DRAFT FOR SIGN ON BY FRIDAY FEB 22

2/22/08

DRAFT FOR SIGN ON BY FRIDAY FEB 22

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DRAFT FOR SIGN ON BY FRIDAY FEB 22 dianed@nirs.org 301 270 6477 x 16

Office of the Secretary
U.S. Nuclear Regulatory Commission
Washington, DC 20555

February 22, 2008 ??
Dear Office of the Secretary,

The Nuclear Regulatory Commission is currently considering applications (Nos. IW023 and XW013, Federal Register Volume 73, Number 28, 2/11/08) from EnergySolutions for import/export licenses that would bring 20,000 tons, 1 million cubic feet, 600,000,000,000,000 becquerels of radioactive waste (mainly from Italian nuclear power and related industries) into the US for processing including incineration, transport and disposal.

Our organizations request a 90-day extension on the time period to request a hearing or petition for leave to intervene and for public comment.

In terms of volume, the application appears to allow close to all of the Italian “low and intermediate” level nuclear waste inventory to be brought to the US through US ports, on US roads, rails and/or waterways for processing in Tennessee and dumping either in Tennessee or at the licensed nuclear dump in Utah.

The activities of the nuclear waste processors in Tennessee, including EnergySolutions, which release some nuclear waste into regular solid waste trash dumps and into recycling streams, currently are being questioned and challenged in that state.

Importing such massive amounts of nuclear waste for transport and processing could affect the ability to manage our own country’s growing amounts nuclear waste.

Because of the
àunprecedented large amounts of waste and radioactivity involved,
àpotential impact on ports, transport routes, communities with processors and those downwind and downstream;
àincreased potential for radioactive materials deregulated via EnergySolutions to get into commerce or unregulated waste facilities;
ànewness of the information to many potentially affected parties and communities;
àpotentially disproportionate impact on communities of color and low income communities in several of the directly affected states,

we call for an extension on the comment, hearing and intervention request period for the EnergySolutions import/export licenses for Italian nuclear waste.

Sincerely

Diane D’Arrigo
Nuclear Information and Resource Service

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1. Climate change is underway. Renewable energy can be brought online faster, more cheaply and more safely than nuclear power. 2. Reactors are sitting-duck targets and are not even defended to the ferocity of the 9/11 attacks. 3. Nuclear power is not emissions-free. Reactors routinely release radioactivity and use fossil fuels at every step from uranium mining to waste storage. 4. Building more reactors in the U.S. sends the wrong message abroad. Commercial nuclear technology inevitably leads to nuclear weapons capability. 5. The Yucca Mountain high-level radioactive dump is unsound and even if opened could not accommodate all wastes if generation continues. 6. Evacuation plans are unrealistic. Hurricane Katrina taught us that a mass evacuation during a serious radiological release would be a chaotic catastrophe. 7. A typical 1000 megawatt nuclear reactor produces enough plutonium each year to make 40 atomic bombs, an unacceptable risk. 8. New and old reactors are most prone to break down. U.S. reactors are old. New ones increase the risk of accident. 9. The Nuclear Regulatory Commission—mandated to watchdog the nuclear industry – chooses to protect industry profit over public health and safety. 10. The most defenseless are at the greatest risk—children, the elderly, minorities, the poor and animals—at every phase of the nuclear fuel chain. Ten Brighter Ideas 1. If every U.S. household installed one compact fluorescent light bulb, the power savings would equal the power produced by one nuclear reactor. 1=1! 2. Twenty compact fluorescents in every U.S. home could displace at least 25% of U.S. nuclear reactors. 3. Updated lighting, appliances, heating, cooling and other electrical systems can save more energy than all 103 U.S. reactors produce annually. 4. Cost-effective energy efficiency measures for homes and businesses can save at least 20% of electricity use. 5. Turning off and unplugging electrical equipment not in use and line-drying clothes seem like small measures but can make a big difference. 6. Homeowners and renters alike can choose to buy green power instead of nuclear generated electricity. 7. Properly sealing and insulating your home can save 25%-40% of building heat loss. 8. Renewable energy sources can meet 25% of U.S. energy needs by 2025. 9. Shifting to locally-generated electricity avoids waste, reduces brownouts and blackouts, increases efficiency of service and creates jobs. 10. Every dollar spent on nuclear power instead of fossil fuels results in releasing six times more carbon than if the same dollar is spent on efficiency. www.nirs.org 301.270.6477

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2/22/08