ML13308D085

Comment (00127) of Gary Shaw on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel

ML13308D085
Person / Time
Site:	Indian Point
Issue date:	11/03/2013
From:	Shaw G - No Known Affiliation
To:	NRC/SECY/RAS
SECY RAS
References
78FR56775 00127, NRC-2012-0246, PR-51
Download: ML13308D085 (3)

Text

1 Rulemaking1CEm Resource From: RulemakingComments Resource Sent: Monday, November 04, 2013 12:15 PM To: Rulemaking1CEm Resource

Subject:

FW: Docket ID No. NRC-20120246DOCKETED BY USNRC-OFFICE OF THE SECRETARY SECY-067 PR#: PR-51 FRN#: 78FR56775 NRC DOCKET#: NRC-2012-0246 SECY DOCKET DATE: 11/3/13 TITLE: Waste Confidence-Continued Storage of Spent Nuclear Fuel COMMENT#: 00127

From: Gary Shaw [1]

Sent: Sunday, November 03, 2013 8:55 PM To: RulemakingComments Resource

Subject:

Docket ID No. NRC-20120246 WASTE CONFIDENCE HEARING_0CTOBER 30 2013 WESTCHESTER MARRIOTT - TARRYTOWN, NY GARY SHAW-PERSONAL FULL COMMENTS TO BE SUBMITTED TO NRC ORAL STATEMENT WAS LIMITED TO 3 MINUTES My name is Gary Shaw. I live 5.5 miles from the Indian Point Nuclear plant and I have been trying to close the plant since Indian Point2 had a steam pipe rupture in February 2000 and became the first nuclear plant in this country to earn a red rating from the NRC. Indian Point 2 stayed offline for almost a year after the steam pipe rupture. That rupture spread radioactive steam into the air near my house and irradiated water through the Buchanan sewer system into the Hudson, a US Heritage waterway that belongs to all the American people.

One might ask what type of oversight the NRC provides if it could not see that the operator was incapable of maintaining safe operations? Over the last 13 years of observing this agency, my conclusion is that the agency is not so good at preemption, but works hard to find root causes after damage has been done. That is the same type of oversight we have seen from this agency that did not ensure that the IP2 transformer would not explode three years after the same transformer at IP3 exploded, that has not prevented ruptures and leaks from underground piping and that did not know that there was spent fuel pool leakage, probably for years, until the operator started excavating to prepare to move high level radioactive waste into dry cask storage and. That leakage included Strontium

90. Again, Indian Point became the first nuclear plant in our country to set a bad standard. And the GAO has identified Indian Point as the nuclear plant with the highest number of safety violations in the past year. And this agency has granted numerous exemptions from regulatory standards including the waiver of the requirement that Hemyc fire wrap protect critical safety cables in the automatic shutdown system from fire for an hour. The same person who let the Davis-Besse plant in Ohio get within a quarter of an inch from breach of containment then oversaw the reduction of the Hemyc 60-minute requirement to 24-minutes. In a public meeting, when NRC was asked how many exemptions have been granted at Indian Point, not one member of the NRC panel knew the number. Now you are telling us that you 2 have a workable plan to secure and keep the public safe from the thousands of tons of high level wastes that are currently sitting in the plant and the additional tonnage that will accumulate if the plant gets a new twenty year operating license. If that wasn't so scary it would be funny.

It is my understanding that only about 15% of the spent fuel assemblies that have been accumulating at Indian Point for these last 40+ years have been moved to on-s ite dry cask storage although far more, perhaps 75% - 80% is cool enough to be moved, and you seem in no hurry to reduce the dense packing that has resulted in many times more fuel assemblies than design basis specified. I would remind the Region 1 NRC that the current NRC Chairman was part of a waste storage study in 2003 at MIT that concluded that dry cask storage is less dangerous than wet pool storage. But we have had 10 more years of wet storage since that report was issued with very little waste moved. Why? Because it costs the operator money. When NRC says it has a viable waste management plan with public health and safety as the preeminent concern, we must look at that in the light of NRC's record. When NRC talks about "lessons learned" what they are in fact saying is "glad that unexpected bad day didn't happen here."

In terms of your one size fits all GEIS approach, how ca n you rationalize that the magnitude of risk is equal and that policy standards and protocols should be the same at all nuclear plants regardless of size, age and physical environment across the US nuclear fleet, stretching from the Pacific Coast to the flooded Midwest to the East Coast stretching from Florida to New England.

In terms of Indian Point, we have an intersection of two seismic faults, two large high pressure natural gaspipes between the faults and the plant, and during Superstorm Sandy, the plant came close to flood level from the Hudson River surge. It would seem to me that th ese characteristics might not be universal, so why should there not be site specific EIS perspectives rather than one universal policy paper?

Another element that makes Indian Point unique is that Indian Point has been ordered to install closed cyclecooling. If that order is affirmed by the courts and a large structure must be built, what impact does that have on the ability to expand cask storage space for what would be a 60 year accumulation of fuel assemblies?

What procedures will be in place to conduct dry transfer of degraded fuel assemblies from the Holtec caskswhen they expire in 100 years or less? What about 200 years? What about 300 years? That is about how long it takes for Cesium137 to become benign? What about 240,000 years? That is the amount of time it takes for plutonium, the deadliest element known to man, to lose its ability to mutate human cells.

The truth is that there is no real plan to isolate high level radioactive materials effectively for the amount o ftime really necessary to protect public health and safety. If there is no real plan and no real solution, then weshould not make any more. Anything less would seem self-destructive and a shameful legacy for our grandchildren and their grandchildren.

With all due respect, the policies perpetrated by this agency put the interests of the nuclear power operatorsfar above the welfare of populations in reactor communities. In the Indian Point community, the result of a spent fuel fire would put at risk the NYC water supply at the Kensico and Croton reservoirs. And if the financial capital of the world suffers a partial evacuation from which there is no return, what happens to the USeconomy? So let's just roll the dice and say the Waste Confidence approach is "probably good enough."

Gary Shaw 9 Van Cortlandt Pl Croton on Hudson, NY 10520 Member of the Leadership Council of the lndian Point Safe Energy Coalition (IPSEC)

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