ML071870146
| ML071870146 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/02/2007 |
| From: | Becker R Alliance for Nuclear Responsibility |
| To: | Hall J Rulemaking, Directives, and Editing Branch |
| References | |
| 72FR30398 00031 | |
| Download: ML071870146 (7) | |
Text
Page I ot 1 NRCREP - Fwd: Additions to Comments sent earlier by ANR From: James Randall Hall 70 To: NRCREP - ;) *...
Date: 07/03/2007 7:26 AM " ..
Subject:
Fwd: Additions to Comments sent earlier by ANR -"1 .
Additional comments received on Docket No. 72-26.
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James R. Hall 492-3319
>>> < beckers@theg rid.net> 07/02/2007 11:47 PM >>>
Dear Mr. Hall,
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týý-i t-tle r rcddated COMMENTS REGARDING THE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS DIVISION OF SPENT FUEL STORAGE AND TRANSPORTATION SUPPLEMENT TO THE ENVIRONMENTAL ASSESSMENT AND DRAFT FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE CONSTRUCTION AND OPERATION OF THE DIABLO CANYON INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NO. 72-26 PACIFIC GAS AND ELECTRIC COMPANY In Peace Rochelle Becker, Executive Director Alliance for Nuclear Responsibility www.a4nr.org PO 1328 San Luis Obispo, Ca 93406-1328
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Fwd: Additions to Comments sent earlier by ANR Creation Date Tue, Jul 3, 2007 7:26 AM From: James Randall Hall Created By: JRH@nrc.gov Recipients nrc.gov TWGWPO01.HQGWDO01 NRCREP (NRCREP)
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COMMENTS REGARDING THE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS DIVISION OF SPENT FUEL STORAGE AND TRANSPORTATION SUPPLEMENT TO THE ENVIRONMENTAL ASSESSMENT AND DRAFT FINDING OF NO SIGNIFICANT IMPACT RELATED TO THE CONSTRUCTION AND OPERATION OF THE DIABLO CANYON INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NO. 72-26 PACIFIC GAS AND ELECTRIC COMPANY Chief, Rulemaking, Directives, and Editing Branch, Mail Stop T6-D59, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.
jrh @nrc.gov.
Attention: James R. Hall, Senior Project Manager, The Supplement to the NRC's Environmental Assessment (EA) provides no more assurance to the public who live in the shadow of Diablo Canyon - or any other nuclear reactor - than did the Commission's short-sighted and non-comprehensive EA of October 24, 2003. Furthermore, the reconstituted EA continues to ignore the requirements of the National Environmental Policy Act (NEPA).
The organizations listed below are in agreement with the assessment of the San Luis Obispo Mothers for Peace that the recently reissued EA:
- Misrepresents and underplays the environmental impacts of attacks on the facility by using baseless suppositions, resulting in an assessment that neglects credible attacks that could trigger significant damage to the human environment.
" Omits key documents on which the Commission's EA relies, thus making it impossible for any party or reviewing court to verify the appropriateness of its reliance on those documents.
- Fails to address the U.S. government's major plan for protection of critical infrastructure and key resources, the National Infrastructure Protection Plan ("NIPP") (2006), and
- Finally, the EA fails to comply with NEPA because it does not consider the significant cumulative impacts of the proposed ISFSI in relation to the impacts of the existing high-density pool storage system for spent fuel at the Diablo Canyon nuclear plant.
As a result of these profound deficiencies, the EA Supplement completely fails to demonstrate that the NRC made a "fully informed and well-considered" determination of
no significant impacts. NEPA requires the NRC to go back to the drawing board and provide an analysis that is understandable and scientifically supported.
The signatories to these comments do not oppose hardeneddry cask storage systems that will alleviate the dangerous overcrowding of spent fuel assemblies at Our nation's 104 reactors. Yet the signatories to these comments believe that the dry cask storage sites will be not "temporary". In fact this belief is reinforced by the fact that the NRC appears to have no definition for "temporary" storage. Furthermore, at a recent workshop of the California Energy Commission, the Department of Energy, the Nuclear Energy Institute and other nuclear proponents stated that there is no need to rush either the Yucca Mountain project or reprocessing projects as radioactive waste stored at reactor sites is perfectly safe for 100 or more years. There were even suggestions that radioactive waste casks from decommissioned sites could be transferred to operating reactor sites, increasing the risks that the NRC has chosen to ignore.
The San Luis Obispo Mothers for Peace Contentions are well reasoned and solely designed to protect the residents of the Central Coast as well as the citizens of the United States. The signatories to these Comments fully support all Contentions and request the NRC reconsider its Supplemental EA as the country deserves protection, and the full attention of the Nuclear Regulatory Commission's oversight. To place the financial interests of nuclear utilities above the safety of the public is more than just a disservice to our country; it is exactly what the 911 Commission determined to be the cause of the worst tragedy on U.S. soil - "The failure to imagine the unimaginable".
There is no single person who could better relate and legally argue for a true, transparent, and independent environmental impact statement-not just a cursory assessment-of foreseeable impacts of acts of terrorism, sabotage or acts of malice and insanity at nuclear targets than Diane Curran. Therefore, we ask that the Nuclear Regulatory Commission honor the request of the San Luis Obispo Mothers for Peace and admit all contentions and hold a formal adjudicatory hearing on the adequacy of the EA Supplement to consider the environmental impacts of intentional attacks on the proposed dry cask storage site for high-level radioactive waste produced at the Diablo Canyon Nuclear Plant.
Sincerely, Rochelle Becker, Executive Director Alliance for Nuclear Responsibility PO 1328 San Luis Obispo, CA 93406
Citizens Awareness Network Judy Treichel deb katz Executive Director box 83 shelburne falls, ma 01370 Nevada Nuclear Waste Task Force www.nukebusters.org P. O. Box 26177 Las Vegas, NV 89126 Ken Bossong, Executive Director Phone: 702-248-1127 SUN DAY Campaign Fax: 702-248-1128 1612 "K" Street, N.W.; #202 Washington, DC 20006 Nuclear Age Peace Foundation David Krieger Coalition for a Nuclear Free Great Lakes Santa Barbara, CA P.O. Box 331 Monroe, MI 48161 David A. Kraft, Director Michael J. Keegan Nuclear Energy Information Service (NEIS)
Don't Waste Michigan Mail & Street Address:
6677 Summerview 3411 W. Diversey, Ste. 16 Holland, MI 49424 Chicago, IL 60647 USA Alice Hirt (773)342-7650; -7655 fax neis@ neis.org Citizens' Resistance at Fermi Two www.neis.orgq P.O. Box 463 SKYPE: davekhamburg Monroe, MI 48161 Keith Gunter North American Water Office PO Box 174 Elaine Nichols Lake Elmo, MN 55042 NoNuke.org 651-770-3861 Tampa, FL George Crocker, Executive Director elaine@ nonuke.orq .qwillc@comcast.net Mary Lampert Prairie Island Coalition Pilgrim Watch 148 Washington Street 4425 Abbott Avenue South Duxbury MA 02332 Minneapolis Minnesota 55410 Bruce A Drew, Steering Committee Environmental Priorities Network 612-927-5087 Lillian Light, President bdrew@igc.org Environmental Priorities Network 310 - 545 1384 Peace Resource Center of San Diego Carol Jahnkow, Executive Director Ecological Life Systems Institute, Inc 3850 Westgate Place, Coalition for Sustainability San Diego, CA 92105 Jim Bell, Director 619-263-9301 4862 Voltaire ST San Diego, CA 92107- 2108 619 758 9020 jimbellelisi @cox. net
Philip Klasky, co-director, Bay Area Nuclear Waste Coalition 2760 Golden Gate Ave.
San Francisco, CA 94118-4109 415/752-8678ph Nuclear Information and Resource 415/531-6890 cell Service Kevin Kamps, Nuclear Waste Specialist Sandra Gavutis, 6930 Carroll Ave, Suite 340 C-1 0 research and Education Takoma Park, MD 20912 Foundation. (301) 270- 6477 ext 14 Kevin @nirs.orq Peg Pinard www.nirs.orgq Former Mayor, City of San Luis Obispo Former Chairperson, San Luis Obispo Grandmothers for Peace County Board of Supervisors San Luis Obispo County Chapter Molly P Johnson, area coordinator Stephen Brittle San Miguel, CA Don't Waste Arizona, Inc. Ph: 805/467-2431 6205 South 12th Street Phoenix, AZ 85042 John B. Ashbaugh, Ph D, Past President, San Luis Obispo Democratic Club Santa Lucia 602-268-6110 Chapter (name of organization included for identification purposes only)
Center for Safe Energy 193 Los Cerros DR Fran Macy, co-director San Luis Obispo, CA 93405 2828 Cherry Street, Berkeley, CA 94705 ibashbaucqh @charter.net Phone 510-883-1177 (805) 550-7713 Amy Goldsmith Ken Smokoska - Chair State Director, Energy/ Climate Change Committee Peggi Sturmfels Conservation Committee Program Organizer Sierra Club of California NJ Environmental Federation 7971 Price Street, # 142 1002 Ocean Avenue Pismo Beach, CA 93449 Betmar, NJ 07719 805.541.1360 732-280-8988--voice Foundation for Global 732-280-0371 --fax Community/Atlanta psturmfets@cteanwater.org Tom Ferguson tf@thinkspeak.net Border Power Plant Working Group Bill Powers, PE co-chair Food Not Bombs/Atlanta 4452 Park Blvd, Suite 209 Bob Darby San Diego, CA 92116 robertwdarby @bellsouth.net Tel: 619-295-2072
Sustainable Marin Ed Mainland Local Power (415) 902 6365 contact: Robert Freehling, Research emainland @comcast.net Director c/o PO Box 606 Fair Oaks, CA 95628 Santa Lucia Chapter of the Sierra Club 916.966.3410 P.O. Box 15755 rfreeh123 @sbccqlobal.net San Luis Obispo, CA 93406 (805) 543-8717 Tom Campbell The Guacamole Fund Laura Hunter, Campaign Director Post Office Box 699 Environmental Health Coalition Hermosa Beach, CA 90254 401 Mile of Cars Way Suite 310 email Guacfund@bicqplanet.com National City, CA 91950 New Phone: 619-474-0220 Beyond Nuclear/Nuclear Policy New Fax: 619-474-1210 Research Institute ehc@environmentalhealth.ora Linda Gunter 302 Grant Avenue GE Stockholders Alliance Takoma Park, MD 20912 contact: Pat Birnie Tel. 301/455-5655 5349 W. Bar X Street, Email: Ipgunter@msn.com Tucson, AZ 85713 patbirnie@qreenbicycle.net 520 908 9269 Concern About Radiation In the Environment (C.A.R. I. E.)
Karen Prather RD 1 Box 305 Corry. PA 16407