ML13360A121
| ML13360A121 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/20/2013 |
| From: | Malboeuf S - No Known Affiliation |
| To: | NRC/SECY/RAS |
| SECY/RAS | |
| References | |
| 78FR56775 00669, NRC-2012-0246, PR-51 | |
| Download: ML13360A121 (10) | |
Text
1 Rulemaking1CEm Resource From: RulemakingComments Resource Sent: Thursday, December 26, 2013 9:26 AM To: Rulemaking1CEm Resource
Subject:
FW: Docket ID No. NRC-2012-0246 Attachments:
Docket ID No. NRC-2012-0246.doc Importance:
High DOCKETED BY USNRC-OFFICE OF THE SECRETARY SECY-067 PR#: PR-51 FRN#: 78FR56775 NRC DOCKET#: NRC-2012-0246 SECY DOCKET DATE: 12/20/13 TITLE: Waste Confidence-Continued Storage of Spent Nuclear Fuel COMMENT#: 00669
From: Simone Malboeuf [
] Sent: Friday, December 20, 2013 1:42 PM To: RulemakingComments Resource
Subject:
Docket ID No. NRC-2012-0246 Importance: High DATE:
Dec. 20, 2013 TO:
Rulemakings and Adjudications Staff FROM:
Simone Malboeuf, simonemalboeuf@gmail.com The U.S. Court of Appeals rejected the current Waste Confidence Rule noting that, after decades of failure to site a repository, the NRC "has no long-term plan other than hoping for a geologic repository." Therefore it is possible that spent fuel will be stored at reactor sites "on a permanent basis." The NRC must examine the environmental consequences of storing radioactive wastes at reactor sites into the indefinite future.
2The NRC Draft Generic Environmental Impact Stat ement (GEIS) relies on the fundamentally flawed assumption that all reactor sites are the same. On the contrary, they each have unique geographic, environmental, geological, climactic, and epidemiological considerations. The creation of a one-size-fits-all plan is scientifically invalid.
(1) The Draft GEIS cl aims that the environmental impact of long-term or indefinite storage is small.
This is an absurd statement on its face, given the known extreme hazards of radioactive wastes and the lack of any experience of st oring these toxins for even a hundr ed years, let alone hundreds of thousands of years. (2) The Draft GEIS claims that impact of a severe accident would be small. Such a conclusion cannot be supported by logic or experience. A severe accident would release deadly radioactivity into the environment. Every release of manmade radioactive matter into the environment to date has had serious and long-lasting impacts on humans and other living things within the area affected. (3) The Draft GEIS assumes that the impact of terrorism would be small. However, according to the National Institute of Health, an attack on a nuclear reactor could result in a "massive release of radioactive material". In the aftermath of 11 Sept ember, David Kyd, spokesm an for the International A tomic Energy Agency, confirmed this view, stating: "[Reactors] are built to withstand impacts, but not that of a wide bodied passenger jet full of fuel. . . . These are vulnerable targets, and the consequences of a direct hit could be catastrophic." (4) Unrecognized in the Draft GEIS is the fact that no civilization and no human institutions have lasted for hundreds of thousands of years. Any credible plan must include ways to mitigate the risks of environmental contamination in t he event of failure of governments or institutions. A realistic plan must be devised to keep manmade radioactive elements isolated from the biosphere for the million years the EPA declares them to be lethal.
For these reasons and many others, the Draft GEIS is not scientifically valid and remains no more than a hope. I urge you to reject the Draft GEIS and recommend the decommissioning and closing of Diablo Canyon Nuclear Power Plant in S an Luis Obispo, CA immediately.
Please see my attachment for further comments. Thank you for your thoughtful consideration.
Rev. Simone Malboeuf
3 Hearing Identifier: Secy_RuleMaking_comments_Public Email Number: 695 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D0014433C4A0D6)
Subject:
FW: Docket ID No. NRC-2012-0246 Sent Date: 12/26/2013 9:25:35 AM Received Date: 12/26/2013 9:25:41 AM From: RulemakingComments Resource Created By: RulemakingComments.Resource@nrc.gov Recipients: "Rulemaking1CEm Resource" <Rulemaking1CEm.Resource@nrc.gov> Tracking Status: None
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When we produce nuclear power, we are depleting a non-renewable resource (uranium) taken from the earth, that will eventually not be available for future generations. When we turn it into fuel rods that are spent, we create non-disposable waste that
needs to be dealt with as it is highly radioactive and dangerous. Therefore, from an intergenerational justice point of view, the process of building and operating nuclear power plants is inherently
unethical.
In addition, the total costs of providing electricity through nuclear power plants cannot be honestly calculated. It includes many unknowns that have been left out of the equation: such as the cost of unconceivable long term storage of spent fuel rods; the efficacy of even attempting to do that; the costs to future generations that our actions will impose upon th em; the health risks imposed on the human race and the planet, the long term medical costs of caring
for people negatively affected by the nuclear industry and its waste;
the future costs on the environment for all inhabitants of the planet.
When all is added together, it is clear that the real total cost of nuclear power is incalculable and therefore, morally unacceptable. Instead, we need to explore which scientifically feasible future technologies have the potential to provide needed power and that help us comply with our obligatio ns to protect our home, the earth, and to future generations better than nuclear power. Traditional approaches to cost analysis and risk assessment should include the moral non-acceptability of nuclear technology and the risks it poses. Intergenerational justice should be included in this analysis.
The fact is that nuclear energy has been imposed on the human race as an ongoing social experiment.
Moral issues such as the long term risks and feelings of responsi bility for future generations need to be taken seriously and not dismissed fro m the debate in denial. High-level nuclear waste is the inevitable end result of nuclear energy production. The waste w ill remain radioactive and/or radiotoxic for at least 100,000 years. It is estimated that the total amount of high-level nuclear wast e in the world today is between 250,000 and 300,000 tons. The amount of waste increases daily. This needs to stop. This is no t intergenerational justice.
Diablo Canyon NPP needs to close immediately. Radioactive waste is hazardous to all living or ganisms and exposure to radiation may result in death, incurable disease, as well as mutation of the genetic code. The security standards are based on theoretical 2assumptions, as humanity has no previous experience to build on with regards to radioactive waste. In Europe there is a security standard of 100,000 years for the min. period that the waste must remain isolated from all living organisms. In the US it is 1,000,000 years. Is it moral for our generation to leave this legacy for our children, their children and all fu ture generations? I THINK NOT! It is commonly known that there is no place in the US that currently can provide for the long term storage of the nuclear waste
the ancestors of future generations are creating today. The first and only such repository in the world is Onkalo, Finland. The planning for Onkalo begin in 1994 and excavation began in 2004. The projected completion of phase 4, the encapsulation and burial of
areas filled with spent fuel is projected to begin around 2020. The estimated cost of this project is about 818 million Euros. The State Nuclear Waste Management Fund has currently saved approximately
1.4 billion
Euros from charges pa id by customers for generated electricity. This cost should be pa id for by the industry owners, before profits are distributed to shareholders and not charged to the users of electricity. It is a cost of production that should not be paid for by the government, but the businesses who created the expense. Onkalo is expected to accept canisters of spent fuel for about 100 yrs; around 2120. At that time, the site will be buried and the access tunnel sealed, for Eternity. In 2012, The Royal Institute of Technology in Stockholm Sweden published research suggest ing that the copper capsules designed to hold the fuel rods are not as corrosion safe as they were claimed to be. Remedies for this are being studied. Already the world's only repository is needing to be upgraded.
Released in 2010, the documentary film INTO ETERNITY's director Michael Madson interviews the Onkalo experts for answers to important questions: How much waste will there be to store? How do you know it can be safely st ored for 1000. 100,000 yrs? How long can we keep creating nuclear waste? Can we guarantee even when we store it in bedrock that the earth will remain stable? Can
we insure future generations won't disturb Onkalo? Why should we be afraid of human intrusion into Onkalo? Is it possible another Ice Age might occur? What if the knowledge of the existence of Onkalo is lost? Will there ever be another world war like the two in the 20 th century that might disturb this site? How many of these sites will
the world need? How much will the total cost be?Who should pay these costs? The answers to these questions are critical and need to be taken seriously in making the decision about not continuing the 3mistakes of the past - the development of nuclear power for providing electricity. Please view this film right away and become educated.
When asked if the designers and scientists working on Onkalo had a message for the future generations- their response was: Stay Away; You should not have come to this place; Create a better world for the future."
I believe it's time for the experiments with nuclear power on the human race and inhabitants of earth to cease. We already know the answer - it costs too much, the risks are too great. How much should
be sacrificed for the profits of th e share holders of the corporation? At the November 20 NRC meeting in San Luis Obispo, the NRC representative openly expressed the idea that the radioactive waste generated at Diablo would need to stay there until the Federal government established a repository in the US. This is a big lie. At this time, there is no such place and no concrete plans to build one. The standard of the nuclear power industry is to keep the waste on site. There are no completed repositories for radioactive waste in
China, Japan, the United States, France, Germany, Canada or anywhere else in the world. How much waste does PG&E expect to store there over the lifetime of this plant? I am greatly concerned that the NRC representative at this meeting was blatantly perpetuating this lie. As a representative of NRC, he appeared to have no scruples. How can the public trust the NRC with representatives like this? The NRC knows this and is perpetuating the LIE that there will someday, in the near future, be a place for radioactive waste to be shipped to and "safely stored" for eternity. This is done to placate the audience into not objecting more strongly than they already are, so the NRC representative can get through the meeting and pretend the audience is in agreement with the plans to continue operating Diablo Canyon Nuclear Power Plant as usual.
Even if there was such a pl ace, or many of them in the world, the concept of storing unlimited amounts of radioactive waste for unconceivable lengths of time is absurd and irresponsible. It is morally wrong for the nuclear power corporations to create this highly toxic and destructive waste and plan to "dispose" of it in the earth. It is also wrong for the corporations to reap the financial profits and give them to stock shar eholders who keep them for their own families while subjecting the families of 99.9% of the population on the earth to the negative affects of the waste of their business. It is wrong to leave the problem of wh at to do with the radioactive waste to future unborn genera-tions. They will not have use of the electricity (it has already been used). They will not share in the 4profits made from its generation. Th ey should not be forced to bear the burden of dealing with the waste products produced and the
effects they have on the environment of their homes.
The notion that the Federal Government should build/fund a repository for the waste products of this industry that has been highly profitable to shareholders over the past 60 years at least, is wrong. We, the tax payers, are the ones funding the government.
This means we, the electricity users, would be funding the costs of the largest expense for the owners/shareholders of the nuclear power industry. That is the oldest trick in the book. You create the mess.
You clean it up. Only, you really can't in this scenario. The mess is too big to be cleaned up.
In addition, the idea that this waste should be buried in the Earth is dangerou. We cannot predict what seismic or other "natural disasters" are in store for the Earth in the future. We can only react to them to the best of our ability.
What would be the consequence of a nuclear explosion deep within the bedrock of the earth? Nobody knows, not even the smartest and wisest "scientists", though they may be asked to suggest the pr obability that nothing bad would happen. If paid enough money, people may say anything which may
then be promoted as the "truth". What we do to the Earth, we do to
ourselves and our future generations. The Earth is a living organism. How much abuse can its environment take before it reacts in self defense?
All of the people who spok e in support of DCNPP at this meeting were either employees of PG&E, most of them working at the plant, or from other groups funded by the profits of the nuclear power industry. It is clear that they were all protecting their jobs, for which
they are highly paid, or their hopes of getting a job in the future for which they will be highly paid. The ace in the hole for the nuclear industry is the incubation period of radiation exposure. It's damage does not show up for a long time.
It's 2-5 yrs for lung cancers and 15-17 years for solid cancers to appear. Because radiation is invisible, undetectable, workers and the public cannot tell they have been damaged by its affects for years. The employees of NCNPP apparently think they are immune to radioactivity. The public knows we are not. It is very revealing that though PG&E says its first
concern in public safety, they have not done one study on the incidence of cancer in this area since the opening of Diablo Canyon.
It is true that if DCNPP were closed, those employees would be out of work. I submit that if PG&E should stop promoting the continuation of an outdated system of the production of nuclear 5power, and started becoming a leader in solar, wind and wave power.
Let them lead the way not just in the US but in the world to a new and better standard of producing needed electrical power for the world's population that is not as toxic and potentially dangerous as nuclear power. This discourse is w asting valuable time. It is time now to take our heads out of the sand. Admit the shortcomings and negatives of the nuclear power indu stry. Step up to the opportunity to become leaders with a bold mission to develop renewable energy sources that hold real promises for the future. The time is NOW. If
PG&E cannot accomplish this on their own, then the courts and the NRC need to order them to do this.
The people of San Luis Obis po, California, including myself, who are not employed by PG&E, have NO CONFIDENCE in the Waste Confidence Rule. I urge you to begin the of decommissioning Diablo Canyon Nuclear Power Plant immediately. Direct PG&E to also begin the process of finding the safest possible process of way of dealing with the radioactive waste. The only "safe" nuclear power plant is one that is not operational. As long as the radioactive waste
is still at the site, it needs to be taken care of and monitored by
PG&E, whether its cost effect or not. These costs should be absorbed by PG&E's corporation/share holders and not pushed upon the tax payers of California or the United States.
Thank you for your thoughtful consideration.
Rev. Simone Malboeuf simonemalboeuf@gmail.com December 20, 2013