Comments on NUREG-1800

by of the Alliance for Nuclear Responsibility, Environmental Health Coalition, Paul Blanch Energy Consultant and Pilgrim Watch, Three Mile Island Alert, EMFR Monitoring and California Earth Corps 30mar2005

The Nuclear Regulatory Commission stated in NUREG – 1800, that it "is especially interested in stakeholder comments that will improve the safety, effectiveness, and efficiency of the license renewal process." Therefore the Alliance for Nuclear Responsibility is providing the following comments for consideration.

To improve the safety and effectiveness of the license renewal process it is vital that the Nuclear Regulatory Commission cease its pretense that:

1. All nuclear power facilities’ aging components are mostly generic in nature;
2. The only issues to address are aging components;
3. Existing nuclear power plants do not need to meet criteria of new nuclear plants;
4. Security issues have not changed since existing nuclear plants were licensed – most over 20 years ago;
5. A solution to permanent safe storage of high-level radioactive waste exists;
6. Anyone at the NRC involved in decision-making on relicensing will be in position of responsibility for the duration of license renewals;
7. Degradation of waters offshore of nuclear power plants is not a problem;
8. The radiological impacts to the environment of low-level waste storage will remain small during the term of license renewal. This assumes, without basis, that new sites will be developed and that existing sites will continue to accept LLRW. More fundamentally, this falsely assumes that the classification system for waste based on how waste is generated –not its toxicity and longevity – is protective of human health and the environment;
9. Decommissioning at the end of a 20 + year license renewal period would generate no more solid wastes than the end of the current license;
10. The effects of global warming – elevated at sea levels, erosion and increased frequency and intensity of storms can be ignored and do not have to be analyzed for impact on each site seeking a re-license;
11. Review process for re-licensing does not need to evaluate potential accident consequences when making calculations, simply accident probabilities;
12. Review process for re-licensing assumes that it is not necessary to evaluate when calculating risk whether: nuclear utilities conform to safety requirements; reactors have design problems; components are counterfeit and/or substandard; plants workers make mistakes; threats are not only from damage to reactor cores, but also from irradiated fuel in spent fuel pools; plant owners accurately performing calculations without NRC providing minimum standards for the accident probability calculations;
13. Emergency planning simply for slow breaking accidents of minimal consequences ignoring populations that have radically expanded over the last 20 years; and not providing realistic assumptions in emergency drills;
14. A new pool of trained nuclear workers is in place or will be place to replace the current aging workforce;
15. License renewals do not change the original land use intent of the facilities by breaching their tech spec designs and converting them into LLRW and HLRW storage facilities;
16. Safe and secure transport exists to remove radioactive waste from nuclear power plant sites to "somewhere" else;
17. Nuclear power is a solution to global warming. In 2001, 93% of the nation's reported emissions of CFC-114, a potent greenhouse gas, were released from the U.S. Enrichment Corporation, where nuclear reactor fuel is produced. These facilities are so energy intensive that some of the nation's dirty; old coal plants exist just to power the nuclear fuel facilities;
18. Current allowable releases of radiation into the air and water are acceptable, protective of public health. Especially in light of an upcoming National Academy of Science BEIR 7 Report, and other recent research, that supports a supra-linear relationship between low dose and human health effects. 
19. Site-specific hearings are not necessary for all of the above.

The NRC has stated that "all comments should include supporting justification in enough detail for the NRC staff to evaluate the need for changes in the guidance, as well as references to the operating experience, industry standards, or other relevant reference materials that provide a sound technical basis for such changes." However, the public who live with the NRC’s criteria for license renewals are increasing prevented from knowledge of "operating experience, industry standards and relevant reference materials that would provide a sound technical basis for changes." This leaves the reactor communities at a great disadvantage and belies the NRC’s statement that it is "especially interested in stakeholder comments."

All nuclear power plant license renewals result in the following:

1. Additional tons of high-level radioactive waste to be temporarily stored onsite and paid for by utility ratepayers – the NRC has no definition of "temporary";
2. Continued degradation of waterways and ocean life;
3. Continued operation of nuclear power plants disproportionately affecting communities of color - from the mining of uranium on Native American lands, to the targeting of black and Hispanic communities for new uranium processing facilities and targeting of black and Hispanic and Native American communities for so-called "low-level" nuclear waste disposal sites. All of the sites proposed for "temporary" and permanent storage of high-level nuclear waste (nuclear reactor fuel rods) have been Native American lands - i.e. proposed storage at Yucca Mountain.
4. Perpetual years of heightened security and risk for reactor communities.

Yet none of these concerns are at issue in NRC re-licensing proceedings; this omission signals to reactor communities that the NRC is not really interested in the public’s concerns, but will receive "token" comment to fulfill its legal obligations. Another "token" action is a re-licensing workshop held nowhere near reactor communities most effected by NRC actions. For example: If a workshop had been held near a reactor site, the public would have asked that verification of releases by monitors be required - state-of-the art- monitors computer linked to state and local authorities at all points where radiation is released from the reactor and at appropriate off-site locations. Environmental monitoring of deposition in soil, plants, animal and marine life must be independently verified.

As for aging - the one issue that NRC finds relevant to re-licensing proceedings - the Commission considers it mostly generic in nature. Nuclear power plants are not cookie cutter designs. Some are subject to saltwater and salt air intrusion, some experience tornadoes or other geologic activity and/or weather conditions that can impact how components age. Some are located near earthquake faults where geologic science is constantly being refined, but the utilities are not required to update seismic information as new data is collected – even though this could impact how aging components will react in a seismic event.

The only way, according to the AEA, that the NRC can provide reasonable assurance of public safety is to assure the plant is in compliance with the NRC and other applicable regulations. We believe that in order to assure safety, the NRC must identify all applicable regulations and demonstrate, with objective evidence – nuclear plants are and will remain in compliance with all regulations. (See attached 2.206 petition)

Aging of components can be related to weather, geologic conditions, maintenance, personnel errors, quality of design of components and other factors. These aging issues cannot be generic, yet the NRC ignores the site- specific conditions of aging in favor of expediting license renewals for nuclear utility owners. The public fails to see how aging components can be considered a generic issue for the purpose of license renewals, or why other impacts of continued operation are being ignored.

Until regulations for re-licensing are in place to assure that aging reactors and all conditions that impact aging are addressed and resultant impacts of continued operation are considered NO license renewals should be approved.

Submitted by:

Rochelle Becker, Executive Director 		Al Huang
Alliance for Nuclear Responsibility 		Environmental Health Coalition
PO 1328 					Mile of Cars
San Luis Obispo, CA 93406-1328 			San Diego, CA

Paul M. Blanch, Energy Consultant 		Mary Lampert
135 Hyde Rd. 					Pilgrim Watch
West Hartford, CT 06117 			148 Washington St.
860 236 - 0326 					Duxbury, MA 02332

Eric Joseph Epstein Chairman, 			Don May
Chairman, TMI_Alert 				Coordinator, California Earth Corps
Coordinator, EFMR Monitoring			4727 Minturn
4100 Hillsdale Road				Lakewood, CA 90712
Harrisburg, PA 17112 
(717)-541-1101 Phone
(717)-541-5487 fax