ML13357A832

Comment (00601) of Roger Johnson on PR-51, Waste Confidence - Continued Storage of Spent Nuclear Fuel

ML13357A832
Person / Time
Site:	San Onofre
Issue date:	12/19/2013
From:	Rachel Johnson - No Known Affiliation
To:	Macfarlane A M NRC/Chairman, NRC/SECY/RAS
SECY RAS
References
78FR56775 00601, NRC-2012-0246, PR-51
Download: ML13357A832 (3)

Text

1 Rulemaking1CEm Resource From: RulemakingComments Resource Sent: Monday, December 23, 2013 8:15 AM To: Rulemaking1CEm Resource

Subject:

FW: The GEIS report especially with reference to San Onofre DOCKETED BY USNRC-OFFICE OF THE SECRETARY SECY-067 PR#: PR-51 FRN#: 78FR56775 NRC DOCKET#: NRC-2012-0246 SECY DOCKET DATE: 12/19/13 TITLE: Waste Confidence-Continued Storage of Spent Nuclear Fuel COMMENT#: 00601

From: r johnson [1]

Sent: Thursday, December 19, 2013 5:54 PM To: CHAIRMAN Resource

Subject:

The GEIS report especially with reference to San Onofre

Dear Dr. Macfarlane,

As a resident of San Clemente, CA, I would like to strongly oppose the GEIS report. Our town shares the same zip code as San Onofre, and now y ou want us to share the nuclear waste, possibly forever. When the plant was built, you promised t hat the waste would never remain here, and now you are reneging on that promise.

There isn't any city or town in Southern California which is a suitable site for a nuclear waste dump, and certainly not ours. San Onofre is situated in an earthquake and tsunami zone in the middle of two large metropolitan areas.

It is an extremely inviting target for terrorists. The waste is stored in an extremely vulnerable location with free public access on all sides: it is a few hundred feet from a public beach and a few hundred feet from an important Interstate Highway.

Nuclear waste has been accumulating here since 1968. We have housed it long enough (about a half-century) and it is outrageous that you want to keep it her e for another 60 years (or 160 or forever). The GEIS report is not a plan. Rather it is an avoidance of responsibility. The NRC logo says "protecting people and the envir onment" but this is a plan to do the opposite. The idea of labeling this time period as "short te rm" and "temporary" is irresponsible.

Since the GEIS report is not a plan but rather a continuation of doing nothing, you need to completely revise it with a serious plan. Here is a suggestion: The government owns millions of acres of land, much of it isolated and remote, much of it on secure military fa cilities. There are many possibilities for temporary storage sites on such remote locations. Sites could be regional or state-specific to avoid federal issues. What is requ ired is only a pad, not an elab orate repository. This would be designated as a temporar y waste storage facility until a pe rmanent repository is opened.

Current nuclear power plants were never designed to be long term (anything over 20 years) waste storage facilities. San Onofre especially is totally unsuitable and it cannot be turned into a long term storage facility just by changing its name.

Moving waste to re mote sites has many powerful advantages: (1) Waste can be removed from tsunami and earthquake prone areas; (2) Waste can be stored far from populati on centers; (3) waste 2 can be stored in secure areas away from public access; (4) waste stored in a remote temporary site would be mostly immune from terror ist threats since terrorists would not be interested in targets far from population zones.

Please rewrite t he plan to say the following: (1) All waste currently in transportable casks should be moved to the designated temporary site within one year. (2) All waste which is safe to remove from pools should be done so immediately with a high-priority accelerated schedule. Once in casks, it should be moved quickly to the temporary storage area. (3) All remaining fuel in the pools should be removed and casked and sent to the site as soon as the fuel is cool enough to place in dry casks. (4) All fuel pools at cl osed plants should be emptied ASAP.

In addition to a real plan like that outlined above, here are some more suggestions:

(1) The plan should specify close cooperation with local cities and towns.

(2) The plan shoul d include Class C or greater waste (rath er than exclude it as the current GEIS plan does).

(3) The plan should be site-specific, not generic.

The failure of the GEIS plan to make important distinctions based on particular situations is particularly troubling. How can the NRC write a report which states that earthquakes, tsunamis, human error, breakdowns, and terrorist vulnerability are trivial issues not worth worrying about?

(4) The plan should be based on science, not on PR considerations. The GEIS report reads like a PR document promoting the nuc lear industry. It minimizes, ignores, dismisses and trivializes true dangers. It grossly overstates safety and expresses blind faith in the most optimistic possibilities.

Its excessive reliance on probabilistic risk analysi s is unwarranted and unprof essional. Everyone knows that risk analysis is heavily flawed and full of questionable assumptions.

(5) The dismissal of terrorist attacks shows that this is not a serious report. Everyone who has read the Sandia reports knows that a truck bomb (o r missile, or high explosives, etc.) outside the perimeter could have disast rous effects on fuel pools. Nuclear power plants were never designed to be fortified against such attacks, and any report wh ich ignores this is a report not to be taken seriously.

Roger Johnson, PhD Professor Emeritus San Clemente, CA Dec. 16, 2013

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