A forward from the Nuclear Information and Resource Service: We have three days to speak out to keep Bush’s team from falsifying science yet again in order to justify filling Yucca Mountain with high-level nuclear waste.

New Sign-On- By Nov 10th: NRC Waste Confidence Decision
HIGH LEVEL SHENANIGANS AT NRC in the last days of the Bush Administration:

November 7, 2008

Dear Safe Energy Activists:

The United States Nuclear Regulatory Commission (NRC) is “updating” its “Waste Confidence Decision,” a set of 5 findings in which NRC uses its authority to claim long-lasting, intensely radioactive and biologically dangerous high level radioactive waste and irradiated nuclear fuel can be and will be safely disposed in a deep geological repository some day. In addition, NRC is revising its generic determination there are no significant environmental impacts from storage of irradiated fuel at, or away from, reactor sites after the expiration of reactor operating licenses. NRC is now proposing that the irradiated fuel from any reactor can be stored safely and without significant environmental impacts beyond the licensed life for operation, including the time for extended or renewed licenses reactors, at its spent fuel storage basin or at either onsite or offsite independent spent fuel storage installations (ISFSIs) [we call them IFFY] until a disposal facility can reasonably be expected to be available.

These determinations by NRC are used legally to justify making more waste. NRC is giving us until Dec 8th to comment. Sign on to our extension request letter by midnite MON Nov 10 or send NRC a request directly for 3 months more time. Send comments by Dec 8th in case extension is not granted.

(1) Sign-on by Monday NOV 10 2008 (Midnight eastern time) by e-mailing your NAME / ORGANIZATION / CITY AND STATE to .(JavaScript must be enabled to view this email address) (301 270 6477 x 16) See letter Below.
(2) COMMENT directly to NRC by Dec 8th telling NRC to
(a) revoke the its Waste Confidence Decision and
(b) require more robust storage of irradiated fuel already at operating and closed reactors.

To comment E-mail comments to: .(JavaScript must be enabled to view this email address) SUBJECT: Docket IDs 2008-0482 and 0404

If you do not receive a reply e-mail confirming that NRC received your comments, contact NRC directly at 301–415–1677

Extension Request Letter:

(Sign-on by Monday NOV 10, 2008 Midnight eastern time at .(JavaScript must be enabled to view this email address) )

If you are late please send a note directly to NRC with your request for more time:

To: the US Nuclear Regulatory Commission

From: Multiple Organizations

RE: Request to NRC to EXTEND for 3 months the Public Comment Period on

► Waste Confidence Decision and

► Consideration of Irradiated Fuel Storage at Closed Reactors

Date: November 12, 2008

The organizations below call on the US NRC to provide additional time for the public to comment on proposed Waste Confidence Decision Update

http://edocket.access.gpo.gov/2008/pdf/E8-23381.pdf and

Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation http://edocket.access.gpo.gov/2008/pdf/E8-23384.pdf

We request that NRC extend the comment periods for 90 additional days beyond the December 8, 2008 deadline for both of these high level radioactive waste/irradiated (spent) nuclear fuel proposals published in the Federal Register October 9, 2008. Both of the NRC’s proposals make assumptions that have legal, regulatory, environmental, economic, health, safety, security, moral, genetic and philosophical significance. In order to have a meaningful opportunity to comment on the proposals and their underlying assumptions, and thereby ensure that the NRC complies with the National Environmental Policy Act in evaluating the environmental impacts of high-level radioactive waste disposal, the undersigned organizations require additional time to evaluate the claims and assumptions made in the proposals.

 

The last time the NRC published anything more than a cursory review of the Waste Confidence determination was 1990 in 55 Fed. Reg. 38474 (September 18, 1990). In the proposed revision of waste confidence Findings 2 and 4, the NRC has made some critical and complex judgments that are very different than the judgments made in support of Findings 2 and 4 in the 1990 Waste Confidence rule. It will take considerable time to study the NRC’s judgments and make informed comments on them in a manner that would promote public discourse and better decision-making.

 

The proposed Waste Confidence rule raises important technical and policy questions that demand a significant amount of research and analysis – far more than can be accomplished in 60 days. For instance, the NRC has cited the history of repository programs in various countries as justification for its confidence that “sufficient mined geologic repository capacity can reasonably be expected to be available within 50–60 years beyond the licensed life for operation (which may include the term of a revised or renewed license) of any reactor…” The NRC has cited programs from the UK, Sweden, Finland, Switzerland, Canada, and Germany as part of the basis of its conclusion. The history of these programs is complex and involved, and more than 60 days is required to do the level of research and analysis necessary to determine whether the NRC has correctly interpreted the history of these programs.

 

While the NRC does not rely on the idea that the capacity of Yucca Mountain will be increased, it provides no technical basis that would indicate that such an increase in capacity could be accommodated within the final EPA dose limits. Public comment on this issue requires some time to address the various complexities, especially in view of the fact that the EPA final rule has only recently been published.

 

As another example, the NRC has made assumptions about legislative actions in arriving at its proposed text for Findings 2 and 4. The basis for these assumptions is not clear. It will require a study of the legislative and regulatory history of the U.S. repository program, including the history of the NWPA and the PFS program to address.

 

Finally, the proposals impact communities with existing and new nuclear power reactors, existing and proposed reprocessing facilities, high level waste storage and disposal facilities as well as existing and proposed transportation routes between these facilities. As organizations involved in public education on nuclear issues and as organizations concerned about nuclear safety and the environment, we believe that 60 days is entirely insufficient for us to be able to inform the public about the proposed changes and seek their input. This problem has become even more complex in the last year, since there are now proposals for almost three dozen new reactors, spread from East to West and potentially for new reprocessing facilities.

 

NRC is required to responsibly regulate and manage nuclear waste, which will remain dangerous for literally millions of years. Given the significant and long-lasting character of the risk, given the NRC’s unique role in managing that risk, and given that the NRC’s determinations may be used to justify the construction and operation of an entire new generation of nuclear power plants, it is critical that the public be given a sufficient amount of time to analyze and respond to the issues raised by these two proposals. We respectfully submit that an extension of time of three months is the minimum amount of time required in order to provide a meaningful opportunity to comment on the proposals.

 

Sincerely,

YOUR NAME and ORGANIZATION

TOWN OR CITY AND STATE