ML19311C738
| ML19311C738 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/23/2014 |
| From: | Public Watchdogs |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| Cruz Z | |
| Shared Package | |
| ML19311C699 | List:
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| References | |
| Download: ML19311C738 (46) | |
Text
Z 0D Letter 16, page 13 10 presented in Appendix G Appendix G uses units of collective dose equivalent; however, as also outlined in the appendix, the radiation protection standards are in units of annual individual dose.
The Supplement should use consistent units and provide data on population densities for nuclear power plants.
Appendix 0.2 (page G-19) provides the average public dose within a 50 miles radius of a facility The Supplement should clarify if facilities which fall outside this analysis (e g, have denser populations yielding more person-remn than indicated in the appendix) must complete a site-specific analysis.
CL-16166 61.
Page 4-31. Section 4.3.8.4. While the overall worker health impact is SMALL, Appendix 0 shows data from some decommissioning facilities where worker exposure is higher during decommissioning than during operations. The Supplement should clarify how these higher exposure levels compare with the radiation protection standards. Also, this section should clarify whether an analysis was done of the normal wastewater streams produced during decommissioning that are contaminated with radiation.
CL-16/67 62.
Pames 4-30.4.12 and xii. The Supplement should clarify the circumstances under which rubblization is permitted. It is EPA's understanding that, to date, rubblization has only been permitted after site decontamination. Does the term "rubblization" on page 4-30 refer to the treatment of concrete or structures that have not been decontaminated? Note that page xii indicates that the continued dismantlement of structures that have been radiologically decontaiminated falls outside the scope of the Supplement.
Environmental Justice CL-16/68 63.
Pape 4-57. Section 4.3.13.4. Lines 36-38. The environmental sections of some PSDARs submitted to date have not provided detailed information. The Supplement should elaborate on the *appropriate information" that licensees should provide relating to environmental justice in the environmental section of their PSDARs to enable NRC to obtain sufficient information on potential environmental justice issues at decommissioning facilities.
Cultural, Historical and Archeological Resources CL-16/69 64.
Page 4-58. Section 4.3.14, EPA appreciates that, on the whole, decommissioning is not likely to affect previously undisturbed archeological resources potentially located near the facilities, but is concerned about the potential loss of these facilities as a body of engineering work. The Supplement mentions that a few facilities may be eligible for listing on the National Register of Historic Places individually and that those facilities would then be the subject of mitigation based upon consultation with the SHPO. Eventually, however, a substantial number of facilities may be decommissioned. While the facilities themselves may not be fifty years old nor require physical iMnit preservation, the processes and engineering they employed may merit inclusion in the Historic American Engineering Record (HAER) The HAER is designed to provide uniform documentation standards so future scholars can look back at our achievements and study them for a multitude of purposes. Rather than make this determination on a case-by-case basis, the NRC may want to consider working with the Advisory Council on Historic Preservation and the National Conference of State Historic Preservation Officers to achieve a programmatic agreement or other programmatic treatment for these facilities Letter 16, page 14 11 Transportation CL-16/70 65.
Page 4-68. Section 4 3 17, 1. This section should address regulations governing the transportation of hazardous and mixed wastes as well as of low level waste.
CL-6/71 66.
Pane 4-69. Section 4.3.17 2. Line 5. What is meant by "not large enough to destabilize the important attributes of the system?"
CL-16/72 67.
Pages 4-72 to 4-73, Section 4.3. IS. The discussion of irretrievable resources more properly belongs in a section that summarizes environmental consequences. The Supplement could benefit from having such a section as was done with the recently issued draft NMSS guidance document on NRC preparation of NEPA documents.
CL-16/73 68.
Page 4-72. Section 4.3.1B. Line9. It seems inappropriate to include concrete as aii ietrievable resource.
CL-16/74 69.
Page 4-72, Section 4 3.18.Line 14. The Supplement states that there "are no regulations that deal specifically with the concept of irretrievable resources." It is unclear what is meant by this statement. The following statutory and regulatory provisions pertain to irreversible and irretrievable resources in the NEPA context:
- NEPA § 102(2)(C)(v), 42 U S C. § 4332(2)(C)(v);
- 40 C.F.R. § 1502.16 (CEQ regulations); and,
- 10 C F.R. Part 51, Subpart A, Appendix A (NRC regulations).
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George H. Ryan Governor January 7,2002 62704
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USNRC FROM:
Gordon Appel Deputy Direcor Illnois DepL of Nuclear Safety 217/5244723 Response to Comments on NUREG-0586 We nailed the response on Decmbwer 28,2001. Due to the mail, we are faxing this lettr to CL-17/1 PAGES....+/-
(including Uansmittal sheet)
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Letter 17, page 2 rEAR SAFETY 30---n' DEPARTMEN-TOF N 4t EAR SAFETY 1035 omUR PA.t DRVE
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Trhomas W. Ontcigcr Governor Director December 28, 2001 Chief, Rules and Directives Branch Division of Administrative Services MailstopT6D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chief,
Rules and Directives Branch:
The NRC published a Notice of Availability of the Draft Supplement I to the Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (NUREG-0586) on November 9, 2001 and invited comments from intercted parties. In addition, the NRC hosted a series of public meetings to solicit comments from the public. The Department of Nuclear Safety was represented at one of these meetings and would like to offer these additional comments on the Draft Supplement.
As mentioned at the December 6, 2001 public meeting in Chicago, the scope of the Draft Supplement is inadequate in its evaluation of the long-term radiological exposure to the public for the reactor entombment decommissioning method. The scope of the radiological impact studies in the supplement appear to focus solely on the actual decommissioning process, not the resultant site conditions remaining after the decommissioning is completed. Specifically, section 4.3.8 Radiological on page 4-26 states:
"The NRC considers radiological doses to workers and members of the public when evaluating the potential consequence of decommissioning activities. Radioactive materials are present in the reactor and support facilities after operations cease and the fuel has been removed from the reactor core. Exposure to these radioactive materials during decommissioning may have consequences for workers. Members of the public may also be exposed to radioactive materials that are released to the environment during the decommissioning process. All decommissioning activities were assessed to determine their potential for radiation exposures that may result in health effects to workers and the public. This section z
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z Co Letter 17, page 3 Chief, Rules and Directives Branch Page 2 December28, 2001 considers the impacts to workers and the public during decommission activities performed up to the time of the termination of the license. Any potential radiological impacts following license termination are not considered in this Supplement. Such impacts are covered by the Generic Environmental impact Statement In Support of Rulemaking on Radiological Criteria for License Termination ofNRC-LicensedNuclear Facilities, NUREO-1496."
CL-17/2 For purposes of this GEIS, the NRC is only focussing on the environmental impact of the actual decommissioning activities between the cessation of operations and license termination. This approach completely and inappropriately ignores the environmental impact associated with any radioactive material remaining following license termination.
CL-1 7/3 For a site decommissioning that results in a license termination for T
unrestricted use, the long-term radiological impacts to the public may well be "I
within acceptable limits. However, for a decommissioning that results in a license co termination with restricted site use the potential exists for long-term radiological impacts to the public to be far above acceptable limits. The draft Supplement does not consider this potential. While narrowly focussing the radiological studies to the decommissioning process, the NRC does not consider those potential long term impacts to the public.
When the original GEIS was issued in 1988, the NRC viewed entombment as an unlikely decommissioning method. The issue of entombment was not publicly discussed in the 1997 timefranie that NUREG-1496 was published. It is unlikely that NUREG-1496 addresses the long-term radiological impacts associated with entombment. In 1999, the NRC began to consider entombment as possible decommissioning options or methods and conducted a workshop in CL-17/4 December 1999 to gain input from the public. On October 16, 2001, the NRC z
published an advance notice of proposed rulemakling regarding entombment C
U options for power reactors. Even with that notice and this draft Supplement, the m
NRC has yet to evaluate the long-term environmental impacts associated with G) 6 CL-17/5 entombment of power reactors. In this Supplement, the NRC fails to consider ci whether it has the statutory or regulatory authority to terminate a license that P)co allows for unrestricted site use with residual contaminition present on site or to Cn CL-7/6 terminate the license with restricted site use in an Agreement State. Residual r_
",a contamination left at a site whose license was terminated for unrestricted use could
" CL-17/7 be perceived as disposal of low-level radioactive waste. By definition CD Letter 17, page 4 Chief, Rules and Directives Branch Page 3 December 28,2001 entombment is disposal of low-level radioactive waste in the containment CL-7/8 structure. The Atomic Energy Act allows states to assume regulatory authority over the disposal of low-level radioactive waste in their state. In an Agreement State it is the Agreement State not the NRC that has the jurisdiction over disposal of low-level radioactive waste at reactor sites.
The federal government has established policies regarding the disposal of low-level radioactive waste. The federal Low-Level Radioactive Waste Policy Act of 1980 and the Amendments Act of 1985 require the states to provide for the disposal of low-level radioactive waste generated within their B6rders. States were encouraged to form regional compacts to limit the number of disposal facilities developed. As an incentive to form compacts, compacts were given certain rights to control the import and export of low-level radioactive waste into or out of their region as well as to establish policies regarding the management of waste within their region. To date, 10 such compacts have been formed and ratified by Congress. Most compacts envision having one regional disposal facility that CL-17/9 would accept and safely dispose of their region's waste. Allowing NRC to determine whether waste can or will remain after a reactor license is terminated is contrary to the policy of the respective compacts and in direct disregard of the federal low-level radioactive waste framework established by Congress.
CL-17110 As the NRC evaluates the comments received on the GETS, it should look beyond the actual decommissioning process and focus on what condition the site CL-I 7/11 would be in following license termination. If the possibility exists that radioactive material will remain on site under an unrestricted or restricted use condition, the GEIS should consider the associated long-term environmental impacts. In CL-i 7/12 addition, the NRC should reevaluated their legal standing in deciding what radioactive material would remain at a reactor site located in an Agreement State and whether their proposed action would be contrary to the waste management policies of the applicable compact.
I Any question you may have regarding this letter may be directed to me at 217/785-9868.
7bomasW.OrtcigJ~z Director TWO:bac
Letter 18, page 1 z
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- 'mtm2@nrc.gov" <mtm2@nlrC.gov>. sxf@nrc gov" <.sxf@nrc.go 1115/02 6 25PM FW: Comments on NUREG-0586 Draft Supplement I
-- Onginal Message-From: Jerry Delezenskl rmaito:JDeleze@smud orgj Sent: Tuesday. November 20,200111:12 AM To: 'dgeis@nrc.gov'
Subject:
Comments on NUREG-0586 Draft Supplement 1 Cynthia Carpenter. Chief Rules and Directives Branch Division of Administrative Services U.S. Nuclear Regulatory Commission Re: Comments on NUREG-0586 Draft Supplement 1 Ms. Carpenter.
CL-8/1 We would like to comment on the draft NUREG to correct an error in Table 4-3, line 21 regarding the Cost Impacts of Decommissioning for Rancho Seco.
Une 21 should read:
Rancho Seco 913MWe PWR DECON
$394 Please refer to our letter submitted to the NRC Document Control Desk dated 3/26/01 entitled Rancho Seco Report on Decommissioning Funding Status. On page 2 of the letter we stated:
"...Their [TLGI estimate was $495.4 million In 2000 dollars. The portion of this total that Is non NRC-defined decommissioning activities related to non-radiological dismantlement and management and storage of spent fuel is $101 mllion, most of which is related to fuel storage costs-.'
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U, Letter 18, page 2 numbers quoted for some of the other plants may be inaccurate. Each plant should verify the numbers for accuracy.
Thank You, Respectfully, Jerry Delezenski, Supt. QNLicensing/Admln Rancho Seco
...TABLE 2...
2000
$495 Million.
SMUD. when it first established its decommissioning fund, included radiological dismantlement costs and costs related to storing spent fuel.
Therefore, $495m -$101im leaves $394 million for equivalent cost discussed in Table 4-3 of the NUREG.
CL-18/2 Since 1999, Rancho Seco has embarked on an extended DECON process scheduled for completion In 2008 (including license termination). After license termination, SMUD will, depending on Its business needs, embark on sit restoration currently estimated at -$45-80 million. This approximate estimate dollar figure was never a part of the decommissioning trust fund.
(We assume your number In Table 4-3 Includes all the costs of dismantlement, fuel storage and non-radiological site restoration.)
CL-18/3 Also, based on information presented in various Industry forums, several G-~~e0-From:
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,Chief, Rules and Directives Branch Division of Administrative Services Mailstop T 6 D 59 U. S. Nuclear Regulatory Commission Washington. DC 20555-0001 Gentlemen' Letter 19, page 1 Stephen A Byrne Senior Vice President. Nuclear Operations 8033454622 o,
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December 20, 2001 RC-01-0204
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SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 COMMENTS ON THE DRAFT SUPPLEMENT TO THE FINAL
- GENERIC ENVIRONMENTAL IMPACT STATEMENT ON DECOMMISSIONING OF NUCLEAR FACILITIES
Reference:
'Draft Supplement I to NUREG-0586, 'Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" November 9, 2001, Federal Register, 66-FR-56721 South Carolina Electric & Gas (SCE&G) company offers the following comments on the above-mentioned document.
CL-1 9/1 Page 3-24 mentions the contairnment ceiling being lowered to the top of the pressurizer for a PWR under the ENTOMB2 option. Appendix E, page 9 lists this action as optional. This action needs to clearly be listed as optional on pages 3-24, 3-25, and 3-31. SCE&G believes this action should be optional as listed in Appendix E due to the extreme effort to lower the ceiling of a massive building such as the reactor building and yet maintain it intact for entombment purposes.
"T3 z C CL-19/2 In1 CD 9-CD Also, on page 3-24 'low density concrete grout" is mentioned. Grout is not lightweight, but concrete can make use of lightweight large aggregate to lower the weight per volume. Therefore, SCE&G recommends concrete be used in place of grout on -pages 3-24, 3-25, 3-3 1, and 3-33.
ey S(190 I V'srgi1C.
ummer NudwS*cfn
- F0 Box 88
- Af540%th (eo h
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- wiscmoran N UCLEA R EXCELLENCE - A S UMME R TRA DITION!
Letter 19, page 2 Nuclear Regulatory Commission 0-L-99-0290 RC-01-0204 Page 2 of 2 If you have any questions, please call Chris Crowley of my staff at (803) 345 4409.
Very truly yours, Stephen A. Byrne CACISAB/mb c:
N.O0. Lorick N. S. Cams T. G. Eppink R. J. White L. A. Reyes R. R. Assa NRC Resident Inspector K. M. Sutton W. R. Higgins RTS (0-L-99-0290 #4)
File (811.10)
DMS (RC-011-0204)
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- Chief, ulaes and Dirextivea Branch, Division of Ad-irnistrative Services,,
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h Washington, D.C. 2D55.5-00i0 S Ils Comments for the record. on MDrfth Supplement 1 to3 Nureg-05a6,**naI Generic Edreonmental Impact Statement on Decommissioning or Nacla"s Facilitits (GEIS),
Draft Supplement Beating with Nuclear rower Haanabaraso WuA a way to. spend the dq after Christamna-uhat a way to-spend. many hours: of December and. Noxemher-having to plow: through this. document -
a momnuent l manet arrogance, stupidity,, lack of foresightý and, greed1i" there, eve*r wa one. fwsver, CL-20/1 the document can be condened-Into threse words, namely 18W AI* D COVeR2. If on.
wants a: bazim overview, of what NRG put in It, as that seems to be part of the, main desire of the nuclear industry7/=R (an" D.O.E ), concerning what to do with the horrendous nuclear legacy of the atomic. ags w-At the height. of the Coll Var, frm tha. U.S.) defense against the atomic.:bomb and, the hydrogen bomb (which in essence, Suses a fission - atom=i.- darvice/bmib/reaction to trigger the fusiom reaction/bomb/
deviace,hich triggers, etc. etc. etc. ) was iam incredible defens" which i cea ad OMM AND COVEe. They actually hadb the population believing that if you duc-kesi under a. door jamb, or under a. desk at school, or-under a table in the kitchen, you woult survive, nuclear war.. Ails this side of' tb&. Atlantio ditifUflly behaved like a; bunch of sheep going over a; precipice following the leader, tha' other side, oa the Atlanti.c~thouasnds. upon thousands. demonstrated, against the insanity of the arms raze and. nuclear weapons in general. Way w*a there a difference in behavior ?
Becau"s, justl.lika today with this issue of nuclear waste and "decommissioning' (a worxt everyone swallows it seems -must be a n*w mada up word. as it is not in my huge olX dictionary) - there wag/is almost no; dlicussion of the, issues in the presasnd DO education on the issues,, and this isJ purposeafT.
There is, and has bean, press interference on the issues -
bY both inustry and govdr-6nt-s.
,.CL-20/2 The nuclear issue is the m important issue facing humanity and has been since the atom was first split. The nuclear issue. is the Sword of Damoclee. over-the planet and. all futuor generations should *e survive the nelt dAcadeI(a I write India' and' Paki stan are once again on the verge of war, only they now haae nuclear" J
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Letter 20, page 2 2
weapons, thanks to the fact that they got both nuclear power plants and research reactors-gati thoseand, with enough money and infrastructure and a goveriment willing to squander billions) just-like the Soviets, the British, the US, the-French, the Chinesag the Israelis, the Swath Africans under apartheid, gfd,-smd sooner or later youhA. gno.i.ursel a. bomb-T BOMB - )hat 011i
-clear power/atOmic bomb connection no one: wants to mention.)
You mean NM thought no one realized the nuclear p over route, was just a, diversion am the public wouldn't realizw they were running ?W*
to produce extra plutonium for, weapons Li needed,? Oppenheimer SAID am. Besides, any CL-20/3 onn vitIL common sense could figure that out. Just as anyuone with com&M sarea can tell this-Draft Suppl3menti 1r to Nureg-0586 wi have dire consequences if Implemhstai CL-20/4 i1n its current fore. It. always gazea me how the Nuclear Regulatory Commission, INW3 S its own laws, and standards - its-awn regulations, its own definitions%
(such asP"s o=miasioninge goo pxii) and most of the publia doesn't realize (If they did, it is safe to assume they woulc-probably borseatip the Co='ission out of town)hwat a CL-20/5 sham it. all isr andl be%- industry writes its own tickt.
Fr= exOsmplw, p. 2U, the Commission hae concluded (says the Commission) that Impacts that do not exceed pe misaihie levels ib thal Co* sisionty rmarultibls a"r considere d smell. In other words, using made up ratlations based a great deal on that appalling, criminally negligent outfit the IRCP (am= of the. dumpin grounds for Manhattan Project. scientists post S-for anyone reading this from the younger genera;tionsr the, Manhattan Project was thel name of the project that built the atomic bombs dumped on Hiroshima and
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Nagasaki) and: its early determinations that they would set allowable levels of exposure that were at levels that would, allow the emerging atomic energy industry.
and everything that went with itto operate with 1l the releases which they knewt and admitted would cause genetic damage )0bt they decided it would be acceptable to damage sperm and ovum.
M damage countless generations (until they di. out) to cause countless birth defects, countless miscsrriAges, countless cases of spine bifida - look at South Carolina, nuclear power plants anr the Death of the Earth squad*'s Savannah Bivar Nuclear, Site and. the highest spine hifida rate in the US.
CL-20/6 NRC haa absolutely no basis to say whether impacts will be sm*el etc. based on that
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. The great R.14 Sievert (after whom the unit the Sievert is named)
M'inted out that there was no level below which radiation did not cause damage, 110 threshold that must be exceeded for damage to ocourr, yet MM~ says a threehold vast be exceded for effect to occur, I believe Sievert. The ICp standard of 5RM per yoar is based on a principle called risk/benefit that allows a one in five thou*and chance of contracting cancer. In other words, the death or-cancer risk is the uorkors and the publics* # the benefits are the dollars flowtng to the industry and the IM (from the indhetry in return for MC services end licensee ate)
The fCP also pushee the 5 R standard - this in the wse bunch of borns who in tryinZ to refute the world renowmed findings of Dr. Alice Stewart and the fenaus-fxfoed Study accepted vorlduide1 that showed in-raying a develloping fetus eaused a major increase in childhood cancer - claimed obstetrictann had x-reyed thon* fetuses which they somehov M would goet cancer, which explained why the x-rayed fetuses vwnt on tAP get childhood canc-'P(SBe "The *man W. Kn Too 1,ch - Dr.,lice Stewart andt the Secrets of Radiation' by Gayle Greene. Read it and learn all about the Commission and its buddies.
Read it and imep for umeanity, then, if you have something called a ooncience at the NRC, go do comething about this Draft so it is no longer en Jndusty wish Itst. ) The ALARA principle that N2C uses "hich basically say3 that doses mist only be kept Ac Low As Reasonably Achiovablo (ALAnA) based on the state of the technology and the rount of money npent by tha industry - uhat Dr. Gohamn calls "planmed deatha" ns HM knows CL-20/8 is referenced by NE, many times, and the Draft even says cdýrin! liceniing the ar.l:.cuntn coait to inplament ALIRA progrnans.
7be combination of ic',In-Fc.w end *_AIt..itcndords is, and hes been a recipe for premeditated r-urdcr and/or illness, CL-20/9 genetlc c.aego and Creat suffering ae it is, NHC savinC' that it hbe not established strunda-rJe to biota other than humans on the basin that limits sstablishoJ (by the afore'antioned) for the public would provide adequate protsctLon for other species is outrageous end ontrary to what aes been established for decades. PlUs, to 3
Alsmst W-yerw ego, the. Georgia.ecologist Eugene Odgn, who did a lot of work for the Atomic Energy Conmission/DGoE (a. fact that is not now widely known) undbr. contract,, wrote, of the:need to "accelerate, the study of the functibn of intact biotic communities In order that the'+/-t.a radiation effects can be eval3-uate&f of the. need fo "ean understanding on the long term influences of low IevelL radiations on aquatic. end terrestial environments into which the by-produch may be released,." and that it was concievable Othat every large atomic power plant of the futtre will need a radiation ecologist to work with anvironmentfl problems outside of the plonte and'that there was a need to train "Yuung men simultaneously in the fundamentals of modern ecology and radiation biology n.
order that this inevitable need can be mot.*' Mw rterribly sad - th& lil ham one doctor for the entire NRC. Radiation biologists, ? Stop me. before I scream..
It is-obvious that an inventory of all life forms on a site should be-made and, that they be sreaened for chromosome aberrations and 'radioactive conteminationrthen Letter 20, page 4 then cite the bozor at NCRP again)saying that the "fate of individual non humon organisanis-of less concern than the maintainance of endemic'populatio,"
shows A OMMM LACK OF UNDERSTANDING OR COMRPERESION OF THE WEB OF LIFE AND THE NATURAL WORLD.
The' effects of ionizing radiation exposure' on AM lifer forms' inclidts sterility and genetic damage which can lead to extinction.(Think frult flies. an'!Herman IMullers experiments which gaves.im a Nobel Prize.
Think they.
effects to fishtproved years ago. )
When thinking about exposurer to plants ancd anioea and fish, one needs to take the affects to aaiinfant an& to ai chil'd'in'the womb to, better. approimnata the. effects to wildlife, the analler the, ron-human entitY (e.9'. a biM,. a frog) the child in utero dow* to embryonic-level wuold bh appropriate. Wa all know what happens when an embryo is exposed - rmely eatlr on*
or-severe damage.. Tha samehappens to birds eggs.
Thm InternationaT Atomic, Energy Agency i' about' as trustworthy on the radiation dose issue as Atila i
- the, Hum would have been on the gentleness issue the IAEA has, a
che*rtr that states itkr sole purpose in life is'to push all things
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10 a similar comparison be done at. a site as sii as possible to the plant site CL-20/14 about twenty miles away upstream and out of the predominant windpath on a thirty year wind, rmrse It would notý be half as good as one would, want,. but it maoldube CL-20/15 better than nothing and establish seas differences and' give a. better idea of the contamination problems, even though a, site! twenty miles avay ui have recieved!
somarairborne deposition from the. plant.
In terms oW aquatic species, the recardi from,Statasources and the licensee on tests ran on flsh/mussels etc. can baeuead and compars to the' fact, repeat PACT, that contaminants such as Cobalt-b, Sr-W Ca-1>Z,, U-3 above, theminute natural burden, plutonium etc. are.not natural. and should never be found in fishmollusks etc. and one can look for chromosome aber-CL-20/17 rations.. Dtatiam can be. examined for bioaccumulation of the uraniums from the plant.
Centrides hence -
in some cases decades -
a measure of equatic health would be the decrease in levels of contaminants found in species and decrease in aberrations etc.
It is vital, that contaminated sediment found' downstream (an&
also somer upstream due. to airborne depositton on water sinking down) be recoxe&
for many miles, downstreaq.
This-houl& be-done by perhaps sucking it up vie vw uu1 type hoses as opposed to dredging which could dislodge and spread the contam ination further..
With rsgard.to plant-life,, microorgsZani s etc. oneoould comparXplant see8d production of say twenty species on sitr, with production twenty miles away, and; number and type etc. of microorganisms likewise, as well as radioactive contaminat CL-20/1 1 ion.. I don't really know. why I an bothering to write all this, as the NRC wil ignore it anyway,, but hope' springs eternal as they say. If we don'tt have' compar-CL-20/18 isons, we. can't.have at least some idea of. what constitutes the, start of a return t'
- a. more unpollutted. site, and we can't. astahlish what needs bulldozing and taken to-01 2
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B TE HO EER THE ADDITIONAL CL-20/12 TW H~~A9 V
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EXPOSU IS TOTALLY NSANX.
WHEN DR. K&L MOWRAH AS ALIVE S THE FAT OF RADIO LOGIVAL HEALTH pHiSICS, iO EEl WITH OAK RIME FOR DECADES, HE SID LESS THAN ON CL-20/19 CL-20/13 WOULlDL PER oEBRoNL,
L E pERHAPS ACCT.TA=
FROM, ALL PAT-WAX.
TIER.
SHOULD BE A LACK OF INSTITUTIONAL COI1TWL EITkHO1.
The Technical Specifications and what the facility was allowed to dump undea.
the license are
&outdated and bear no resemblance to current knowledge and should, be junked and the whole thing done over. Furthermore, the way the environmental and water issues were looked at during the t&me, of plant licensing were often equally awful.. It. all needs reconsidering.
What is. ridiculous, is the worry about messing-up the enviroment while decommiss Ionia4 the dump.
For crying out loud, every second the plants are runniing they arie contributing to ecological ruin, at the microscopic level, and impacting human health to a distance of appronimately 100 miles.
This Draft I references MLRSSIM (Multi-Agency Radiation Survey'and Ste Inves togation Manual. Y I comented on the Draft, never saw the final, never heard" from anyone again on it.
It was mindnumbing1y awful. Put together by some peopleI from NRC,,WE, Dspt_ of Defense, and EPA. Industry was represented big time. Im It the, DOD aei"' how committed-it was to protecting the environment - this from am entitV that had left thousands of contaminated sites on and off bases, themselves requiring an estimated (govt. estimate) ;t007HILLIUN to W0 Billio0nto cleanup worldwide.
In its introduction, DrafteMarssix did not address all aorts of things.
from contamination on vicinity properties through contaminated subsurface soil, water, construction materials and on and on.
All of which must be cleuandi up/hay.
the contamination removed. They showedi s lack of understanding of the groundwater cycle, and groundwater issues JUST LIKE THIS D-RAT DOES (in fact Ilm still looking for it to be addressed),Groundwater is used by oou-ness communitlesagrOundwater let eventually released to surface and other water bodies and)as groundwater onsite is usually radioactively contaminatedl (At Plant Hatch they contaminated it by 1979 and that was just for starters)'
is is a SERIOUS issue that MUSTbe dealt WkIcJ, groundwater te..
is contarninated*4=ba puped out etc. kHefer to what I a$
said.in earlier comments) THIS GROUNDWATER CONTAAIkNATION ISSUE IS ANOTHER REAON WHY SiROuBLIZATIONT MUST HE FDRuDDEwn THE CONTAvMINATION IN WHAT THEY WAdT TO Ru~lzSLI AND EURY WILL LEACH TO THE 6RDUNDWATER AN DIRECTLY IRRADIATE SOIL AND MICF0OROANIRES. The industry just wants to nave money and "dump and cover*.
b
Letter 20, page 7 z
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CD Letter 20, page 8 CL-20/20 The fact that the Staff and the Commission have even considered rubblization.
shows an utter disregard for the health and welfare and safety of the public CL-20/21 and the ecosystem upon which life depends. Anything dumped or buried from the past practices on site must also be dug up and removed.
CL-20122 To= find, out" the extent of past problemsr and. contamination levels, IT IS VITAL THAIT THE NlO, TME LICZS= (as' some an new owerR/licensees),
AND THE CONTRAC TO AN D SUB-CONTRACTORSG T ALLACOIDENTS, LICENSEZ V=
RIEOORS, VIOLATIONS, INSPECTION REPORTS, SPILLS AND CONTA11INATION EVEVTS FROM TIM RDOC=
FOR THE REACTOR AND SITS IN qUS= ON AND OODY WELL GET OFT T=
REAR ENDS AND nffm TMHR MONEY AND RVA TEM. THEM N= THE WGOLZ LOT, SINC
- STARTWUP, EM IF IT Tj= TWO MONTHS TO IEAD TM I AM SICK AND TIM OF EM=ONZ,NRC INCLUDED, REFUSING TO READ THOSE REPORTS FROM THE NOCIEM AND IX THE PUELIC 10MOMENT ROOM.
- TUEN, AS THE LICENSPS USUALLY PUT A GOOD SPIN ON IT, PEOPLE SHOULD REALIZE THE pRD I MRS LISTED WERE PBOM I IA.!WN.
-Another I sase '-which I touchadi on in my comments on MARSSI*,I ws the-fact that in the real ijorld, iasy people can nct" reeL or imAite very wenl, an-d if things are contracted out, this' could hama CL-20/23 eeriou-s'consequen~caea IMM must stipulatu, that ALL CONTRACTORS AND SOR'-.CIDTRAfC TORS RIGHTI DOW TO THE BACK-HOPE OP*TATORS MUST HE HIGH SCHOOL GRADUATES.
asnup cannot" just be dished out to any contractor,. all involved ishould not' only have a stirling track record, but experience in nuclear fields. There should. be-n radiation biologist on site, plus-ah ealth physicist, plus a wildlife biologist" with a.
knowledge of radiation effects, plus tlere must be federal end state oversightt CL-20124 ON THE SITE at all times.. I noticed that the Draft blabbers on about OSHA standards T
FA3LS TO H=TION THAT OSHA IDES NOT COME ON SITE AND IS NOT ALLOWIC TO ACCORDING TO OSHAJEVERYTHING IS UNDER NRC.. So lets print the truth shall we 7.,
CL-20/25 The Draft saysp.-6 1that the NRI and. the Commission are not considering the issue of-spent-fuel storage (in a pool or-in one of those ridiculous casks outside in plain view for every terrorist to see) as part of decommissioning. The excuse is CL-20/26 that it's dealt with under other license aspects. It also says that the Commission has made a finding that the D=lMY, RADIOACTIVE SPENT FUEL CAN BE STORED SAFELt AND WITHOUT SIGNIFICANT ENVI MTAL IMPACTS FOR AT LEAST THRIiT AnS BDMN THE LIFE FUR OPERATION ETC. ETC.
IS THE COMMISSION OUT OF ITS COTTONAPICKINO MI=RT CL-20127 Those issues are of grave concern. Wht happens, if during decommissioning (i.e.
during "dump and cover 3 amidst much licensee laughter about how they stuck it to the rate payers and taxpayers and local community yet again) terrorist& take out three spent fuel casks blasting them to kingdom come (the Milan anti-tank weapon would do that as I wrote XRC before) OR two casks had a major problem and needed to beopened under shielding inside the spent fuel pool and there was either no room in the spent fuel pool or the cask came apart while trying to move it due tor brittlement of the cask from the radioactive decay heat coming off the spent-fuel ?
Whatt will NXI do, what will the licensee do, send for Chostbusters ?
CL-20/28 Under Water Quality p.4-10,,t11 The NRl must stop giving the impression that it is
-sheer chance that nuclear reactors are located on wateruhen in fact they require-miflions of gallons of' water a day to operate and'that water source is con sidered the ultimate heat' sink in the case of a meltdoun - itill ooze on down the riverbisasing and sputtering like a volcano hitting water. NME assumes compliance, with NPDES discharge permits for on-radioactive contaminants (NPDES and the Clasis Water Act do not cover most radioactive contaminants, this was purposeful1 so inndstr-y andi the. ammq.nts crowd, could do. what they liked, ) however, NPDES permits, are often violated or. bypassed - just look at the NPDES situation in Georgia. as one CL-20/29 example. Discharges should never have been allowed without prior cleanup and should CL-20/30 not. be now. Surface and groundwater quality, p. /-12should NOT be considered, a geý nario decommissioning issue - climate zone can also create unique problems, terrain CL-20/31 likewise, it should be site specific.
Air quality issues, p.- 412 etc.1 do not address the fact that HEPA filters are about as good as useless for radioactive particulate CL-20/32 holdup and sand filters should be added as well. All wrkers must have self-contained CL-20/33 breathing systems (moon-suits). The area being worked in should be covered to con tain dust if it means covering the whole site with a tent with an adhesive inner capture surface to capter particulates - after all If flypaper' is good enough for the DOE when it, like the NRC was cealle* the AEC)to capture particulates on, a tent with
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Letter 20, page 9 Ssome sort of a sticky undersurface is a step up!
Thr point I'm getting C
a CL-20/34 at, isone does not want radioactive and chemical particulate matter getting CD
- J CL-20/35 off site if possible.
If such a tent system were used, afterwards it would be disposed of as red waste.
Also, workers and the publinWJXST understand the fact that one can not clean up radioactive contamination, only contain it to some extent and remove contaminated materials to better sites where they can be better contained - in other words to national sacrifice areas remote fr*m all human habitation and far from water sources, where wild life is fenced out.
CL-20/36 Regarding aquatic ecology p.4.--6, as touched on earlier, the anvironmentalL impact statements originally written for the plants were often very poor, an&
did noramention that the discharge water would be radioactively contaminated non= that sediment would be contaminated for miles e*m. In the long term, if that contaminated sediment is removed and no further radioactive and chemical releases CL-20/37 are made towter and air, the aquatia ecology can only mve.
a quality U1
- 0) should continue to be tested for radioactive contaminants for at least 600 years which is the full radioactive hazardous life approximately for cesium-137 which is a contaminant of concern in fish and shellfish as it migrates to muscle in CL-20138 particular. The aquatic ecology issue should also be site specific, for exa=ple, Plant Hatch in Southern Georgia had a massive spent fuel pool spill which con taninated not only the river and sediment but also a huge wetland area which has many creatures feeding in it and becoming contaminated, inc"ld threatened' and endangered birds. And& on the endangered bird subject, let. me adress the CL-20/40 Migratory Med Tz-aty Act of 1918 - (p. 4-20)
It is a proven fact - proven by the old Atomic Energy Commission and its contractors,- that migratory birds become contaminated eating seeds,drinking water and so on at radioactively con taminated sites, wetlands areas etc. and the birds carry this contamination in their bodies worldwide. NRCC oE and licensees violate the FMT bk not pro Z
teating birds from such contamination, and by spewing radioactive noble gases CD out that impact passing birds. No wonder birds are decliningý This is one of thor C"
reasons I suggest that netting or similar should be placed over the sites in CD Letter 20, page 10
/D).
question, fine wire mesh sat at an angle that can have leaves and other debris hosed off it, it must be anall enough to keep birds out down to the size of hummingbirds. Enclosed, such an obscene site poses slightly less of a threat to bird and-other wildlifer the, utilities can pay for it all, it can come, outL ofthe, salaries of the top management and company owners. NRC better sat it up now, befora.they all pull an "Enron"
- i.
e, an "end run" round everyonem.
CL-20/41 I notice that the General Accounting Office-haus slammed the NM f=
its lack of oversight of transfers and mergers in the nuclear industry and had not.
verified that new owners would have guaranteed acess to the decommissioning charges that their affiliated utilities would collect, in some cases, plus, a host of other safety and other issues were raised, all of which are troubling.
The NEC must immediately address problems, and should demand that conpanies provide enough money for-oversight
- to include security staff,maintainance staff, nuclear engin CL-20142 eers, radiaLion safety officers ate. - essentially forever. Even after all fuel is removed from the site and the entire structure-is removed, the site will still be radioactive forever and still need a security person, basic maintain-nce person (for'upkeep of fences, gates, runoff detention ponds etc.3 and regular visits from CL-20/43 a-radiation safety officer. It is absuard that. XC states that "decommissioning activities do not include the maintainance, storage or disposal. of spent" nuclear fuel, or the removal and disposal of nonradioactive structures and-materials beyond that necessary to t1rminate thatNRC license
-...they are not considered, aw a cost impact because the licensees-are not required to accumulate funds for these act ivities.e (Smp. 4-a2)
Why not ? This is an outragel The NRC must pass a Ib*le" at once requiring such money be set aside, some of it perhaps in form of gold and silver bullion at bank deposit in case of financial collapse. The fact of thin matter is thiss the licensees must be held responsible and, accountable for every thing about and on the site and generated by the site past, present and future.
As NRC states (p.43) local jurisdictions may impose stricter~cleanup" or* waste' CL-20/44 or contamination containement and this will cost more.
The NRC should add a 10%
sucharge to any calculated fees-for dco-naissioning to help cover those costs-
z Letter 20, page 11 CD SII.
ro CL-201 that a"e unforseen which may arise.
And of course they must pay for-the "spent" 45-46 deadly radioactive fuel storage at the sites, whether in pools or casks at ISFSI's and the maintainance and upkeep and security and waste handling and fire preventiom and similar. This MUST be addressed as part of this decommissioning, it must be' CL-20/47 incorporated.
THE COSTS MUST NOT BE pAN=D ON TO TO RATPAYRS a NIC says: they CL-20/48 are currently.
Furthermore, the most expensive estimate should always be assumed for everything as a mise precaution. NNO lists the decommissioning costs ImC MILLIONS as estimated bj the utilities - however,. NBO WELL KNOWS THE COSTS ARE if TH& BILLIONS WHEN EVME NO FROM SPENT FUEL ON DOW IS FACTORED IN, AND THAT MUST BE REPLECTED, PLUS THE NRO INSPBOTOR GENERALS OFFICE SHULD GO OVER ALL ERWCATES CL-20/49 MADE BY UTILITIES TO SEE RHO TRUSTWORTHY AND ACCURATE THEY AM Inflation must also be added to costs..
CL-20/50 Regardi ng the.loss ot local tax revenues due to "db osemtsioningw. The-utility most bet reqmdred to notify the local govermient as far in adivancea m possiblet. that IL 4
they will lose taxes. The, fact that the local gover*ment should' never have, allowed such unuclear dumps;,posing as power plant. inth'ttheir -communities i's another Issue,,
They need to understhnd that they betten' di-vesify their tax baea Ir. a hurry-.
CL-20/51 HgyER, themnuclear idustry - the entire industry -
(from nuclear plant owners to uranium enrichment plants to users of radiation for medical experiments poasint as 'therapy" etc) should! hav a tax levied on it by NIC th be paiW into, a spaefeal ancount-tb go towards compettng the communities.' An additional tax can be: levied' on them yearly in the form of a sull, flat fee which would help pay for theýNRC and thei,PA t do qu-rterly Inspections' at facilities, in perpetuity.
CL-20/52 BebreI forget a NPC MUST MAKE LICENSS, CONTACTORS,SU IONTRACTOR AND ANTONS Z
A* *WHO WORKS ON DMEOO10ISSIONING TAKE THE EFFECTS OF RADIOACTIVE "DAUGHTER" PRODUCTS SINTO CONSIDERATION AS THE! HA!Y HAVE VER! DIFFE7N PHYSICAL,CHEMICAL AND RADIO
(
ACTIVE PROPERTIES THAN THE RADIOACTIVE "PARENT'. THIS MUST BE PART OF DM 1NISSION 01O co ING STANDARDS. 'HyjSS3?, basically ignored that, another reason their Draft was so CL-20/53 awful. NRO seems to have ignored it in this Draft also. This is an important C
V health and also environmental isuse that cannot be ignored.
CD CD Letter 20, page 12 13,.
CL-20/54 Regarding Occupational Dose and nuclear power plant exposure data (p.G 12,eta)
The regulatory limits for exposul-were not set based on medical reasons, but were set in order to enable the industry to operate, - that is historic FACT because what people are being exposed to is' either not found in nab-rs, (i.e.
CL-20/55 it is man-made) or found in nature at far, far lower legels. The' exposure allowed by regulation is, in fact, slow death, and furthermore, worker doses canht alwaym be.- trusted because of faulty measuring equipmaent, borror stories of workers being told-not to wear their dosimeters periodically, and so on. Tht dose recieved also has a different effect on each person depending on age,sexp.
current and:past health status and many other factors, plus each organ is affected differently. The fact that the. ICRP,DOENRC etc. didn't know what on earth they were doing -other than guesswork -regarding exposura levels vetis" shown by the fac that they had to keep adjusting the. "allowable" regulatbry limits down ward. A sort of continuous NOopr,, we 'screwed up I Bat-don't. vorry, this-time.
we've got it.right.' All the' blather on "Risks" from radiation expograu,,caAlt
- hide't.he, fact that it.kills
- not just cells here and.there-such as aell&.
about-to form the septum of a babyr heart so the child is born with a hole in it's heart,because a bunch of murderers at the ICRP decided the risk war, anoeptable,-- but it kills people.
Tor KNuWINGLY ALLOW PEOPLE TO BE EXPuSED TO NOMEMB THAT WILL KILL A CESTAIN PMERENTAGE OF TEMN HIS A NAME, PREDITATED MURDER
Further,. the ICRP 40oea not consider effects manifested after the second gen eration in assess"ng the genetic risks to' workers offspring (p.G 5) again sholwin they don't give a damn about the workera and their families and whether o= not workers great grandchildren are born deaf, or with learning disabilities, or CL-20156 unable to reproduce. For tha Draft to take the attitude of "well, the dbses at plants being decommissioned are generally only a small fraction of doses at operating plants " p. G.13 is no comfortland all the charts 'show)concerning' Occupational doses(page 0 14 and on'j is tbousands upon thousands of contaminated workers,.
ItLia obvious that this contamination of workers (and the environment)
z Letter 20, page 13 G) co
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0r)
C-must be massively reduced.
SCL-2057 I notAced that it said cutting methods included abrasive water G-17, but in Sany Case where. there is plutonium contamination or depleted uranium matal, that CA
_3 is meant to be cut under heavy oils and iusbh else besides Sincemany of the c..omponents win have been contaminated with plutonium, or were made of depleted uranium (when is the NIR going to te;4.l the public that DU is'NOT radioactive CL-20158 waste..?)
it i-robvioUs that thwereactor vessl. should NEVER be cuxtup, but do.what was done w"th the Trojan vessel (p. (-18,Aesova, the whole, thng offaits)
CL-20/59 Haweer,. the. vessea should.hara additional shielding placed around. it prior tm placumenton the heavy haul trailer, and upon arrival at the disposal site it CL-20/60 should'be further encased in what would amount to a giant burial cask. Remu ng the vessel offaite massively reduces worker doses, water contamination and the.
o ontemination to the local community and the environment, Obviously, theu spent.
I.
%fuel.
i/has been removed from the reactor vessel and all liquid radwaita etc.
01 Co CL-20/61 tbo I UNDER NO CIRCUMSTANCES SHOULD A FACILITY BE ALLOWED THE OPTION OF CHOOSING CL-20/62 THE METHOD OF DEOMOSSIONING IT WANTS, AS IS THE CURRENT CASE. Comhinatloan of DECON and SAFSTOR would be. the best, howaver, under no circumstances should; SAFSTOR continue past five years (the regulation should be changed, as to expect that oversight will continue for 60 years at such sites-is-ridiculous) that+/- would enable workers familiar' with the plant to be still available,. but at the same-time allow for the decay of.some of the radioactive contaminants which have shorter full hazardous radioactive lives prior to removal thugr lowering CL-20/63 worker exposure etc.. NO WAY THIS SIDE OF HELL SHOULD ENTONB I OR ENTOMB II HE ALLOWED.
BOTH STAFF AND THE IMIVIDUAL COI*0SSIONERS SHOULD BE CHADGED W=H CR:IINAIL NEGLIGENCE -
ALONG WITH THE LICENSEE - IF THEY PUSH THAT THROUGH, AND I AM CONFIDANT THAT MANY WOULD ENSURE SUCH CHARGES AM FILED.
THERE IS INDIVIDUAL RESPONSIBILITY CONCERNING THESE MATTMS, AND IF NIX CANNOT UNDERSTAND WH! THE Z
ENTOMB OPTIONS ABE AN ABSOLUTE NO-4O, THOSE WHO CAN'T GRASP THE "WYN PART SHOULD CD RESIGN AND STICK TO SOME DIPLOYiT WHEE THE USE OF THE BRAIN IS NOT HIGH ON THE CD IQ 0
N3 Letter 20, page 14 Ji..
LIST OF JOB REQUIPU;TS.
CL-20/64 It appears that the nuclear industry has written its own ticket, as usual, on the issues in the Draft. P. E-5 notes the help from the Nuclear Energy CL-20/65 Institt in gathering information.
HOW ABOUT THE NIC ACTUALLY iEADING THE INSPECTION REPORTS AND VIOLATIONS ETC. ON THE DOCKETS OF EACH FACILITY AS I CL-20166 SAID EARLIER. HOW A*OUT TESTS BEING RUN Bi THE NRO ON THE SITE.HOW ABOUT INTERVIEWS WITH LONG TIME STAFF CONCERNING PAST PROBEM-1S THAT COULD BE EM*b CL-20/67 COUNTERED?
NBC should take its own indRpendant samples-cD oo ofsite-water andt sediment and suilhlas Wall as onsite.
The NRC mustL not ga, by the. original. Off site Dose Calculation Manuals a f
was allowed in theaa ent out with thw ARK - i.e. thelaveals-were terrible%, a recipe CL-20/68 for radioactiveaipollution, I cannot stress. enough that tha egroundwater issuaes.
CL-20/69 ae.r not adeqiately addressed. Tha usim of high. pressure water sprayx.ia obsconw.
CL-20/70 HAT IS 1=NG *ITH THE NRG T DW'T NRC UNDERSTAND THAT ONE CANNOT DECONTAMINATE SOMETING RADIOACTIVELY CONTAMINATED IK THE TRADITIONAL SENSE, UNLIKE WITH A CHEMICAL OR OTHER CONTAMINANT, WHATEVER IS DONE TO SOEIM NG RADIOACTIVE DOES NOT CHANGE THE CHARACTER OF THE RADIATON, IT CONTINUES TO ENIT ITS DEADLI ALPHABElA,*OJHk, NRUTHON ETC. RADIATION THROUGH THE FULL RADIOACTIVE HAZARDOUS CL-20/71 LIFE. YOU CAN'T BURN IT/ INCInERATE IT, IT GOES OUT THE STACK AND POLLUTES THE
- STACK, YOU CAN'T WASH IT, IT WINDS UP ALL OVER THE PLACE AND IN THE WATER, IT IS ALWAYS THERE. THE DEADLM INVISIgBLE KILLER.
AT OST YOU CAN TRY AND CONTAIN IT. The. Tritims cant even be-contained.
CL-20/72 The original site, maps and drawings and, photos made during construction-should be, consulted (some building techniques may have changed) all modifications and-revisions should be tracked down. All vaent Bystema-should go through both HBIA (for the chemicals) and senud filters. Additional containment should.
ba added around spent fuel pools including over the top and beneath it, extra supports, neow liners. They will suffer serious embrittlemet and activation, CL-20/73 same goes for the casks. Such issues must be addressed.
Again THERE MUST NEVER BE A PARTIAL OR FULL SITE RELEASE. ALL PROPERTY DEEDS MUST STATE THE SITES ARE
z Letter 20, page 15 0
CD 3
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CD 8
Pi NOT Ohly RADIOACTIVE, BUT SUPERFUND SITES, AS THAT IS WHAT THEY ARE.
THE RIVER,
- LAKE, OCEAN BEACH STRETCH OR WiATEVER IS NEXT TO THE SITE SHOULD BE POSTED AS RADIOACTIVE ALRCJ EVEN IF THE SIDD4ET IS HD4OVED AS IT 1S IlPOSSIBLE TO GET EVER~rTINO.
CL-20174 Security must be upgrade, not downgraded.
CL-20175
. structural remains should, be sent. to local landfis
- thatlndfill will be, CL-20/76 radioactively contaminated mome than at present. As all landfills leak, it will CL-20/77 go to the. groundwater and migrate offaite. None of the-miad*waste should, bm dealt with as mixed waste (i.e. a combination of chemical/hazardous end radioactive) because MV= WASTE FALLS THROUGH ALL REGULATORY CRACKS# BUT IT SHOULE BE TREATED CL-20/78 AS RADIOACTIVE WASTE. WASTE OILS SHOULD NOT BE SENT TO VENDORS FOR INCINERATION OIL RECYCLINL OR tMIJSE AS THEY ARE CONTAMINATED.
CL-20/179 jEV SnT, OPERATING OR NOT OPERATIMGIS A PRIME TERRORIST TARGET AS I HAVE
.- CL-20/80 SAID FOR =EADER.
THE S T FUEL IS THE ULTIMATE IN TERRORIST TARGETS.
- CL-20/81 Tearsr ago, when peple spoke of some. type of monitored,. retrievable spent ffmal storage, they meant monitored so repairs could be made by remote control if needed) an& retrievable so problemis could be addressed -
no ona&in their wrstl. night mares-with any aenee, ever imagined that a bunch of nuclear bozos would be-allowes to stick the most deadly stuff known to humanity in a cement and metal barrel and stick it outside in plain view.
Spent fuel-is the stuff (ALL TOGETHER Now...)
that theDepartaent-of Energy has been charged with try.Ij to contihin for approI.
10j,000 years removed from the biosp*here,. after which it becomes the-radioactive blob from hell under whatever piece of dry land they stick it.
That assumes they x Z
can contain it for 10,000 years, wbhic I doubt. I have many concerns with the C
X Yucca Mountain site. I will not elaborate on here, but will mention that the G)
"dump it on the Native Americanao idea, is odious end imoral in the extreme; 6 01 Yucca Mountain is sacred to them.. That having been said, the sits is already 100 O) contaminated due to fallout from the ujeapons teats, and Nevadas belated concern "about radioactive issues is hypocritical and distaksful, as this is' the. state, that did not give a damn that hundreds of nuclear tests were conducted on Indian D
Letter 20, page 16 1 1 CL-20/82 land, (The Western Shoshone Nation, AKA the, Nevada Nuclear Test Site) that hlew-radjoactive fallout across the nation causing serious illness, birth defects and cancers~besides doing the same to some nearer the site in Nevada.
Theonly thing Las Vegas worried aboutwas if the tests shook their gambling tables according to press reports.
When the. wind blew towards Las Vegas tha--y tried not to test.
For Nevada to now. whine that they don't see why they should Wat the spent nuclear fuel as they have no reactors - power reactors -
is obscenelconsid ering that a huge Curie quantity of the spent fuel was generated making/creating the plutonium and the tritium for the nuclear weapons-m*at of them supportesi and' didn't care that the fallout dumped on their fellow planetary citizens.
Thw fact that there we."e, and ara, some smal groups who vere~and are, against the. waspous and theLtesting-and the horrors of nuclear power does notbthe fact that the Stati did4t pmoteaq.
Thw States current protests, even if valid for other reasons; ring hollow against that history of nuclear collaboration Aen they use the 'no p owle reactor" excuse to keep the waste 'out.. It is-time history was set straight.
CL-20183 The NRC in thia Draft says p.' D-2 that the temporary storage or future permanent disposal of spentifusl at'a site-other than t*e.reactor site.sis not within the, scope-of this Supplement.
Why the hell not T It MUST MEOTHERWISE THIS DRAFT IS CL-20184 EVEN MORE MEANINGLESS. THE SENT FUEL IS THE MST SERIOUS ISSUE TH IS.
ANONE WHO DOME NOT UNDERSTAND THAT SPENT FUEL CANNOT BE LEFT WHERE IT IS ON SITE, IN POOLS OR TOM ISFSI'S BEYOND A VER LIMITED NUMBER OF YEARS, BUT MUST HE PLACED aE? UNDERGROUND, IN A DRY LOCATION, GEOLOGICALLY AS SOUND AS POSSIBLE, MONIOBED FOR ETERNITY, DOES NUT UNDERSTAND RADIATION OR THE NUCLEAR ISSUE AND SHOULD NOT BE WR0INO FOR THE NBC.
NRC MUST ITE THE PROVERBIAL BULLET AND SETHTM TM W
THE SPENT FUEL SHOULD ALL BE RMOVED OFFSITE AS NO LATER THAN TW YEARS AFTER THE LAST CORE OFILOAD HAS SPENT TEN YEARS IN T7E SPENT FUEL POOL,I.E.
FIRO!
SPENT FUOL REMOVED FROU THE REACTOR INTO THE SP=T FMEL POOL AND THEN THE TEN YEAR "COOL DowsU PLUS TwO YEARS, (A SAFETY MARGIN),
AFTER WHICH IT iST BE mOVED.
IF SUCH A DEADLINE IS NOT DICIDED, AND SET, COM*UNITIES ARE GOING TO BE STUCK WITH
Letter 20, page 17 Z
C 03 01 P
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C CD CD
"-I IT, WITH AWUL CONSEQUENCES.
'I The "Mobile Chernobyl" issue - thajdangerous moving of the spent fuel to a, F0SITOH!, can be somewhat alleviated by aL~dessing the concerns people CL-20/85 have instead of ignoring them, as follows s Thm Dramf shows the awful DOT and NRX regulations for transport and radiation levels allowed p. 3-14, theser should be changed to be-massively lower, this can be done by better shielbng" and more shielding and the~transport. of fewer asse-blies per cask or fewer rods per cask, and shielding that is thick enough that anti-tank weapons would not penetrate through to the fuel.. Disguising the shipments is not.
an option due to the size of the casks,. thereforaufar stricter security i.a%
military escorts and the sealing off of roads ahead of transports would be a, CL-20/86 must. Th--NWR needs to pens rules on these issues, and put.out orders for morm and better transport casks and vehicles. All shipments of"LLVL should alsau:ell under these batter packaging and shielding standards.. If ther NRG does-not address all these issues as part of decommissioning, future generations (that means IOUR children and grandchildren) are.going to die due-to NWlse' lack of CL-20/87 actions today.
It.is murderous that potential radiological impacts following, lice nsing/licanse termination that are related to kctivitea performed during-decommissioning are not in the Supplement - this allows the licensee to c.low*wy murder a ommunity as thebradiologicaL criteria for-license termination CL-20/88 by NRC was woefully inadequate anyway. The, NXC must:zontinue.to monitor-sites EDREVX after license termination in case of sudden increases in radiation l3eye.ls from a source on the site no one had either considered or knew was CL-20189 there.. All sites should have audible(sirens) alarms that are-tr*ggered during decommissioning, and after decommissioning, when monitors exceed the. EPA ievels EPA allows,, but reduced below what EPA allows to give an advance warning.
Such, audible alarm systems are absolutely vital also during the.-the time radioactive spent fuel is still on the site, these alarms should be at various, locations onsite, including next to the spent fuel pool and one, above It, and next to an ISFSI/caAk area and suspended on a wire' or pole, abovaeit. Theaealarms should be audible miles o4site via relay loudspeakers.
Letter 20, page 18 1%.
CL-20/90 Under "Dose to members of the public" p.. G-19, and following pages, the doses to the public are'liated in the usual deceptive and innacurate moanner.
CL-20/91 Thm radioactive material releases is not released in stringently controlled c-onditions, technical-specifications are often violated, monitoring is only CL-20/92 d.one at select locations and frequently monitors don't work, emissions-aren allowed to be averaged out to make them appear less, and there is no independent CL-20/93 monitoring and utilities do and say whatever they please. Tritium can't bh CL-20194 contained. The direct gamma radiation coming off the plants to the public is the equivalent of a continuousi I-ry emanating from their midst. No X-ray is "negligable-. (This sort of garbage:was probbly written by someone who ism CL-20/95 not a medical proffessional). Often the plants: DO NOT HLVE TO BEPOBT THEIR RIEASES UNTIL THOSE RELEASES REACH A CERIAIN LEV-,
IT DEPZNDS WHAT THEIR CL-20/96 LICENSE STATS.
FOR THE; Nra TO HAvW USED DATA OR SOUTHEW coMPoAN's PLANT HATCH IS SICKE2(IN -
WHE HATCH HAD THEIR DISASTRDUS SPENT FUEL POOL SPILL, DID ANYONE ADD THE EXTRA DOSES AND CONTA9INATION IN 7 THIS IS THE SAME HATCH CL-20/97 WITH OVER 1200 wom=ER CONTAMINATION EvnTS IN ONE EA,. WH YOU CALCULATED THE RADIO-ZODINES, DID YOU ADD IN THE HUGE RADIO-IODINE KILEASE OFF PLANT FAME! THAT WENT UOER GEORO1A ?
CL-20/98 Ta point'. is, that no one asked'to be exposed to AnH dose of radiation,, and' most people in surrounding communities don't even know they are being exposed, or if. they know, they think they are being prtected because they think therwe CL-20/99 isa safe level of radiation, when of course ev2n the NRC admitted back in the late '17'1 tJa there was no safe level.
CL-20/1 00 Perbhpmost disgusting is that under "'Consequence of Potential Accidants"p.Z-1 6
the impression given is that spent fuel pool accident risks are low, when in fact-NRC a own cited document showshundreds upon hundreds would die, and also many spent fuel pools were highly vulnerable to catastrophic accident-4.ile to earthquakes and a lot more besides - spent fuel pool accidents would havw terrible consequences. The-fact that licensees determined that basically 67en if the damned site was hit. by a meteor and a, nuclear bomb and a
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and a hurricane all at. the same time (obviously I am being sarcastic) nothing would hapen-and there would be "nTo dose; consequenceW is to be soeceted sae,the licensee analyses are, a bad joke.
CL-20/102 M
NRe SHOULD READ ITS OW DOCUMERTS AND THE FAMOUS "CRAC-!" REPORT DONE BY SANDIA LABS, THE NC AND THEN CONG SIONAL OVERSIGHT BECAUSE TO PRESET DATA TIM FRC4 LICER*sI B,-ASIS DOCUMENS WHICH HISTORICALLY HAVE DOWN PLAYED ANYTHING'THAT COULD HAPPD4 IS UUTRAGEOUS, AND IF THERE IS STILL FUEL IN THE REACTOR IND A LOSS UF WATER COOLANT HAPPENS, EVEN IF THE REACTOR HAS BE SHUTDOWN RECENTLY, IRE WILL BE A MELTDOWN.
CL-20/101 I chall*Inge any licensee and any NRC stafferp, to walk into thiLsrea wherethen spent fuel pool is after the water has drained from the spent fuel pooland try and refill the spent fuel pool with a garden hose (that is: what they thought they'd do at the Georgia Instittte of. Technology Rdactor) and-see,bow well
"-u they can "mitigate 5 the situation before woffsiteýdose consequences could occurs -- they'd be.dead beforeathey could pick up the hose. Tosay that such an accident could be mitigated is the height of deception.
CL-20/103 On p-M-Z it says., under the glossary, under Background Radiation, that Othe typically quoted US average individual exposure from background radiation is 36DTmrea per year!
It msy be typically quoted, but it is.a blatant LI For' example,. typical background radiation in Georgia is A2 mren year accosdiW to the State (which recently upped it a inotch probably due mu zhe radioactive fallout on the State from nuclear power plants and the Savannah River NucTeW CL-20/104 Sit*'on its borders-The. dhfinition of CONTAIATION isr also a, LIE, in that Z
it states that 'omething is contaminated if it's in excess of "acceptabla C SCL-20/105 levels".
There are~no "acceptable levels"'- the public does not accept any m
(7) level of radioactive contamiýation -plutonium, cobalt-60,Strontium-90 etc. or 01 CL-20/106 tritium,radioactive iodine and so on and on - Contamination means i that som 00 P) thingsomeone etc. has been brought into contact with sonething that defiles or Cn Spollutes it etc.. -- go look the word up -
NRC must stop redefining words and CD lying about their meaning.
cD CL-20/107 What the NRC decides to do concerning decommissioning, is what the following generations of children,vome, men, plants,animals, insects, birds, fish - all life, is going to suffer fromsand die by. A small bunch of (mainly) m*e i2n. -a office co=plax in Washington, along with a few cohorts elsewhere, plus an immoral multinational polluting industry (in the business for money only) arem seemingly se tting a set of criteria that will impact the whole world to no CL-20/108 good end end cause great misery, in this Draft.
Haver:you all no shame 7 CL-201109 Th radioactive components,parts, liquids i.e. anything pert of or to do with or emanating from the structures and the site MUST NEVER RE HE-CYCLVE, OR RE-_USED.
CL-20/110 NM MUST DIMNIATEY CEASE ALLOWING, OR THINNG OF ALOWING, RADIOACTIVELY CL-20/111 COTAmImu Son To B RE0USED FOR ANYTHING. IT MUST FORIDM TEE MTIrNG,SMLTING OR RE-USE OF RADIOACTIVELY CO07AMINATiD METALS, PIPING, PLASTICS, 4OOD, (INCLUDING CL-20/112 FORBIDDING. THE BURNING OF WOOD)
, ASPHALT, AND SO ON. IF NRC, EPA, THE DOE AND OTHRS DO NOT STOP THIS INSANE RUSH TO RENUSE,RECYCLE, DUM AND COVER ETC. NUCLEAR MATERIALS, RADIOACTIVE MATERIALS, ACTIVATED MATERIALS ETC., WITHIN FIFTY YEARS NO LIVING BEING WILL BE BORN WITHOUT SOME TYPE OF DZMRMITYGII!EIC ABNOR4ALITY, CEHRO0SOHE ABERRATION ETC.
AND THE IMUNE SYSTEMS OF EVERY LIVING BEING WILL BE SROUSLY COMPR0MSED DUE TO RADIatION SUPPRESSING THE f NE SYSTE4 RESPONSE, AND ALL BECAUSE WE WIL BE COMPLETELY ENGULFED IN A MIASKA OF MAN-MIDEIOR 'AN ENHANCED, RADIOACTIVE CONTAMINATION..
I havewritten this on and off over a series of days after finding out CL-20/113 the comment.period bad been extended. I recognize that it has probably been a waste of my timeand.wil be ignored, as usual, therefore I am not bothering to vrite it). again with every paragraph in the right-place.. In any event I speak,read and writi:three languages and the grammar and spelling in all of them suffers somewhat CL-20/114 but it is the content that mattersi The fact is, wherever this radioactively contaminated refuse winds up - from spent fuel to contaminatedL rags - it cam' t bem contained forever end will reach the environment, whibh is why it must. go to a remote location,below ground, (noneof this idiot parking lot out in Utah or Nevada cask stbrage either ) in dry-geologically sound (as far as possible in a moving planet) location where monitoring could alleviate problems that arise prior to.reaching the public and wildlife.
NRC must recognize that this solutiom a
zI c Letter 20, page 21 G) 6 (31 to
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- in the solution that has been gone back to repeatedly 3*
over the decadesafter thousands of studies contemplating what to do with CD the waste failed to Identify anything better, or safer.. What NBC and industry are: proposing in this Draft)f2.les in the face of the thousands of prior studies by some.of the worlds most ranommed people who understand the horror of the dilema and the.Ar conclusions.
Leaving all this. contamination on sites around*
the nation to contaminate and kill hundreds of communities is sinply barbaric CL-20/115 and must be stopped at all oosts.
Furthermore, no now nuclear plants should' be allowed or built as they will Just add to the exieting contamination, and all o..erating plants should be shutdoln to stop furthsmstastas - such as plutonium CL-201116 generation.
Nona, shouldh be rm-liceased - the. NRC shoul& be ashamed of reliceasibg.
Thisi Draft ls.an absolute horror - fur fuaturegenerations who will suffer-i:f CL-20/117 this goes through as proposed, I would point out that on pages C-1 asd C-2 a C0 the names of those responsible for this abomination for reference in cas of future lawotda, so the public should make a note of that (this is, after all public record, what I have written) ý Plus the Utility in question and the ever helpful nuclear pushers at the NEI, should be remembered too, for their contribution to the' nuolear nigtmetr.
CL-20/1 18 Thera is still time to correot all the serious problens in the Draft, still time for the NRC to turn from the path of wickedness and ruin the Draft t plement and Gels wil lead to if passed as is.
Remember thei Creator.
Do not allow the-further desecration of the world, the NE will also be,accounkable to God one. day for what it allows to be done toCreation. Think on that, and correct this Draft to the better.
pamela Blockey-O 'frien.
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Letter 21, page 1 From:
- Sharon Guynup" <sguy@cybemex net>
To:
<dgels@nrc.gov>
Date:
1/19/02 4"37PM
Subject:
comments on Decommissioning US Nuclear Power plants I am violently opposed to the Nuclear Regulatory Commission's proposal to further CL-21/1 relax its decommissioning requirements for nuclear power reactors. This Is nothing but a sellout to the nuclear industry-which puts citizens at rIsk-with no recourse In case of liabilites.
This Is wrong and dangerous.
Thank you for your time.
Sharon Guynup Hoboken, NJ
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Letter 23, page 1 From:
'Fred Long' <ajlongg99g earthlink net>
To:
<dgeis nrc gov>
Date:
1U20/02 8 59AM
Subject:
DECOMMISSIONING NECLEAR FACILITIES CL-23/1 Has the NRC no common sense at all?
Releasing radioactively contaminated materials Into daily consumer use and commerce and unregulated disposal Is a direct assault on humanity.
Don't let this happen.
AJ Long 20550 Earl St Torrance CA 90503 (3
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To:
<dgets@nrc gov>
Date:
1/20/02 2 03PM
Subject:
Public comment on USNRC Decommissioning US Nuclear Power Reactors To. Chief.
Rules and Directives Branch Division of Administrative Services Maltstop T 6 D 59 US Nuclear Regulatory Commission Washington DC 20555-001 CL-24/1 I am appalled at the NRC's draft of decommissioning requirements for nuclear power reactors. The requirements should be made stricter not more relaxedll 111111111 I oppose the use of "Genenc listing of CL-24/2 issues. I support "Site Specific" listing so that local communities can still raise issues they have.
CL-24/3 I support the designation of environmental justice and endangered species issues as site-specific, NOT generic.
CL-24/4 I oppose Rubblizalion but support its designation as site-specific.
CL-24/5 I Firmly oppose the 'release* of radIoactively contaminated matenals into daily consumer use and commerce and unregulated disposal.
CL-24/6 This Is common sense people. You need to start doing what Is safest and In the best interest of the people of the United States and its land, NOT what is going to relieve the nuclear power companies of their responsibility to what they have created and profited off.
Citizen of the United States of America Rachel Grftdhs 2022 West Chicago Avenue Chicago, IL 60622
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Letter 25, page 1 z
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<EdRussel@aol corn>
To:
<dgelsOnrc gov>
Date:
1/20/02 9 34PM
Subject:
Decommissioning rule changes Law Offices of Edward T. Russell 725 Long Pond Road Plymouth, MA 02360 508-224.2007 3
-1 l'3 January 20, 2002 Chief, Rules and Directives Branch DMslon of Administrative Services Mallstop T 6 D 59 US Nuclear Regulatory Commission Washington. DC 20555-0001 Re: Decommissioning Nuclear Power Reactors Environmental Impact Statement Supplement 1
Dear Sirs:
I am a resident of, and practice law In. Plymouth MA. For years I have lived at peace with the neighboring Pilgrim nuclear plant. However. Sept 11 was an awakening for me and for many others In eastern Massachusetts.
CL-2511 I strongly object to the proposed changes to the decommissioning rules. We have recently become more sensitive to the rules governing nuclear power plants, even their decommissioning Since these proposals were begun before September 11, I hope and expect that they will be dead on arrival at the Commission.
CL-25/2 The only rules changes that I want to see until spent rods are removed to Yucca Mountain are to stricter rules.
CL-2513 Utility deregulation has put the ownership of these plants In hands that are not as responsible as they once were. Plymouth MA suffers financially because of the loss of tax revenue from the Pilgrim Plant -we cannot assume the CL-25/4 additional risk these rules would place on us. Until the spent rods are removed from local nuclear power plants the decommissioning rules should be tightened, not loosened. Your proposal may have seemed reasonable earlier this year but we live In a very different world now It can no longer be business as usual at the NRC (X-25/5 Many key issues that local communities face as reactors close and owners leave (lIability-free) will be unchallengeable, because they are being listed as 'generic' issues. I support the designation of environmental justice and CL-25/6 endangered species issues as site-specific (not generic) and designation of Rubblitzation as site-specific.
CL-25/7 The proposed rules Ignore radiation dangers after decommissioning The NRC I
4,
CL-2518
,q. /Q 5/JA-6/77Li.a 2 9 Letter 25, page 2 must Incorporate offsrte contamination In all evaluations of environmental CL-25/9 Impacts. The National Environmental Policy Act was wntten for a purpose, your proposed rules side step that purpose.
CL-25/10 You must not remove license amendment requirements when changing from an operating license to a nuclear materials possession-only license. I stand CL-25/11 firmly against the 'release' of contaminated materals Into daily consumer contact and commerce or unregulated disposal.
CL-25/12 Deregulation has already had serious negative Impact on local municipalities this will be just another blow Sincerely, Edward T. Russell
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CC CD CD CD 00 From:
Dave Matthews <david matthews a sun.corm>
To:
cdgeis@nrc.gov>
Date:
1/21/02 10.52AM
Subject:
Decommissioning Nuclear Power Reactors EIS Suppl
Dear Sirs,
I am writing to comment on the EIS supplement 1.
CL-26/1 In general. I am strongly opposed to the attempts to designate many esues as geneno Instead of site specific and thus to remove these issues form public review end comment.
CL-26/2 Specifically. I am opposed to the following proposals in the EIS:
NRC allows "rubbktzaton" (crumblng the concrete reactor building) of nuclear reactors, without opportunity for public intervention until the action Is completed.
CL-26/3 NRC allows portion of lites to be "released" from regulatory control before the whole site It released.
CL-26/4 NRC opens up two "entombrment" options.
CL-26/5 NRC Ignores radiation dangers after decommissioning is done and utility is relieved of llabliy.
CL-26/6 NRC Ignores radiation exposures to children and other vulnerable members of the population and creates a fictitious highest exposed 'cntical group* based on unsubstantiated assumptions.
CL-26/
NRC Ignores radiation offsite and permits utilitles to ignore It In 7-9 decommissioning planning. I ask that the NRC incorporate offsite contamination Into all evaluations of environmental Impacts.
CL-26/10 NRC prevents the National Environmental Policy Act from applying to most of the decommissioning process.
CL-26/11 NRC redefines terms to avoid local, site specific opportunity to question, challenge and prevent unsafe decommissioning decisions.
CL-26/12 NRC sets arbitrary and unsubstantiated (low, medium and high) environmental Impact categories for each of the steps In decommissioning, to give the appearance that they have minimal effects, to justify not fully addressing them now and to prevent their inclusion In site-specific analysis.
CL-26/13 NRC is removing the requirement for a license amendment when changing from a nuclear power operating license to a nuclear materials possession-only license. (With no license amendment, there is no opportunity for public challenge or adjudicatory processes )
CL-26/14 NRC is attempting, with this supplement, to legally justify the removal of the existing opportunities for community involvement and for legal public intervention until after the bulk of the decomrmssioning has been completed. This includes such activities as flushing, cutting, hauling and possibly rubblztrig of the reactor.
cri Letter 26, page 2 NRC states that the portion of the decommissioning regulations (10 CFR 20 section E and its Environmental Impact Statement, NUREG 1496) that set the 25, 100 and 500 millirems per year allowable public dose levels from closed, decommissioned nuclear power sites, are not part of the scope of this Supplement NRC defines decommissioning, in part, to Include the 'release of property for unrestricted use...' and the "release of property under restricted conditions...'
CL-26/15 I stand firmly against the 'release" of radioactively contaminated materials into daily consumer use and commerce or unregulated disposal.
Thank you David Matthews ii
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<dgeis @nrc.gov>
1/21/02 12 52PM comment to nureg 5086
Dear NRC,
I do not support any attempt of your agency to narrow the scope of CL-27/1 site-specific issues by declaring them to be genenc.
CL-27/2 While the 9/11 events may call for some more secrecy. in most cases Its a matter of 'closing the gates long after the horses are gone*.
Instead you should adopt a policy of allowing more public participation to ensure public confidence In your processl CL-27/3 Re 9/11: 1 direct you to a quote from a recently published German report concerning the vulnerability of the Castor containers to terrorism: 'the fact that all the technical data used In the report can ve accessed by terrorists does not Imply that a more restrictive policy towards Information is required. Rather, it should be regarded as an argument against the use of a technology which is, at the time, hazardous and complex to a large degree, creating a conflict between the necessary societal discussion on the one hand and the protection of society from terrorist attacks on the other.'
Compare: www bund.netlthemen/energglepoldiklStudleCASTORTerror rtf If we eliminate the necessary public discussion the terrorists will have won[
KLaus Schumann 6LY c~
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Dennis Larson <larsondf@yahoo.com>
To:
cdgeis~nrc.gov>
Date:
1/21/02 1:36PM
Subject:
reactor decommissioning Re: decommissioning nuclear reactors CL-28/1 Issues common to the process of decommissioning nuclear reactors should be raised with every reactor being decommissioned, not excluded from every specific reactor being decommissioned.
These common issues have not been resolved.
Dennis Larson Do You Yahool?
Send FREE video emads in Yahool Maull httpi/promo.yahoo com/videomail/
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1/21102 7.32PM Decommissioning
Dear Mr. Gels:
CL-29/1 There are still radioactive dangers after decommissioning. I oppose the CL-29/2 concept of rubbltzation as it Is very dangerous: I oppose the release of CL-29/3 radioactive contaminated materials Into daily consumer or commercial uses.
That Is an idea that Is Insanely dangerous. Would you eat off a fork that contains radioactive mataerial? Why would anyone?
Sincerely, Martin Kellernman
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December 26, 2001 BYR 2001-084 CY-01-199 Letter 30, page 2 "U.
S. Nuclear Regulatory Commission BYR 200 1-084/CY-01-199 I Page 2 Sincerely, Kesneith J. elderij Vice President of U'perations & Decormmissioning Chief, Rules and Directives branch Division of Administrative Services Mailstop T 6 D 59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Haddam Neck and Yankee Rowe Plant Comments on Draft Suplptment to GElS cc.
H. J. Miller, NRC Region I Administrator J. E. Donoghue, Senior Project Manager, Haddam Neck Plant R. R. Bellamy. Chief, Decommissioning and Laboratory Branch, NRC Region I Document Control Desk, U.S. Nuclear Regulatory Commission D. C. Scailetti, U.S. Nuclear Regulatory Commission Paul H. Genoa, Nuclear Energy Institute E. L. Wilds, Jr., Director, CT DEP Monitonng and Radiation Division Yankee Atomic Electric Company (YAEC) and Connecticut Yankee Atomic Power Company (CYAPCO) appreciate the opportunity to provide comments on the draft supplement I to NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities".
In a letter dated Apnl 25, 2001 (), CYAPCO submitted a response to a Nuclear Regulatory Commission (NRC) request for additional Information to support development of the Generic Environmental Impact Statement (GElS) supplement. Many of these comments were incorporated in the draft CL-30/1 supplement In general the draft supplement meets the goal of updating the GElS to current decommissioning practices and dismantlement options. We have reviewed the draft supplement and offer specific comments contained In the attachment.
If you have any questions regarding this submittal, please contact Gerry van Noordennen at (860) 267-3938.
(i) CYAPCO letter CY-01-076 to U.S. Nuclear Regulatory Commission, "Response to NRC Request for Additional Information to Support GElS Supplement, dated Apnl 25,2001.
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CL-30/3 2.
CL-30/4
- 3.
-4 W' The Figure 1-1, "Decommissioning Timellne" should also reflect the 60 year window, mentioned In 10CFR50.82(a)(3), that starts from the permanent cessation of operation.
Revise the first part of the last sentence on page 1-5 to read:
If a licensee chose to operate the ISFSI under a Part 50 license, they could choose to continue under the Part 50 license, or by way of license amendment request..................
CL-30/7
- 6.
Revise the second to last sentence on page 3-15 to read:
The entire structure (or portions) must be removed..........
CL-3018 7.
CL-30/9 8.
Delete the discussion of 'Rubblization" on page 1-7 and delete the term
"*Rubblization" In the Glossary (Appendix M). Maine Yankee first utilized this CL-30/10 9.
term in a January 13, 2000 letter which served to submit their License Termination Plan (LTP). On June 1, 2001, Maine Yankee filed revision 1 to their LTP. On August 13, 2001, Maine Yankee filed revision 2 to their LTP. In their current LTP, Maine Yankee does not propose to use "Rubblizatlon" and no longer utilizes the term. No licensee is currently pursuing the "Rubblization" CL-30/11 10.
concept as described in Maine Yankee's original LTP submittal.
The term which most accuratel describes the 'approach which licensees are currently pursuing is 'concrete backfilr. Connecticut Yankee described the process as follows in section 4.3.1 of our LTP submitted on July 7, 2000:
Concrete from contaminated structures will be romediated to a level meeting the radiological criteria for unrestricted release of the site. After completion of final status surveys and absent any findings during NRC inspections, concrete building debris from decontaminated structures may be used as backfill and placed Into the remaining subsurface building "foundations.'
CL-30/5
- 4.
Under the description of the Turbine building (on page 3-6) revise the last two sentences to read:
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PWRs. However, it is not unusual for the turbine building to become lG) mildly contaminated during power generation at PWRs.
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- 5.
Add the following sentence to the first paragraph in section 3.1.4:
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activation of corrosion products and not fuel.
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The sentence should be revised to read:
If corrosion products are Included, the radioactive decay...........
The last two p.ragraphs on page 3-15 need to be rewritten. The discussion of contamination and activation needs to be clarified. If requested, CYAPCO will work with the Commission to rewrite this text.
Yankee Rowe should be added to the list of plants mentioned In the second to last paragraph of page 3-26. The Yankee Nuclear Power Station was one of the plants In the AEC's Demonstration's Program. Yankee Rowe's license number is DPR-3.
The second to last paragraph on page 3-32 discusses the creation of nuclear Islands. Nuclear Islands are not primarily created because of security reasons.
The real benefit In creating nuclear islands is to not Interfere with spent fuel storage. The purpose for creating a nuclear island is to provide a facility for the safe long-term storage of spent fuel, which Is Independent of the remainder or the rest of the facility. The purpose of the modifications Is to divorce the spent fuel cooling function from dependence on systems which must be dismantled as part of the overall decommissioning process.
Expand the discussion about Stage 4 of the decommissioning process. This discussion should contain as much description as the descriptions under stages 1 through 3.
CL-30/13 12.
Delete *groundwater" from the first sentence in section 4.3.3.4. Releases are not made to groundwater under NPDES permits. NPDES discharge points discharge to surface water locations.
"U.
S. Nuclear Regulatory Commission BYR 2001-084/CY-01-199 / Attachment I Page 1 YAEC & CYAPCO Comments on the draft supplement to the GEIS
Letter 31, page 1 Letter 31, page 2 Exelbn.
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December 28, 2001 Secretary U.S. Nuclear Regulatory Commission Attn: Rulemakings and Adjudications Staff Washington, DC 20555-0001 Nucle*
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Subject:
Comments Concerning Draft Supplement I to NUREG-0586, *Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilites" (66FR5671f2, dated November 9, 2001)
Dear Sir or Madam:
This letter Is being submitted In response to the NRC's request for comments concerning Draft Supplement I to NUREG-0586, 'Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" which was published In the Federal Register (i.e.,
66FR5672', dated November 9,2001). The NRC Is proposing that this Supplement updates information In the existing 1988 GElS relating to pressurized water reactors, boiling water reactors, and multiple reactor stations. Additionally, this Supplement goes beyond the 1988 GElS by considering high-temperature gas-cooled reactors and fast breeder reactors. The NRC's intent is that this Supplement be used to consider, in a comprehensive and generic manner to the extent practicable, the environmental impacts of radiological decommissioning of nuclear reactor facihties by incorporating updated information, regulations, and analyses.
Exelon Generation Company, LLC (Exelon) appreciates the opportunity to comment. Generic and specific comments follow in Attachments 1 and 2, respectively. If you have any questions, please do not hesitate to contact us.
Very truly yours, Michael P. Gallagher Director, Licensing and Regulatory Affairs Mid-Atlantic Regional Operating Group Attachments TI ATTACHMENT 1 Generic Comments on NUREG-0586 Draft Supplement I CL-3111
- 1. Exelon believes the proposed Draft Supplement correctly concludes that most of the environmental issues assessed result in impacts that are generic and SMALL for all plants.
We reach this conclusion based upon our experience decommissioning one BWR (Dresden 1), two PWR's (Zion Station), one HTGR (Peach Bottom 1), and our observation of other industry decommissioning projects We have not seen to date - and currently do not expect to find - environmental impacts different from those addressed and bounded by this Supplement to the GElS.
CL-31/2 2. Exelon continues to maintain that providing guidance, which addresses environmental issues generically, provides the highest standard the public at large can use effectively to challenge industry to return power plant sites to beneficial use upon facility retirement CL-3113
- 3. The Supplement properly addresses the ENTOMB decommissioning option Issues related to the ENTOMB option after the facility has terminated Its NRC license and entered the entombment period are outside the scope of this GELS. Power reactor entombment is not construction of a LLW disposal facility - it is properly classified as a decommissioning scenario, which creates an assured storage facility for radioactive material to decay in place, until it no longer represents a hazard considering future public use of the site. The clear distinction between entombment as a decommissioning scenario and a LLW disposal facility may be found in the ability to reuse the site in the future for other purposes.
Regulation goveming LLW disposal facilities does not contemplate future use of the site, restricted or unrestricted. Future use of an entombed site will be dictated by the dose based performance cntena found in 10 CFR Part 20, Subpart E.
CL-31/4 4. The Supplement improperly addresses rubblization by stating it will require a site-specific analysis at the time the license termination plan is submitted Rubblization should be addressed generically as a part of the decommissioning process. The NRC should continue to maintain that to the extent that 10 CFR Part 20, Subpart E dose performance criteria are met - and that decommissioning has been performed using the ALARA principal, rubblization has a SMALL environmental impact.
CL-3115
- 5. The Supplement incorrectly addresses the impact on the SAFSTOR scenario due to the time gap between cessation of operations and decommissioning activities. The Supplement expects the time gap will result in a shortage of personnel familiar with the facility when decommissioning activities commence. Our own experiences have shown us that both DECON and SAFSTOR decommissioning scenarios can be conducted in a safe and efficient manner. Regarding the familiarity of the facility at the end of licensed life, whether the plant begins decommissioning immediately or waits for some defined period - the most difficult aspect is retrieving records from the earliest days of operation. Recently retired facilities have taken the appropriate step of preparing a site historical assessment documenting the operating years of the facility. This historical assessment will guide the decommissioning process whether it begins immediately upon retirement or 50 years later.
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Exclon Nuclear 200 Exelon Way Kermeti Square. PA 19348
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- 1. On Pg 3-17 there Isa discussion of the advantages of the DECON alternative for decommissioning. One advantage of DECON Is not discussed and should be Generally speaking the shorted lived nuclides are easier to detect because of their beta/gamma emissions, versus the alpha emissions of longer lived nuclides. The difficulty of detecting the alpha emitters will increase analysis costs and increase the difficulty of performing surveys. Ultimately the cost of providing RP coverage and of performing the Site Characterization and Final Status Survey will also be increased.
CL-3117 2. On Pg 3-19 the discussion of the SAFESTOR option assumes that there Is a savings associated with less Solid RW disposal costs. However they do not consider that the current NRC guidance for release of material includes a no detectable cnteria.
In order for the reduction of Solid RW to be achieved, significant quantities of plant matenals would need to be released from the site. The current regulations do not support this assumption.
CL-3118 3 On Pg 4-9 the NUREG concludes (Sec 4 3 2.4) that the environmental impact of water usage will be small. In the evaluation they consider the anticipated reduction in water usage for cooling in the condenser. This conclusion appears reasonable, however the analysis should also consider the environmental effects of the loss of heat provided by cooling water discharged to a closed lake or pond system that is a habitat for aquatic animals and vegetation. Many nuclear facilities are on natural or man-made bodies of water making this environmental effect generic in nature.
CL-31/9 4 On Pg 4-16 the NUREG concludes (Sec 4.3 4 4) the environmental impact of air emissions will be small In the evaluation they did not consider that many sites use extraction steam to provide plant heat In the winter months The shutdown of the reactor means that Aux Boilers will be operated for longer periods to provide heating steam. This needs to be considered in the NUREG or many facilities will need to address this issue in their PSDAR CL-31/10 5 On Pg 4 -29 the NUREG (section 4.3 8.3) concludes that it is not necessary to update estimates for collective dose due to decommissioning activities. This is an Important conclusion that Is supported by the current range in collective dose that decommissioning plants have experienced. Any change to this conclusion needs to be well supported by actual data and needs to be thoroughly studied to identify all potential impacts.
CL-31/11 6 Table 4-1 on page 4-30 Is misleading The totals given include 100 rem of transportation dose that Is not tracked by the facility undergoing decommissioning. It also does not include dose Incurred during construction of a Spent Fuel Pool Island or in support of a dry cask storage campaign. A footnote should be added explaining these differences CL-31/12 7. Table 4-3 lists the decommissioning cost of Peach Bottom Unit I to be 54 million dollars (in January 2001 dollars) In our letter submitted on March 30, 2001, in accordance with Letter 31, page 4 10CFR50.75 the decommissioning cost estimate for Peach Bottom Unit 1 reported in beginning of year 2001 dollars is 65 4 million dollars Table 4-3 should be changed to reflect the latest cost estimate.
L-31113 8. Table 4-4 lists the decommissioning cost of the high-temperature gas-cooled reactor in SAFSTOR (Peach Bottom Unit 1) to be 54 million dollars (in January 2001 dollars). In our letter submitted on March 30,2001, in accordance with 10CFR50.75 the decommissioning cost estimate for Peach Bottom, Unit 1 reported In beginning of year 2001 dollars Is 65 4 million dollars. Table 4-4 should be changed to reflect the latest cost estimate,
- L-31/14 9. Table F-I lists the total site area for Peach Bottom Unit I to be 620 acres. 620 acres Is the total site area reported in the Peach Bottom Unit 2 and 3 Updated Final Safety Analysis Report However, Table F-2 reports the total site area for Peach Bottom Units 2 and 3 to be 618 acres. Table F-2 should be changed to reflect the total site area for Peach Bottom Units 2 and 3 to be 620 acres.
'L-31/15 10 Table 1-3 incorrectly lists site flooding as the only accident analyzed for Peach Bottom Unit 1 in the documents referenced in Appendix I for Peach Bottom Unit 1.
The additional accidents analyzed for Peach Bottom Unit 1 that should be added to Table 1-3 are:
"* Release of helium coolant under containment breach (open penetration to containment) for accidents involving radioactive materials (non-fuel-related) on page 1-9
"* Fire inside reactor vessel under fire for accidents involving radioactive materials (non-fuel -related) on page 1-10.
L-31/16 11. On page 1-6 of Appendix L, line 4 refers to cnticality accident monitoring requirements descnbed In 10CFR7.24 Cnticality accident monitoring requirements are descnbed in 10CFR70 24. This typographical error should be corrected.
- L-31/17 12. On page 1-6 of Appendix L, line 17 refers to 10CFR50 73 as requiring a licensee event report within 30 days 10CFR5O 73 was recently revised to require a licensee event report within 60 days This change should be made to Appendix L,
'L-31/18 13 While the Supplement addresses two entombment options stating they have prepared as extreme cases to envelop a wide range of potential options, there should be additional language early In Section 3 2.3 ENTOMB clarifying that utilities are likely to develop entombment scenarios based upon their site specific needs.
C-31/19 14. All spent fuel at Dresden Unit I will be moved to dry storage on site by the end of the first quarter of 2002. This change needs to be reflected in Table 3-2.
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Letter 32, page 1 ii/'/ oi 00 From:
<GEORGNBAY@aol.com>
91 To:
<dgeis@nrc.gov>
cf Date:
1/24102 9.17AM
Subject:
relaxing standards CD
Dear Sir/Madame,
B CL-32/1 I urge you to stop any further relaxing of nuclear power reactor decommissioning requirements. Enough Is enough. The suggestions you are "making toward relaxing further standards will create massive public health CL-32/2 and economic problems. Just one example is letting the concrete reactors CL-32/3 erode naturally which is extremely unsafe. And to Ignore radation concerns to the unsuspecting public health is criminal.
It is out rageous to allow the reactors to be hability-free. That is hke saying to the consumer" Your money AND your life". We have paid and paid for nuclear power and we all know it is the biggest welfare mother of all time.
Yours in concern Susan Clark
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-5 Letter 33, page 1 rMoioa..Weakening Requirements for Decomrrssis Iong US Nuclear PowerReactors From:
To:
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Subject:
From*
Margaret Nagel 631 Hneman Ave Evanston, IL 602 To, Margaret Nagel <dormargaretnoearthllnk not>
<dgelsOnrc.gov>
1124/021 S1PM Weakening Requirements for Decommissioning US Nuclear PowerReactors 22-2514 Chief. Rules and Directives BranchlDivislon of Administrative Services Msilstop T 6 D 59 US Nuclear Regulatory Commission Washington, DC 20555-0001 January 24, 2002 CL-33/1 In setting requirements for decommissioning US nuclear power reactors, please bear In mind other things besides the needs of Richard (Enron)
Cheney, Halliburton Inc., Brown & Root, and other powers that be. Long after these miserable 'powers' have crumbled away, your children and grandchidren CL-33/2 and mine, and thei descendants. will have to live In this world. The nuclear power Industry was a colossal mistake to begin with. as we all know.
CL-33/3 Most of us also reaize that the Immune systems of every Itng thing on this planet - human systems Included - are becoming Intolerably stressed by mounting (and syriergisticaly Interacting) levels of pollution of all CL-33/4 sots. To add to these levels by deliberately Ignoring the dangers of radiation exposure is wantonly criminal. Those who do so will go down In history as villains of the worst sort: smug, obtuse, shrlvel-hearted.
decelvirg, opportunistic, self-serving, cowardly, corrupt people who really CL-3315 ought to know better, I fall to see any moral dcrileroeic between terrorists who fly planes Into buildings, and bursacrats who are perfectly witting to CL-33/6 expose whole populations to additional dangers from radiation. In the name of humanity and morality, you should all leave your jobs now In righteous protest at what you're being asked to do. Walk out. Say goodbye. Go work at Wet-Mart If you have to But don't recklessly endanger the health of this nation by acquiescing In these evil plans I utterly oppose, CL-33/7 I "rbbllzation" with no opportunities for meaningful public Intervention ahead of time CL-3318 2 allowing portions of sites to be released from regulatory control before the whole site Is released.
CL-33/9 3 ignoring readiation dangers after decommissioning is done and ullty i relieved of liability. L CL-33/10 4 Ignoring radiation exposures to children and other vuklnerable members of the population and creating a fictitious highest exposed 'critical group' based on unsubstantiated assumptions.
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CL-33/11 S. Ignoring offslte radiation and permitting utilities to ignore it in CL-33/12 decommission planning NRC should Incorporate offsle contamination Into all evaluations of environmental Impacts I also utterly oppose:
CL-33/13 1. Preventing the National Environmental Policy Act from applyng to most of the decommissioning process.
CL-33/14 2. Making moat aspects of decommissioning genencr rather than srte-speciftc, so they cannot be legally reviewed or challenged at Individual sites CL-33/15 3. Redefining terms to avoid local, Site-specifIc opportunity to question, challenge, and prevent unsafe decommissioning decisions.
CL-33/16 4 salting low, medium, and high' environmental Impact categories for each of the steps In decommissioning, to give the appearance that some things have negligible effects that don't warrant further conslderation.
CL-33/17 S. removing the requirement for a license amendment when changing from a nuclear power operating ricense to a nuclear materials possession-only license, thereby eliminating the opportunity for public challenge or adjudicatory processes.
CL-33/18 6. attempting to legally justify the removal of the existing opportunities for community Involvement and for legal public intervention until activities such as flushing, cutting, hauling ard possibly rubbzizng of the reactor are complete - in other words, until the damage has Irretrievably been done.
CL-3311 9 7. statling that t0 CFR 20 section E and Its Environmental Impact Statement.
NUREG 1496, are not par of the scope of this Supplement.
CL-33/20 8 defining decommissioning, In part, to Include the 'release of property for unrestricted use' and the *release of property under restricted conditions'.. in other words, releasing radioactively contaminated materials into daily consumer use and commerce and unregulated disposal How can you contemplate such a thing' t 1111lllflll Sincerely, Margaret Nagel CC:
Margaret Nagel <formargeretniearthlink.net>, 'Richard J Durbin*
.dick @durbin senate gov>. 'Peter G Fitzgerald'
ýsenatorjf'tzgeraldtlfitzgerald senate govy Letter 33, page 2 Dods Mendiola-Weakenmng Reluirements for Decommssioning US Nuclear PowerReactors page 2
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Letter 34, page 1 z
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'Liane Casten' <lcasten@interacceas.com>
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<dgeis@ nrc.gov>
Date:
1/24102 3.40PM
Subject:
NUCLEAR POWER PLANTS To even think that decommissioning nuclear power plants' regulations via presidential fiat is acceptable is beyond logic and reason.
You are Insunng the further deterioration of health for innocent cwlians and this planet.
Bush is stripping us all of those safeguards we all need to protect citizens-and this Includes you. He has only corporate Interests-the nuclear power industry being one. To enforce no riabilty after they leave is simply criminal. You do not need to further endanger our Ives while the polluters go scott free..
Enough.
kane Casten
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(*b DEods Mendiola - Public Comment'.Shame on you!
35, page 1 I-dye I From:
<little lamb@att net>
To:,
<dgels nrc.gov>
Date:
1/25/02 I 0OPM
Subject:
Public Comment=Shame on you!
Public Comment re: the U.S. Nuclear Regulatory Commission's (NRC) draft Decommissioning Nuclear Power Reactors Enironmental Impact Statement Supplement 1.
Dear Nuclear Regulatory Commission,
CL-35/1 Please increase, rather than decrease, public participation in every single aspect of the planning, building, and running of Nuclear Power Plants. Please do this even if you don't want to.
The public, to you, may seem like a thorn in your side, something that gets in the way of your plans. But a democratic government should not seek to shut their people out of decisions that effect their lives. It is a very sad reflection on the state of our democracy that this seems to be precisely the aim of your draft regulations. -Don't you believe In democracy? Are you tired of playing by democratic rules if it means you can't win each and every time? Is democracy too
'inconvenient for you?
If you were busy doing the "right thing' you would be excited and proud to open your process to the public. If you were Involved In an honest process, you would be eager to engage your opponents In debate about it. You would not have to stack the deck, hide your process.
shut the people out. Shame on youl See df you have the courage to do the right thingl -- And have the courtesy not to send one of those dummy automatic repliesl Mary Kim 116 Pinehurst Avenue #C3 New York City 10033 212.923.7800 x 1303 175--~/2 11/9/q /1 L.
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From:
Donald Miller <d.w miller@csuohio.edu>
To:
<dges@nrc gov>
Date:
1/25/02 5.56PM
Subject:
NRCas supplement to NUREG-0586, re decommissioning I have some questions.
CL-36/1 Why, In this same democracy that we hold up so proudly to the world, does the NRC seek to prevent public comment on the basic issue of public health m a nuclear world?
CL-36/2 If the NRC Is confident-as h supplementary changes to NUREG-O58S suggest-that onsite and offalte radioactive contamination during decommisslonlng and afterward will be manimaaL why does It seek to remove all liability from the owner even before the process Is complete? (if the NRC Is wrong, who will pay?)
CL-36/3 I is my understanding that the purpose, and certainly the effect, of the proposed supplement to NUREG-0588 is to reclassify many decommissloning issues as "generinc in order to avoid a community's right of challenge and to allow owners to depart without liability, I understand that the NRC supplement seriously limits a commuraty's abdity to challenge even those issues that are considered site-specific.
The designaton of environmental Justice Issues and endangered species issues must remain viable SITE-SPECIFIC matters for public debate and legal challenge, as must the hazardous technology (I think of the continuing, poisonous twin-towers fallout) of rubblization.
CL-36/4 The NRC must retain regulatory control Of the entire ote. The NRC must require a LICENSE AMENDMENT when an owner is granted a change from an operating license to a matensla-possession-only license.
CL-36/5 The owner must remain fully liable.
CL-36/6 The NRC must address the subject of radiation dangers after decommissioning HONESTLY, USING THE BEST INDEPENDENT RESEARCH, including
-exposure of children
-exposure of the weak. he 111, the elderly
-offslte contamination
-credible, not arbitrary, environmental Impact categories FOR EACH STEP OF A DECOMMISSIONING.
CL-36/7 The NRC must NOT permit 'release of property for unrestricted use" or under "restricted conditions' To permit the release of radioactively contaminated materials Into daily consumer use and commerce, or to allow unregulated disposal of such materials is abhorrent. Bin Laden might approve of such an interesting expenment; I trust that the NRC does not and will not.
CL-36/8 The NRC must resistthe pressureofthenuclear Industry If their profits are waning, they have had their turn. The citizens of the U.S. who pay everyone's way, have a nght to expect a healthy environment, and a right to fight for it wiitin the U S. legal system. (But what a shame that a fight is eiver needed)
Sincerely yours, Letter 36, page 2 S...Pane 1i l Doria Mend iota-NRC's supl:lemsrnt to NUREG-O5.8, re d eco.mmisso=ning Pa
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Letter 37, page 1 z
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'James Nordlund <reality@pld corn, To:
<dgels@nrc gow.
Date:
1W26SW2 7"32PM
Subject:
Comments on the N R C draft, please add them :)
CL-37/1 Hellof As NIRS. I stand firmly against the 'release* of radloactivey contaminated materiael Into daily consumer use and commerce or unregulated disposal.
I I hope youl give these matters the serious attention they wamrnt.
Viva Is evolution, viva green party' reality Thanx for your aftention.
lime. and efforts!
Matutinaily Yours, Name - fames m nordlund Preferred E-Mail Address = reelilyapid corn Additional E-Mail Address - jamesmnordurndl@yspoo.com Web Site URL - www everythingforeveryone org Home Address; - p o.b. gB2. lakin, KS 67860-0982 Work Address - s a.
Send Correspondence - Homne Home Telephone Work Telephone *20"-44.3835 Fax - 209-844-3835 Work Sector - nonprofit, human services Professional Field = pscholow Professional Field (others) = evolution Specialization - mental health counseling cZLe,-ýebs A-qoq-Os; j uions menoow-fm-nrnerrl on ue ro. arab, prao* auu
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Letter 38, page 1 z
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To:
Date:
FIoger Voelker -regorOacblackmedia com>
<dgeis O nrc gov>
1t27VX2 8 01PM
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Washington, DC 20555-0001 To Whom it May Concern:
The following constitutes my comments on NUREGIV0586 Draft Supplement 1 Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities-Draft Supplement Dealing with Decommissioning of Nuclear Power Reactors:
Several years ago I attended a meeting between representatives of several Investor-owned electric utiity companies that were attempting to work out a common position on utility deregulation for the state of Indiana.
At one point in the discussion a representatim of American Electric Power. owner of the D.C Cook Nuclear Plant, made a most revealing statement. Concerned that nuclear power could not compete with other forme of electric generation, the AEP representative pointed out that, following decommissioning.
they could not just come In with a wreckig bae, knock the plant down and haul the rubble off to the nearest landfi Instead. he esld, the closed plant would have to be indefinitely isolated from the ernvironmenf. His exact words (delivered with great emphasis) were,§that means fenIes, guards and guard dogs FOREVERIIO CL-38/1 Now. with Supplement I to NUREGjV0586, the NRC would appear to be paving the way for the very rubblization and possible release into the environment of i§ishghtly contaminatediO material that the AEP rep said could not happen.
The vehicle to allow this would appear to be the declaration of more decommissioning issues l§Genenclo rather than I§Site-Speclic, IO thus preempting the dght of local residents to raise concerns during the iUcense Termination Plan review.
CL-38/2 Some of my concerns about NUREGIV0586 Include.
.h the use of generic proceedings to eliminate site-specdic evaluation of concerns; CL-38/3
- h the generic approval of rubblizatlon of reactor buildings and leaving them on site, CL-38/4 h the vague and arbitrary use of i§&Small, Moderate, and Largelc significance levela and the intent for use of these designations, which echoes previous attempted bogus designations such as ibelow regulatory concernmI; CL-38/5
.h the extant to which radioactive contamination levels that are permitted to be I§releasedio from regulatory control for decommissioning would result in the release of radioactive materals routinely, CL-38/6 The draft GElS says that I§low-lavsiiO radioactive waste disposal is not part of the scope of this GElS.
However. this would appear to be contradicted by the definition of decommissioning (pg. All), and by the scope, the release and removal of Stes, Systems and Componets (SSCs).
CL-38/7 I specifically oppose any release of contaminated materials during decommissior*
g or other times/
procedures.
Letter 38, page2 ia. Mail Pa 2
Roger Voelker 5849 E North SL, Tucson, AZ 85712 Sign up for FREE email from SCBLACKMEDIA.com at httpJ/www.scblackmedia.com Dria-z 0
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-U CA) atter 39, page 1 From:
"Anne and Tom Moore' <c3mooremhotmail comr>
To:
<dgeis@nrc gov>
Date:
1/202 7:41AM
Subject:
NUREG-0586 Chief, Rules and Directives Branch, CL-39/1 I find the proposals In Supplement 1 to the Generic Environmental Impact Statement on Decommissioning unrealistic when It comes to the health of U.S.
citizens at the time of decommissioning and to those lrving years later.
CL-39/2 To catergonza as 'generic" the release' from regulatory control portions of sites before they are completely decommissioned is not CL-39/3 responsible. No radiosctivily cotamlnated parts should be allowed into consumer use, commerce, or unregulated disposal CL-3914 To allow utilities to have no liability after decommissioning Is done when the proposals are seen as 'generic' does not provide any protection to local citizens. Accountllbllty for our actions Is Important and utility companies should not be exempt from that.
CL-39/5
- There should be a requirement for a license amendment when a utility changes from being a nuclear power operating license to a nuclear materials possession-only license.
CL-3916 I know that lam not alone In asking you to protect our citizens from radioactivity on such a large scale and hope that you will live up to your responsibility by not lessening the requiremets that utirity companies face when decommissioning takes place.
Sincerely, Anne H. T. Moore Join the world's largest e-mail service with MSN Hotmail.
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Dons Mendjola-Decommisssinong Nuclear Power Reactors EIS Supplement 1
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1/2802 1:11PM; i
Sub jecft Decommissioning Nuclear Power Reactors EIS Supplement 1 VIA EMAIL & Mall
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j1 From: Conservation Counci of North Carolina, Post Office Box 12671, Raleigh, North Carolina 27605; telephone: 919-839-0006 To: Chief, Rules Directives Branch; Division of Administrative Services,Mailstop T 6 D 59; U.S. Nuclear Regulatory Commission; Washington D.C. 205550001 Re: Draft Decommissioning Nuclear Power Reactors EIS Supplement 1 (Supplement to NUREG-0586)
Dear Sir.
The Conservation Council of North Carolina Is a statewide environmental organIzabon with a long history of involvement in nuclear plant lcensing. waste storage and decommissioning. We offer the following comments on the NRC's Draft Decommissioning Nuclear Power Reactors EIS Supplement 1:
-i CL-40/1
- 1. We are deeply concerned about the NRC's proposal to treat almost all decommissioning issues in a generic EIS rather than In an individual EIS for each plant. As we have seen in many of the licensing proceedings, nuclear plants have a wide variety of dissimilarities, even with other plants owned by the same utility and constructed by the same companies. These differences are compounded when it comes to decommissioning as the different work plans for each plant may have considerably different impacts on workers on-site and the public off-site.
CL-40/2
- 2. All decommissioning activities need to consider the Impacts of radiation exposure to workers and the public. Radiation exposures to children and other vulnerable members of the population should be separately and realistically addressed with all pathways to exposure closely examined. Assumptions about off-site exposure should be substantiated with full peer-review from neutral parties, I.e. not employees of the nuclear utilities. The risk to publio health cannot be minmitzed or discounted.
CL-40/3
- 3. Decommissioning should never be deemed to be complete until the entire site Is no longer radioactive.
We understand that this means extremely long-term oversight of the reactor sites. Some of the decommissioning wastes, such as the nickel compounds, have extremely long half-lives and remain dangerous for millennia. Uabdity for the site needs to remain with the utilies and the NRC must retain regulatory control over the entire sIte.
CL-4014
- 4. As we have previously commented In other dockets, there should be no release of radioactively contaminated material of any kind into consumer use or into general commerce. Disposal of all materials from decommissioning need to be regulated, regardless of whether they are radioactive or not.
Please notify me of any decision you make regarding this docket.
Sincerely, John D. Runkle General Counsel CD K311>1 8
Letter 41, page 1 Letter 41, page 2 z
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rage 'i Doris Mendloia-s66ble deregulation Page 2 From:
Benjamin Schlau mbetitothecat yahoo cornm To:
<dgeisOnrcgov.
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1/29/02 2 58PM
Subject:
subtle deregutlaon Chief, Rules and Directives BranchlDivision of Administrative Servces Mallstop T a D 59 US Nuclear Regulatory Comnission Wasthngton. DC 20555-0001 CL-4 I/
it has come to my attention that the Nuclear Regulatory Commission Is possibly compremising the securnty of our nations future by making way for further build up of nuclear waste that will theoretlcly be safe In so many thousands of years CL-41/2 I am opposed to any extensions on operating licenses for nuclear facllities of airy sort and wish for a move to cleaner renewable energy.
Thank you.
U S. Voter Benjamin Schlau 1163 Lazy Lm. CL Mt. Pleasant, SC 29464 The Nuclear Regulatory Commission has already relaxed and Is further relaxing Its decommissioning requirements for nuclear power reactors*
NRC Is Justifying these regulatory changes by "supplementing* the 1988 Generic Environmental Impact Statement on Dcormlassionig Nuclear Facilities (NUREG-0586) with new, "updated" Information on nuclear power reactor deconmissioning It NRC succeeds, many key issues that local communities face as reactors close and owners leave (haibffity-free) wit be unchallengeabte, because they are being listed as generlc Issues. OGeneric decommissioning issues are ones that NRC determines apply to numerous reactors and which are supposedly being resolved with this Supplement to the Generic Environmental Impact Statement. "Site specrfc" issues are ones that can still be raised in local communities, but the opportunities to address even site-specific issues Is being curtailed dramatically. MRS supports the designation
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NiRS opposes Rubblizaeion but supports Its designation as ode-specific Do You Yahool?
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<dgelsenrc goYv 1129102 4.3PM comment (NRC) draft Decommnilssiong Nuclear Power Reactors EIS CL-42/1 One of the important ard obvious things to be said about decommissioning nuclear power plants is that it is expensive. potentally dangerous and nearly unprecedented. We appreciate that entombment is now being considered.
CL-42/2 It ought to be equaly obvius that 1.Saice a satisfactory waste Isolation solution evades US (we do not agree with Secretary Abraham that Yucca Mountain Is l
suitable repository based on science - the DOE itself admits that the sde is not geologically suitable and the GAO reises serious questions about the selection process).
CL-42/3 2.That a serious accident or terrorist act in this industry could be catastrophic. leaving immense fatalibe. injuries, future cancer victims and vast areas uruhebitble for years CL-42/4 3 That without public ubsIdy (via Price-Arnderson) nuclear power Is economicaly untenable C L-42/5 4.Given these factors the complete phase-out of nuclear power should be a high prionty Alternative power sources such as wind, solar. hydrogen fuel cat [and conservation) should be vigorously pursued in its stead Tom Ferguson Cyndla Hunnicunt Kalo Hunnlcutt-Ferguson 372 Oakdand eve so Atlanta, GA 30312 From:
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From:
'MaryS Reed' <maryreed localnet com>
To:
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Date:
1I29/02 5 44PM
Subject:
NUREF-0586 Comments Chief, Rules and Directives Brrch/ Division of Administrative Servicead Maf stop T 6 D 59 US Nuclear Regulatory Commission Washington, DC 20555-CO01 CL-4311 I am opposed to the foflowing changes to NUREF-0588 In Supplement 1 to the Generic Environmental Impact Statement on Decommmsloning.
NRC aliows "rubbtzation' (crumbling the concrete reactor bui*lIng) of nuclear reactors, without opportunity for public Intervention until the action Is completed CL-4312 NRC allows portions of sites to be "releasead from regulatory control before the whole site it released CL-43/3 NRC opens up two 'ent"mbment' options CL-43/4 NRC Ignores radiation dangers after decommissioning is done and utility is relieved of liablity.
NRFC Ignores radiation exposures to children and other vulnerable members CL-4315 of the population and creates a flctitious highest exposed "critical group" based on unsubstantiated assumptions..
NRC Ignores radiation offsite and permits utilties to ignore it In CL-43/6 decommissioning planning NIRS calls on the NRC to incorporate oftiite contamination Into alt evaluations of environmental Impacts.
NRC prevents the National Environmental Policy Act from appling to most CL-43/7 of the decommissioning process (The claim appears to be that this proposed Supplement 1 satisfies the Environmental Policy Act for most of the decommissioning issues)
NRC makes most aspects of decommissioning *generic" rather than CL-43/8 sihsspecrifc, so they cannot be legally reviewed or challenged at Individual sites.
CL-43/9 NRC redefines terms to avoid local, site specific opportunity to question, chaltenge and prevent unsafe decommissioning decisions CL-43/10 NRC sets arbitrary and unsubstantiated (low. medium and high) environmental Impact categories for each of the steps In decommissioning, to give the appearance that they have minimal effects.
to justify not fully addressing them now and to prevent their Inclusion In ste specific analysis.
CL-43/11 NRC is removing the requirement for a license amendment when changing
- from a nuclear power operating Scense to a nuclear materisas possession-only license. (With no license amendment, there Is no i/9/A/'
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CL-43/12 NRC Is attempting, with this supplement, to legally justify the removal of the existing opporttinties for community Involvement and for legal public Intervention until after the bulk of the decommissioning has been completed. This includes such activities as flushing, cutting, hauling and possibly rubblizing of the reactor.
CL-43/13 NRC stales that the portion of the decommtssloning regulations (10 CFR 20 section E and Its Environmental Impact Statement. NUREG 1496) that set the 25, 100 and 500 millirems per year aliowable public dose levels from closed, decommissioned nuclear power sites, are not pert of the scope of this Supplement CL-43/14 NRC defines decommissioning, In part, to Include the 'release of property for unrestricted use.- and the 'release of property under restricted conditions.'
CL-43/15 If the changes pass, many key issues that local communities face as reactors close and owners leave (Iabtily-free) will be unchaliengeable, because they are being listed as
'generic*
Issues. "Generic' decommissioning Issues are ones that NRC determines apply to numerous reactors and which are supposedly being resolved with this Supplement to the Generic Environmental Impact Statement *Site specific! Issues are ones that can stiff be raised In local commitnlies, but the opportunitles to address even aite-pecifio Issues Is being curtailed dramatically I support the designation of environmiental justice and endangered species Issues as site-specIfIc (not generic)
I oppose Rubbrlzatlon but supports Its designation as elte-specfic.
CL-43/16 Pleise consider my opposition to many of the proposed Supplements. The public should not be further shut out of the decommissioning process., Nuclear waste Is deadly and It's handling should not be downgraded In any way.
Slncerely, Mary 8. Reed 29 Sunnyside Road Scotia, NY 12302 CC:
'Senator Charles Schumer' <senatorD Schumer senate go=, "Senator Hillary Clinton'
<senator @clrmton senate go,>, 'Rep Mike McNuty" inlike mcnuity@mail house gov>
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1/29102 7.04PM Comments-NRC Rules on Decommissironng - EIS Supplement I Jan. 30 2M2 11i-1Pri P1 platncia Borchmann 176 Walker Way Vista, Ca 92083 (760) 941-9625 I am forwardng Attachment (word document) letter to NRC. wrth my personal comments on proposed NRC Rules on Decommrnsaornmi.
Please confirm their receipt and acceptance by emaI, Thank you in advance Patrma Borchmann
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Divislon of Administrative Services I MILstop T 6 D U.S. Nuclea Regulatory Commission WashIngton DC 20555-0001 CS WJ Email to: d&CIS@um=
Ill: US, Nuclear Regulatory Coemlissoa's Draft Deeommissioning Nuclear Power Reactors LI.& Supplemeat 1 CL-44/1 I ant very stroagly opposed to the regulatory changes sought by NRC to further relax decommissioning requhicrcist for nuclear power reactors. as proposed by the 1998 "Omeric" HI.S. on Decommussiomng Nuclear Facilities (NURE(-0586). with new "update" information on nuclear power reactor decommrssioning. The Proposed regulatory changes sought by N.R.C. ore an insult to the public Interest CL-44/2 I also strongly opposeo& and object to the proposed supplement to the "Gencro" E.1 S.,
wan the deliberate and napprop&to exclusion of"usa specific" issues, which should be an IMperstive part ofany analyss, for any form of an E.LS. Supplement.
CL-44/3 "Site specific" Issues are of vital importance. cepecially at San Onofie Nuclear Generating Station (SONGS) where Unit I Is currintly being deoommissioned. It is imperative that N.R.C. evaluate and analyze SONGS Decommissioning on a "ste specific" basis instead of a "Gncrie" but,, due to the very unique physical site charactuestics at SONGS, which other existing nuclear plants in U.S. do not possess.
The distinctions, and physical characteristics which make conditions at SONGS so different and unique are vitally Important, and are ofutmost importance in any analysis of ocommissionirg at SONGS. in order to ensure the level ofpublic health and safety will be assured, and provided without compromise to citizens in communities surrounding SONGS. As SONGS Unit I ia curr=ly being Decommissioeod, the site specific analysis must include both the ahort term and long term effects, and must alt analyze effects of offurte contamination. effects ofcumulative contamination exposure, and must provide reastic mitigation measurm.
A Summary of the "site spocific" physical charactenstics and conditions at SONGS, winch should justify "ste specific" analyas (as opposed to a Generic El S. Supplement) include the following:
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41962S SONGS is located in a highly populated uar with deise populations in both Orange County and San Diego County, where citizits may be exposed to potentially significant offeite effects.
SONGS is located in a highly active seismic zone, where Seismic activity is speculated by some geological experts to generate quakes up to 7 6 Magnitude on the Richter Scale (by new evidence of local off-shore blind thruat faults, which cause a greater extent of groundhaldng and acceleration than the mnner In which quakes am traditionally studied).
SONGS was only designed and coustructed to withstand a nimurn quake of7.0 Magnitude.
- SONGS is located in au ar immediately on the southern California coastline, with most facilities elevated only to a level of 20' ft. above mean sea level. These facilities are highly exposed and vulnerable to effects ofcising sea leveis, and tsunamis, and am i fiendy protected.
CL-4415 I am eppoesed to NRC resgulatlos pertalinig to Deeemmlissonlng which would
, allowc.
a Rubbilizaton (cnnnbling the concrete reactor building) of nucle5t reactors, CL-44/1 CL-44/
CL-441 CL-44.
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without opportunity for public intervntion until the action is completed.
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Allows poirtom of sites to be"released" from regulatory control before the whole site is released.
a Allows outite radiation to be ignored, and permits utihti to ignore it in decommissiontng plarming. It is imperative to include offtite contamination into all aspects of decommissioning planning and evaluation of envkOnfmental Impacts.
5 0
Allows NRC to make most aspects ofidecommissioning "ge*nric" rather than site specific so NRC cannot be legally reviewed or challenged at individual sites.
Allows NRC to redefine terms to avoid local, site specific opportunity by public to quetion, challenge and prevent unsafe decommissioning decisions.
aAllows NRC to sds asbitrary and unsubstantiated (low, medium and high) z CL-44/10 environmental Impact categories for each of the steps in decommissioning, to give C
the appearance that they have minimal effects, to justify rot frilly addrcssuig them X
now, and to prevent their inclusion in site-specific analysis. This use of this m
plecemealing approach is unsaceptable.
al 00 01 CD CL-44/11 0
- Would allow (with this supplement), NRC to legallyjustify removal ofexisting opportunities for community Involvement and for legal public Intervention until after the bulk of the decommissioning has been completed, including activities as flushing, cutting, hauling and possible rubbilizatlon of reactor.
NRC asserts that the portion of decommissioning regulations (10 CFR 20 section CL-44112 I and its M., NUIREG 1496) set the 25. 100 and 00 rniirems pery er allowable public dose levels from closed, decommussone nuclear plants sites, and we not part of the scope ofthis Supplement. I disagree, and consider the inclusion of expoamne from closed decommissioned plants a necessity to develop an accurate and ralistsie analysis of cumulative Impacts.
CL-44/1 3 e
Allows NRC to define decommissiouing in part, to include "the release of property for *uestricted use"., and the "release of property under restricted conditions." It Is entirely inappropriate and scieitefically ludicrous ito allow "release" of highly radioactively contaminated materials into daily consumer use and commerce, or unregulated disposal, or the recycling of such materials Into any form which causes public exposure with radioactively contaminated materials.
CL-44/14 In conclusion. it Is with utmost disappointment to again observe with each and every new NRC Rulemaking, Important components of the public's exusting "right to know" and the public's right of active Involvement In plant processes, decisions and their methodology, on all aspects ofidcoummlsaioning activities routinely appears to be fUthe-dimninished.
As proposed, the ES (Supplement !) would eliminate all opportunities for public Intervetiorn, and public oversight ani/or inteeton entirely with use of a "generi*'
EIS In such cues, the loss ofpublic ovensight and intervention on projects with a scope as large as decommissioning at SONGS, such losses may be unparalleled, or fully undeustood without a site specific issue analysis. The citizens In local commutultes surroindlat nuclear plants suck as SONGS deserve this entitlement, sad demand "tis entitlement.
CL-44/1 5 The public has not only the "right to know", but NRC and the industry has the duty to fully disclose all related impacts, short and long term, on and offifte, direct and Indirect, as well as cumulative effects resulting from decommissioning to citizens and members of the public living in local communities surrounding the nuclear plants.
CL-44/16 We are tired of being unknowingly treated msan entity frm whom the Industy can escape the obligation of fhll disclosure, and %used" as the entity upon whom tho industry dumps the rea long term costs, and as the entity who absorbs the costs.
Patricia Borchmann FAXo NO. : 7*09419U65 FROM: Bo MD
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CD IN) 0 to I Dons Mendrel*- ets 1 U0 do0 PHYSICIANS FOR SOCIAL RESPONSIBILITY / ATLANTA P 0. Box 95190, Atlanta, Georgia 30347 404-378-9078 PSRatlanta@aol.com NRC EMAIL, dgelsa@nrgov MAIL, Chief, Rules and Directivea Branch/Division of Administrative Seviceas/ Malstop T 6 D 59 US Nuclear Regulatory Commission Washington. DC 20555-0001
Dear Ladies and Gentlemen:
CL-46/1 In keeping with appropriate medical and public policy principles, we urge total transparency. We CL-4612 urge that the Commission always lead it's interactions with the public at large by being fully open and informative about the potential dangers, the expense and the limited experience we as a nation have with the decommissioning of nuclear reactors United States citizens deserve nothing less than total transparency.
We believe that the following statements am true and belong in the public dialogue, as the Issues associated with decommissioning ant presented to ciuzens, I. A uthsfactery waste isolation slte evades an. Yore, Mountaia is not a amtable geologic repository based on scIence - the DOE Itself admits that the site Is not geologically suitable, storage ca*isters will be raquirod to protect the wase from exteior emnvronmental eontaninatlok-Addidonalty, the GAO rahes aedoms questions about the selection procss
- 2. A serus aeddent or terrorlst me ceuid be eutaairphlc. Such an occurrence could result In large numbers of human fatalltles inltaies and Illnesses and vast areas of land ulrdniubtable for yearn.
3 Its enterprlse of electricity generation uing nuclear fission requires public robeldy. Without Prce Andeiooi protection, nularer power would be eeonorncalty untenable.
- 4. Coiudestla of these factrsa most be fully mad pub"ld dies*!sed before expostlg our utlzeas to additlonal expoeures throeugh development of new dear generatioa facilities. The complete phase-out of enlear power should be coesidered based on objective analyis of health and econanne effects Including probabilhty evaluadoss of al posible accddent and ieldentUA.
fartifson of all potentlalegy sources such as wind, solar, hydrogen fuel oell and IncldAing conservat*on.
Tom Ferguson, Physicians for Social Responslblity/Atflanta PO Box 95190 Atlanta, GA 30347 404 378-9078 PSRatlanta@ mindsorpnq,com www.PSRatanta org X1/.
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1i3002 4.22PM Decommisloning comments Letter 47, page 2 fOods Mendlola 30 PC Comments on NRC's Decomm GEtS Supplement - NUREG-0586 doc Page 1 January 30, 2002 Chief, Rules and Directives Branch Division of Administrative Services Mailstop T 6 D 59 US Nuclear Regulatory Commission Washington, DC 20555-0001 Zo Cl Ca t.J
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($27A4-AD To Whom It May Concern:
Please accept the following comments in regard to Draft Supplement I to NUREG-0586, "Draft Supplement Dealing With Decommissioning of Nuclear Power Reactors," and place them into the public record.
CL-47/1 Public Citizen is very concerned about several aspects of this supplement to NUREG 0586. specifically those that could pose risks to public health, the public's right to CL-47/2 participate in decisions that affect them, and environmental quality. Additionally, Public Citizen is concerned that the provisions outlined in the Supplement might allow owners and operators of nuclear power reactors to reduce or completely evade their civic, environmental, economic and legal responsibilities.
CL-4713 Having stated that, we would like to make it abundantly clear that we see decommissioning to be the most appropriate and responsible action to take with all CL-47/4 nuclear reactors. Nonetheless, any and all decommissioning activities should be performed methodically and with great caution, ensuring that the public is appropriately involved in the processes and thoroughly protected from dangers every step of the way.
CL-47/5 Certainly, every reactor shut-down is another step away from further creation of radioactive waste, the ever-present possibility of nuclear terror (be it a reactor accident or terrorist attack) and the continuing irradiation of our everyday lives. Every shut-down CL.-476 reactor can take us a step closer to a sustainable energy future but, unfortunately, reactor shut-down is not the threshold of safety, where the public can be assured that no health or CL-47/7 environmental dangers will originate from the site. There still remains a mountain of radioactive waste after shut-down, including the reactor itself and, typically, an incredibly dangerous stockpile of irradiated reactor fuel. Whereas the reactor itself and the equipment and materials of the central facilities are often treated as the object of decontamination, it must be noted that the previous operation of the plant has dispersed radiation and contamination that did not regard the facility's fenceline as a barrier. Any serious approach to decommissioning a site must take this into account.
CL-47/8 Decommissioning should not be a final opportunity for the nuclear industry to "take the money and run" -be it to make a profit from inadequate cleanup and monitoring, or to limit losses from costs that had been underestimated for decommissioning throughout the CL-47/9 operating lifetime of the nuclear reactor. There should be no allowance for the industry to rag..,
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