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Category:General FR Notice Comment Letter
MONTHYEARML24108A0532024-02-29029 February 2024 Comment (51) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24056A0012024-02-24024 February 2024 Comment (50) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24055A0042024-02-24024 February 2024 Comment (49) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24055A0032024-02-24024 February 2024 Comment (48) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A1102024-02-23023 February 2024 Comment (40) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24058A0052024-02-23023 February 2024 Comment (5) of Tony Brown on Behalf of Nuclear Energy Institute (NEI) on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 an ML24058A0062024-02-23023 February 2024 Comment (6) of Nelson Chloe on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 ML24054A8512024-02-23023 February 2024 Comment (46) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24055A0022024-02-23023 February 2024 Comment (47) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24058A0042024-02-23023 February 2024 Comment (4) of David Bender on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 ML24054A0872024-02-23023 February 2024 Comment (38) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A8502024-02-23023 February 2024 Comment (45) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A4442024-02-23023 February 2024 Comment (41) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24058A0072024-02-23023 February 2024 Comment (7) of Kermit Kubitz on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 ML24054A8492024-02-23023 February 2024 Comment (44) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0172024-02-23023 February 2024 Comment (37) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0162024-02-23023 February 2024 Comment (36) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A8482024-02-23023 February 2024 Comment (43) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0902024-02-23023 February 2024 Comment (39) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A4592024-02-23023 February 2024 Comment (42) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0012024-02-22022 February 2024 Comment (31) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0052024-02-22022 February 2024 Comment (35) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24073A0022024-02-22022 February 2024 Comment (8) of Kenneth S. Petersen and Craig H. Piercy on Behalf of American Nuclear Society on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Pacific Gas and Electric Company; Diablo Canyon, Units 1 ML24054A0002024-02-22022 February 2024 Comment (30) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0022024-02-22022 February 2024 Comment (32) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24053A4162024-02-22022 February 2024 Comment (29) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24053A4152024-02-22022 February 2024 Comment (28) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0032024-02-22022 February 2024 Comment (33) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24054A0042024-02-22022 February 2024 Comment (34) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24052A3622024-02-21021 February 2024 Comment (24) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24052A3632024-02-21021 February 2024 Comment (25) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24053A0192024-02-21021 February 2024 Comment (26) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24053A1432024-02-21021 February 2024 Comment (3) of Mila Vujovich-LaBarre on Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 ML24053A0222024-02-21021 February 2024 Comment (27) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24051A1052024-02-20020 February 2024 Comment (23) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24050A0102024-02-19019 February 2024 Comment (22) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24050A0032024-02-18018 February 2024 Comment (20) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24050A0042024-02-18018 February 2024 Comment (21) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24046A0222024-02-15015 February 2024 Comment (17) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24047A0982024-02-15015 February 2024 Comment (19) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24108A0542024-02-15015 February 2024 Comment (52) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24047A0972024-02-15015 February 2024 Comment (18) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24046A0792024-02-14014 February 2024 Comment (2) of Anonymous on Pacific Gas and Electric Company; Diablo Canyon Nuclear Power Plant, Units 1 and 2 ML24046A0212024-02-14014 February 2024 Comment (16) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24043A1402024-02-12012 February 2024 Comment (15) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24042A0022024-02-11011 February 2024 Comment (14) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24041A0012024-02-0909 February 2024 Comment (13) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24040A0002024-02-0808 February 2024 Comment (9) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24040A0032024-02-0808 February 2024 Comment (12) E-mail Regarding Diablo Canyon Lr EIS Scoping ML24040A0022024-02-0808 February 2024 Comment (11) E-mail Regarding Diablo Canyon Lr EIS Scoping 2024-02-09
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-Doke ag 1-From: "Elie Axelroth" <eaxelrot@calpoly.edu> T Cr To: "NRCREP@nrc.gov" <NRCREP@nrc.gov> *-- ,m Date: Mon, Jul 2, 2007 12:09 PM Y .- '
Subject:
Docket No. 72-26 To James R. Hall, -- 1 I am writing in regards to Docket No. 72-26 with comments on the NRC Staff's Supplemuent to the t...n Environmental Assessment and Draft Finding of No Significant Impact Related to the Construction are Operation of the Diablo Canyon Independent Spent Fuel Storage Installation. This document was written in response to the decision by the Ninth Circuit Court of Appeals in San Luis Obispo Mothers for Peace v.
NRC to address the environmental impacts of intentional attacks on the Diablo Canyon dry cask storage facility. I am outraged by the simplistic and inadequate assessment.
The NRC has done a very poor job of evaluating the environmental impacts of intentional attacks on the Diablo Canyon facility. The EA distorts and minimizes the environmental impacts of attacks on the facility by using hidden and unjustified assumptions.
The EA rules out credible threat scenarios that could cause significant environmental damage by contaminating the environment. The EA creates the appearance of compliance with NEPA's requirements to consider reasonably foreseeable catastrophic impacts even if their probability is low by claiming to consider all "plausible" attack scenarios. But the EA clearly fails to consider credible scenarios that could cause significant environmental damage. For instance, the EA fails to consider attack scenarios in which penetration of a spent-fuel canister is accompanied by the use of an incendiary device to ignite the zirconium cladding of the spent fuel. It should include a detailed description of a wide range of potential attack scenarios and in which several canisters could be affected. These details could be available to persons cleared to receive such information.
The EA also fails to identify the key documents on which it relies, thus making it impossible for any party to verify the appropriateness of its reliance on those documents. In violation of Council on Environmental Quality (CEQ), the EA fails to identify the scientific and other sources it relies on for its conclusion that the impacts of attacks on the Diablo Canyon facility pose no significant impact.
Additionally, CEQ regulation requires an agency to "identify any methodologies used" in its environmental analysis. In violation of this requirement, the EA fails to provide a clear description of the NRC's process for identifying plausible or credible attack scenarios and assessing their consequences to determine whether they are significant. The EA does not describe any analysis that it did for the specific purpose of complying with NEPA. Instead, it describes an analysis that apparently took place in 2002, long before the Ninth Circuit's decision, and that apparently was based on compliance with NRC's AEA-based security requirements. The EA fails to clearly establish that the 2002 analysis was based on reasonable foreseeability of impacts under NEPA.
In considering the consequences of potential releases of radioactive material, the NRC has employed only one indicator, namely "the potential for early fatalities." To exclude consequences other than early fatalities is absurd. Land contamination is a very serious impact that can cause delayed fatalities, illness, and billions of dollars in expenses of relocation and lost income.
The EA for the Diablo Canyon spent fuel storage facility completely fails to demonstrate the NRC made a "fully informed and well-considered" determination of no significant impacts.
Sincerely, Elie Axelroth San Luis Obispo, CA 93405 - eý).
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Docket No. 72-26 Creation Date Mon, Jul 2, 2007 12:08 PM From: "Elie Axelroth" <eaxelrot@calpoly.edu>
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