See below from the NRC blog website.
In the link immediately below, is the NRC page you can paste in a comment on Continued Storage of Spent Fuel.
It's easy. You have to leave your name, that shouldn't be a big deal to you. At the bottom of this post, I will addend my comment to them.
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The public comment period on the Waste Confidence proposed rule and generic
environmental impact statement (GEIS) ends December 20. During the 98-day
public comment period (the end date was extended due to the government
shutdown), the NRC staff conducted 13 meetings around the country to receive
your feedback.
We’d like to thank the more than
1,400 people who attended these meetings, either in person or by
teleconference. We have posted transcripts of the public meetings on the Public Involvement section of
our Waste Confidence webpage.
We appreciate all of you who spoke at the meetings providing your thoughtful
comments. The safe storage of spent nuclear fuel and the impact on the environment
are critical issues in the country’s nuclear policy. We here at the NRC are
committed to ensuring that spent fuel remains safely stored until a repository
can be built for permanent disposal.
So what’s next? The staff of the Waste Confidence Directorate is
busy cataloguing the tens of thousands of public comments we have received so
far. You can read the comments we’ve processed already using ADAMS and http://www.regulations.gov/(search
for Docket ID NRC-2012-0246). We are continuing to post comments, and of course
we expect to receive additional comments up to the December 20 deadline.
Instructions on how to submit comments are on the Public Involvement section of
our Waste Confidence webpage.
Once the comments are fully catalogued, the staff will consider
them and prepare responses to be included in the final GEIS and rule. These
final versions will of course include any changes from the drafts stemming from
the comments. We are working to issue the final rule and environmental study
later in 2014.
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Testimony
to NRC
When
nuclear power plants were first built, the spent fuel pool was designed as a
very temporary storage site. The pools were never intended for long term
storage. I have studied the situation
to a large degree, and I feel qualified to speak on these matters with several
thousand hours of training in nuclear processes and radiation physics.
I have a BSME from Northwestern University,
and MSME from University of Michigan, and have worked as a Safety and Security
officer on important Government projects, as well as being a Mechanical and
Electrical Construction Estimating specialist.
Because
no Government knows how to handle the spent fuel “hot potato” in the long term,
the problem has not even begun to be addressed. There is no good long term solution, but
we do have a good short term solution, and it immediately creates good
productive jobs while making the spent fuel a whole lot safer than it is
sitting in fuel pools near reactors.
Dry
Cask everything that can be Dry Casked now.
Typically spent fuels that have been cooling for 5 years can be Dry
Casked.
Until
the fuels are put into Dry Cask, there is a risk of a regional economy killing event
due to power loss/natural diasaster, or terrorist action. There have been far too many close calls in
the last few years, in the USA. We are flirting with disaster. Our good judgment in risk control has been
decimated by lack of good choices and the hope of a Yucca mountain, always
right around the corner.
There
is a GREAT interim solution, which creates good jobs in America, and we need
that badly, and solves much of the problem, immediately increasing our safety
and reducing our risk of terrorist attack.
The
numbers are simple, a dry cask can handle about 10 tons of material, and costs
between $1M to $2M.
There
is roughly 60,000 tons of spent fuel in the USA that is not already Casked. USA generates around 2000 tons a year, and
it takes 5 years to cool enough to be Casked, therefore 5 * 2000 = 10,000 tons have
to wait to be Dry Casked, leaving 50,000 tons that could be and SHOULD BE Casked
now.
At
10 tons per Cask, that is 5000 Casks
Material
cost of $1.5M each, that is $7.5 B in Cask material cost.
Let’s
allow 50% of the material cost as a labor cost related to making the slabs the
Casks will sit on, and moving the fuel, documentation and testing, or $3.75B. The security cost of monitoring and
protecting the Dry Cask will be far less than securing the much more dangerous
spent fuel pools, so there will out years savings on that cost item.
So
the total cost with labor and materials will be around $11.25B to dry cask
everything that can be Dry Casked now.
This is about $225,000 per ton.
Let’s say the process takes 7 years, an additional 14,000 tons will be
created, that’s another $3.125B needed.
Or a total
of $14.375B to dry cask ALL of the spent fuel in the USA up to 2020. But keep in mind $4.8B of that will be
going into the hands of US trade workers, who will immediately put that income
back into the economy, and create a further economic boost when we need it the
most.
In
2013 President Obama commissioned a study on the costs of “doing nothing” and
found that Utilities have already sued the US Gov with 80 victories to recover
their storage costs because USA did not come through with a Yucca mountain or
similar. Direct payouts around $2B,
and further they estimated that as more plants age and close that the USA
taxpayers could be on the hook for $20B in judgments by the year 2020. And up to an additional 20% could be legal
and consultants fees, bringing the tab to $24B
How
much more simple can this be?
$14.375B to “pretty darn well” fix to the problem for 50 years and
reduce our risk of disaster or terrorist attack, create good jobs, or squander
$24B in judgment fees and lawyer costs and NO PROGRESS?
Although
no viable long term solutions are currently available, we insist on the
immediate transfer of spent fuel rods which have sufficiently cooled for 5
years in the vulnerable pools into more secure, hardened on site, dry cask
storage.
Making matters far worse, years ago the NRC quietly approved burning the fuel in the reactors longer, resulting in "high burnup" waste, which turns out may not actually be safe for storage or transport. High burnup fuel, and it's excessive thermal and radioactive heat accelerating the degradation of dry cask storage containers, has not been adequately addressed in the GEIS.
While the NRC has licensed the storage of "normal" radioactive fuel for up to 50 years, they can't endorse the storage of high burnup fuel for even 20 years. STOP high burn up fuel now.
Making matters far worse, years ago the NRC quietly approved burning the fuel in the reactors longer, resulting in "high burnup" waste, which turns out may not actually be safe for storage or transport. High burnup fuel, and it's excessive thermal and radioactive heat accelerating the degradation of dry cask storage containers, has not been adequately addressed in the GEIS.
While the NRC has licensed the storage of "normal" radioactive fuel for up to 50 years, they can't endorse the storage of high burnup fuel for even 20 years. STOP high burn up fuel now.
MOX reprocessing IS NOT an answer. MOX reprocessing is attempting to “burn up”
the fuel by removing the plutonium from the spent fuel and concentrating it in
new fuel rods to be burned in a nuclear plant.
There are 2 problems with this.
1) It is much more
expensive to process and create the MOX fuel than it is to simply cask it. A
study by Princeton presented April 4, 2008 to Congress estimated that
processing MOX including the costs of the MOX facility and decommissioning the
MOX facility is about 10 times more expensive than simply Dry Casking.
2) The MOX fuel is far more likely to blow up in a modified
nuclear explosion called a Moderated Prompt Criticality. Even in the 1940’s it was theorized that a
nuclear explosion could happen in a nuclear reactor, and in the 1950’s Argonne
National Laboratory did a series of experiments that were filmed and proved
that even with normal nuclear fuel rods, under the right conditions, and
uncontrolled criticality could blow up the reactor. With MOX, enriched with bomb making
plutonium, this type of nuclear explosion is much more likely, as Japan found
out in their Reactor 3 at Fukushima, which was running MOX. The amount of Uranium detected by the EPA in
Saipan, Guam, Honolulu, and California could only be caused by one thing….and
explosion from within the reactor vessel, that launched the inventory into the
air. MOX is too dangerous, MOX can
turn a 80 foot tall reactor with 6” steel walls into a “Canon” which can launch
the entire inventory.
The Dry Cask is proven technology, we can produce them in
the USA, we can create jobs in the USA, and we can increase safety, all at an
acceptable cost. Most or all of the
cost should be borne by the existing utilities, since they had the obligation
to decommission their plants. But I
also propose that the US Government, using taxpayer dollars, assist the
utilities, as it is in our common interest to Dry Cask as soon as possible, by
providing 50% of the cost of the cask itself.
