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:
|
| References | |
| Download: ML19311C738 (46) | |
Text
Letter 16, page 14 Z Letter 16, page 13 0D 11 10 presented in Appendix G Appendix G uses units of collective dose equivalent; however, as also Transportation dose.
outlined in the appendix, the radiation protection standards are in units of annual individual The Supplement should use consistent units and provide data on population densities for nuclear Page 4-68. Section 4 3 17, 1. This section should address regulations governing the CL-16/70 65.
power plants. transportation of hazardous and mixed wastes as well as of low level waste.
Appendix 0.2 (page G-19) provides the average public dose within a 50 miles radius of a facility CL- 6/71 66. Pane 4-69. Section 4.3.17 2. Line 5. What is meant by "not large enough to destabilize the The Supplement should clarify if facilities which fall outside this analysis (e g, have denser important attributes of the system?"
populations yielding more person-remn than indicated in the appendix) must complete a site-specific analysis. more properly CL-16/72 67. Pages 4-72 to 4-73, Section 4.3. IS. The discussion of irretrievable resources 0 belongs in a section that summarizes environmental consequences. The Supplement could CL-16166 61. Page 4-31. Section 4.3.8.4. While the overall worker health impact is SMALL, Appendix benefit from having such a section as was done with the recently issued draft NMSS guidance during shows data from some decommissioning facilities where worker exposure is higher document on NRC preparation of NEPA documents.
higher decommissioning than during operations. The Supplement should clarify how these should clarify exposure levels compare with the radiation protection standards. Also, this section Page 4-72. Section 4.3.1B. Line9. It seems inappropriate to include concrete as aii ietrievable whether an analysis was done of the normal wastewater streams produced during CL-16/73 68.
resource.
decommissioning that are contaminated with radiation.
CL-16/74 69. Page 4-72, Section 4 3.18 . Line 14. The Supplement states that there "are no regulations that CL-16/67 62. Pames 4-30.4.12 and xii. The Supplement should clarify the circumstances under which deal specifically with the concept of irretrievable resources." It is unclear what is meant by this been rubblization is permitted. It is EPA's understanding that, to date, rubblization has only statement. The following statutory and regulatory provisions pertain to irreversible and to the permitted after site decontamination. Does the term "rubblization" on page 4-30 refer irretrievable resources in the NEPA context:
treatment of concrete or structures that have not been decontaminated? Note that page xii - NEPA § 102(2)(C)(v), 42 U S C. § 4332(2)(C)(v);
indicates that the continued dismantlement of structures that have been radiologically - 40 C.F.R. § 1502.16 (CEQ regulations); and, decontaiminated falls outside the scope of the Supplement. - 10 C F.R. Part 51, Subpart A, Appendix A (NRC regulations).
.- 4 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 but is affect previously undisturbed archeological resources potentially located near the facilities, The concerned about the potential loss of these facilities as a body of engineering work.
of Supplement mentions that a few facilities may be eligible for listing on the National Register Historic Places individually and that those facilities would then be the subject of mitigation of facilities based upon consultation with the SHPO. Eventually, however, a substantial number old nor require may be decommissioned. While the facilities themselves may not be fifty years merit inclusion physical iMnit preservation, the processes and engineering they employed may z in the Historic American Engineering Record (HAER) The HAER is designed to provide C and study uniform documentation standards so future scholars can look back at our achievements m them for a multitude of purposes. Rather than make this determination on a case-by-case basis, Preservation and the NRC may want to consider working with the Advisory Council on Historic
- 6) the National Conference of State Historic Preservation Officers to achieve a programmatic 00 agreement or other programmatic treatment for these facilities a,
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z(7- Letter 17, page 1 Letter 17, page 2 m
CA 00 CO o' rEAR SAFETY DEPARTMEN-TOF N4t EAR SAFETY 62704 1035 omUR PA.t DRVE
- SPRJIý0; b,0ILUNOIS 62704 (D 21t'5.9 . J3 oD) 3 CD M_ George H. Ryan Thomas W. Ortatger Governor Director -; George H.Ryan A Trhomas W.Ontcigcr Governor Director
-7 December 28, 2001 Ii January 7,2002 ci U Chief, Rules and Directives Branch Division of Administrative Services TO: USNRC MailstopT6D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 FROM: Gordon Appel
Dear Chief,
Rules and Directives Branch:
Deputy Direcor Illnois DepL of Nuclear Safety 217/5244723 The NRC published a Notice of Availability of the Draft Supplement I to the Final Generic Environmental Impact Statement on Decommissioning of 0=0 Nuclear Facilities (NUREG-0586) on November 9, 2001 and invited comments Response to Comments on NUREG-0586 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 We nailed the response on Decmbwer 28,2001. Due to the mail, we are faxing this lettr to represented at one of these meetings and would like to offer these additional comments on the Draft Supplement.
CL-17/1 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 PAGES....+/- radiological exposure to the public for the reactor entombment decommissioning (including Uansmittal sheet) 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 A4S'-6Ž~" public may also be exposed to radioactive materials that are released to the z environment during the decommissioning process. All decommissioning 0 activities were assessed to determine their potential for radiation exposures CD 3 that may result in health effects to workers and the public. This section 30---n' 0
0N
z Letter 17, page 3 Letter 17, page 4 Co Chief, Rules and Directives Branch Chief, Rules and Directives Branch Page 2 Page 3 December28, 2001 December 28,2001 considers the impacts to workers and the public during decommission activities performed up to the time of the termination of the license. Any entombment is disposal of low-level radioactive waste in the containment potential radiological impacts following license termination are not CL- 7/8 structure. The Atomic Energy Act allows states to assume regulatory authority considered in this Supplement. Such impacts are covered by the Generic over the disposal of low-level radioactive waste in their state. In an Agreement EnvironmentalimpactStatement In Support of Rulemaking on Radiological State it is the Agreement State not the NRC that has the jurisdiction over disposal Criteriafor License Termination ofNRC-LicensedNuclearFacilities, of low-level radioactive waste at reactor sites.
NUREO-1496."
The federal government has established policies regarding the disposal of CL-17/2 For purposes of this GEIS, the NRC is only focussing on the environmental low-level radioactive waste. The federal Low-Level Radioactive Waste Policy impact of the actual decommissioning activities between the cessation of Act of 1980 and the Amendments Act of 1985 require the states to provide for the operations and license termination. This approach completely and inappropriately disposal of low-level radioactive waste generated within their B6rders. States were ignores the environmental impact associated with any radioactive material encouraged to form regional compacts to limit the number of disposal facilities remaining following license termination. 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 For a site decommissioning that results in a license termination for region as well as to establish policies regarding the management of waste within CL-1 7/3 T unrestricted use, the long-term radiological impacts to the public may well be their region. To date, 10 such compacts have been formed and ratified by "I within acceptable limits. However, for a decommissioning that results in a license Congress. Most compacts envision having one regional disposal facility that co termination with restricted site use the potential exists for long-term radiological CL-17/9 would accept and safely dispose of their region's waste. Allowing NRC to impacts to the public to be far above acceptable limits. The draft Supplement does determine whether waste can or will remain after a reactor license is terminated is not consider this potential. While narrowly focussing the radiological studies to contrary to the policy of the respective compacts and in direct disregard of the the decommissioning process, the NRC does not consider those potential long federal low-level radioactive waste framework established by Congress.
term impacts to the public.
CL-17110 As the NRC evaluates the comments received on the GETS, it should look When the original GEIS was issued in 1988, the NRC viewed entombment beyond the actual decommissioning process and focus on what condition the site as an unlikely decommissioning method. The issue of entombment was not CL-I 7/11 would be in following license termination. If the possibility exists that radioactive publicly discussed in the 1997 timefranie that NUREG-1496 was published. It is material will remain on site under an unrestricted or restricted use condition, the unlikely that NUREG-1496 addresses the long-term radiological impacts GEIS should consider the associated long-term environmental impacts. In associated with entombment. In 1999, the NRC began to consider entombment as CL-i 7/12 addition, the NRC should reevaluated their legal standing in deciding what possible decommissioning options or methods and conducted a workshop in radioactive material would remain at a reactor site located in an Agreement State CL-17/4 December 1999 to gain input from the public. On October 16, 2001, the NRC and whether their proposed action would be contrary to the waste management z published an advance notice of proposed rulemakling regarding entombment policies of the applicable compact.
C this draft Supplement, the U options for power reactors. Even with that notice and impacts associated with m NRC has yet to evaluate the long-term environmental I Any question you may have regarding this letter may be directed to me at G) NRC fails to consider 6 CL-17/5 entombment of power reactors. In this Supplement, the 217/785-9868.
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 r_ terminate the license with restricted site use in an Agreement State. Residual
",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 7bomasW.OrtcigJ~z Director TWO:bac
Letter 18, page 1 Letter 18, page 2 z
m G) 0") numbers quoted for some of the other plants may be inaccurate. Each plant 00 CD, From:
To:
"Hickey. Eva E"<eva.hlckey@pnl goa>
- 'mtm2@nrc.gov" <mtm2@nlrC.gov>. sxf@nrc gov" <.sxf@nrc.go (L'2 should verify the numbers for accuracy.
Date: 1115/02 6 25PM cn FW: Comments on NUREG-0586 Draft Supplement I Thank You, C
Subject:
- 1 Respectfully, "CD 3 -- Onginal Message- Jerry Delezenski, CD I.
From: Jerry Delezenskl rmaito:JDeleze@smud orgj -. .'
Supt. QNLicensing/Admln Sent: Tuesday. November 20,200111:12 AM Rancho Seco To: 'dgeis@nrc.gov'
Subject:
Comments on NUREG-0586 Draft Supplement 1 U,
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.
to correct an error in Table CL- 8/1 We would like to comment on the draft NUREG Seco.
4-3, line 21 regarding the Cost Impacts of Decommissioning for Rancho Une 21 should read:
Rancho Seco 913MWe PWR DECON $394 Desk dated 0"1 Please refer to our letter submitted to the NRC Document Control On C> 3/26/01 entitled Rancho Seco Report on Decommissioning Funding Status.
page 2 of the letter we stated:
"...Their [TLGI estimate was $495.4 million In 2000 dollars. The activities portion of this total that Is non NRC-defined decommissioning storage of related to non-radiological dismantlement and management and spent fuel is $101 mllion, most of which is related to fuel storage costs-.'
...TABLE 2...
2000 $495 Million.
SMUD. when itfirst established its decommissioning fund, included fuel.
radiological dismantlement costs and costs related to storing spent in Therefore, $495m -$101im leaves $394 million for equivalent cost discussed Table 4-3 of the NUREG.
Since 1999, Rancho Seco has embarked on an extended DECON process scheduled CL-18/2 for completion In2008 (including license termination). After license on sit termination, SMUD will, depending on Its business needs, embark restoration currently estimated at -$45-80 million. This approximate fund.
estimate dollar figure was never a part of the decommissioning trust (We assume your number InTable 4-3 Includes all the costs of dismantlement, fuel storage and non-radiological site restoration.)
several CL-18/3 Also, based on information presented in various Industry forums, z
0 CD 3 G-~~e0-CD rJ
Z Letter 19, page 1 Letter 19, page 2 Stephen A Byrne 3" Senior Vice President.Nuclear Operations Nuclear Regulatory Commission Cr~o S E 8033454622 0-L-99-0290 RC-01-0204 CD*AGOPN
"! 7? '; 7:7 ~ December 20, 2001 Page 2 of 2 o,
RC-01-0204 It.,, - -,
- If you have any questions, please call Chris Crowley of my staff at (803) 345
///'7/,0 1 4409.
6641 Very truly yours,
,Chief, Rules and Directives Branch Division of Administrative Services Stephen A. Byrne Mailstop T 6 D 59 U. S. Nuclear Regulatory Commission Washington. DC 20555-0001 CACISAB/mb Gentlemen' c: N.O0. Lorick N. S. Cams T. G. Eppink
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 R. J. White OPERATING LICENSE NO. NPF-12 L. A. Reyes COMMENTS ON THE DRAFT SUPPLEMENT TO THE FINAL R. R. Assa "T3 * *GENERIC ENVIRONMENTAL IMPACT STATEMENT ON NRC Resident Inspector
,. DECOMMISSIONING OF NUCLEAR FACILITIES K. M. Sutton W. R. Higgins
Reference:
'Draft Supplement I to NUREG-0586, 'Final Generic Environmental RTS (0-L-99-0290 #4)
Impact Statement on Decommissioning of Nuclear Facilities" File (811.10)
November 9, 2001, Federal Register, 66-FR-56721 DMS (RC-011-0204)
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.
z C CL-19/2 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.
In1 CD 9
-CD ey S(190 I V'srgi1C.
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- F0 Box88* Af540%th (eoh eC~n 29065.TI BO) 455209
- wiscmoran N UCLEA R EXCELLENCE - A S UMME R TRA DITION!
Z Letter 20, page 1 Letter 20, page 2 C
6 2
power plants and research weapons, thanks to the fact that they got both nuclear (n
Branch, reactors-gati thoseand, with enough money and infrastructure and a goveriment Chief, ulaes and Dirextivea PaAewCMYRDod.vb Division of Ad-irnistrative Services,, 1//1i01 the British, the US, the- French, 0$W1%A30134 willing to squander billions) just- like the Soviets, Meilatop T 6 D 59 , 4 4" MI5Wo H" D. h apartheid, gfd,-smd sooner or
- 3 E) US Nuclear Regulatory Commission, the Chinesag the Israelis, the Swath Africans under Washington, D.C. 2D55.5-00i0 later youhA. gno.i.ursel a. bomb- T BOMB - )hat 011i -clear power/atOmic bomb Generic S
Ils Comments for the record. on MDrfth Supplement 1 to3 Nureg-05a6,**naI Facilitits (GEIS), Youmean NM thought no one realized the nuclear Edreonmental Impact Statement on Decommissioning or Nacla"s connection no one: wants to mention.)
Draft Supplement Beating with Nuclear rower Haanabaraso realizw they were running ?W*
p over route,was just a, diversion am the public wouldn't many hours: of WuA a way to. spend the dq after Christamna-uhat a way to- spend. SAID am. Besides, any to produce extra plutonium for, weapons Li needed,? Oppenheimer l manet December and. Noxemher-having to plow: through this. document - a momnuent can onn vitIL common sense could figure that out. Just as anyuone with com&M sarea CL-20/3 arrogance, stupidity,, lack of foresightý and, greed1i" there, eve*r wa one. fwsver, have dire consequences if Implemhstai tell this-Draft Suppl3menti 1r to Nureg-0586 wi 18W AI*D COVeR2.If on.
CL-20/1 the document can be condened-Into threse words, namely i1n its current fore. It. always gazea me how the Nuclear Regulatory Commission, INW3 S CL-20/4 wants a: bazim overview, of what NRG put in It, as that seems to be part of the, main own definitions% (such asP"s its own laws, and standards - its- awn regulations, its desire of the nuclear industry7/=R (an" D.O.E ), concerning what to do with the publia doesn't realize (If they did, it o=miasioninge goo pxii) and most of the Coll Var, frm horrendous nuclear legacy of the atomic. ags w-At the height. of the is safe to assume they woulc- probably borseatip the Co='ission out of town)hwat a bomb (which in essence, tha. U.S.) defense against the atomic.:bomb and, the hydrogen CL-20/5 sham it. all isr andl be%- industry writes its own tickt.
Fr= exOsmplw, p. 2U, the N
CJr a fission - atom=i.- darvice/bmib/reaction to trigger the fusiom reaction/bomb/ that do not exceed pe Suses Commission hae concluded (says the Commission) that Impacts defens" which i cea ad considere d smell. In other words, deviace ,hich triggers, etc. etc. etc. ) was iam incredible misaihie levels ib thal Co* sisionty rmarultibls a"r that if you duc-kesi appalling, criminally negligent OMM AND COVEe. They actually hadb the population believing using made up ratlations based a great deal on that under a table in the kitchen, you grounds for Manhattan Project. scientists post under a. door jamb, or under a. desk at school, or- outfit the IRCP (am= of the. dumpin ditifUflly behaved like Manhattan Project woult survive, nuclear war.. Ails this side of' tb&. Atlantio S- for anyone reading this from the younger genera;tionsr the, the leader, tha' other side, oa bombs dumped on Hiroshima and a; bunch of sheep going over a; precipice following was thel name of the project that built the atomic
. I scats.
Q set allowable levels of the Atlanti.c~thouasnds. upon thousands. demonstrated, against the insanity of the Nagasaki) and: its early determinations that they would there a difference in behavior ? atomic energy industry.
arms raze and. nuclear weapons in general. Way w*a exposure that were at levels that would, allow the emerging (a operate with 1l the releases which they knewt Becau"s, justl.lika today with this issue of nuclear waste and "decommissioning' and everything that went with itto it would be acceptable seems -must be a n*w mada up word. as it is not in my and admitted would cause genetic damage )0bt they decided worxt everyone swallows it (until they di. out) no; dlicussion of the, issues in the to damage sperm and ovum . M damage countless generations huge olX dictionary) - there wag/is almost countless cases of spine isJ purposeafT. There is, and has to cause countless birth defects, countless miscsrriAges, presasnd DOeducation on the issues,, and this anr the Death of the Earth bifida - look at South Carolina, nuclear power plants inustry and govdr-6nt-s.
bean, press interference on the issues - bY both highest spine hifida rate in the US.
squad*'s Savannah Bivar Nuclear, Site and. the since The nuclear issue is the m important issue facing humanity and has been impacts will be sm*el etc. based on that 2
,.CL-20/2 CL-20/6 NRChaa absolutely no basis to say whether the Sword of Damoclee. over- the C the atom was first split. The nuclear issue. is the nelt dAcadeI(a I write planet and. all futuor generations should *e survive on the verge of war, only they now haae nuclear" India' and' Paki stan are once again J,5- A'9'b Z p"W-J Y3 I',D
Z Letter 20, page 3 Letter 20, page 4 CD 3
CD 3
N) . The great R.14 Sievert (after whom the unit the Sievert is named)
CL-20/7 VOrt of gabage M'inted out that there was no level below which radiation did not cause damage, then cite the bozor at NCRP again)saying that the "fate of individual non 110threshold that must be exceeded for damage to ocourr, yet MM~says a threehold humon organisanis-of less concern than the maintainance of endemic'populatio,"
vast be exceded for effect to occur, I believe Sievert. The ICp standard of 5RM shows A OMMM LACK OF UNDERSTANDING OR COMRPERESION OF THE WEB OF LIFE AND per yoar is based on a principle called risk/benefit that allows a one in five THE NATURAL WORLD. The' effects of ionizing radiation exposure' on AM lifer forms' thou*and chance of contracting cancer. In other words, the death or- cancer risk inclidts sterility and genetic damage which can lead to extinction.(Think frult Think they.
flies. an'!Herman IMullers experiments which gaves.im a Nobel Prize.
is the uorkors and the publics* # the benefits are the dollars flowtng to the effects to fishtproved years ago. ) When thinking about exposurer to plants ancd industry and the IM (from the indhetry in return for MC services end licensee ate) CL-20/10 one needs to take the affects to aaiinfant an& to ai chil'd'in'the anioea and fish, The fCP also pushee the 5 R standard - this in the wse bunch of borns who womb to, better. approimnata the. effects to wildlife, the analler the, ron-human in tryinZ to refute the world renowmed findings of Dr. Alice Stewart and the entitY (e.9'. a biM,.a frog) the child in utero dow* to embryonic-level wuold bh fenaus-fxfoed Study accepted vorlduide1 that showed in-raying a develloping fetus appropriate. Wa all know what happens when an embryo is exposed - rmely eatlr on*
eaused a major increase in childhood cancer - claimed obstetrictann had x-reyed or- severe damage.. Tha samehappens to birds eggs. Thm InternationaT Atomic, thon* fetuses which they somehov M would goet cancer, which explained why the Energy Agency i' about' as trustworthy on the radiation dose issue as Atila i the, x-rayed fetuses vwnt on tAP get childhood canc-'P(SBe "The *man W. Kn Too Hum would have been on the gentleness issue the IAEA has,a che*rtr that states C' 1,ch - Dr. ,lice Stewart andt the Secrets of Radiation' by Gayle Greene. Read it itkr sole purpose in life is'to push all things ="clea',. just what does NHC and learn all about the Commission and its buddies. Read it and imep for umeanity, expect the W 2 say then , if you have something called a ooncience at the NRC, go do comething about 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) this Draft so it is no longer en Jndusty wish Itst. ) The ALARA principle that undbr. contract,, wrote, of the:need to "accelerate, the study of the functibn of N2C uses "hich basically say3 that doses mist only be kept Ac Low As Reasonably 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 W Achiovablo (ALAnA) based on the state of the technology and the rount of money 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 npent by tha industry - uhat Dr. Gohamn calls "planmed deatha" ns HM knows 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 CL-20/8 is referenced by NE, many times, and the Draft even says cdýrin! liceniing the simultaneously in the fundamentals of modern ecology and radiation biology n.
order that this inevitable need can be mot.*' Mwrterribly sad - th&lil ham ar.l:.cuntn coait to inplament ALIRA progrnans. 7be combination of ic',In-Fc.w one doctor for the entire NRC. Radiation biologists, ? Stop me. before I scream..
end *_AIt. .itcndords is, and hes been a recipe for premeditated r-urdcr and/or illness, It is- obvious that an inventory of all life forms on a site should be-made and, Z
CL-20/9 genetlc c.aego and Creat suffering ae it is, NHCsavinC' that it hbe not established that they be sreaened for chromosome aberrations and 'radioactive conteminationrthen C
m strunda-rJe to biota other than humans on the basin that limits sstablishoJ (by the 0 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 Cr1 0o ci)
CD CD
z Letter 20, page 5 Letter 20, page 6 C
m 6G) b co SHOULD BEA LACK OF INSTITUTIONAL COI1TWL EITkHO1.
(3 a similar comparison be done at. a site as sii as possible to the plant site CL-20/14 The Technical Specifications and what the facility was allowed to dump undea.
=1 the license are &outdatedand bear no resemblance to current knowledge and should, about twenty miles away upstream and out of the predominant windpath on a thirty CD be junked and the whole thing done over. Furthermore, the way the environmental year wind, rmrse It would notý be half as good as one would, want,. but it maoldube CL-20/15 CD
-o and water issues were looked at during the t&me, of plant licensing were often better than nothing and establish seas differences and' give a. better idea of the equally awful.. It. all needs reconsidering.
contamination problems, even though a, site! twenty miles avay ui have recieved!
What is. ridiculous, is the worry about messing- up the enviroment while decommiss somarairborne deposition from the. plant. In terms oW aquatic species, the recardi Ionia4 the dump. For crying out loud, every second the plants are runniing they from,Statasources and the licensee on tests ran on flsh/mussels etc. can baeuead arie contributing to ecological ruin, at the microscopic level, and impacting and compars to the' fact, repeat PACT, that contaminants such as Cobalt-b, Sr-W human health to a distance of appronimately 100 miles.
Ca-1>Z,, U-3 above, theminute natural burden, plutonium etc. are.not natural. and CL-20/17 This Draft I references MLRSSIM (Multi-Agency Radiation Survey'and Ste Inves should never be found in fishmollusks etc. and one can look for chromosome aber-for bioaccumulation of the uraniums from the togation Manual. Y I comented on the Draft, never saw the final, never heard" rations.. Dtatiam can be. examined plant. Centrides hence - in some cases decades - a measure of equatic health from anyone again on it. It was mindnumbing1y awful. Put together by some peopleI would be the decrease in levels of contaminants found in species and decrease in from NRC,,WE, Dspt_ of Defense, and EPA. Industry was represented big time. Im It aberrations etc. It is vital, that contaminated sediment found' downstream (an& the, DODaei"' how committed-it was to protecting the environment - this from am also somer upstream due. to airborne depositton on water sinking down) be recoxe& entitV that had left thousands of contaminated sites on and off bases, themselves This- houl& be- done by perhaps sucking it up vie vw requiring an estimated (govt. estimate) ;t007HILLIUN to W0 Billio0nto cleanup for many miles, downstreaq.
CD uu1 type hoses as opposed to dredging which could dislodge and spread the contam worldwide. In its introduction, DrafteMarssix did not address all aorts of things.
ination further.. from contamination on vicinity properties through contaminated subsurface soil, With rsgard.to plant-life,,microorgsZani s etc. oneoould comparXplant see8d All of which must be cleuandi up/hay.
water, construction materials and on and on.
production of say twenty species on sitr, with production twenty miles away, and; the contamination removed. They showedi s lack of understanding of the groundwater contaminat number and type etc. of microorganisms likewise, as well as radioactive fact Ilm still looking cycle, and groundwater issues JUST LIKE THIS D-RAT DOES (in
-3 this, as the NRC wil CL-20/1 1 ion.. I don't really know. why I an bothering to write all for it to be addressed),Groundwater is used by oou-ness communitlesagrOundwater T ignore it anyway,, but hope' springs eternal as they say. If we don'tt have' compar-CL-20/18 let eventually released to surface and other water bodies and)as groundwater onsite the, start of a return isons, we. can't.have at least some idea of. what constitutes by 1979 is usually radioactively contaminatedl (At Plant Hatch they contaminated it what needs bulldozing and taken t' a. more unpollutted. site, and we can't. astahlish is is a SERIOUS issue that MUSTbe dealt and that was just for starters)'
CL-20/122 TW H~~A9t~ V 0B R~V' o TE RFM HO M EER THE ADDITIONAL to what I a$
to-01a, raa WkIcJ, groundwater te.. is contarninated*4=ba puped out etc. kHefer DR. K&L MOWRAH AS ALIVES THE FAT OF RADIO CONTAAIkNATION ISSUE IS ANOTHER REAON EXPOSU IS TOTALLY NSANX. WHEN said.in earlier comments) THIS GROUNDWATER FOR DECADES, HE SID LESS THAN ON CL-20/19 LOGIVAL HEALTH pHiSICS, iO EEl WITH OAKRIME TIER. WHYSiROuBLIZATIONT MUST HE FDRuDDEwnTHE CONTAvMINATION IN WHATTHEY WAdT TO CL-20/13 PER oEBRoNL L, E pERHAPS ACCT.TA= FROM, ALL PAT-WAX.
WOULlDL Ru~lzSLI ANDEURY WILL LEACH TO THE 6RDUNDWATER AN DIRECTLY IRRADIATE SOIL cover*.
CD AND MICF0OROANIRES. The industry just wants to nave money and "dump and C:)
10
z Letter 20, page 7 Letter 20, page 8 CD CD ANDWITHOUT SIGNIFICANT ENVI MTAL IMPACTS FOR AT LEAST THRIiT AnS BDMN 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 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.
CL-20/21 and the ecosystem upon which life depends. Anything dumped or buried from the past during "dump and cover amidst much licensee laughter about how they stuck it to practices on site must also be dug up and removed. 3 CL-20122 To= find, out" the extent of past problemsr and. contamination levels, IT IS VITAL the rate payers and taxpayers and local community yet again) terrorist&take out THAIT THE NlO, TME LICZS= (as' some an new owerR/licensees), AND THE CONTRAC three spent fuel casks blasting them to kingdom come (the Milan anti-tank weapon TO AND SUB-CONTRACTORSG T ALLACOIDENTS, LICENSEZ V= RIEOORS, VIOLATIONS, would do that as I wrote XRC before) OR two casks had a major problem and needed to INSPECTION REPORTS, SPILLS ANDCONTA11INATION EVEVTS FROM TIM RDOC= FOR THE beopened under shielding inside the spent fuel pool and there was either no room REACTOR ANDSITS IN qUS=ON AND OODY WELL GET OFT T= REAR ENDSAND nffm in the spent fuel pool or the cask came apart while trying to move it due tor TMHR MONEY ANDRVA TEM. THEMN= THE WGOLZ LOT, SINC STARTWUP, EM IF IT brittlement of the cask from the radioactive decay heat coming off the spent-fuel ?
Tj= TWOMONTHS TO IEAD TM . I AMSICK ANDTIM OF EM=ONZ,NRC INCLUDED, Whatt will NXI do, what will the licensee do , send for Chostbusters ?
AND IX THE PUELIC 10MOMENT ROOM. CL-20/28 Under Water Quality p.4-10,,t11 The NRl must stop giving the impression that REFUSING TO READTHOSE REPORTS FROM THE NOCIEM (1) 6 TUEN, AS THE LICENSPS USUALLY PUT A GOOD SPIN ON IT, PEOPLE SHOULD REALIZE THE it is -sheer chance that nuclear reactors are located on wateruhen in fact they pRDIMRS LISTED WERE PBOM IIA.!WN. -Another Isase '-which I touchadi on in my require- miflions of gallons of' water a day to operate and'that water source is con
_0 sidered the ultimate heat' sink in the case of a meltdoun - itill ooze on down the comments on MARSSI*,I ws the-fact that in the real ijorld, iasy people can nct" En reeL or imAite very wenl, an-d if things are contracted out, this' could hama riverbisasing and sputtering like a volcano hitting water. NMEassumes compliance, with NPDES discharge permits for on-radioactive contaminants (NPDES and the Clasis CL-20/23 eeriou-s'consequen~caea IMMmust stipulatu, that ALL CONTRACTORS ANDSOR'-.CIDTRAfC TORS RIGHTI DOW TO THE BACK-HOPE OP*TATORS MUST HE HIGH SCHOOL GRADUATES. asnup 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 cannot" just be dished out to any contractor,. all involved ishould not' only have a often violated or. bypassed - just look at the NPDES situation in Georgia. as one stirling track record, but experience in nuclear fields. There should. be- n radiation and should biologist on site, plus- ah ealth physicist, plus a wildlife biologist"with a. CL-20/29 example. Discharges should never have been allowed without prior cleanup geý knowledge of radiation effects, plus tlere must be federal end state oversightt CL-20/30 not. be now. Surface and groundwater quality, p. /-12should NOT be considered, a nario decommissioning issue - climate zone can also create unique problems, terrain CL-20124 ON THE SITE at all times.. I noticed that the Draft blabbers on about OSHA standards likewise, it should be site specific. Air quality issues, p.-412 etc. 1 do not address T FA3LS TO H=TION THAT OSHA IDES NOT COME ON SITE AND IS NOT ALLOWIC TO ACCORDING CL-20/31 z TO OSHAJEVERYTHING IS UNDER NRC.. So lets print the truth shall we 7.,
the fact that HEPA filters are about as good as useless for radioactive particulate C must have self-contained The Draft saysp.-6 1 that the NRI and. the Commission are not considering the issue CL-20/32 holdup and sand filters should be added as well. All wrkers X CL-20/25 in should be covered to con of- spent-fuel storage (in a pool or-in one of those ridiculous casks outside in CL-20/33 breathing systems (moon-suits) . The area being worked 0
tain dust if it means covering the whole site with a tent with an adhesive inner 01 plain view for every terrorist to see) as part of decommissioning. The excuse is capture co CD surface to capter particulates - after all If flypaper' is good enough for the DOE 0)
CL-20/26 that it's dealt with under other license aspects. It also says that the Commission Cl has made a finding that the D=lMY, RADIOACTIVE SPENT FUEL CAN BE STORED SAFELt when it, like the NRC was cealle* the AEC)to capture particulates on, a tent with CD 9
Z Letter 20, page 9 Letter 20, page 10 C
60 (3)
Co /D).
Ssome sort of a sticky undersurface is a step up! Thr point I'm getting question, fine wire mesh sat at an angle that can have leaves and other C
debris hosed off it, it must be anall enough to keep birds out down to the a CL-20/34 at, isone does not want radioactive and chemical particulate matter getting CD site poses slightly less of a would be size of hummingbirds. Enclosed, such an obscene
- J CL-20/35 off site if possible. If such a tent system were used, afterwards it threat to bird and- other wildlifer the, utilities can pay for it all, it can come, 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 outL ofthe, salaries of the top management and company owners. NRC better sat it some extent and remove contaminated materials to better sites where they can up now, befora.they all pull an "Enron" - i. e, an "end run" round everyonem.
be better contained - in other words to national sacrifice areas remote fr*m all CL-20/41 I notice that the General Accounting Office-haus slammed the NM f= its human habitation and far from water sources, where wild life is fenced out. lack of oversight of transfers and mergers in the nuclear industry and had not.
CL-20/36 Regarding aquatic ecology p.4.--6, as touched on earlier, the anvironmentalL verified that new owners would have guaranteed acess to the decommissioning impact statements originally written for the plants were often very poor, an& 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 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 must immediately address problems, and should demand that conpanies provide enough contaminated sediment is removed and no further radioactive and chemical releases money for- oversight - to include security staff,maintainance staff, nuclear engin
- CL-20/37 are made towter and air, the aquatia ecology can only mve. a quality CL-20142 eers, radiaLion safety officers ate. - essentially forever. Even after all fuel is U1
- 0) should continue to be tested for radioactive contaminants for at least 600 years removed from the site and the entire structure- is removed, the site will still be which is the full radioactive hazardous life approximately for cesium-137 which radioactive forever and still need a security person, basic maintain-nce person is a contaminant of concern in fish and shellfish as it migrates to muscle in (for'upkeep of fences, gates, runoff detention ponds etc.3 and regular visits from for exa=ple, CL-20138 particular. The aquatic ecology issue should also be site specific, CL-20/43 a- radiation safety officer. It is absuard that. XC states that "decommissioning Plant Hatch in Southern Georgia had a massive spent fuel pool spill which con activities do not include the maintainance, storage or disposal. of spent" nuclear taninated not only the river and sediment but also a huge wetland area which fuel, or the removal and disposal of nonradioactive structures and-materials beyond has many creatures feeding in it and becoming contaminated, inc"ld threatened' that necessary to t1rminate thatNRC license -...they are not considered, aw a cost and endangered birds. And& on the endangered bird subject, let. me adress the impact because the licensees- are not required to accumulate funds for these act CL-20/40 Migratory Med Tz-aty Act of 1918 - (p. 4-20) It is a proven fact - proven by ivities.e (Smp. 4-a2) Why not ? This is an outragel The NRCmust pass a Ib*le" the old Atomic Energy Commission and its contractors,- that migratory birds at once requiring such money be set aside, some of it perhaps in form of gold and become contaminated eating seeds,drinking water and so on at radioactively con silver bullion at bank deposit in case of financial collapse. The fact of thin taminated sites, wetlands areas etc. and the birds carry this contamination matter is thiss the licensees must be held responsible and, accountable for every in their bodies worldwide. NRCC oE and licensees violate the FMT bk not pro thing about and on the site and generated by the site past, present and future.
Z teating birds from such contamination, and by spewing radioactive noble gases As NRC states (p.43) local jurisdictions may impose stricter~cleanup" or* waste' of thor CD out that impact passing birds. No wonder birds are decliningý This is one CL-20/44 or contamination containement and this will cost more. The NRC should add a 10%
C" reasons I suggest that netting or similar should be placed over the sites in sucharge to any calculated fees-for dco-naissioning to help cover those costs-CD
z Letter 20, page 11 Letter 20, page 12 CD 13,.
SII.
ro CL-20/54 Regarding Occupational Dose and nuclear power plant exposure data (p.G 12,eta)
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 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 and the maintainance and upkeep and security and waste handling and fire preventiom because what people are being exposed to is' either not found in nab-rs, (i.e.
and similar. This MUST be addressed as part of this decommissioning, it must be' The' exposure allowed CL-20/47 incorporated. THE COSTS MUST NOT BE pAN=D ON TO TO RATPAYRS a NIC says: they CL-20/55 it is man-made) or found in nature at far, far lower legels.
by regulation is, in fact, slow death, and furthermore, worker doses canht assumed CL-20/48 are currently. Furthermore, the most expensive estimate should always be of costs ImC alwaym be.- trusted because of faulty measuring equipmaent, borror stories for everything as a mise precaution. NNOlists the decommissioning THE COSTS ARE if workers being told-not to wear their dosimeters periodically, and so on. Tht MILLIONS as estimated bj the utilities - however,. NBOWELLKNOWS TH& BILLIONS WHENEVME NO FROMSPENT FUEL ON DOW IS FACTORED IN, AND THAT MUST dose recieved also has a different effect on each person depending on age,sexp.
is affected BE REPLECTED, PLUS THE NROINSPBOTOR GENERALS OFFICE SHULD GO OVER ALL ERWCATES current and:past health status and many other factors, plus each organ they THEY AM Inflation must differently. The fact that the. ICRP,DOENRC etc. didn't know what on earth CL-20/49 MADE BY UTILITIES TO SEE RHOTRUSTWORTHY AND ACCURATE also be added to costs.. were doing -other than guesswork -regarding exposura levels vetis"shown by the The- utility fac that they had to keep adjusting the. "allowable" regulatbry limits down CL-20/50 Regardi ng the.loss ot local tax revenues due to "dbosemtsioningw.
this- time.
most bet reqmdred to notify the local govermient as far in adivancea mpossiblet. that ward. A sort of continuous NOopr,, we 'screwed up I Bat- don't. vorry, IL
- they will lose taxes. The, fact that the local gover*ment should' never have, allowed we've got it.right.' All the' blather on "Risks" from radiation expograu,,caAlt 4
such unuclear dumps; ,posing as power plant. inth'ttheir -communities i's another Issue,, hide't.he, fact that it.kills - not just cells here and.there-such as aell&.
Ir. a hurry-. about- to form the septum of a babyr heart so the child is born with a hole in They need to understhnd that they betten' di-vesify their tax baea HgyER, themnuclear idustry - the entire industry
- (from nuclear plant owners it's heart,because a bunch of murderers at the ICRP decided the risk war, CL-20/51 Tor KNuWINGLY ALLOW PEOPLE TO BE EXPuSED TO to uranium enrichment plants to users of radiation for medical experiments poasint anoeptable,-- but it kills people.
as 'therapy" etc) should! hav a tax levied on it by NIC th be paiW into, a spaefeal NOMEMB THAT WILL KILL A CESTAIN PMERENTAGE OF TEMNHIS A NAME, PREDITATED tax can be: levied' MURDER
ancount-tb go towards compettng the communities.' An additional pay for theýNRC Further,. the ICRP 40oea not consider effects manifested after the second gen on them yearly in the form of a sull, flat fee which would help eration in assess"ng the genetic risks to' workers offspring (p.G 5) again sholwin and thei ,PA t do qu-rterly Inspections' at facilities, in perpetuity. workera and their families and whether o= not they don't give a damn about the LICENSS, CONTACTORS,SU IONTRACTOR ANDANTONS CL-20/52 BebreI forget a NPC MUST MAKE workers great grandchildren are born deaf, or with learning disabilities, or Z A* *WHO WORKS ON DMEOO10ISSIONING TAKE THE EFFECTS OF RADIOACTIVE "DAUGHTER" PRODUCTS CL-20156 unable to reproduce. For tha Draft to take theonly attitude of "well, the dbses at plants being decommissioned are generally a small fraction of doses SINTO CONSIDERATION AS THE! HA!YHAVE VER! DIFFE7N PHYSICAL,CHEMICAL AND RADIO
( ACTIVE PROPERTIES THAN THE RADIOACTIVE "PARENT'. THIS MUST BE PART OF DM 1NISSION at operating plants " p. G.13 is no comfortland all the charts 'show)concerning' 01O ING STANDARDS. 'HyjSS3?, basically ignored that, another reason their Draft was so Occupational doses(page 0 14 and on'j is tbousands upon thousands of contaminated co
. CL-20/53 awful. NRO seems to have ignored it in this Draft also. This is an important workers,. ItLia obvious that this contamination of workers (and the environment)
C V health and also environmental isuse that cannot be ignored.
CD CD
z Letter 20, page 13 Letter 20, page 14 G) co 13. Ji..
0r)
C- must be massively reduced. LIST OF JOB REQUIPU;TS.
SCL-2057 I notAced that it said cutting methods included abrasive water G-17, but in CL-20/64 It appears that the nuclear industry has written its own ticket , as usual, on Sany Case where. there is plutonium contamination or depleted uranium matal, that CA the issues in the Draft. P. E-5 notes the help from the Nuclear Energy
_3 is meant to be cut under heavy oils and iusbh else besides Sincemany of the CL-20/65 Institt in gathering information. HOW ABOUT THE NIC ACTUALLY iEADING THE c..omponents win have been contaminated with plutonium, or were made of depleted INSPECTION REPORTS AND VIOLATIONS ETC. ON THE DOCKETS OF EACH FACILITY AS I uranium (when is the NIR going to te;4.l the public that DU is'NOT radioactive CL-20166 SAID EARLIER . HOW A*OUT TESTS BEING RUNBi THE NRO ON THE SITE .HOWABOUT CL-20158 waste..?) it i-robvioUs that thwereactor vessl. should NEVER be cuxtup, but INTERVIEWS WITH LONG TIME STAFF CONCERNING PAST PROBEM-1S THAT COULD BE EM*b do.what was done w"th the Trojan vessel (p. (-18,Aesova, the whole, thng offaits)
CL-20/67 COUNTERED? NBC should take its own indRpendant samples-cDooofsite- water andt CL-20/59 Haweer,. the. vessea should.hara additional shielding placed around. it prior tm sediment and suilhlas Wall as onsite.
placumenton the heavy haul trailer, and upon arrival at the disposal site it The NRC mustL not ga, by the. original. Off site Dose Calculation Manuals a f was CL-20/60 should'be further encased in what would amount to a giant burial cask. Remu ng allowed in theaa ent out with thw ARK - i.e. thelaveals- were terrible%, a recipe the vessel offaite massively reduces worker doses, water contamination and the.
CL-20/68 for radioactiveaipollution, I cannot stress. enough that tha egroundwater issuaes.
o ontemination to the local community and the environment, Obviously, theu spent.
%fuel.i/has been removed from the reactor vessel and all liquid radwaita etc.
CL-20/69 ae.r not adeqiately addressed. Tha usim of high. pressure water sprayx.ia obsconw.
I.
01 Co CL-20/61 tbo I UNDER NO CIRCUMSTANCES SHOULD A FACILITY BE ALLOWED THE OPTION OF CHOOSING CL-20/70 1=NG *ITH THE NRG T DW'T NRC UNDERSTAND THAT ONE CANNOT DECONTAMINATE HAT IS SOMETING RADIOACTIVELY CONTAMINATED IK THE TRADITIONAL SENSE, UNLIKE WITH A CL-20/62 THE METHOD OF DEOMOSSIONING IT WANTS, AS IS THE CURRENT CASE. Comhinatloan CHEMICAL OR OTHER CONTAMINANT, WHATEVER IS DONE TO SOEIMNG RADIOACTIVE DOES of DECON and SAFSTOR would be. the best, howaver, under no circumstances should; NOT CHANGE THE CHARACTER OF THE RADIATON, IT CONTINUES TO ENIT ITS DEADLI SAFSTOR continue past five years (the regulation should be changed, as to ALPHABElA,*OJHk , NRUTHON ETC. RADIATION THROUGH THE FULL RADIOACTIVE HAZARDOUS expect that oversight will continue for 60 years at such sites- is- ridiculous)
CL-20/71 LIFE. YOUCAN'T BURNIT/ INCInERATE IT, IT GOES OUT THE STACK AND POLLUTES THE that+/- would enable workers familiar' with the plant to be still available,. but at STACK, YOU CAN'T WASH IT, IT WINDS UP ALL OVER THE PLACE AND IN THE WATER, the same-time allow for the decay of.some of the radioactive contaminants which thugr lowering IT IS ALWAYS THERE. THE DEADLMINVISIgBLE KILLER. AT OST YOU CAN TRY AND have shorter full hazardous radioactive lives prior to removal HE CONTAIN IT. The. Tritims cant even be- contained.
CL-20/63 worker exposure etc.. NO WAYTHIS SIDE OF HELL SHOULD ENTONB I OR ENTOMB II ALLOWED. BOTH STAFF AND THE IMIVIDUAL COI*0SSIONERS SHOULD BE CHADGED W=H CL-20/72 The original site, maps and drawings and, photos made during construction- should CR:IINAIL NEGLIGENCE - ALONG WITH THE LICENSEE - IF THEY PUSH THAT THROUGH, ANDI be, consulted (some building techniques may have changed) all modifications AM CONFIDANT THAT MANYWOULD ENSURE SUCH CHARGES AM FILED. THERE IS INDIVIDUAL and- revisions should be tracked down. All vaent Bystema- should go through both RESPONSIBILITY CONCERNING THESE MATTMS, AND IF NIX CANNOT UNDERSTAND WH!THE HBIA (for the chemicals) and senud filters. Additional containment should.
Z ENTOMB OPTIONS ABE AN ABSOLUTE NO-4O, THOSE WHOCAN'T GRASP THE "WYN PART SHOULD ba added around spent fuel pools including over the top and beneath it, extra CD RESIGN AND STICK TO SOME DIPLOYiT WHEE THE USE OF THE BRAIN IS NOT HIGH ON THE supports, neow liners. They will suffer serious embrittlemet and activation, CD CL-20/73 same goes for the casks. Such issues must be addressed. Again THERE MUST NEVER IQ BE A PARTIAL OR FULL SITE RELEASE. ALL PROPERTY DEEDS MUST STATE THE SITES ARE 0
N3
z Letter 20, page 15 Letter 20, page 16 0
CD 30*
CD 11 8
Pi NOT Ohly RADIOACTIVE, BUT SUPERFUND SITES, AS THAT IS WHATTHEY ARE. THE RIVER, that CL-20/82 land, (The Western Shoshone Nation, AKAthe, Nevada Nuclear Test Site)
LAKE, OCEAN BEACH STRETCH OR WiATEVER IS NEXT TO THE SITE SHOULD BE POSTED AS hlew-radjoactive fallout across the nation causing serious illness, birth defects EVEN IF THE SIDD4ET IS HD4OVED AS IT 1S IlPOSSIBLE TO GET Nevada. Theonly RADIOACTIVE ALRCJ and cancers~besides doing the same to some nearer the site in gambling tables EVER~rTINO. thing Las Vegas worried aboutwas if the tests shook their CL-20174 Security must be upgrade, not downgraded. according to press reports. When the. wind blew towards Las Vegas tha--y tried not
- thatlndfill will be, For Nevada to now. whine that they don't see why they should Wat the CL-20175 . structural remains should, be sent. to local landfis to test.
- is obscenelconsid CL-20/76 radioactively contaminated mome than at present.
As all landfills leak, it will spent nuclear fuel as they have no reactors - power reactors making/creating CL-20/77 go to the. groundwater and migrate offaite. None of the-miad*waste should, bm ering that a huge Curie quantity of the spent fuel was generated end radioactive) of them supportesi and' dealt with as mixed waste (i.e. a combination of chemical/hazardous the plutonium and the tritium for the nuclear weapons- m*at Thw fact because MV= WASTE FALLS THROUGH ALL REGULATORY CRACKS# BUT IT SHOULE BE TREATED didn't care that the fallout dumped on their fellow planetary citizens.
against the. waspous CL-20/78 AS RADIOACTIVE WASTE. WASTE OILS SHOULD NOT BE SENT TO VENDORS FOR INCINERATION that there we."e , and ara, some smal groups who vere~and are, fact that the Stati OIL RECYCLINL OR tMIJSE AS THEY ARE CONTAMINATED. and theLtesting-and the horrors of nuclear power does notbthe AS I HAVE valid for other reasons; CL-20/179 jEV SnT, OPERATING OR NOT OPERATIMGIS A PRIME TERRORIST TARGET did4t pmoteaq. Thw States current protests, even if they use the 'no
.- CL-20/80 SAID FOR =EADER. THE S T FUEL IS THE ULTIMATE IN TERRORIST TARGETS. ring hollow against that history of nuclear collaboration Aen was set straight.
- CL-20/81 Tearsr ago, when peple spoke of some. type of monitored,. retrievable spent ffmal p owle reactor" excuse to keep the waste 'out.. It is- time history or future permanent storage, they meant monitored so repairs could be made by remote control if needed) CL-20183 The NRC in thia Draft says p.' D-2 that the temporary storage not within the, an& retrievable so problemis could be addressed - no ona&in their wrstl. night disposal of spentifusl at'a site-other than t*e.reactor site.sis THIS DRAFT IS mares- with any aenee, ever imagined that a bunch of nuclear bozos would be- allowes scope-of this Supplement. Why the hell not T It MUST MEOTHERWISE MST SERIOUS ISSUE TH IS.
to stick the most deadly stuff known to humanity in a cement and metal barrel and CL-20184 EVEN MORE MEANINGLESS. THE SENT FUEL IS THE ANONE WHO DOME NOT UNDERSTAND THAT SPENT FUEL CANNOT BE LEFT WHERE IT IS (ALL TOGETHER Now...)
stick it outside in plain view. Spent fuel-is the stuff BEYOND A VER LIMITED NUMBER OF YEARS, BUT MUST ON SITE, IN POOLS OR TOM ISFSI'S to contihin for approI.
that theDepartaent-of Energy has been charged with try.Ij AS SOUND AS POSSIBLE, HE PLACED aE? UNDERGROUND, IN A DRY LOCATION, GEOLOGICALLY it becomes the-radioactive 10j,000 years removed from the biosp*here,. after which NUCLEAR ISSUE AND MONIOBED FOR ETERNITY, DOES NUT UNDERSTAND RADIATION OR THE stick it. That assumes they x blob from hell under whatever piece of dry land they ITE THE PROVERBIAL BULLET AND SHOULD NOT BE WR0INO FOR THE NBC. NRC MUST for 10,000 years, wbhic I doubt. I have many concerns with the Z can contain it SETHTM TM W THE SPENT FUEL SHOULD ALL BE RMOVED OFFSITE AS NOLATER THAN TW C here, but will mention that the POOL,I.E.
X Yucca Mountain site. I will not elaborate on YEARS AFTER THE LAST CORE OFILOAD HAS SPENT TEN YEARS IN T7E SPENT FUEL in the extreme; G) "dump it on the Native Americanao idea, is odious end imoral FIRO!SPENT FUOL REMOVED FROU THE REACTOR INTO THE SP=T FMEL POOL AND THEN THE TEN 6 already 01 Yucca Mountain is sacred to them.. That having been said, the sits is YEAR "COOL DowsUPLUS TwO YEARS, (A SAFETY MARGIN), AFTER WHICH IT iST BE mOVED.
100 teats, and Nevadas belated concern GOING TO BE STUCK WITH O) contaminated due to fallout from the ujeapons IF SUCH A DEADLINE IS NOT DICIDED, ANDSET, COM*UNITIES ARE the. state, "about radioactive issues is hypocritical and distaksful, as this is' that did not give a damn that hundreds of nuclear tests were conducted on Indian D
Z C Letter 20, page 17 Letter 20, page 18 01 03 P IT , WITH AWUL CONSEQUENCES.
"-I
'I 1%.
0)
C The "Mobile Chernobyl" issue - thajdangerous moving of the spent fuel to a, CL-20/90 Under "Dose to members of the public" p.. G-19, and following pages, the doses F0SITOH! , can be somewhat alleviated by aL~dessing the concerns people to the public are'liated in the usual deceptive and innacurate moanner.
CD CD CL-20/85 have instead of ignoring them, as follows s Thm Dramf shows the awful DOT CL-20/91 Thm radioactive material releases is not released in stringently controlled and NRXregulations for transport and radiation levels allowed p. 3-14, theser c-onditions, technical- specifications are often violated, monitoring is only should be changed to be-massively lower, this can be done by better shielbng" CL-20/92 d.one at select locations and frequently monitors don't work, emissions-aren and more shielding and the~transport. of fewer asse-blies per cask or fewer allowed to be averaged out to make them appear less, and there is no independent rods per cask, and shielding that is thick enough that anti-tank weapons CL-20/93 monitoring and utilities do and say whatever they please. Tritium can't bh would not penetrate through to the fuel.. Disguising the shipments is not. CL-20194 contained. The direct gamma radiation coming off the plants to the public is equivalent of a continuousi I-ry emanating from their midst. No X-ray an option due to the size of the casks,. thereforaufar stricter security i.a% the military escorts and the sealing off of roads ahead of transports would be a, is "negligable-. (This sort of garbage:was probbly written by someone who ism needs to pens rules on these issues, and put.out orders for morm CL-20/95 not a medical proffessional) . Often the plants: DO NOT HLVE TO BEPOBT THEIR CL-20/86 must. Th--NWR and better transport casks and vehicles. All shipments of"LLVL should alsau:ell 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 under these batter packaging and shielding standards.. If ther NRG does- not
-u HATCH IS SICKE2(IN - WHE HATCH HAD THEIR DISASTRDUS SPENT FUEL POOL SPILL, CD address all these issues as part of decommissioning, future generations (that DID ANYONE ADD THE EXTRA DOSES AND CONTA9INATION IN 7 THIS IS THE SAME HATCH means IOUR children and grandchildren) are.going to die due-to NWlse' lack of CL-20/97 WITH OVER 1200 wom=ER CONTAMINATION EvnTS IN ONE EA,. WH YOU CALCULATED CL-20/87 actions today. It.is murderous that potential radiological impacts following, to kctivitea performed THE RADIO-ZODINES, DID YOU ADD IN THE HUGE RADIO-IODINE KILEASE OFF PLANT lice nsing/licanse termination that are related FAME! THAT WENTUOER GEORO1A ?
during- decommissioning are not in the Supplement - this allows the licensee to CL-20/98 Ta point'. is, that no one asked'to be exposed to AnH dose of radiation,, and' c.low*wy murder a ommunity as thebradiologicaL criteria for-license termination sites most people in surrounding communities don't even know they are being exposed, CL-20/88 by NRC was woefully inadequate anyway. The, NXC must:zontinue.to monitor-or if. they know, they think they are being prtected because they think therwe EDREVXafter license termination in case of sudden increases in radiation 0 CL-20/99 isa safe level of radiation, when of course ev2n the NRC admitted back in the l3eye.ls from a source on the site no one had either considered or knew was late '17'1 tJa there was no safe level.
CL-20189 there.. All sites should have audible(sirens) alarms that are-tr*ggered during 6 CL-20/1 00 Perbhpmost disgusting is that under "'Consequence of Potential Accidants"p.Z-1 decommissioning , and after decommissioning, when monitors exceed the. EPA the impression given is that spent fuel pool accident risks are low, when in ievels EPA allows,, but reduced below what EPA allows to give an advance fact- NRC a own cited document showshundreds upon hundreds would die, and also warning.
z Such, audible alarm systems are absolutely vital also during the.-the time many spent fuel pools were highly vulnerable to catastrophic accident-4.ile to radioactive spent fuel is still on the site, these alarms should be at earthquakes and a lot more besides - spent fuel pool accidents would havw Co terrible consequences. The-fact that licensees determined that basically various, locations onsite, including next to the spent fuel pool and one, C* 67en if the damned site was hit. by a meteor and a, nuclear bomb and a 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.
z Letter 20, page 19 Letter 20, page 20 CD CD X0.
generations of children,vome, men, plants,animals, insects, birds, fish - all and a hurricane all at. the same time (obviously I am being sarcastic) -a life, is going to suffer fromsand die by. A small bunch of (mainly) m*e i2n.
nothing would hapen- and there would be "nTodose; consequenceW is to be soeceted sae,the licensee analyses are, a bad joke. office co=plax in Washington, along with a few cohorts elsewhere, plus an REPORT DONE immoral multinational polluting industry (in the business for money only) arem CL-20/102 M NRe SHOULD READ ITS OW DOCUMERTS AND THE FAMOUS "CRAC-!"
BY SANDIA LABS, THE NC AND THEN CONG SIONAL OVERSIGHT BECAUSE TO PRESET seemingly se tting a set of criteria that will impact the whole world to no DATA TIM FRC4 LICER*sI B,-ASIS DOCUMENS WHICH HISTORICALLY HAVE DOWN CL-20/108 good end end cause great misery , in this Draft. Haver:you all no shame 7 FUEL IN PLAYED ANYTHING'THAT COULD HAPPD4 IS UUTRAGEOUS, AND IF THERE IS STILL CL-201109 Th radioactive components,parts, liquids i.e. anything pert of or to do with or REACTOR HAS BE OR RE-_USED.
THE REACTOR IND A LOSS UF WATER COOLANT HAPPENS, EVEN IF THE emanating from the structures and the site MUST NEVER RE HE-CYCLVE, SHUTDOWN RECENTLY, IRE WILL BE AMELTDOWN. CL-20/110 NM MUST DIMNIATEY CEASE ALLOWING , OR THINNG OF ALOWING, RADIOACTIVELY to walk into thiLsrea wherethen Son To B RE0USED FOR ANYTHING. IT MUST FORIDM TEE MTIrNG,SMLTING CL-20/101 I chall*Inge any licensee and any NRC stafferp, CL-20/111 COTAmImu fuel pooland OR RE-USE OF RADIOACTIVELY CO07AMINATiD METALS, PIPING, PLASTICS, 4OOD,(INCLUDING spent fuel pool is after the water has drained from the spent is: what they thought CL-20/112 FORBIDDING. THE BURNING OF WOOD) , ASPHALT, AND SO ON. IF NRC, EPA, THE DOE AND try and refill the spent fuel pool with a garden hose (that a Rdactor) and- see,bow well OTHRS DONOT STOP THIS INSANE RUSH TO RENUSE,RECYCLE, DUM AND COVER ETC. NUCLEAR they'd do at the Georgia Instittte of. Technology
"-u 5 they can "mitigate the situation before woffsiteýdose consequences could MATERIALS, RADIOACTIVE MATERIALS, ACTIVATED MATERIALS ETC. , WITHIN FIFTY YEARS hose. Tosay that such NO LIVING BEING WILL BE BORN WITHOUT SOME TYPE OF DZMRMITYGII!EIC ABNOR4ALITY, occurs -- they'd be.dead beforeathey could pick up the the height of deception. CEHRO0SOHE ABERRATION ETC. AND THE IMUNE SYSTEMS OF EVERY LIVING BEING WILL BE an accident could be mitigated is SROUSLY COMPR0MSED DUE TO RADIatION SUPPRESSING THE f NE SYSTE4 RESPONSE, AND Radiation, that CL-20/103 On p- M-Z it says., under the glossary , under Background
'AN ENHANCED, from background radiation ALL BECAUSE WEWIL BE COMPLETELY ENGULFED IN A MIASKA OF MAN-MIDEIOR Othe typically quoted US average individual exposure but it is.a blatant LI RADIOACTIVE CONTAMINATION..
is 36DTmrea per year! It msy be typically quoted, is A2 mren year accosdiW I havewritten this on and off over a series of days after finding out For' example,. typical background radiation in Georgia a waste to the State (which recently upped it a inotch probably due mu zhe radioactive CL-20/113 the comment.period bad been extended. I recognize that it has probably been and the Savannah River NucTeW of my timeand .wil be ignored, as usual, therefore I am not bothering to vrite fallout on the State from nuclear power plants and isr also a, LIE, in that it). again with every paragraph in the right- place.. In any event I speak,read CL-20/104 Sit*'on its borders- The. dhfinition of CONTAIATION somewhat if it's in excess of "acceptabla writi:three languages and the grammar and spelling in all of them suffers Z it states that 'omething is contaminated is the content that mattersi The fact is, wherever this radioactively C the public does not accept any CL-20/114 but it SCL-20/105 levels". There are~no "acceptable levels"'-
m refuse winds up - from spent fuel to contaminatedL rags - it cam' t cobalt-60,Strontium-90 etc. or contaminated (7) level of radioactive contamiýation - plutonium, bemcontained forever end will reach the environment, whibh is why it must. go to means i that som 01 CL-20/106 tritium ,radioactive iodine and so on and on - Contamination or 00 defiles or a remote location,below ground, (noneof this idiot parking lot out in Utah P) thingsomeone etc. has been brought into contact with sonething that a
Cn must stop redefining words and Nevada cask stbrage either ) in dry- geologically sound (as far as possible in Spollutes it etc.. -- go look the word up - NRC arise prior moving planet) location where monitoring could alleviate problems that CD lying about their meaning. NRC must recognize that this solutiom to.reaching the public and wildlife.
is what the following cD CL-20/107 What the NRC decides to do concerning decommissioning,
c zI Letter 20, page 21 G) 6 (31 to *A.\
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C"J while not a perfect solution as there is no perfect solution to the
- __ nuclear waste issue - 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. NRCshoul& 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 Draftt 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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z Letter 22, page 1 M
00 From: <sublimation @webtv.net>
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Cn To: <dgeis@nrc.gov> Lk/ 5 Date: 1119/02 10.57PM CD
Subject:
decomissioning reactors: environmental impact supplement 1 CD CL-22/1 This is ndiculousl CD httpJ/community.webtv netsublimation/DlsregardAJLAdsHere
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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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Z Letter 24, page 1 C
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- From: "rsla" <rsja@email msn corn>
C) To: <dgets@nrc gov> All, Date: 1/20/02 2 03PM
Subject:
Public comment on USNRC Decommissioning US Nuclear Power Reactors D
CD To. Chief.
3 M Rules and Directives Branch Division of Administrative Services Maltstop T 6 D 59 US Nuclear Regulatory Commission Washington DC 20555-001 for nuclear power reactors.* The CL-24/1 I am appalled at the NRC's draft of decommissioning requirements I oppose the use of "Genenc listing of requirements should be made stricter not more relaxedll 111111111 CL-24/2 issues. I support "Site Specific" listing so that local communities can still raise issues they have.
issues as site-specific, NOT CL-24/3 I support the designation of environmental justice and endangered species generic.
Cr CL-24/4 I oppose Rubblizalion but support its designation as site-specific.
daily consumer use and CL-24/5 I Firmly oppose the 'release* of radIoactively contaminated matenals into commerce and unregulated disposal.
safest and In the best interest of the CL-24/6 This Is common sense people. You need to start doing what Isrelieve the nuclear power companies of people of the United States and its land, NOT what is going to their responsibility to what they have created and profited off.
rl Citizen of the United States of America Rachel Grftdhs 2022 West Chicago Avenue Chicago, IL 60622
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z Letter 25, page 1 Letter 25, page 2 (I) I 3
4, must Incorporate offsrte contamination In all evaluations of environmental From: <EdRussel@aol corn>
8 To: <dgelsOnrc gov> CL-25/9 Impacts. The National Environmental Policy Act was wntten for a purpose, your proposed rules side step that purpose.
to1 Date: 1/20/02 9 34PM
Subject:
Decommissioning rule changes 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 Law Offices of CL-25/11 firmly against the 'release' of contaminated materals Into daily consumer Edward T. Russell contact and commerce or unregulated disposal.
725 Long Pond Road Plymouth, MA 02360 CL-25/12 Deregulation has already had serious negative Impact on local municipalities 508-224.2007 this will be just another blow 3
Sincerely,
-1 January 20, 2002 Edward T. Russell l'3 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
"-U awakening for me and for many others In eastern Massachusetts.
rules. We CL-2511 I strongly object to the proposed changes to the decommissioning power have recently become more sensitive to the rules governing nuclear 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.
In hands that are CL-2513 Utility deregulation has put the ownership of these plants 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 additional risk these rules would place on theus. Until the spent rods are
- 0) CL-25/4 decommissioning rules should be removed from local nuclear power plants 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 close and owners (X-25/5 Many key issues that local communities face as reactors z leave (lIability-free) will be unchallengeable, because they are being listed as 'generic' issues. I support the designation of environmental justice and Co M CL-25/6 endangered species issues as site-specific (not generic) and designation of m Rubblitzation as site-specific.
M The NRC CL-25/7 The proposed rules Ignore radiation dangers after decommissioning CL-2518 Cl) 2
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z Letter 26, page 1 Letter 26, page 2 C
m lllq/oi From: Dave Matthews <david matthewsa sun.corm> NRC states that the portion of the decommissioning regulations (10 CFR
- 0) To: cdgeis@nrc.gov> 20 section E and its Environmental Impact Statement, NUREG 1496) that Date: 1/21/02 10.52AM set the 25, 100 and 500 millirems per year allowable public dose levels C
Subject:
Decommissioning Nuclear Power Reactors EIS Suppl from closed, decommissioned nuclear power sites, are not part of the C scope of this Supplement
Dear Sirs,
CD I am writing to comment on the EIS supplement 1. NRC defines decommissioning, in part, to Include the 'release of property for unrestricted use. .. ' and the "release of property under CD CL-26/1 Ingeneral. I am strongly opposed to the attempts to designate many restricted conditions...'
esues as geneno Instead of site specific and thus to remove these CL-26/15 I stand firmly against the 'release" of radioactively contaminated issues form public review end comment. materials into daily consumer use and commerce or unregulated disposal.
CL-26/2 Specifically. I am opposed to the following proposals in the EIS:
Thank you NRC allows "rubbktzaton" (crumblng the concrete reactor building) of David Matthews nuclear reactors, without opportunity for public intervention until the action Iscompleted.
CL-26/3 NRC allows portion of lites to be "released"from regulatory control before the whole site It released. ii CL-26/4 NRC opens up two "entombrment" options.
-l CL-26/5 NRC Ignores radiation dangers after decommissioning is done and utility is relieved of llabliy. cri 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.
CD 00 CL-26/10 NRC prevents the National Environmental Policy Act from applying to most of the decommissioning process.
specific opportunity to CL-26/11 NRC redefines terms to avoid local, site decommissioning question, challenge and prevent unsafe 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 Insite-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.
':e
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Z Letter 27, page 1 CD CD ;/1/5/0 0 From: "*KlausSchumann' <jayklausO email msn corn>
0 To: <dgeis @nrc.gov>
Date: 1/21/02 12 52PM
Subject:
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 may call for some more secrecy. in most cases Its a While the 9/11 events gates matter of 'closing the 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 Ifwe eliminate the necessary public discussion the terrorists will have won[
KLaus Schumann
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From: Dennis Larson <larsondf@yahoo.com>
To: cdgeis~nrc.gov>
Date: 1/21/02 1:36PM
Subject:
reactor decommissioning Co C Re: decommissioning nuclear reactors CD 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 ,01 N, From: <Tifkeliaol corn>
To: <dgelsO nrc.gov>
Dale: 1/21102 7.32PM
Subject:
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 uses.
or commercial CL-29/3 radioactive contaminated materials Into daily consumer That Is an idea that Is Insanely dangerous. Would you eat off a fork that contains radioactive mataerial? Why would anyone?
Sincerely, Martin Kellernman N,
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- QNQM CT..iq(. YANKEE ATOMIC POWER COMPANY 9 "U.
S. Nuclear Regulatory Commission 00 YANKEE ATOMIC ELECTRIC COMPANY 4
362 njttlfw Road, East Hanmpton, Conecdmo0642 -309
' 3d2 BYR 200 1-084/CY-01-199 I Page 2 o') 19M~dtate Drive, Aubun Massachset 01501 CD December 26, 2001 Sincerely, 3
BYR 2001-084 CD CY-01-199 Kesneith J. elderij Vice President of U'perations &Decormmissioning Chief, Rules and Directives branch Division of Administrative Services Mailstop T 6 D 59 cc. H. J. Miller, NRC Region I Administrator U.S. Nuclear Regulatory Commission J. E. Donoghue, Senior Project Manager, Haddam Neck Plant Washington, DC 20555-0001 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 Haddam Neck and Yankee Rowe Plant Paul H. Genoa, Nuclear Energy Institute Comments on Draft Suplptment to GElS E. L. Wilds, Jr., Director, CT DEP Monitonng and Radiation Division Yankee Atomic Electric Company (YAEC) and Connecticut Yankee Atomic on Power Company (CYAPCO) appreciate the opportunity to provide comments the draft supplement I to NUREG-0586, "Final Generic Environmental Impact
-4 Statement on Decommissioning of Nuclear Facilities".
-Ja In a letter dated Apnl 25, 2001 (), CYAPCO submitted a response to a Nuclear support Regulatory Commission (NRC) request for additional Information to development of the Generic Environmental Impact Statement (GElS) supplement. Many of these comments were incorporated inthe draft the CL-30/1 supplement In general the draft supplement meets the goal of updating We GElS to current decommissioning practices and dismantlement options.
Inthe have reviewed the draft supplement and offer specific comments contained attachment.
Gerry van Ifyou have any questions regarding this submittal, please contact 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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z Letter 30, page 3 Letter 30, page 4 0
CD Cr CD C) "U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission BYR 2001-084/CY-01 -199 / Attachment 1 Page 2 0
BYR 2001-084/CY-01-199 / Attachment I Page 1 YAEC & CYAPCO Comments on the draft supplement to the GEIS 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-30/2 1. The Figure 1-1, "Decommissioning Timellne" should also reflect the 60 year window, mentioned In 10CFR50.82(a)(3), that starts from the permanent The last sentence on page 3-15 is only true if corrosion products are included.
cessation of operation. CL-3018 7. The sentence should be revised to read:
CL-30/3 2. Revise the first part of the last sentence on page 1-5 to read: If corrosion products are Included, the radioactive decay ...........
If a licensee chose to operate the ISFSI under a Part 50 license, they The last two p.ragraphs on page 3-15 need to be rewritten. The discussion of could choose to continue under the Part 50 license, or by way of license CL-30/9 8. contamination and activation needs to be clarified. Ifrequested, CYAPCO will amendment request .................. work with the Commission to rewrite this text.
CL-30/4 3. Delete the discussion of 'Rubblization" on page 1-7 and delete the term Yankee Rowe should be added to the list of plants mentioned In the second to
"*Rubblization" In the Glossary (Appendix M). Maine Yankee first utilized this CL-30/10 9. last paragraph of page 3-26. The Yankee Nuclear Power Station was one of the term in a January 13, 2000 letter which served to submit their License plants In the AEC's Demonstration's Program. Yankee Rowe's license number is Termination Plan (LTP). On June 1, 2001, Maine Yankee filed revision 1 to DPR-3.
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 The second to last paragraph on page 3-32 discusses the creation of nuclear 10.
W' no longer utilizes the term. No licensee is currently pursuing the "Rubblization" CL-30/11 Islands. Nuclear Islands are not primarily created because of security reasons.
-4 concept as described in Maine Yankee's original LTP submittal. 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 The term which most accuratel describes the 'approach which licensees are safe long-term storage of spent fuel, which Is Independent of the remainder or currently pursuing is 'concrete backfilr. Connecticut Yankee described the the rest of the facility. The purpose of the modifications Is to divorce the spent process as follows in section 4.3.1 of our LTP submitted on July 7, 2000: fuel cooling function from dependence on systems which must be dismantled as part of the overall decommissioning process.
Concrete from contaminated structures will be romediated to a level meeting the radiological criteria for unrestricted release of the site. After Expand the discussion about Stage 4 of the decommissioning process. This completion of final status surveys and absent any findings during NRC discussion should contain as much description as the descriptions under stages inspections, concrete building debris from decontaminated structures may 1 through 3.
be used as backfill and placed Into the remaining subsurface building "foundations.' 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 page 3-6) revise the last two CL-30/5 4. Under the description of the Turbine building (on discharge to surface water locations.
sentences to read:
z C: Primary coolant is not circulated through the turbine building systems In building to become m PWRs. However, it is not unusual for the turbine lG) mildly contaminated during power generation at PWRs.
(n CL-30/6 5. Add the following sentence to the first paragraph in section 3.1.4:
O)
W Most of the contamination In the reactor coolant system is from the
"-~ activation of corrosion products and not fuel.
CD 3
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Z Letter 31, page 1 Letter 31, page 2 C
ITl 6 Exelbn.
0Y1 Co ExclonNuclear www.exeloncotpcVF.C Nucle* TI ATTACHMENT 1 200 Exelon Way Generic Comments on NUREG-0586 Draft Supplement I KermetiSquare. PA19348 Cn 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.
CD We reach this conclusion based upon our experience decommissioning one BWR (Dresden 3
CD - 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 December 28, 2001 Supplement to the GElS.
CL-31/2 2. Exelon continues to maintain that providing guidance, which addresses environmental Secretary U.S. Nuclear Regulatory Commission A. -- issues generically, provides the highest standard the public at large can use effectively to Attn: Rulemakings and Adjudications Staff challenge industry to return power plant sites to beneficial use upon facility retirement Washington, DC 20555-0001 CL-3113 3. The Supplement properly addresses the ENTOMB decommissioning option Issues related
Subject:
Comments Concerning Draft Supplement I to NUREG-0586, *Final Generic to the ENTOMB option after the facility has terminated Its NRC license and entered the Environmental Impact Statement on Decommissioning of Nuclear Facilites" entombment period are outside the scope of this GELS. Power reactor entombment is not (66FR5671f2, dated November 9, 2001) 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
Dear Sir or Madam:
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 This letter Is being submitted In response to the NRC's request for comments concerning Draft facility may be found in the ability to reuse the site in the future for other purposes.
Supplement I to NUREG-0586, 'Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities" which was published In the Federal Register (i.e., Regulation goveming LLW disposal facilities does not contemplate future use of the site,
,u 66FR5672',dated November 9,2001). The NRC Is proposing that this Supplement updates restricted or unrestricted. Future use of an entombed site will be dictated by the dose information In the existing 1988 GElS relating to pressurized water reactors, boiling water based performance cntena found in 10 CFR Part 20, Subpart E.
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 CL-31/4 4. The Supplement improperly addresses rubblization by stating it will require a site-specific NRC's intent is that this Supplement be used to consider, in a comprehensive and generic analysis at the time the license termination plan is submitted Rubblization should be manner to the extent practicable, the environmental impacts of radiological decommissioning of addressed generically as a part of the decommissioning process. The NRC should continue nuclear reactor facihties by incorporating updated information, regulations, and analyses. 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, Exelon Generation Company, LLC (Exelon) appreciates the opportunity to comment. Generic rubblization has a SMALL environmental impact.
and specific comments follow in Attachments 1 and 2, respectively. If you have any questions, please do not hesitate to contact us.
CL-3115 5. The Supplement incorrectly addresses the impact on the SAFSTOR scenario due to the Very truly yours, 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 Michael P. Gallagher efficient manner. Regarding the familiarity of the facility at the end of licensed life, whether Director, Licensing and Regulatory Affairs the plant begins decommissioning immediately or waits for some defined period - the most Mid-Atlantic Regional Operating Group 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 Attachments 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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Z Letter 31, page 3 Letter 31, page 4 Co CD ATTACHMENT 2 10CFR50.75 the decommissioning cost estimate for Peach Bottom Unit 1 reported in Specific Comments on NUREG-0586 Draft Supplement I beginning of year 2001 dollars is 65 4 million dollars Table 4-3 should be changed to reflect the latest cost estimate.
CL-31/6 1. On Pg 3-17 there Isa discussion of the advantages of the DECON alternative for L-31113 8. Table 4-4 lists the decommissioning cost of the high-temperature gas-cooled reactor in decommissioning. One advantage of DECON Is not discussed and should be SAFSTOR (Peach Bottom Unit 1) to be 54 million dollars (in January 2001 dollars). In our Generally speaking the shorted lived nuclides are easier to detect because of their letter submitted on March 30,2001, in accordance with 10CFR50.75 the decommissioning beta/gamma emissions, versus the alpha emissions of longer lived nuclides. The cost estimate for Peach Bottom, Unit 1 reported In beginning of year 2001 dollars Is 65 4 difficulty of detecting the alpha emitters will increase analysis costs and increase the million dollars. Table 4-4 should be changed to reflect the latest cost estimate, 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. ;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
- 2. On Pg 3-19 the discussion of the SAFESTOR option assumes that there Is a savings Safety Analysis Report However, Table F-2 reports the total site area for Peach CL-3117 associated with less Solid RW disposal costs. However they do not consider that Bottom Units 2 and 3 to be 618 acres. Table F-2 should be changed to reflect the the current NRC guidance for release of material includes a no detectable cnteria. total site area for Peach Bottom Units 2 and 3 to be 620 acres.
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 'L-31/15 10 Table 1-3 incorrectly lists site flooding as the only accident analyzed for Peach support this assumption. 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 CL-3118 3 On Pg 4-9 the NUREG concludes (Sec 4 3 2.4) that the environmental impact of Table 1-3 are:
water usage will be small. In the evaluation they consider the anticipated reduction "* Release of helium coolant under containment breach (open penetration to in water usage for cooling in the condenser. This conclusion appears reasonable, containment) for accidents involving radioactive materials (non-fuel-related) on however the analysis should also consider the environmental effects of the loss of page 1-9
-4 heat provided by cooling water discharged to a closed lake or pond system that is a "* Fire inside reactor vessel under fire for accidents involving radioactive materials habitat for aquatic animals and vegetation. Many nuclear facilities are on natural or (non-fuel -related) on page 1-10.
-Jn man-made bodies of water making this environmental effect generic in nature.
L-31/16 11. On page 1-6 of Appendix L, line 4 refers to cnticality accident monitoring CL-31/9 4 On Pg 4-16 the NUREG concludes (Sec 4.3 4 4) the environmental impact of air requirements descnbed In 10CFR7.24 Cnticality accident monitoring requirements emissions will be small In the evaluation they did not consider that many sites use are descnbed in 10CFR70 24. This typographical error should be corrected.
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 ;L-31/17 12. On page 1-6 of Appendix L, line 17 refers to 10CFR50 73 as requiring a licensee steam. This needs to be considered in the NUREG or many facilities will need to event report within 30 days 10CFR5O 73 was recently revised to require a licensee address this issue in their PSDAR event report within 60 days This change should be made to Appendix L, CL-31/10 5 On Pg 4 -29 the NUREG (section 4.3 8.3) concludes that it is not necessary to 'L-31/18 13 While the Supplement addresses two entombment options stating they have update estimates for collective dose due to decommissioning activities. This is an prepared as extreme cases to envelop a wide range of potential options, there Important conclusion that Is supported by the current range in collective dose that should be additional language early In Section 3 2.3 ENTOMB clarifying that utilities decommissioning plants have experienced. Any change to this conclusion needs to are likely to develop entombment scenarios based upon their site specific needs.
be well supported by actual data and needs to be thoroughly studied to identify all potential impacts.
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.
Z CL-31/11 6 Table 4-1 on page 4-30 Is misleading The totals given include 100 rem of transportation C
dose that Is not tracked by the facility undergoing decommissioning. It also does not include r dose Incurred during construction of a Spent Fuel Pool Island or in support of a dry cask oX (T1 storage campaign. A footnote should be added explaining these differences be 54 million dollars (in CL-31/12 7. Table 4-3 lists the decommissioning cost of Peach Bottom Unit I to January 2001 dollars) In our letter submitted on March 30, 2001, in accordance with r
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6) 6 ii/'/ oi 00 From: <GEORGNBAY@aol.com>
91 To: <dgeis@nrc.gov>
cf Date: 1/24102 9.17AM
Subject:
relaxing standards CD B
Dear Sir/Madame,
CL-32/1 I urge you to stop any further relaxing of nuclear power reactor decommissioning requirements. Enough Is enough. The suggestions you are "makingtoward 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 page 2 Dods Mendiola- Weakenmng Reluirements for Decommssioning US Nuclear PowerReactors rMoioa..Weakening Requirements for Decomrrssis IongUS Nuclear PowerReactors From: Margaret Nagel <dormargaretnoearthllnk not> CL-33/11 S. Ignoring offslte radiation and permitting utilities to ignore it in To: <dgelsOnrc.gov> CL-33/12 decommission planning NRC should Incorporate offsle contamination Into all Dale: 1124/021 S1PM evaluations of environmental Impacts
Subject:
Weakening Requirements for Decommissioning US Nuclear PowerReactors I also utterly oppose:
From* CL-33/13 1. Preventing the National Environmental Policy Act from applyng to most of the decommissioning process.
Margaret Nagel 631 Hneman Ave CL-33/14 2. Making moat aspects of decommissioning genencr rather than Evanston, IL 602 22-2514 srte-speciftc, so they cannot be legally reviewed or challenged at Individual sites To, CL-33/15 3. Redefining terms to avoid local, Site-specifIc opportunity to question, Chief. Rules and Directives BranchlDivislon of Administrative Services challenge, and prevent unsafe decommissioning decisions.
Msilstop T 6 D 59 US Nuclear Regulatory Commission CL-33/16 4 salting low, medium, and high'toenvironmental Impact categories for each of the steps In decommissioning, give the appearance that some things Washington, DC 20555-0001 have negligible effects that don't warrant further conslderation.
January 24, 2002 CL-33/17 S. removing the requirement for a license amendment when changing from a US nuclear power reactors, nuclear power operating ricense to a nuclear materials possession-only CL-33/1 In setting requirements for decommissioning license, thereby eliminating the opportunity for public challenge or please bear In mind other things besides the needs of Richard (Enron) that be. Long after adjudicatory processes.
Cheney, Halliburton Inc., Brown & Root, and other powers 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 CL-33/18 6.attempting to legally justify the removal of the existing opportunities activities nuclear power Industry was a colossal mistake to begin with. as we allon know. for community Involvement and for legal public intervention until of every Itng thing such as flushing, cutting, hauling ard possibly rubbzizng of the reactor CL-33/3 Most of us also reaize that the Immune systems stressed are complete - in other words, until the damage has Irretrievably been this planet - human systems Included - are becoming Intolerablyall
"-4 by mounting (and syriergisticaly Interacting) levels of pollution of of done.
CL-33/4 sots. To add to these levels by deliberately Ignoring the dangers ti radiation exposure is wantonly criminal. Those who do so will go down In CL-3311 9 7. statling that t0 CFR 20 section E and Its Environmental Impact Statement.
history as villains of the worst sort: smug, obtuse, shrlvel-hearted. I--,
NUREG 1496, are not par of the scope of this Supplement.
really decelvirg, opportunistic, self-serving, cowardly, corrupt people who ought to know better, Ifall to see any moral dcrileroeic between terrorists CL-33/20 8 defining decommissioning, In part, to Include the 'release of property CL-3315 who fly planes Into buildings, and bursacrats who are perfectly witting to for unrestricted use' and the *releaseof property under restricted radiation. In the name conditions' .. in other words, releasing radioactively contaminated CL-33/6 expose whole populations to additional dangers from and unregulated disposal How of humanity and morality, you should all leave your jobs now In righteous 11 commerce materials into daily consumer uset and being asked to do. Walk out. Say goodbye. Go work at can you contemplate such a thing' 11lllflll protest at what you're health of this Wet-Mart Ifyou have to But don't recklessly endanger the nation by acquiescing In these evil plans Sincerely, Margaret Nagel I utterly oppose, public Intervention CL-33/7 I "rbbllzation"with no opportunities for meaningful ahead of time control before CL-3318 2 allowing portions of sites to be released from regulatory the whole site Is released.
and ullty i z CL-33/9 3 ignoring readiation dangers after decommissioning is done Z relieved of liability. L C members of CC: Margaret gov>. Nagel
'Peter <formargeretniearthlink.net>, senate govy
'Richard J Durbin*
G Fitzgerald' ýsenatorjf'tzgeraldtlfitzgerald m CL-33/10 4 Ignoring radiation exposures to children and other vuklnerable
'critical group'
.dick @durbin senate the population and creating a fictitious highest exposed 6') based on unsubstantiated assumptions.
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From: 'Liane Casten' <lcasten@interacceas.com>
9 To: <dgeis@ nrc.gov>
CD Date: 1/24102 3.40PM
Subject:
NUCLEAR POWER PLANTS CL-3411 To even think that decommissioning nuclear power plants' regulations via presidential fiat is acceptable is beyond logic and reason.
CL-34/2 You are Insunng the further deterioration of health for innocent cwlians and this planet.
CL-3413 Bush is stripping us all of those safeguards we all need to protect citizens-and this Includes you. He has CL-3414 only corporate Interests-the nuclear power industry being one. To enforce no riabilty after they leave is CL-34/5 simply criminal. You do not need to further endanger our Ives while the polluters go scott free..
Enough.
kane Casten
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From: <little lamb@att net> 11/9/q /1 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 ifyou 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 L.
democratic government should not seek to shut their people out of decisions that effect their lives. Itis a very sad reflection on the state of our democracy that
-4 this seems to be precisely the aim of your draft I')
(. 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 I;
'inconvenient for you? l3 D Ifyou 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 dfyou 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 z 212.923.7800 x 1303 C
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From: Donald Miller <d.w miller@csuohio.edu>
3 To: <dges@nrc gov>
Suzanne Miller Road 3142 Yorkshire Date: 1/25/02 5.56PM Cleveland His, Ohio 44118
Subject:
NRCas supplement to NUREG-0586, re decommissioning I have some questions.
CL-36/1 Why, Inthis 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 ma 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 willbe manimaaLwhy does It seek to remove all liability from the owner even before the process Is complete? (if the NRC Is wrong, who willpay?)
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 0, challenge, as must the hazardous technology (I think of the continuing, poisonous twin-towers fallout) of rubblization.
C:)
00 CL-36/4 The NRC must retain regulatory control Ofthe 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. c3
£2 "I 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,
,er- = '9 bAf - :3 r /I--
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CD 0 I C0 j uions menoow- -iar fm-nrnerrl on ue ro . arab, prao* auu , i From: 'James Nordlund <reality@pld corn, To: <dgels@nrc gow. 111/71,01 Date: 1W26SW27"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 o-j Home Address;- po.b. gB2. lakin, KS 67860-0982 Work Address - s a.
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Send Correspondence - Homne 8)
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.J1 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 zC
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C From: FIoger Voelker -regorOacblackmedia com>
3 To: <dgeis O nrc gov>
Roger Date: 1t27VX28 01PM /J/ /Il 5849 EVoelker North SL, Tucson, AZ 85712 Chiet, Rules and Directives Branch ( ")"
Division of AdministratWe Services J Sign up for FREE email from SCBLACKMEDIA.com at httpJ/www.scblackmedia.com US Nuclear Regulatory Commission (l, (
Washington, DC 20555-0001 r To Whom it May Concern:
The following constitutes my comments on NUREGIV0586 Draft Supplement 1 Generic Environmental
/D 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 02 the way for the very l%) CL-38/1 Now. with Supplement I to NUREGjV0586, the NRC would appear to be paving 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, for use CL-38/4 h the vague and arbitrary use of i§&Small,Moderate, and Largelc significance levela and the intent of these designations, which echoes previous attempted bogus designations such as ibelow regulatory concernmI; I§releasedio from CL-38/5 .h the extant to which radioactive contamination levels that are permitted to be materals routinely, regulatory control for decommissioning would result in the release of radioactive CL-38/6 The draft GElS says that I§low-lavsiiO radioactive waste disposal is not part of the scope of this GElS.
the However. this would appear to be contradicted by the definition of decommissioning (pg. All),and by scope, the release and removal of Stes, Systems and Componets (SSCs).
CL-38/7 Ispecifically oppose any release of contaminated materials during decommissior* g or other times/
procedures.
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0 Dns Mendcila. P-NUSrEG-058 From: "Anne and Tom Moore' <c3mooremhotmail comr> /I-t 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 Itcomes 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 IsImportant and. utility companies should not be exempt from that.
-U 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.
CA) CL-3916 I know that lam not alone In asking you to protect our citizens from N) radioactivity on such a large scale and hope that you will live up to your N" responsibility by not lessening the requiremets that utirity companies face when decommissioning takes place.
Sincerely, Anne H. T. Moore C.') .J1 Join the world's largest e-mail service with MSN Hotmail.
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' '--I VIA EMAIL & Mall 1/29102 ( 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 Inan 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
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Benjamin Schlau
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1/29/02 2 58PM subtle deregutlaon mbetitothecat yahoo cornm 0 justice and endangered species Issues as stte.speciro (not generic).
NiRS opposes Rubblizaeion but supports Its designation as ode-specific Chief, Rules and Directives BranchlDivision of Administrative Servces Mallstop T a D 59 US Nuclear Regulatory Comnission Wasthngton. DC 20555-0001 Do You Yahool?
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CL-4 I/ ithas come to my attention that the Nuclear httpi/auctlons yahoo corn 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 i-i,=.
and Is further C_;
relaxing Its decommissioning requirements for nuclear power reactors* p..,
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. OGenericdecommissioning 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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From: Tom Ferguson .cthnkspeak@earlhknk.net>
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Date. 1129102 4.3PM
Subject:
comment (NRC) draft Decommnilssiong Nuclear Power Reactors EIS CL-42/1 One of the important ard obvious things to be said about decommissioning and nuclear power plants is that it is expensive. potentally dangerous considered.
nearly unprecedented. We appreciate that entombment is now being Itought to be equaly obvius that tOD CL-42/2 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 itselfadmits that the sde is not geologically suitable and the GAO reises serious questions about the CD selection process).
this industry could CL-42/3 2.That a serious accident or terrorist act in be catastrophic. leaving immense fatalibe. injuries, future cancer victims and vast areas uruhebitble for years nuclear power Is CL-42/4 3 That without public ubsIdy (via Price-Arnderson) 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 inits stead Tom Ferguson Cyndla Hunnicunt 3 Kalo Hunnlcutt-Ferguson 372 Oakdand eveso Atlanta, GA 30312
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- DoansMendiol- NUREF-0586 Comments 1N) SZ ' M5endia- NUREF-O585 Doss Corrments P.- T opportunity for pubtli challenge or adjudicatory processes)
From: 'MaryS Reed' <maryreed localnet com> i/9/A/'
To: <dgeIs@nmcgova> CL-43/12 legally justify the removal NRC Is attempting, with this supplement, toInvolvement Date: 1I29/02 5 44PM of the existing opporttinties for community and for legal
Subject:
NUREF-0586 Comments public Intervention until after the bulk of the decommissioning has been completed. This includes such activities as flushing, cutting, hauling Chief, Rules and Directives Brrch/ Division of Administrative and possibly rubblizing of the reactor.
Servicead Maf stop T 6 D 59 US Nuclear Regulatory Commission portion of the decommtssloning regulations (10 CFR Washington, DC 20555-CO01 CL-43/13 NRC stales that the 20 section E and Its Environmental Impact Statement. NUREG 1496) that set the 25, 100 and 500 millirems per year aliowable public dose levels I am opposed to the foflowing changes to NUREF-0588 from closed, decommissioned nuclear power sites, are not pert of the CL-4311 scope of this Supplement In Supplement 1 to the Generic Environmental Impact Statement on Decommmsloning. CL-43/14 NRC defines decommissioning, In part, to Include the 'release of property for unrestricted use.- and the 'release of property under NRC aliows "rubbtzation' (crumbling the concrete reactor bui*lIng) of restricted conditions.'
nuclear reactors, without opportunity for public Intervention until the action Is completed CL-43/15 Ifthe changes pass, many key issues that local communities face as reactors close and owners leave (Iabtily-free)
CL-4312 NRC allows portions of sites to be "releasead from regulatory control 1- -- t will be unchaliengeable, because they are being listed as 'generic*
before the whole site it released Issues. "Generic' decommissioning Issues are ones that NRC determines 2Z cJ apply to numerous reactors and which are supposedly being resolved with CL-43/3 NRC opens up two 'ent"mbment' options this Supplement to the Generic Environmental Impact Statement *Site 0
specific! Issues are ones that can stiff be raised In local commitnlies, Ignores radiation dangers after decommissioning is done and utility but the opportunitles to address even aite-pecifio Issues Is being CL-43/4 NRC is relieved of liablity. curtailed dramatically I support the designation of environmiental justice and endangered species Issues as site-specIfIc (not generic)
NRFC Ignores radiation exposures to children and other vulnerable members I oppose Rubbrlzatlon but supports Its designation as elte-specfic.
0, CL-4315 of the population and creates a flctitious highest exposed "critical
".4 group" based on unsubstantiated assumptions.. to many of the proposed Supplements. The CL-43/16 consider Pleise should public beopposition notmy further shut out of the decommissioning process., Nuclear NRC Ignores radiation offsite and permits utilties to ignore itIn waste Is deadly and It's handling should not be downgraded In any way.
CL-43/6 decommissioning planning NIRS calls on the NRC to incorporate oftiite contamination Into alt evaluations of environmental Impacts. Slncerely, Mary 8. Reed NRC prevents the National Environmental Policy Act from appling to most 29 Sunnyside Road of the decommissioning process (The claim appearsPolicy to be that this Scotia, NY 12302 CL-43/7 proposed Supplement 1 satisfies the Environmental 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.
CC: 'Senator Charles Schumer' <senatorD Schumer senate go=, "Senator Hillary Clinton' CL-43/9 NRC redefines termsand to avoid local, site specific opportunity to <senator @clrmton senate go,>, 'Rep Mike McNuty" inlike mcnuity@mail house gov>
question, chaltenge prevent unsafe decommissioning decisions CL-43/10 unsubstantiated (low. medium and high)
NRC sets arbitrary andcategories environmental Impact 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 zC Inste specific analysis.
m CL-43/11 NRC isremoving the requirement for a license amendment when changing
- from a nuclear power operating Scense to a nuclear materisas G) possession-only license. (With no license amendment, there Is no
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01 endlola - GomnentsNRC Rules on Decornrnvsssorng - EIS Suppternentl Pa.'" 1"=-1 C0 FROII : BE o FAX 10. : 7609419625 Jan. 30 2M2 11i-1Pri P1 (D From: <Pdbsongs1 cs.cn>
3 To: <dgeia@nrc.gov>
Date: 1/29102 7.04PM platncia Borchmann C- 176 Walker Way
Subject:
Comments-NRC Rules on Decommissironng - EIS Supplement I Vista, Ca 92083 D.Gets - NRC (760) 941-9625 I am forwardng Attachment (word document) letter to NRC. wrth my personal comments on proposed NRC Rules on Decommrnsaornmi. Sarnary 30,2002 Please confirm their receipt and acceptance by emaI, Chief, Rules and Directives Brancth 5 .'
Thank you in advance Patrma Borchmann Divislon of Administrative Services I MILstop T 6 D --.
,Zj U.S. Nuclea Regulatory Commission CS WashIngton DC 20555-0001 WJ Email to: d&CIS@um=
Ill: US, Nuclear Regulatory Coemlissoa's Draft Deeommissioning Nuclear Power
.4 Reactors LI.& Supplemeat 1
- 4 i
- 3 - 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
,-u £3 "update" information on nuclear power reactor decommrssioning. The Proposed 0, regulatory changes sought by N.R.C. ore an insult to the public Interest 00 CL-44/2 I also strongly opposeo& and object to the proposed supplement to the "Gencro" E.1 S.,
wanthe 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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potentially significant offeite effects.
NRC asserts that the portion of decommissioning regulations (10 CFR 20 section SONGS is located in a highly active seismic zone, where Seismic activity is CL-44112 I and its M., NUIREG 1496) set the 25. 100 and 00 rniirems pery er on speculated by some geological experts to generate quakes up to 7 6 Magnitude allowable public dose levels from closed, decommussone nuclear plants sites, which the Richter Scale (by new evidence of local off-shore blind thruat faults, and wenot part of the scope ofthis Supplement. I disagree, and consider the In cause a greater extent ofgroundhaldng and acceleration than the mnner inclusion of expoamne from closed decommissioned plants a necessity to develop which quakes am traditionally studied). SONGS was only designed and an accurate and ralistsie analysis of cumulative Impacts.
coustructed to withstand nimurn a quake of7.0 Magnitude.
coastline, CL-44/1 3 e Allows NRC to define decommissiouing in part, to include "the release of
- SONGS is located in auar immediately on the southern California property for *uestricted use"., and the "release of property under restricted These with most facilities elevated only to a level of 20' ft. above mean sea level. conditions." It Is entirely inappropriate and scieitefically ludicrous ito allow and facilities are highly exposed and vulnerable to effects ofcising sea leveis, "release" of highly radioactively contaminated materials into daily consumer use tsunamis, and am i fiendy protected. and commerce, or unregulated disposal, or the recycling of such materials Into any form which causes public exposure with radioactively contaminated materials.
CL-4415 I am eppoesed to NRC resgulatlos pertalinig to Deeemmlissonlng which would
,allowc. In conclusion. it Is with utmost disappointment to again observe with each and every new
"-u a Rubbilizaton (cnnnbling the concrete reactor building) of nucle5t reactors, CL-44/14 NRC Rulemaking, Important components of the public's exusting "right to know" and the co public's right ofactive Involvement In plant processes, decisions and their methodology, W0 without on all aspects ofidcoummlsaioning activities routinely appears to be fUthe-dimninished.
. opportunity for public intervntion until the action is completed. As proposed, the ES (Supplement !) would eliminate all opportunities for public Intervetiorn, and public oversight ani/or inteeton entirely with use ofa "generi*'
Allows poirtom of sites to be"released" from regulatory control before the whole EIS In such cues, the loss ofpublic ovensight and intervention on projects with a CL-44/15 a site is released. 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 CL-44/ a Allows outite radiation to be ignored, and permits utihti to ignore it in surroindlat nuclear plants suck as SONGS deserve this entitlement, sad demand decommissiontng plarming. It is imperative to include offtite contamination into "tis entitlement.
all aspects of decommissioning planning and evaluation of envkOnfmental Impacts. 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, 5 Allows NRC to make most aspects ofidecommissioning "ge*nric" rather than site as well as cumulative effects resulting from decommissioning to citizens and members of CL-4418 specific so NRC cannot be legally reviewed or challenged at individual sites. the public living in local communities surrounding the nuclear plants.
0 Allows NRC to redefine terms to avoid local, site specific opportunity by public CL-44/16 We are tired of being unknowingly treated msan entity frm whom the Industy can CL-44. 9 to quetion, challenge and prevent unsafe decommissioning decisions. 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.
aAllows NRC to sdsasbitrary 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. Patricia Borchmann al 00 01 CD
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Z Letter 46, page 1 CD IN) 0 rage r-aqe Ia 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:
transparency. We CL-46/1 In keeping with appropriate medical and public policy principles, we urge total by being fully open CL-4612 urge that the Commission always lead it's interactions with the public at large nation and informative about the potential dangers, the expense and the limited experience we as a less have with the decommissioning of nuclear reactors United States citizens deserve nothing 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 evadesan. Yore, Mountaia isnot aamtable geologic repository based on CL-46/3 scIence- the DOE Itself admits that the site Is not geologically suitable, storage ca*isterswill be raquirod to eontaninatlok- Addidonalty, the GAO rahes aedoms questions protect the wase from exteior emnvronmental TD about the selection procss large numbers of CL-46/4 2. A serus aeddentor terrorlst me ceuidbe eutaairphlc. Such an occurrence could result In human fatalltles inltaies and Illnesses and vast areasof land ulrdniubtable for yearn.
Prce CL-4615 3 Its enterprlse of electricity generation uing nuclear fission requires public robeldy. Without Andeiooi protection, nularerpower would be eeonorncalty untenable.
to CL-4616 4. Coiudestla of thesefactrsamost be fully madpub"ld dies*!sed before expostlg our utlzeas additlonal expoeures throeugh development of new
- dear generatioa facilities. The complete phase-out based on objective analyis of health and econanne effects Including of enlear power should be coesidered probabilhty evaluadoss of al posible accddentandieldentUA. of all potentlalegy sources fartifson such aswind, solar, hydrogen fuel oelland IncldAing conservat*on.
Z C Tom Ferguson, Physicians for Social Responslblity/Atflanta PO Box 95190 Atlanta, GA 30347
- 6) 404 378-9078 PSRatlanta@ mindsorpnq,com 00 (11 www.PSRatanta org (n X1/.
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(nI "to From: "Dave Ritter' -cdrifter@c~tIzen.org> January 30, 2002 To:
Date:
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1i3002 4.22PM
-t-f6 Subelec Decommisloning comments see below.... 'OX Chief, Rules and Directives Branch Division of Administrative Services Mailstop T 6 D 59 US Nuclear Regulatory Commission Washington, DC 20555-0001 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 Zo 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 Cl t.J Citizen is concerned that the provisions outlined in the Supplement might allow owners Ca and operators of nuclear power reactors to reduce or completely evade their civic,
-0 to 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
($27A4-AD serious approach to decommissioning a site must take this into account.
eD,4q- PIO.
z0 CL-47/8 Decommissioning should not be a final opportunity for the nuclear industry to "take the to 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 Co o)
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