Please attend the Nuclear Regulatory Commission’s (NRC) Monday, November 18th meeting in Carlsbad, California or the November 20th meeting in San Luis Obispo.

It’s our opportunity to comment on the NRC’s outlandish proposal that the tons highly radioactive nuclear reactor plant waste can safely stay in California virtually forever and that they can use a generic environmental impact statement to cover all future licensing of nuclear reactors in the country.

The NRC did not even consider the critical problem of “high burnup” nuclear fuel waste, which virtually all nuclear reactors are now using.

The NRC will not approve transport or short-term storage of high burnup fuel waste because they have NO CONFIDENCE it is safe.

• Comments to the NRC Waste Confidence GEIS
  • Waste Con Comments Docket NRC-2012-0246 SanOnofreSafety.org
  • High Burnup Executive Summary
  • Waste Con Comments Docket NRC-2012-0246 Core Message to the NRC
  • Citizens’ Oversight Waste Con Comments
  • Waste Con Group Comments submitted by Diane Curran of Harmon, Curran, Spielberg & Eisenberg, L.L.P; and Mindy Goldstein and Jillian Kysor of Turner Environmental Law Clinic
    • Exhibit A. Declaration of Dr. Arjun Mahkijani on high burnup fuel and other risks
    • Exhibit B. Declaration of David Lochbaum on fuel pool leaks
      
    • Exhibit C. Declaration of Gordon Thompson on fuel pool fire risks
    • Exhibit D. Declaration of Mark Cooper on costs of storing irradiated fuel
  • Waste Con Group Comments submitted by Nuclear Information and Resource Service (NIRS)
• Signage
  • Click here for High Burnup Fuel Too Hot To Handle Sign 8.5″ x 11″ sign .Pdf
  • Click here for High Burnup Fuel Too Hot To Handle 24″x30″ Poster  .jpg

The NRC originally thought high burnup fuel would react the same as lower burnup fuel after it cooled longer in the spent fuel pools.  However, scientific studies have proven this fuel remains unstable, unpredictable, hotter and over twice as radioactive as lower burnup fuel. No one knows how to contain it safely in dry cask storage.

The NRC is claiming in their Draft Waste Confidence Environmental Impact Statement they have confidence all waste can be stored safely in California and the rest of the U.S. indefinitely.

Tell the NRC they need to complete their research on extended storage before completing the Environmental Impact Statement. How can they have confidence when they haven’t even finished their research on storing this dangerous waste?

These are the two of twelve public meetings being held by the NRC around the country to take comment on the Draft Waste Confidence Generic Environmental Impact Statement report.  See complete schedule and other details at http://www.nrc.gov/waste/spent-fuel-storage/wcd/pub-involve.html#schedule

Stop the Nuclear Waste Con!

The NRC Draft Waste Confidence Generic Environmental Impact Statement and proposed rule are unacceptable. They are based on unsubstantiated hope. The Coalition to Decommission San Onofre (CDSO) and the Sierra Club Angeles Chapter have prepared the following core message to the NRC. Click here for NRC Core Message Handout and suggested signage.

Stop the Nuclear Waste Con: The NRC Draft Waste Confidence Generic Environmental Impact Statement (GEIS) is unacceptable. Much of it appears to be based on unsubstantiated hope and it ignores the unsolved problems of high burnup fuel. The NRC won’t approve short-term storage or transport of high burnup used nuclear fuel because they have no confidence it is safe. The Waste Confidence GEIS needs to address:

√ HIGH BURNUP FUEL – Too hot to handle

No short-term storage or transportation solutions for high burnup fuel waste.

• The NRC and DOE are concerned with the instability of high burnup nuclear waste in both storage and transport, yet the NRC continues approving this dangerous fuel for reactors.
• The NRC won’t approve high burnup dry cask storage over 20 yearsbecause they have NO CONFIDENCE it can be stored longer without releasing radiation into the environment, even though it must be stored for thousands of years. 
• The NRC won’t approve transportation of high burnup used fuel because they have NO CONFIDENCE it can be transported without releasing radiation into the environment. 
• San Onofre’s high burnup used fuel is so hot and radioactive, it requires up to a MINIMUM 20 YEARS cooling in the crowded spent fuel pools, instead of the minimum 5 years for lower burnup fuel.

√ Generic Environmental Impact Statement – NOT acceptable for California

• California didn’t “sign up” for permanent (100+ years) nuclear waste dumps.
• California nuclear waste sits in the world’s earthquake “ring of fire”, the same as Fukushima, the most active and dangerous earthquake zone in the world. California’s nuclear waste is surrounded by known active earthquake faults and the USGS says no one has ever predicted a major earthquake.
• California’s nuclear waste sits along an eroding coastline, in tsunami zones, and is exposed to a highly humid and corrosive coastal environment. NRC’s NUREG/CR-7030 states atmospheric corrosion of sea salt can lead to stress corrosion cracking within 32 and 128 weeks in austenitic [corrosion resistant] stainless steel canisters.
• It would be impossible to evacuate the millions of people living near California’s waste. Of the 34 million people in California, over 8.5 million reside within 50 miles of San Onofre.
• A radiological disaster impacts the nation’s and world’s security, economy and food supply.
  • California is the eight ranking economy in the world, virtually tied with Italy and the Russian Federation, and larger than Canada, Australia and Spain.
  • More than 40 percent of containerized imports enter the country through California ports, and nearly 30 percent of the country’s exports depart through them.
  • California produces nearly half of the U.S. grown fruits, nuts and vegetables. California remained the number one state in cash farm receipts in 2011, with its $43.5 billion in revenue representing 11.6 percent of the U.S. total. U. S. consumers regularly purchase several crops produced solely in California.
  • San Onofre is located adjacent to the primary vehicle transportation artery between Los Angeles and San Diego (I-5), and one of the largest military installations (and targets) on the West Coast (Camp Pendleton).

√ We oppose NRC’s proposed rule that future licensing can be based on the assumption spent fuel can be safely stored above ground virtually forever.

• In the proposed NRC rule that accompanies the draft GEIS, the NRC proposes to incorporate into every reactor license the Draft GEIS’ conclusion that spent fuel can be safely stored above ground indefinitely. 
• This proposal would in effect forbid any further public discussion, in individual reactor licensing actions, of the serious question of whether generation of additional spent fuel is justifiable in light of the absence of any means of safe disposal.

Background

As described by the NRC Chairman, Allison Macfarlane, in a recent speech,

“…in June 2012, the D.C. Circuit Court of Appeals vacated the NRC’s 2010 Waste Confidence rule. In the court’s opinion, the Commission’s conclusion that a high-level waste repository would be available ‘when necessary’ lacked an appropriate discussion of the environmental consequences of failing to achieve that objective. The ruling also expressed concern about potential spent fuel pool leaks and fires. In the time since the court issued its decision…NRC staff has been working to revise the Waste Confidence rule and develop a generic environmental impact statement. From the beginning, the Commission made it clear that public involvement must be an essential part of this process. Starting last month, the NRC has been holding a series of public meetings around the country to get important input for our final products.”

NRC Presentation

NRC Poster

Page 1 of poster

Page 2 of poster.

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NRC Slide Presentation (ML13273A339.pdf)

Submit Written Comments to the NRC by December 20, 2013

Email comments to the NRC at Rulemaking.Comments@nrc.gov, citing Docket ID No. NRC–2012–0246.  For other ways to submit comments go to http://www.nrc.gov/waste/spent-fuel-storage/wcd/pub-involve.html#schedule.

For other sample comments, go to Beyond Nuclear.

Coalition to Decommission San Onofre includes Citizens Oversight, Inc., Peace Resource Center of San Diego, San Clemente Green, SanOnofreSafety.org, and Women Occupy San Diego. For more information on nuclear waste, go to SanOnofreSafety.org.