ML070660632

Comment (30) Submitted by Marilyn Harquail on Massachusetts Attorney General'S PRM 51-10 Re Amend 10 CFR Part 51

ML070660632
Person / Time
Site:	Pilgrim
Issue date:	03/07/2007
From:	Harquail M - No Known Affiliation
To:	NRC/SECY/RAS
SECY RAS
References
71FR64169 00030, PRM-51-10
Download: ML070660632 (4)

Text

PRM-51-10 DOCKETED 03/07/07 (71FR64169)

Comment No. 30 From: Marilyn <marilyn@alabe.com>

To: <Matthew.Brock@ago.state.ma.us>, <senator@kennedy.senate.gov>,

<william.delahunt@mail.house.gov>, <john_kerry@kerry.senator.gov>,

<Michal.Freedhoff@mail.house.gov>, <Michal.Freedhoff@mail.house.gov>, <SECY@nrc.gov.>

Date: Wed, Mar 7, 2007 10:40 AM

Subject:

RE: Docket No. PRM-51 Support The Massachusetts Attorney Generals Petition for Rulemaking- Spent Fuel Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Attn: Rulemakings and Adjudications Staff.

E-mail comments to: SECY@nrc.gov.

RE: Docket No. PRM-51 Support The Massachusetts Attorney Generals Petition for Rulemaking- Spent Fuel (You/We) support the Massachusetts Attorney Generals Petition for Rulemaking in its entirety.

Specifically we support the conclusions that, the Nuclear Regulatory Commission should:

(a) Consider new and significant information showing that the NRC's characterization of the environmental impacts of spent fuel storage as insignificant in the License Renewal GElS is incorrect, (b) Revoke the regulations which codify that incorrect conclusion and excuse consideration of spent fuel storage impacts in NEPA decision-making documents, (c) Issue a generic determination that the environmental impacts of high-density pool storage of spent fuel are significant, and (d) Order that any NRC licensing decision that approves high-density pool storage of spent fuel at a nuclear power plant or any other facility must be accompanied by an EIS that addresses (i) the environmental impacts of high-density pool storage of spent fuel at that nuclear plant and (ii) a reasonable array of alternatives for avoiding or mitigating those impacts.

We know that this rule change is important to better protect our public health and safety. For example, simply look at the estimates of costs and latent cancers following the releases of Cesium-137 from Pilgrims spent fuel pool prepared by Dr. Jan Beyea for the Massachusetts Attorney

General Motion to Intervene in the Re-licensing Application for Pilgrim and Vermont Yankee, May 25, 2006.

Estimates of Costs and Latent Cancers Following Releases of Cesium-137 from Pilgrims Spent-Fuel Pool Consequence 10% release C-137 100% release C-137 Cost (billions)

$105-$175 billion

$342-$488 Billion Latent Cancers 8,000 24,000

Signed, Marilyn Harquail

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Subject:

RE: Docket No. PRM-51 Support The Massachusetts Attorney Generals Petition for Rulemaking- Spent Fuel Creation Date Wed, Mar 7, 2007 10:40 AM From: Marilyn <marilyn@alabe.com>

Created By: marilyn@alabe.com Recipients nrc.gov.

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