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Saturday, January 7, 2012

Comments to NRC - Send an Email

The Tag Line of NRC is

"Protecting People and the Environment"

Speak Your Mind!

The NRC has determined that it has confidence in using spent fuel pools for up to 60 years past the closing of a Nuke Plant.    Hmmmm.

They assume that

1) Society won't break down AND loss of knowledge (like there won't be a single CD that shows how dangerous spent fuel is).   Well what if society breaks down, but there is still a CD of knowledge left.   OK!  Their conditions are met, their assumptions were not wrong!
2) Terrorism doesn't need to be considered, it is outside of their scope.
3) They don't consider that "loss of institutional control" will ever happen because "the trend in modern society is toward more awareness and control over issues that pose a risk to humans and their environment."   Yeah Right!
4) They assume that the nuke plant operators will provide continuing financial support for their used fuel "regardless of cost",  can I puke now?
They won't even touch the 8000 lb Gorilla in the Room....The Carrington effect, a large sun storm that wipes out transformers and thus the world wide power grid.   As you may know, if a nuke plant loses power, it melts down, and I mean the reactor AND the fuel pools.

I summarized some of their comments from the PDF (invitation to comment), below, it will make your blood boil.

The comment period is 45 calendar days, from January 3 to February 17, 2012.
You may submit comments via email to or through the U.S. mail:

Christine Pineda, Project Manager
Mailstop EBB-2B2
Office of Nuclear Material Safety and Safeguards
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001

These are some "highlights" from their proposal for an EIS and comments on same.

To prepare for this situation, the Commission updated the NRC’s Waste Confidence decision and rule in December 2010, stating that commercial spent fuel can be stored safely and without significant environmental impacts for at least 60 years beyond the licensed life of any commercial power reactor.

In September of 2011, the State of New York and several other petitioners filed a lawsuit
challenging the 2010 Waste Confidence rule and its related consideration of environmental
impacts. That case (Case No. 11-1045) is currently under consideration before the U.S. Court
of Appeals for the District Of Columbia Circuit.

The NRC, as part of its regulatory oversight,
continually assesses the need for additional safety or security measures. Loss of institutional
control and oversight of spent fuel storage facilities is not viewed as a credible scenario during
the period to be analyzed in the Waste Confidence EIS.

At a recent public meeting on its Waste Confidence update plans,14 the NRC received a request
that it include in the EIS a scenario that accounts for a collapse of society and loss of
government institutions, with a resulting lack of control over, and knowledge about, nuclear
plants and radioactive waste. The staff has considered this suggestion and, as explained
below, is proposing not to include this as one of the analyzed scenarios.

There are
no trends or evidence to suggest that society’s control of spent fuel and highly radioactive waste
will decline in the future or cease to be a government-regulated endeavor.
A NEPA analysis evaluates impacts that are “reasonably foreseeable.” For the Waste
Confidence EIS, this includes impacts associated with each of the four scenarios proposed in
this report. It may also include impacts from reasonably foreseeable scenarios that have not yet
been identified. The request to include a societal-collapse scenario would require an analysis of
the impacts of storage under a highly speculative scenario in which societal institutions,
knowledge, and controls no longer exist. However, as described above, the trend in modern
society is toward more awareness and control over issues that pose a risk to humans and their
environment. The staff concludes that a loss of societal structures and the associated
knowledge base is not reasonably foreseeable and, in fact, is highly unlikely to occur within the
200-year timeframe to be considered in the EIS.

The Waste Confidence EIS will also assume that the current structure of financial assurance for
spent fuel storage will continue to exist. The responsible entities will provide the necessary
financial resources for operating, securing, and maintaining storage facilities for extended
periods of time, regardless of cost.

In 2007, the U.S. Court of Appeals for the Ninth Circuit held that NEPA requires an examination
of the environmental impacts resulting from an act of terrorism against a dry cask storage
facility.15 However, outside of the Ninth Circuit, the Commission has adhered to its traditional
position that the environmental effects of a terrorist attack do not need to be considered in its
NEPA analyses.16 In 2009, the U.S. Court of Appeals for the Third Circuit upheld the
Commission’s position that terrorist attacks are too far removed from the natural or expected
consequences of agency action to require an environmental impact analysis.17 Even so, and
without a definitive ruling that would resolve the split between the Circuit Courts on this issue,
this EIS will include a discussion of terrorism that the NRC believes satisfies the Ninth Circuit’s
holding in Mothers for Peace. The staff plans to consider the environmental impacts of
terrorism related to storage and transportation at a generic level.

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