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{{#Wiki_filter:Page 1 of 1As of: April 08, 2014Received:
{{#Wiki_filter:Page 1 of 1 As of: April 08, 2014 Received:
April 07, 2014PUBLIC SUBMISSION Status: Pending-Post PUBLC S BMISIONTracking No. ljy-8bef-gd5p Comments Due: April 07, 20Submission Type: WebDocket: NRC-2012-0001 Receipt and Availability of Application for License RenewalComment On: NRC-2012-0001-0008 License Renewal Application for Callaway Plant, Unit 1; Draft Supplemental Generic Environmental ImpactStatement Document:
April 07, 2014 PUBLIC SUBMISSION Status: Pending-Post PUBLC S BMISIONTracking No. ljy-8bef-gd5p Comments Due: April 07, 20 Submission Type: Web Docket: NRC-2012-0001 Receipt and Availability of Application for License Renewal Comment On: NRC-2012-0001-0008 License Renewal Application for Callaway Plant, Unit 1; Draft Supplemental Generic Environmental Impact Statement Document:
NRC-2012-0001-DRAFT-0007 Comment on FR Doc # 2014-03845 14Submitter Information DDName: Edward Smith --Address:  
NRC-2012-0001-DRAFT-0007 Comment on FR Doc # 2014-03845 14 Submitter Information DD Name: Edward Smith --Address: " -7co -=3115S. GrandBlvd.
" -7co -=3115S. GrandBlvd.
Ste. 650 St. Louis, MO, 63118 C-/---t Email: esmith@moenviron.org  
Ste. 650St. Louis, MO, 63118 C-/---tEmail: esmith@moenviron.org  
,.]C-/]General Comment See attached file(s)Attachments 2014_0407LCallawayNRCComments SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= 6- Y. .4>https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064816a47de&for...
,.]C-/]General CommentSee attached file(s)Attachments 2014_0407LCallawayNRCComments SUNSI Review CompleteTemplate
04/08/2014 Missouri Coalition for the Environment Effective Citizen Action Since 1969 Cindy Bladey, Chief April 7, 2014 Rules, Announcements, and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Nuclear Regulatory Commission Generic Environmental Impact Statement for License Renewal of the Callaway I Nuclear Reactor 5.3 Severe Accidents NRC: Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, fires, and sabotage have not traditionally been discussed in quantitative terms in FES's and were not specifically considered for the Callaway site in the GElS (NRC 1996). However, the Generic Environmental Impact Statement (GELS) did evaluate existing impact assessment performed by the NRC and by the nuclear industry at 44 nuclear plants in the United States and concluded that the risk from beyond design-basis earthquakes at existing nuclear power plants is SMALL. The GElS for license renewal performed a discretionary analysis of terrorist acts in connection with license renewals and concluded that the risk from such acts would be no worse than the damage and release expected from internally initiated events. In the GELS, the Commission concludes that the risk from sabotage and beyond design-basis earthquakes at existing nuclear power plants is small and, additionally, that the risks from other external events are adequately addressed by a generic consideration of internally initiated severe accidents (NRC 1996).Based on the information in the GELS, the staff found the following to be true: The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to ground water, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.
= ADM -013E-RIDS= ADM-03Add= 6- Y. .4>https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064816a47de&for...
The staff identified no new significant information related to severe accidents during review of the applicant's ER (Ameren 2011a), the site audit, the scoping process, or the evaluation of other available information.
04/08/2014 Missouri Coalition for the Environment Effective Citizen Action Since 1969Cindy Bladey, Chief April 7, 2014Rules, Announcements, and Directives BranchOffice of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Nuclear Regulatory Commission Generic Environmental Impact Statement for LicenseRenewal of the Callaway I Nuclear Reactor5.3 Severe Accidents NRC: Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, fires, and sabotage have not traditionally been discussed in quantitative terms in FES's andwere not specifically considered for the Callaway site in the GElS (NRC 1996). However, theGeneric Environmental Impact Statement (GELS) did evaluate existing impact assessment performed by the NRC and by the nuclear industry at 44 nuclear plants in the United States andconcluded that the risk from beyond design-basis earthquakes at existing nuclear power plantsis SMALL. The GElS for license renewal performed a discretionary analysis of terrorist acts inconnection with license renewals and concluded that the risk from such acts would be no worsethan the damage and release expected from internally initiated events. In the GELS, theCommission concludes that the risk from sabotage and beyond design-basis earthquakes atexisting nuclear power plants is small and, additionally, that the risks from other externalevents are adequately addressed by a generic consideration of internally initiated severeaccidents (NRC 1996).Based on the information in the GELS, the staff found the following to be true:The probability weighted consequences of atmospheric  
Therefore, there are no impacts related to these issues beyond those discusses in the GELS.3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
: releases, fallout onto openbodies of water, releases to ground water, and societal and economic impacts fromsevere accidents are small for all plants. However, alternatives to mitigate severeaccidents must be considered for all plants that have not considered such alternatives.
The staff identified no new significant information related to severe accidents during review ofthe applicant's ER (Ameren 2011a), the site audit, the scoping process, or the evaluation ofother available information.
Therefore, there are no impacts related to these issues beyondthose discusses in the GELS.3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
.moenviron@moenviron.org  
.moenviron@moenviron.org  
.www.moenviron.org MCE Petition:
.www.moenviron.org MCE Petition:
The Missouri Coalition for the Environment (MCE) believes that spent fuelstorage risks are one of the most serious unaddressed safety and environmental issues facingthe NRC today. The consequences of a pool fire are potentially catastrophic, affecting millionsof people and costing billions of dollars.
The Missouri Coalition for the Environment (MCE) believes that spent fuel storage risks are one of the most serious unaddressed safety and environmental issues facing the NRC today. The consequences of a pool fire are potentially catastrophic, affecting millions of people and costing billions of dollars. There is no excuse for imposing this potentially colossal risk on the public. The only reason the risk exists is that the government and reactor licensees have not done a good job of managing the waste generated by reactors.
There is no excuse for imposing this potentially colossal risk on the public. The only reason the risk exists is that the government and reactorlicensees have not done a good job of managing the waste generated by reactors.
The volumes of waste piling up in the fuel pool at Callaway was never contemplated when its original license was issued in 1984.We think the Nuclear Regulatory Commission (NRC) has swept the issue of pool fires under the rug for far too long. The NRC has never conducted a comprehensive analysis of pool fire risks, as it did for reactor accidents with the Severe Accident Study (NUREG-1150).
The volumesof waste piling up in the fuel pool at Callaway was never contemplated when its original licensewas issued in 1984.We think the Nuclear Regulatory Commission (NRC) has swept the issue of pool fires under therug for far too long. The NRC has never conducted a comprehensive analysis of pool fire risks,as it did for reactor accidents with the Severe Accident Study (NUREG-1150).
The imposition of such great risks on the public without careful study is inexcusable.
The imposition ofsuch great risks on the public without careful study is inexcusable.
The Fukushima accident supposedly inspired NRC to take a closer look at the problem in the Expedited Spent Fuel Transfer proceeding  
The Fukushima accidentsupposedly inspired NRC to take a closer look at the problem in the Expedited Spent FuelTransfer proceeding  
-but the Consequence Study the NRC Staff turned out in 2013 was extremely inadequate.
-but the Consequence Study the NRC Staff turned out in 2013 wasextremely inadequate.
In spite of its inadequacies, however, the Consequence Study and the cost-benefit analysis that accompanied it yielded new and significant information about the risks of pool fires and the benefits of reducing the density of fuel in pools. MCE participated in a rulemaking petition, submitted Feb. 18, 2014, seeking re-opening of the License Renewal GElS to consider new and significant information generated by the NRC's proceeding on expedited transfer of spent fuel.It is unreasonable to issue a license extension without fully examining the risk of the spent fuel pool fire at the Callaway 1 nuclear reactor as a part of the Environmental Report. The NRC response to this concern at the March 19, 2014 public meeting in Fulton was that spent fuel considerations were outside the scope of the Environmental Report, which is simply bad public policy.In the Expedited Spent Fuel Transfer Proceeding, the NRC Staff found that if even a small fraction of the inventory of a Peach Bottom reactor pool were released to the environment in a severe spent fuel pool accident, an average area of 9,400 square miles (24,300 square kilometers) would be rendered uninhabitable, and that 4.1 million people would be displaced over the long-term.
In spite of its inadequacies,  
This information is "new" because no EIS for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment for standardization design certification has specified the size of the area that could be contaminated or the number of people who could be displaced for an extended period of time by a high-density spent fuel pool fire. The information is "significant" because it undermines the NRC's conclusion in environmental studies, such as the one for Callaway, for reactor licensing and re-licensing that the impacts of spent fuel storage during reactor operation are insignificant.
: however, the Consequence Study and the cost-benefit analysis thataccompanied it yielded new and significant information about the risks of pool fires and thebenefits of reducing the density of fuel in pools. MCE participated in a rulemaking  
Such widespread contamination and long-term displacement of people could have enormous socioeconomic impacts, as witnessed by the effects of the Fukushima accident, where "land contamination has disrupted the lives of a large number of Japanese Citizens." 3115 S. Grand Blvd. Ste. 650. St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
: petition, submitted Feb. 18, 2014, seeking re-opening of the License Renewal GElS to consider new andsignificant information generated by the NRC's proceeding on expedited transfer of spent fuel.It is unreasonable to issue a license extension without fully examining the risk of the spent fuelpool fire at the Callaway 1 nuclear reactor as a part of the Environmental Report. The NRCresponse to this concern at the March 19, 2014 public meeting in Fulton was that spent fuelconsiderations were outside the scope of the Environmental Report, which is simply bad publicpolicy.In the Expedited Spent Fuel Transfer Proceeding, the NRC Staff found that if even a smallfraction of the inventory of a Peach Bottom reactor pool were released to the environment in asevere spent fuel pool accident, an average area of 9,400 square miles (24,300 squarekilometers) would be rendered uninhabitable, and that 4.1 million people would be displaced over the long-term.
This information is "new" because no EIS for reactor licensing, GElS forreactor re-licensing, or Environmental Assessment for standardization design certification hasspecified the size of the area that could be contaminated or the number of people who couldbe displaced for an extended period of time by a high-density spent fuel pool fire. Theinformation is "significant" because it undermines the NRC's conclusion in environmental
: studies, such as the one for Callaway, for reactor licensing and re-licensing that the impacts ofspent fuel storage during reactor operation are insignificant.
Such widespread contamination and long-term displacement of people could have enormous socioeconomic  
: impacts, aswitnessed by the effects of the Fukushima  
: accident, where "land contamination has disrupted the lives of a large number of Japanese Citizens."
3115 S. Grand Blvd. Ste. 650. St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
.moenviron@moenviron.org
.moenviron@moenviron.org
* www.moenviron.org It is estimated that over 100,000 Japanese people are still displaced from their homes andcommunities.
* www.moenviron.org It is estimated that over 100,000 Japanese people are still displaced from their homes and communities.
The Japan Times recently cited a report from local Fukushima prefecture authorities that found more people have died from stress-related illnesses and other healthrelated problems near the nuclear reactor than who died from disaster-related injuries.
The Japan Times recently cited a report from local Fukushima prefecture authorities that found more people have died from stress-related illnesses and other health related problems near the nuclear reactor than who died from disaster-related injuries.
Realworld nuclear disasters show the impact on communities surrounding a nuclear reactor aresignificant and therefore must be considered by the Nuclear Regulatory Commission in ameaningful way.In the Peach Bottom review, the NRC acknowledged for the first time that the potential consequences of a pool fire are severe enough to warrant mitigation, regardless of the lowprobability estimated by the NRC for such an accident.
Real world nuclear disasters show the impact on communities surrounding a nuclear reactor are significant and therefore must be considered by the Nuclear Regulatory Commission in a meaningful way.In the Peach Bottom review, the NRC acknowledged for the first time that the potential consequences of a pool fire are severe enough to warrant mitigation, regardless of the low probability estimated by the NRC for such an accident.
No Environmental Impact Statement (EIS) for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment forreactor design certification has acknowledged that mitigation of pool fires is warranted orweighed the costs and environmental benefits of such mitigation measures.
No Environmental Impact Statement (EIS) for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment for reactor design certification has acknowledged that mitigation of pool fires is warranted or weighed the costs and environmental benefits of such mitigation measures.To ensure compliance with National Environmental Policy Act (NEPA) in the consideration of this new and significant information, MCE and other petitioners requested the NRC to take the following actions: " Suspend the effectiveness of Table B-1 of 10 C.F.R. Part 51, Subpart A, Appendix B ("Table B-i"), which codifies the NRC's generic finding that spent fuel storage in high-density reactor pools during the license renewal term of operating reactors poses no significant environmental impacts and therefore need not be considered in individual reactor licensing decisions.
To ensure compliance with National Environmental Policy Act (NEPA) in the consideration ofthis new and significant information, MCE and other petitioners requested the NRC to take thefollowing actions:" Suspend the effectiveness of Table B-1 of 10 C.F.R. Part 51, Subpart A, Appendix B("Table B-i"), which codifies the NRC's generic finding that spent fuel storage in high-density reactor pools during the license renewal term of operating reactors poses nosignificant environmental impacts and therefore need not be considered in individual reactor licensing decisions.
* Withhold Ameren Missouri's license extension until a comprehensive risk assessment is undertaken by the NRC on the environmental impact of a high, medium, and low density spent fuel pool fire at the Callaway 1 nuclear reactor. The risk assessment must be available for public comment once completed." Suspend the effectiveness, in any new reactor licensing proceeding for reactors that employ high-density pool storage of spent fuel, of all regulations approving the standardized designs for those new reactors and all Environmental Assessments approving Severe Accident Mitigation Design Alternatives,* Re-publish for public comment the following documents with respect to new and significant information regarding the environmental impacts of high-density spent fuel storage in reactor pools and the costs and benefits of measures for avoiding or mitigating those impacts: o The License Renewal Generic Environmental Impact Statement (NUREG-1437, Rev. 1, June 2013) ("2013 Revised License Renewal GELS");" The ElSs for all new reactors;3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
* Withhold Ameren Missouri's license extension until a comprehensive risk assessment isundertaken by the NRC on the environmental impact of a high, medium, and lowdensity spent fuel pool fire at the Callaway 1 nuclear reactor.
The risk assessment mustbe available for public comment once completed.
" Suspend the effectiveness, in any new reactor licensing proceeding for reactors thatemploy high-density pool storage of spent fuel, of all regulations approving thestandardized designs for those new reactors and all Environmental Assessments approving Severe Accident Mitigation Design Alternatives,
* Re-publish for public comment the following documents with respect to new andsignificant information regarding the environmental impacts of high-density spent fuelstorage in reactor pools and the costs and benefits of measures for avoiding ormitigating those impacts:o The License Renewal Generic Environmental Impact Statement (NUREG-1437, Rev. 1, June 2013) ("2013 Revised License Renewal GELS");" The ElSs for all new reactors; 3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
.moenviron@moenviron.org.
.moenviron@moenviron.org.
www.moenviron.org o The EAs for all new certifications for standardized reactor designs (MCE includesthis in our comments given Ameren Missouri's longstanding interest in expandednuclear reactor development in Missouri),
www.moenviron.org o The EAs for all new certifications for standardized reactor designs (MCE includes this in our comments given Ameren Missouri's longstanding interest in expanded nuclear reactor development in Missouri)," Duly modify NRC regulations that make or rely on findings regarding the environmental impacts of spent fuel storage during reactor operation, including Table B-i and all regulations approving standardized reactor designs; and" Suspend all new reactor licensing decisions and license renewal decisions pending completion of this proceeding.
" Duly modify NRC regulations that make or rely on findings regarding the environmental impacts of spent fuel storage during reactor operation, including Table B-i and allregulations approving standardized reactor designs; and" Suspend all new reactor licensing decisions and license renewal decisions pendingcompletion of this proceeding.
The Missouri Coalition for the Environment appreciates the opportunity for comment and hope that we receive a specific response to our comments.
The Missouri Coalition for the Environment appreciates the opportunity for comment and hopethat we receive a specific response to our comments.
NRC staff was unable or unprepared to answer most of MCE's questions at the March 19, 2014 meeting in Fulton and would appreciate a written response.Thanks, Ed Smith Safe Energy Director Missouri Coalition for the Environment (314) 727-0600 3115 S. Grand Blvd. Ste. 650 St. Louis, Missouri 63118 www.moenviron.org 3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
NRC staff was unable or unprepared toanswer most of MCE's questions at the March 19, 2014 meeting in Fulton and would appreciate a written response.
Thanks,Ed SmithSafe Energy DirectorMissouri Coalition for the Environment (314) 727-06003115 S. Grand Blvd. Ste. 650St. Louis, Missouri 63118www.moenviron.org 3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665  
.moenviron@moenviron.org.
.moenviron@moenviron.org.
www.moenviron.org}}
www.moenviron.org}}

Latest revision as of 18:42, 9 July 2018

Comment (5) of Edward Smith on Behalf of Missouri Coalition for the Environment on License Renewal Application for Callaway Plant, Unit 1; Draft Supplemental Generic Environmental Impact Statement
ML14107A067
Person / Time
Site: Callaway Ameren icon.png
Issue date: 04/07/2014
From: Smith E
Missouri Coalition for the Environment
To: Bladey C K
Acquisition Management Division
References
79FR10200 00005, NRC-2012-0001
Download: ML14107A067 (5)
v • d • e


Text

Page 1 of 1 As of: April 08, 2014 Received:

April 07, 2014 PUBLIC SUBMISSION Status: Pending-Post PUBLC S BMISIONTracking No. ljy-8bef-gd5p Comments Due: April 07, 20 Submission Type: Web Docket: NRC-2012-0001 Receipt and Availability of Application for License Renewal Comment On: NRC-2012-0001-0008 License Renewal Application for Callaway Plant, Unit 1; Draft Supplemental Generic Environmental Impact Statement Document:

NRC-2012-0001-DRAFT-0007 Comment on FR Doc # 2014-03845 14 Submitter Information DD Name: Edward Smith --Address: " -7co -=3115S. GrandBlvd.

Ste. 650 St. Louis, MO, 63118 C-/---t Email: esmith@moenviron.org

,.]C-/]General Comment See attached file(s)Attachments 2014_0407LCallawayNRCComments SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= 6- Y. .4>https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064816a47de&for...

04/08/2014 Missouri Coalition for the Environment Effective Citizen Action Since 1969 Cindy Bladey, Chief April 7, 2014 Rules, Announcements, and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Nuclear Regulatory Commission Generic Environmental Impact Statement for License Renewal of the Callaway I Nuclear Reactor 5.3 Severe Accidents NRC: Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, fires, and sabotage have not traditionally been discussed in quantitative terms in FES's and were not specifically considered for the Callaway site in the GElS (NRC 1996). However, the Generic Environmental Impact Statement (GELS) did evaluate existing impact assessment performed by the NRC and by the nuclear industry at 44 nuclear plants in the United States and concluded that the risk from beyond design-basis earthquakes at existing nuclear power plants is SMALL. The GElS for license renewal performed a discretionary analysis of terrorist acts in connection with license renewals and concluded that the risk from such acts would be no worse than the damage and release expected from internally initiated events. In the GELS, the Commission concludes that the risk from sabotage and beyond design-basis earthquakes at existing nuclear power plants is small and, additionally, that the risks from other external events are adequately addressed by a generic consideration of internally initiated severe accidents (NRC 1996).Based on the information in the GELS, the staff found the following to be true: The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to ground water, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives.

The staff identified no new significant information related to severe accidents during review of the applicant's ER (Ameren 2011a), the site audit, the scoping process, or the evaluation of other available information.

Therefore, there are no impacts related to these issues beyond those discusses in the GELS.3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665

.moenviron@moenviron.org

.www.moenviron.org MCE Petition:

The Missouri Coalition for the Environment (MCE) believes that spent fuel storage risks are one of the most serious unaddressed safety and environmental issues facing the NRC today. The consequences of a pool fire are potentially catastrophic, affecting millions of people and costing billions of dollars. There is no excuse for imposing this potentially colossal risk on the public. The only reason the risk exists is that the government and reactor licensees have not done a good job of managing the waste generated by reactors.

The volumes of waste piling up in the fuel pool at Callaway was never contemplated when its original license was issued in 1984.We think the Nuclear Regulatory Commission (NRC) has swept the issue of pool fires under the rug for far too long. The NRC has never conducted a comprehensive analysis of pool fire risks, as it did for reactor accidents with the Severe Accident Study (NUREG-1150).

The imposition of such great risks on the public without careful study is inexcusable.

The Fukushima accident supposedly inspired NRC to take a closer look at the problem in the Expedited Spent Fuel Transfer proceeding

-but the Consequence Study the NRC Staff turned out in 2013 was extremely inadequate.

In spite of its inadequacies, however, the Consequence Study and the cost-benefit analysis that accompanied it yielded new and significant information about the risks of pool fires and the benefits of reducing the density of fuel in pools. MCE participated in a rulemaking petition, submitted Feb. 18, 2014, seeking re-opening of the License Renewal GElS to consider new and significant information generated by the NRC's proceeding on expedited transfer of spent fuel.It is unreasonable to issue a license extension without fully examining the risk of the spent fuel pool fire at the Callaway 1 nuclear reactor as a part of the Environmental Report. The NRC response to this concern at the March 19, 2014 public meeting in Fulton was that spent fuel considerations were outside the scope of the Environmental Report, which is simply bad public policy.In the Expedited Spent Fuel Transfer Proceeding, the NRC Staff found that if even a small fraction of the inventory of a Peach Bottom reactor pool were released to the environment in a severe spent fuel pool accident, an average area of 9,400 square miles (24,300 square kilometers) would be rendered uninhabitable, and that 4.1 million people would be displaced over the long-term.

This information is "new" because no EIS for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment for standardization design certification has specified the size of the area that could be contaminated or the number of people who could be displaced for an extended period of time by a high-density spent fuel pool fire. The information is "significant" because it undermines the NRC's conclusion in environmental studies, such as the one for Callaway, for reactor licensing and re-licensing that the impacts of spent fuel storage during reactor operation are insignificant.

Such widespread contamination and long-term displacement of people could have enormous socioeconomic impacts, as witnessed by the effects of the Fukushima accident, where "land contamination has disrupted the lives of a large number of Japanese Citizens." 3115 S. Grand Blvd. Ste. 650. St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665

.moenviron@moenviron.org

  • www.moenviron.org It is estimated that over 100,000 Japanese people are still displaced from their homes and communities.

The Japan Times recently cited a report from local Fukushima prefecture authorities that found more people have died from stress-related illnesses and other health related problems near the nuclear reactor than who died from disaster-related injuries.

Real world nuclear disasters show the impact on communities surrounding a nuclear reactor are significant and therefore must be considered by the Nuclear Regulatory Commission in a meaningful way.In the Peach Bottom review, the NRC acknowledged for the first time that the potential consequences of a pool fire are severe enough to warrant mitigation, regardless of the low probability estimated by the NRC for such an accident.

No Environmental Impact Statement (EIS) for reactor licensing, GElS for reactor re-licensing, or Environmental Assessment for reactor design certification has acknowledged that mitigation of pool fires is warranted or weighed the costs and environmental benefits of such mitigation measures.To ensure compliance with National Environmental Policy Act (NEPA) in the consideration of this new and significant information, MCE and other petitioners requested the NRC to take the following actions: " Suspend the effectiveness of Table B-1 of 10 C.F.R. Part 51, Subpart A, Appendix B ("Table B-i"), which codifies the NRC's generic finding that spent fuel storage in high-density reactor pools during the license renewal term of operating reactors poses no significant environmental impacts and therefore need not be considered in individual reactor licensing decisions.

  • Withhold Ameren Missouri's license extension until a comprehensive risk assessment is undertaken by the NRC on the environmental impact of a high, medium, and low density spent fuel pool fire at the Callaway 1 nuclear reactor. The risk assessment must be available for public comment once completed." Suspend the effectiveness, in any new reactor licensing proceeding for reactors that employ high-density pool storage of spent fuel, of all regulations approving the standardized designs for those new reactors and all Environmental Assessments approving Severe Accident Mitigation Design Alternatives,* Re-publish for public comment the following documents with respect to new and significant information regarding the environmental impacts of high-density spent fuel storage in reactor pools and the costs and benefits of measures for avoiding or mitigating those impacts: o The License Renewal Generic Environmental Impact Statement (NUREG-1437, Rev. 1, June 2013) ("2013 Revised License Renewal GELS");" The ElSs for all new reactors;3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665

.moenviron@moenviron.org.

www.moenviron.org o The EAs for all new certifications for standardized reactor designs (MCE includes this in our comments given Ameren Missouri's longstanding interest in expanded nuclear reactor development in Missouri)," Duly modify NRC regulations that make or rely on findings regarding the environmental impacts of spent fuel storage during reactor operation, including Table B-i and all regulations approving standardized reactor designs; and" Suspend all new reactor licensing decisions and license renewal decisions pending completion of this proceeding.

The Missouri Coalition for the Environment appreciates the opportunity for comment and hope that we receive a specific response to our comments.

NRC staff was unable or unprepared to answer most of MCE's questions at the March 19, 2014 meeting in Fulton and would appreciate a written response.Thanks, Ed Smith Safe Energy Director Missouri Coalition for the Environment (314) 727-0600 3115 S. Grand Blvd. Ste. 650 St. Louis, Missouri 63118 www.moenviron.org 3115 S. Grand Blvd. Ste. 650 .St. Louis MO 63118 .314.727.0600 Fax: 314.727.1665

.moenviron@moenviron.org.

www.moenviron.org

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