3/18/07

ACTION ALERT PILGRIM WATCH

ACTION ALERT from Pilgrim Watch

Here's what's needed for people to do:
1. Send in a comment to NRC in support of the Petition by the March
19 deadline,send email to: SECY@nrc.gov – sample comment below.
2. Important - Cc. Your comment to Attorney General Martha Coakley
by email to the AGO Attorney handling this case-
Matthew.Brock@ago.state.ma.us
3. Email your comments to your local, state and federal elected
officials asking that they do the same, such as:
senator@kennedy.senate.gov; john_kerry@kerry.senator.gov

Comments due March 19, 2007 – NRC Docket No. PRM-51- 10.
Sample Comment:
----------------------------------------------------------

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-51-10 – Pilgrim Watch's Comments in Support
Massachusetts Attorney General's Petition for Rulemaking
(You/We) support the Massachusetts Attorney General's 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
Pilgrim's 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 Pilgrim's 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,


Cc. Matthew.Brock@ago.state.ma.us
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Background info:

We have a huge chance to take a giant step forward on reducing the
risk from spent fuel storage, now.
Obviously it is wrong that NRC is making its decision to re-license
Pilgrim, and any nuclear reactor, to operate an additional 20 years
and not consider spent fuel storage. NRC automatically, across the
board, calls spent fuel storage's environmental impact "insignificant"
and refuses to hear any testimony! And the decision to ignore spent
fuel storage in all re-licensing decisions was made before 9/11;
before the National Academy of Sciences and others studied and
confirmed the vulnerability of spent fuel storage; before we learned
that even a small drop in the pool's water to the tops of the
assemblies would result in an uncontrolled fire and contaminate
hundreds of miles; and before it became obvious that Yucca Mountain
would not open any time soon, if ever - time to change the rule.

The Massachusetts Attorney General hired Diane Curran and did
something about it and filed a Petition for Rulemaking, August 25,
2006. It asks:
NRC to change their rule so that the environmental impacts of
high-density pool storage of spent fuel, will be considered
significant; and require that any NRC licensing decision concerning
high-density pool storage of spent nuclear fuel be accompanied by an
environmental impact statement that addresses the environmental
impacts of this storage and alternatives for avoiding or mitigating
any environmental impacts.

NRC will deny the rulemaking, for sure. Will the Massachusetts
Attorney General appeal to Federal Court? The AGO has a strong case;
stronger than potential appeals in any other state, and Diane Curran
is the best there is to win!

It all depends on us. If the AG sees that it is important -as