ML070650360

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Comment (20) Submitted by C-10 Research and Education Foundation, Sandra Gavutis on Massachusetts Attorney Generals 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)


Text

1 SECY - Fw: A.G.'s petition to NRC Page 11

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

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"Sandra Gavutis" <gavutis@comcast. net>

<SECY@nrc.gov>

Fri, Mar 2, 2007 3:31 PM Fw: A.G.'s petition to NRC DOCKETED USNRC March 5, 2007 (3:15pm)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF

Subject:

A.G.'s petition to NRC 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.

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I SECY - Ew: A.G.'s petition to NRC Page?

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$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 Fri, Mar2, 2007 3:31 PM "Sandra Gavutis" <gavutis@comcast.net>

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