ML070650360

Comment (20) Submitted by C-10 Research and Education Foundation, Sandra Gavutis on Massachusetts Attorney General'S PRM-51-10 Re to Amend 10 CFR Part 51

ML070650360
Person / Time
Site:	Pilgrim
Issue date:	03/02/2007
From:	Gavutis S C-10 Research & Education Foundation
To:	NRC/SECY/RAS
SECY RAS
References
71FR64169 00020, PRM-51-10
Download: ML070650360 (3)

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1 I SECY SECY - Fw:

NRC A.G.'s petition to NRC Fw: A.G.'s Page 1_1 PRM-51-10 (71 FR64169)

From: "Sandra Gavutis" <gavutis@comcast. net> DOCKETED To: <SECY@nrc.gov>

Date: Fri, Mar 2, 2007 3:31 PM USNRC

Subject:

Fw: A.G.'s petition to NRC March 5, 2007 (3:15pm)

OFFICE OF SECRETARY

Subject:

A.G.'s petition to NRC RULEMAKINGS AND ADJUDICATIONS STAFF Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Attn: Rulemakings and Adjudications Staff.

RE: Docket No. PRM-51 Support The Massachusetts Attorney General's Petition for Rulemaking-Spent Fuel I strongly support the Massachusetts Attorney General's Petition for Rulemaking in its entirety.

Specifically I support the conclusions that, the Nuclear Regulatory Commission should:

(a) Consider new and significant information showing that the NRC's characterization of the environmental impacts of spent fuel storage as insignificant in the License Renewal GElS is incorrect, (b) Revoke the regulations which codify that incorrect conclusion and excuse consideration of spent fuel storage impacts in NEPA decision-making documents, (c) Issue a generic determination that the environmental impacts of high-density pool storage of spent fuel are significant, and (d) Order that any NRC licensing decision that approves high-density pool storage of spent fuel at a nuclear power plant or any other facility must be accompanied by an EIS that addresses (i) the environmental impacts of high-density pool storage of spent fuel at that nuclear plant and (ii) a reasonable array of alternatives for avoiding or mitigating those impacts.

We know that this rule change is important to better protect our public health and safety. For example, simply look at the estimates of costs and latent cancers following the releases of Cesium-1 37 from Pilgrim's spent fuel pool prepared by Dr. Jan Beyea for the Massachusetts Attorney General Motion to Intervene in the Re-licensing Application for Pilgrim and Vermont Yankee, May 25, 2006.

Estimates of Costs and Latent Cancers Following Releases of Cesium-137 from Pilgrim's Spent-Fuel Pool Consequence 10% release C-137 100% release C-137 Cost (billions)

~ ~~Y4. 7

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ISECY SECY - Fw:

- A.G.'s petition to NRC Ew: -A.G.'s- Page 2 '

$105-$175 billion

$342-$488 Billion Latent Cancers 8,000 24,000 Sincerely, Sandra Gavutis, Executive Director C-10 Research and Education Foundatio 44 Merrimac Street, Newburyport, MA 01950 CC: <Matthew. Brock@ago. state. ma.us>

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Fw: A.G.'s petition to NRC Creation Date Fri, Mar2, 2007 3:31 PM From: "Sandra Gavutis" <gavutis@comcast.net>

Created By: gavutis@comcast.net Recipients nrc.gov TWGWPOO2.HQGWDOO1 SECY (SECY) ago.state.ma.us Matthew.Brock CC Post Office Route TWGWPO02.HQGWDOO1 nrc.gov ago.state.ma.us Files Size Date & Time MESSAGE 2171 Friday, March 2, 2007 3:31 PM TEXT.htm 13261 Mime.822 18270 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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