 2012 Federal Register Notice announcing the public comment opportunity on its scoping proceeding in the lead up to a court-ordered Environmental Impact Statement (EIS) on its Nuclear Waste Confidence Decision and Rule is legally deficient. It does not clearly describe the proposed federal action, nor the preferred alternative(s). Due to those fatal legal flaws, the Federal Register Notice must be withdrawn, corrected, and re-issued. In the meantime, this proceeding must be suspended by NRC, and the allotted time for public comments must be re-started from the beginning. (For more information, click on this link.)
The time frame for making public comment (October 26, 2012 to January 2, 2013) is absurdly short. A six-month time period for making public comments is more reasonable. The public comment deadline should be significantly extended.
A single in-person hearing (Nov. 14th at NRC HQ in Rockville, MD), and a mere handful of webinars, is far from enough. In-person public comment meetings should be held in every nuclear power plant community, supplemented each time with the remote webinar/teleconference participation option for those unable to attend in person . At the bare minimum, in-person public comment meetings should be held in each region of the country.
Also, NRC should stop rushing this environmental impact statement process. Just last year, NRC staff estimated it would take 7 years to do a quality job on an EIS. But now, NRC is rushing the entire process in just 2 years. NRC should extend comment deadlines, and hold public comment periods in every atomic reactor community, to do a comprehensive, high quality EIS.
SUBSTANCE POINTS
No more NRC licenses enabling atomic reactors to generate high-level radioactive waste.
Urge NRC to include in its EIS scope the preferred alternative of the agency not approving any more new reactor combined Construction and Operating License Applications (COLA), nor approving any more old reactor 20-year license extensions. That way, no more high-level radioactive waste, for which there is no solution after 70 years of splitting atoms, will be generated. In short, STOP MAKING IT! The only safe, sound solution for high-level radioactive waste is to not make it (or, in NRC's case, allow it to be made) in the first place!
For wastes that already exist, urge NRC to require Hardened On-Site Storage.
For wastes that already exist, urge NRC to include Hardened On-Site Storage (HOSS, a phrase coined by Dr. Arjun Makhijani of IEER in 2002) as the preferred alternative. High-level radioactive waste must be transferred out of water pools, at risk of catastrophic radioactivity releases in the event of a loss of cooling and consequent radioactive waste inferno. But on-site dry cask storage must be significantly upgraded. Dry casks must be designed and fabricated well, with full quality assurance. They must be designed to withstand terrorist attack (as by camouflage, fortifications, and adequate spacing in between casks), to safeguard against accidents, and to prevent radioactivity leakage into the environment for the decades or centuries the wastes will be stuck at the reactor sites. (In 2003, Dr. Gordon Edwards of IRSS published a report, commissioned by Citizens Awareness Network, entitled "Robust Storage." See the executive summary of this report, including an illustration of a "robust storage" design for dry casks, by clicking this link. Also see the Statement of Principles for Safeguarding Nuclear Waste at Reactors, signed by nearly 200 environmental organizations.)
The risks of pool fires must be considered in this EIS. The precarious situation at Fukushima Daiichi Unit 4 --where a 7.0 earthquake could cause the complete collapse of the reactor building -- risks 135 tons of irradiated fuel catching fire, and releasing ten times the radioactive cesium-137 as was released by the Chernobyl nuclear catastrophe, directly into the environment. This would dwarf the radioactivity released thus far by the Fukushima nuclear catastrophe. But pools at most U.S. atomic reactors contain several times more high-level radioactive waste than does Fukushima Daiichi Unit 4, meaning the potential catastrophes downwind, downstream, up the food chain, and down the generations would be even worse here in the event of a pool fire, whether caused by a sudden drain down (due to an earthquake, heavy load drop, terrorist attack, etc.) or a slower motion boil down (due to loss of off-site electricity, whether due to a natural disaster such as a hurricane, an intentional attack, a reactor accident causing abandonment of the nuclear power plant site, etc.).
Radioactivity leaks from storage pools – into soil, groundwater, and surface waters – should also be included in the EIS scope. After all, leaks from pools have already occurred at more than a half-dozen nuclear sites across the U.S., such as from Indian Point into groundwater which then flows into the Hudson River, not far upstream from New York City.
Both industry and NRC whistleblowers have identified major quality assurance violations with current U.S. dry cask storage design and fabrication. These QA violations must be corrected for dry cask storage systems before they can be considered for use in Hardened On-Site Storage.
The many problems that have occurred over the years and decades with dry cask storage – from explosions, to leaks, to design and fabrication flaws, as well as security vulnerabilities -- must be included in the EIS scope, and preferred alternatives identified, such as HOSS.
Seismic risks to dry cask storage – such as Palisades’ violation of NRC earthquake safety regulations, as well as the damage done to North Anna’s dry cask storage by the August 23, 2011 earthquake – must also be included in the EIS.
For more background information, as well as additional ideas for talking points, please click on this link.
Prepared on December 4, 2012 by Kevin Kamps, Radioactive Waste Watchdog, Beyond Nuclear,kevin@beyondnuclear.org, (240) 462-3216, www.beyondnuclear.org.
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