December 18, 2012
Earlier this year, a federal court threw out the fundamental underpinning of the NRC’s radioactive waste policy–the agency’s Waste Confidence rule. In a nutshell, that rule stated that the NRC had confidence that highly radioactive irradiated fuel from nuclear reactors would be stored and managed safely forever. That confidence gave the NRC the ability to license and re-license nuclear reactors. The court ruled that the NRC had no basis to make that assertion.
To its credit, the NRC did not challenge the court’s finding, and instituted a two-year moratorium on new reactor licensing and existing reactor re-licensing while it rewrites its rule–a process we think will take a lot longer than two years if it is to include any valid technical justification. Indeed, we believe that there is no such technical justification, and that the moratorium should be made permanent.
In November, the NRC issued a request for comments on the scoping of an Environmental Impact Statement for its rule revision–in other words, what should the agency be considering as it rewrites its rule?
It seems, however, that the NRC doesn’t really want many comments. Despite more than 2,000 of your letters urging extension of the comment period, they have stuck to an uncommonly short period smack in the middle of the holiday season and ending January 2. They have refused to provide an e-mail address for people to send comments to and instead are using only the cumbersome regulations.gov website.
1) NRC must assess the overfilling of highly radioactive irradiated nuclear fuel pools as a factor in catastrophic events, including drain-downs and fires, but also inadvertent criticality and other events where loss of pool integrity results in inability to stabilize cooling within the structure.
2) NRC must compare and contrast the worst-case-scenarios for radioactive releases and health consequences from a disruption of current dry storage, fuel pools and “hardened” dry storage. Based upon this, NRC must examine alternative changes in its regulatory requirements for waste storage on-site since it is easy to forecast, based on existing data, that hardened storage provides a greater margin of health and safety to the public compared to over-filled pools.
3) NRC should exclude off-site “interim” consolidation of waste storage because the transport evaluations done to date are not an adequate basis upon which to claim an increase in health, safety or security. The period of transport (likely decades) must itself be included in the overall evaluation of increased health, safety or security, where clearly it will not support such a claim.
4) One of the options that the EIS must include is no further production of this waste; based on no further licenses, no license extension and expiration of existing licenses. Inclusion of this alternative must include a consideration of the environmental and health consequences of the production of nuclear fuel since commercial production of nuclear fuel would be phased out under this alternative, but not others. NEPA requires that impacts that are tied together by causation be assessed together.
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Updates / 最新記事
- 281_Anti Nuke: The Japanese street artist taking on Tokyo, TEPCO and the nation’s right-wing extremists via
- Pandora’s False Promise by Kennette Benedict via the Bulletin of Atomic Scientists
- 高市早苗議員の原発関連発言を田母神俊雄氏が擁護する via アメーバニュース
- Japan Moves Toward Restarting Nuclear Reactors via The New York Times
- 東海村放射能漏れ、換気扇６５時間半も回し放し via Yomiuri online
- High levels of strontium, tritium found in well water at Fukushima plant via The Asahi Shimbun
- ２号機海側、地下水が高濃度汚染＝トリチウムなど検出—東電福島第１via ウォール・ストリート・ジャーナル
- GOP bill would feed new funding to stalled Yucca Mountain project via the Las Vegas Sun
- 原発の活用は経済成長につながるか・金子勝 via 報道するラジオ
- 【6/19】緊急提言「原発再稼働を3年間凍結し、原子力災害を二度と起こさない体系的政策を構築せよ」に関する記者会見のお知らせ via 原子力市民委員会
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