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{{#Wiki_filter:UNITED STATESNUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 0ý///7ý7/ýX7DFr-,c1-1N3SUNSI Review CompleteTemplate
= ADM -013E-RIDS= ADM-03Add=,ef-/
-4?fý el-x.&'nAý Law OfficeTERRY JONATHAN LODGE316 N. Michigan Street, Suite 520 Phone (419) 255-7552Toledo, Ohio 43604-5627 Fax (419) 255-8582Iodgelaw@yahoo.com March 25, 2014PUBLIC COMMENTS OF BEYOND NUCLEAR, DON'T WASTE MICHIGAN, GREENPARTY OF OHIO AND CITIZENS ENVIRONMENT ALLIANCE OFSOUTHWESTERN ONTARIO TO U.S. NUCLEAR REGULATORY COMMISSION ON DRAFT SEIS FOR DAVIS-BESSE NUCLEAR POWER STATIONOPERATING LICENSE EXTENSION I represent Beyond Nuclear, Don't Waste Michigan and the Citizens Environment Alliance of Southwestern Ontario in the pending license renewal proceeding for Davis-Besse.
It is our opinion that circumstances in recent weeks in New Mexico have seriously undermined the assumptions that have given rise to the generic conclusion that nuclear powerplants like Davis-Besse can be allowed to continue in operation, generate incredibly lethal wasteproducts from fissioning, and that there will be adequate measures in place to keep those deadlygenies bottled up for the necessary tens or hundreds of thousands of years.On February 4, 2014, assumptions of very low probability crumbled at the EnergyDepartment's Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico, when a fire in alarge salt truck raged for hours, deep underground.
Ten days later, an even more unlikelyaccident happened:
Wastes containing plutonium blew through the WIPP ventilation system,traveling 2,150 feet to the surface, contaminating at least 17 workers, and spreading smallamounts of radioactive material into the environment More than a month after the fire, WIPP remains closed, and what happened underground remains unclear.
It is not known whether the leak and the truck fire are connected; a waste-drum explosion or the collapse of a roof of one of the facility's storage chambers could be to blame forthe radiation event. As DOE contractors send robots to explore WIPP's caverns, the future of theworld's only operating high-hazard radioactive waste repository is uncertain.
The fire is believed to have started when diesel fuel or hydraulic fluid leaked inside atruck's engine compartment.
The fire consumed the driver's compartment and the truck's largefront tires, which produced copious amounts of thick black smoke, prompting 86 workers to beevacuated.
Six workers were treated at the Carlsbad hospital for smoke inhalation, and anotherseven were treated at the site. Workers have not been allowed back in the mine since.The Energy Department investigation report of March 14 concluded the fire could havebeen prevented had the contractor and Energy Department site managers
: bothered, after beingrepeatedly warned, to remove a buildup of flammable material in the mine, to regularly maintainPage 1 of 3 trucks and equipment, and to correct emergency response deficiencies.
: Moreover, the automatic fire suppression system had been turned off before the fire. There was also a radiation leak whichmay or may not be connected to the truck fire. Among possible causes of the leak, a waste drumexplosion is now under consideration.
Waste drums containing transuranics generate
: hydrogen, methane, and other volatile gases which, if unvented, can build up and, if ignited, explode.Concerns have also been raised about the possibility of a storage room ceiling or wallcollapse.
Eventually, when WIPP closes, sometime after 2030, the salt formation is expected toslowly collapse and seal off the drums of waste. But this was not expected to happen until longafter the repository is filled and closed. If a collapse has already occurred, just 15 years after thefacility opened, it will raise additional questions about WIPP's ability to ensure engineered barriers and institutional controls will work for a 10,000 year period.Intervenors in the NRC's pending "waste confidence" decisionmaking process havewarned, authoritatively, of the dangers of storing high-level radioactive waste in salt formations.
Physicist Arjun Makhijani filed a formal declaration with the NRC on December 20, 2013[http://www.cleanenergy.org/wp-content/uploads/MakhijaniDeclaration.pdfl, in which he stated:(p. 6/70)"Disposal impacts are relevant because they are part of the waste confidence finding that a mined geologic repository is feasible.
By definition of such feasibility, sucha repository must meet reasonable health and safety standards.
: Moreover, we note thatTable S-3 at 10 CFR 51.51 is invalid for estimating high-level waste disposal impacts.Among other things, its underlying assumption of disposal in a bedded salt repository forspent fuel disposal was repudiated by the NRC itself in 2008. {citation:
U.S. NuclearRegulatory Commission.
10 CFR Part 51: [Docket ID-2008-0482]:
Waste Confidence Decision Update,"
Federal Register,
: v. 73, no. 197 (October 9, 2008): pp. 59555. On theWeb at http://www.gpo.gov/fdsys/pkg/FR-2008-10-09/pdf/E8-233 81 .pdf. "FR DOC #E8-23381" "Proposed Rules"}(p. 9/70)3.5. Proposed Table B-I is inconsistent with another regulation that also makes afinding on the same subject:
Table S-3 in 10 CFR 51.51.' Table S-3 summarizes theNRC's conclusion that the impacts of spent fuel disposal will be zero, based on theassumption that spent fuel will be disposed of in a bedded salt repository.
Proposed Table'[Footnote 26 of Makhijani's statement reproduced here:] The Draft GElS acknowledges that"[t]he environmental impacts of portions of the uranium fuel cycle that occur before new fuel is delivered to the plant and after spent fuel is sent to a disposal site have been evaluated and are codified" in 10 CFR51.51 and Table S-3. [U.S. Nuclear Regulatory Commission.
Waste Confidence Generic Environmental Impact Statement:
Draft Report for Comment.
(NUREG-2157)
Washington, DC: Waste Confidence Directorate, Office of Nuclear Material Safety and Safeguards, NRC, September 2013. On the Web athttp://pbadupws.nrc.gov/docs/ML1322/ML13224A106.pdf.
Page 1-22)]Page 2 of 3 0 .. .. "B- I contradicts Table S-3 by concluding that long-term doses could be as high as 100millirem per year. But the NRC does not attempt to reconcile proposed Table B-I andTable S-3; nor does it address the fact that in the 2008 Draft Waste Confidence Update, itrepudiated bedded salt as a geologic medium for a repository.
2 Nothing in the NRC'sresponse to public comments on this point negated this repudiation of the unsuitability ofbedded salt for spent fuel disposal.
3Dr. Makhijani's conclusion is that "[t]he NRC's understanding today is that radiation doses tothe public could be well above the zero exposure assumed in Table S-3." (Statement
: p. 41/70).I understand that there is an ongoing rulemaking proceeding over waste confidence, butthe point the Intervenors in the Davis-Besse license renewal case are here to make to you,tonight, is that there is serious recent new information that calls into question the Table S-3assumptions that allowed Davis-Besse to be licensed in the first place, much less granted anextension.
The NEPA document for the LRA cannot be considered thorough and fully-disclosing without scientific reconsideration of the assumption that the dangerous garbage fromnuclear fissioning will not pose horrific hazards to less-informed and more vulnerable populations in the poorer which are likely to be found in the, overpopulated world of the future.The NRC itself has repudiated the science of WIPP, yet relies on that now-discredited science forone of the fundamental driving rationales for commercial nuclear power. The time of reckoning commenced February
: 4. You must heed the lesson and shut Davis-Besse down, not allow it tolimp through another score of years, creating even more uncontainable lethality for our children's children's children.
Counsel for terven s2-[Footnote 27 from Makhijani statement reproduced here] U.S. Nuclear Regulatory Commission.
10 CFR Part 51: [Docket ID-2008-0482]:
Waste Confidence Decision Update,"
Federal Register,
: v. 73,no. 197 (October 9, 2008): pp. 59555. On the Web athttp://www.gpo.gov/fdsys/pkg/FR-2008-10-09/pdf/E8-2338 1.pdf. "FR DOC # E8-2338 1" "Proposed Rules"}.3 [Footnote 28 from Makhijani reproduced here] U.S. Nuclear Regulatory Commission.
"10 CFRPart 5 1: [NRC-2008-0482]:
Waste Confidence Decision Update,"
Federal Register,
: v. 75, no. 246(December 23, 2010): pp. 81043 and 81044. On the Web athttp://www.gpo.gov/fdsys/pkg/FR-2010-12-23/pdf/2010-31637.pdf.
"FR DOC # 2010-31637" "Updateand final revision of Waste Confidence Decision."]
Page 3 of 3}}

Revision as of 22:15, 1 July 2018

Comment (5) of Terry J. Lodge, on of Behalf Beyond Nuclear, Don'T Waste Michigan and the Citizens Environment Alliance of Southwestern Ontario, Opposing Draft SEIS for Davis-Besse Nuclear Power Station Operating License Extension
ML14098A026
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 03/25/2014
From: Lodge T J
Beyond Nuclear, Citizens Environmental Alliance of Southwestern Ontario, Don't Waste Michigan, Law Office of Terry Jonathan Lodge
To:
Division of Administrative Services
References
79FR13079 00005
Download: ML14098A026 (4)
v • d • e


Text

UNITED STATESNUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 0ý///7ý7/ýX7DFr-,c1-1N3SUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add=,ef-/

-4?fý el-x.&'nAý Law OfficeTERRY JONATHAN LODGE316 N. Michigan Street, Suite 520 Phone (419) 255-7552Toledo, Ohio 43604-5627 Fax (419) 255-8582Iodgelaw@yahoo.com March 25, 2014PUBLIC COMMENTS OF BEYOND NUCLEAR, DON'T WASTE MICHIGAN, GREENPARTY OF OHIO AND CITIZENS ENVIRONMENT ALLIANCE OFSOUTHWESTERN ONTARIO TO U.S. NUCLEAR REGULATORY COMMISSION ON DRAFT SEIS FOR DAVIS-BESSE NUCLEAR POWER STATIONOPERATING LICENSE EXTENSION I represent Beyond Nuclear, Don't Waste Michigan and the Citizens Environment Alliance of Southwestern Ontario in the pending license renewal proceeding for Davis-Besse.

It is our opinion that circumstances in recent weeks in New Mexico have seriously undermined the assumptions that have given rise to the generic conclusion that nuclear powerplants like Davis-Besse can be allowed to continue in operation, generate incredibly lethal wasteproducts from fissioning, and that there will be adequate measures in place to keep those deadlygenies bottled up for the necessary tens or hundreds of thousands of years.On February 4, 2014, assumptions of very low probability crumbled at the EnergyDepartment's Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico, when a fire in alarge salt truck raged for hours, deep underground.

Ten days later, an even more unlikelyaccident happened:

Wastes containing plutonium blew through the WIPP ventilation system,traveling 2,150 feet to the surface, contaminating at least 17 workers, and spreading smallamounts of radioactive material into the environment More than a month after the fire, WIPP remains closed, and what happened underground remains unclear.

It is not known whether the leak and the truck fire are connected; a waste-drum explosion or the collapse of a roof of one of the facility's storage chambers could be to blame forthe radiation event. As DOE contractors send robots to explore WIPP's caverns, the future of theworld's only operating high-hazard radioactive waste repository is uncertain.

The fire is believed to have started when diesel fuel or hydraulic fluid leaked inside atruck's engine compartment.

The fire consumed the driver's compartment and the truck's largefront tires, which produced copious amounts of thick black smoke, prompting 86 workers to beevacuated.

Six workers were treated at the Carlsbad hospital for smoke inhalation, and anotherseven were treated at the site. Workers have not been allowed back in the mine since.The Energy Department investigation report of March 14 concluded the fire could havebeen prevented had the contractor and Energy Department site managers

bothered, after beingrepeatedly warned, to remove a buildup of flammable material in the mine, to regularly maintainPage 1 of 3 trucks and equipment, and to correct emergency response deficiencies.
Moreover, the automatic fire suppression system had been turned off before the fire. There was also a radiation leak whichmay or may not be connected to the truck fire. Among possible causes of the leak, a waste drumexplosion is now under consideration.

Waste drums containing transuranics generate

hydrogen, methane, and other volatile gases which, if unvented, can build up and, if ignited, explode.Concerns have also been raised about the possibility of a storage room ceiling or wallcollapse.

Eventually, when WIPP closes, sometime after 2030, the salt formation is expected toslowly collapse and seal off the drums of waste. But this was not expected to happen until longafter the repository is filled and closed. If a collapse has already occurred, just 15 years after thefacility opened, it will raise additional questions about WIPP's ability to ensure engineered barriers and institutional controls will work for a 10,000 year period.Intervenors in the NRC's pending "waste confidence" decisionmaking process havewarned, authoritatively, of the dangers of storing high-level radioactive waste in salt formations.

Physicist Arjun Makhijani filed a formal declaration with the NRC on December 20, 2013[http://www.cleanenergy.org/wp-content/uploads/MakhijaniDeclaration.pdfl, in which he stated:(p. 6/70)"Disposal impacts are relevant because they are part of the waste confidence finding that a mined geologic repository is feasible.

By definition of such feasibility, sucha repository must meet reasonable health and safety standards.

Moreover, we note thatTable S-3 at 10 CFR 51.51 is invalid for estimating high-level waste disposal impacts.Among other things, its underlying assumption of disposal in a bedded salt repository forspent fuel disposal was repudiated by the NRC itself in 2008. {citation:

U.S. NuclearRegulatory Commission.

10 CFR Part 51: [Docket ID-2008-0482]:

Waste Confidence Decision Update,"

Federal Register,

v. 73, no. 197 (October 9, 2008): pp. 59555. On theWeb at http://www.gpo.gov/fdsys/pkg/FR-2008-10-09/pdf/E8-233 81 .pdf. "FR DOC #E8-23381" "Proposed Rules"}(p. 9/70)3.5. Proposed Table B-I is inconsistent with another regulation that also makes afinding on the same subject:

Table S-3 in 10 CFR 51.51.' Table S-3 summarizes theNRC's conclusion that the impacts of spent fuel disposal will be zero, based on theassumption that spent fuel will be disposed of in a bedded salt repository.

Proposed Table'[Footnote 26 of Makhijani's statement reproduced here:] The Draft GElS acknowledges that"[t]he environmental impacts of portions of the uranium fuel cycle that occur before new fuel is delivered to the plant and after spent fuel is sent to a disposal site have been evaluated and are codified" in 10 CFR51.51 and Table S-3. [U.S. Nuclear Regulatory Commission.

Waste Confidence Generic Environmental Impact Statement:

Draft Report for Comment.

(NUREG-2157)

Washington, DC: Waste Confidence Directorate, Office of Nuclear Material Safety and Safeguards, NRC, September 2013. On the Web athttp://pbadupws.nrc.gov/docs/ML1322/ML13224A106.pdf.

Page 1-22)]Page 2 of 3 0 .. .. "B- I contradicts Table S-3 by concluding that long-term doses could be as high as 100millirem per year. But the NRC does not attempt to reconcile proposed Table B-I andTable S-3; nor does it address the fact that in the 2008 Draft Waste Confidence Update, itrepudiated bedded salt as a geologic medium for a repository.

2 Nothing in the NRC'sresponse to public comments on this point negated this repudiation of the unsuitability ofbedded salt for spent fuel disposal.

3Dr. Makhijani's conclusion is that "[t]he NRC's understanding today is that radiation doses tothe public could be well above the zero exposure assumed in Table S-3." (Statement

p. 41/70).I understand that there is an ongoing rulemaking proceeding over waste confidence, butthe point the Intervenors in the Davis-Besse license renewal case are here to make to you,tonight, is that there is serious recent new information that calls into question the Table S-3assumptions that allowed Davis-Besse to be licensed in the first place, much less granted anextension.

The NEPA document for the LRA cannot be considered thorough and fully-disclosing without scientific reconsideration of the assumption that the dangerous garbage fromnuclear fissioning will not pose horrific hazards to less-informed and more vulnerable populations in the poorer which are likely to be found in the, overpopulated world of the future.The NRC itself has repudiated the science of WIPP, yet relies on that now-discredited science forone of the fundamental driving rationales for commercial nuclear power. The time of reckoning commenced February

4. You must heed the lesson and shut Davis-Besse down, not allow it tolimp through another score of years, creating even more uncontainable lethality for our children's children's children.

Counsel for terven s2-[Footnote 27 from Makhijani statement reproduced here] U.S. Nuclear Regulatory Commission.

10 CFR Part 51: [Docket ID-2008-0482]:

Waste Confidence Decision Update,"

Federal Register,

v. 73,no. 197 (October 9, 2008): pp. 59555. On the Web athttp://www.gpo.gov/fdsys/pkg/FR-2008-10-09/pdf/E8-2338 1.pdf. "FR DOC # E8-2338 1" "Proposed Rules"}.3 [Footnote 28 from Makhijani reproduced here] U.S. Nuclear Regulatory Commission.

"10 CFRPart 5 1: [NRC-2008-0482]:

Waste Confidence Decision Update,"

Federal Register,

v. 75, no. 246(December 23, 2010): pp. 81043 and 81044. On the Web athttp://www.gpo.gov/fdsys/pkg/FR-2010-12-23/pdf/2010-31637.pdf.

"FR DOC # 2010-31637" "Updateand final revision of Waste Confidence Decision."]

Page 3 of 3

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