2003-07-11 Generic Environmental Impact Reports For Licensing

Comments of the San Luis Obispo Mothers For Peace regarding the NRC's Generic Environmental Impact Statements for the license renewal of aging nuclear plants

San Luis Obispo Mothers For Peace

P.O. Box 164
Pismo Beach, CA 93448
(805) 773-3881

July 15, 2003


Nuclear power plants are granted operating licenses for a set amount of time - typically 40 years. It has been the practice of the Nuclear Regulatory Commission to allow applications for renewals before the license expires, which, if granted, add an additional 20 years to operation potential. It is time for the NRC to reconsider this practice. The NRC's primary task is to protect public health and safety and it is essential that the NRC abide by its mandate when considering the issues of continued operation of aging nuclear plants.

There exists a myriad of significant problems that must be resolved before license renewals are granted. These issues include, but are not limited to:

  • terrorism and acts of malice and/or insanity;
  • the absence of a safe site for storage of high-level radioactive waste;
  • aging reactor components;
  • cost/benefit analysis to determine if continuation of nuclear power is in the best interest of California residents and PG&E and Edison ratepayers.


The NRC and the nuclear industry are in a serious predicament. September 11, 2001 brought attention to the vulnerability of nuclear plants as terrorist targets. The catastrophic consequences of an attack are unthinkable, yet they must be considered in any GEIS for nuclear power license renewals. Our President has warned us that nuclear plants are on terrorists' short-lists and vulnerable to attack from air, sea, and land. In addition, it has been widely reported that the designs for U.S. nuclear plants were found in Al Quaeda terrorist hideouts.

Our President has repeatedly promised that our government will do everything in its power to protect U.S. citizens. Yet, all petitions to the NRC filed by communities and states requesting defense-in-depth at nuclear facilities have been denied. But residents of reactor communities continue to raise the issue of security. California's Attorney General and Senator Dianne Feinstein have both sent letters to the NRC requesting that security be more adequately addressed.[1]

The NRC must change the assumptions that it previously held before September 11, 2001. As a condition of re-licensing, the GEIS for nuclear plant license renewals must require that the licensee:

  • has the means to resist an attack on the reactor building, its support structures, and its spent fuel storage - from air, land and water by a team of well equipped terrorists;
  • be required to pass tests and mock-attack drills which would demonstrate the adequacy of its security. These tests should be required every two years and include mock-attacks testing when the licensee is refueling.


When U.S. nuclear reactors were originally built, costly components such as steam generators, turbine rotors, component cooling systems, and reactor vessel heads were thought be able to last the lifetime of the nuclear plant. This has not been the case. Across the nation, these and other very expensive parts have begun the age-related process of corrosion and erosion. The result has been that:

  • major, expensive components are not replaced, simply patched;
  • components have been identified as substandard or counterfeit - making it impossible to judge expected lifespan;
  • federal oversight has been lacking, allowing undiscovered degradation, i.e. Davis Besse plant.

The escalating potential for accidents at aging reactors has received nationwide attention and derogatory audits by the NRC's own Office of Inspector General. Additionally, the General Accounting Office (GAO) has documented the widespread use of counterfeit and substandard parts in nuclear reactors. Furthermore, in a deregulated electric market, or a hybrid such as currently exists in California, the licensee is motivated to cut costs by delaying expensive repairs. There is thus an economic disincentive to find and remedy problems. Hence, the GEIS must require that site- specific issues be performed by the NRC, not the licensee.[2]


The NRC must improve its risk assessment guidelines for nuclear power plant renewals. An integral component of the GEIS for nuclear license renewal is the evaluation of consequences and correction of flaws in calculating accident probabilities. Nuclear plant risk assessments are not valuable because potential accident consequences are not evaluated. They merely examine accident probabilities -- only half of the risk equation. Consequences are potentially so catastrophic that they must be considered.

Moreover, the accident probability calculations are seriously flawed. They rely on assumptions that contradict actual operating experience. The risk assessments assume nuclear plants always conform to safety requirements, yet each year more than a thousand violations are reported. Plants are assumed to have no design problems even though hundreds are reported every year. Aging is assumed to result in no damage, despite evidence to the contrary. Reactor pressure vessels are assumed to be fail-proof, even though embrittlement forced the Yankee Rowe nuclear plant to shut down. The risk assessments assume that plant workers are far less likely to make mistakes than actual operating experience demonstrates. The risk assessments consider only the threat from damage to the reactor core despite the fact that irradiated fuel in the spent fuel pools represents an equally serious health hazard. The results from these unrealistic calculations are, therefore, overly optimistic.

Risk assessment analyzes health impacts by calculating impacts from exposure to a healthy 30-year- old "reference man" weighing179 pounds. However, there are no age, sex, and weight requirements to allow residences near a reactor. The very young, old, and disabled also live in the community and may be impacted. The results from these unrealistic calculations are overly optimistic.

Furthermore, the NRC requires plant owners to perform the calculations, but it fails to establish minimum standards for the accident probability calculations. Thus, the reported probabilities vary widely for virtually identical nuclear plant designs indicating that self-assessment is inaccurate.

Any risk assessment must also include human error and terrorism/sabotage in order to have any real-life validity. For example, a 1987 study found that human error contributed to 74% of all incidents at nuclear power plants.


For nearly three decades, residents of reactor communities and the nuclear industry have been promised a solution to safe disposal of nuclear waste. Unfortunately, that has not materialized, and the problem of storing high level radioactive waste - both in the short and long term - remains unresolved.

  1. Long term: Yucca Mountain is not certain. Litigation is still pending and technical and transportation issues are unresolved. Even if Yucca Mountain is licensed, it will take decades to transfer all of California's current waste. Re-licensing reactors will result in so much additional waste that Yucca Mountain will be filled to capacity by 2036. 44,000 tons of nuclear waste will remain at reactor sites.
  2. Short term: interim, onsite storage in low-density pool storage and independently tested hardened dry casks must be mandatory before re-licensing. In January 2003, a study appeared in the spring issue of "Science and Global Security," a publication of Princeton University. This study confirmed 25 years of government research in concluding that spent fuel pools are particularly vulnerable to terrorist attacks and acts of malice and could generate a pool fire and corresponding contamination of hundreds of square miles. The Science and Global Security study calls for removal of the fuel from the densely packed pools into hardened, dry storage and placing any new fuel in a low density pool.

An example of the dangerous situation exists at Diablo Canyon Nuclear Power Plant. By 2006, Diablo Canyon's two storage pools will contain 2,648 radioactive waste assemblies, yet the pools were originally designed for approximately 500. The pools have no significant reinforcement structures to prevent damage from an external hazard such as an intentional attack on the facility, and it is dependent for its functioning on the operation of even softer targets such as the control room, pumps, and switch yard. If an attack or accident causes sufficient loss of coolant water, a pool fire could result in the release of up to 40 times more highly radioactive Cesium137 than was released at Chernobyl. The radioactive contamination there rendered 12,400 square miles uninhabitable for centuries. For comparison, the entire county of San Luis Obispo consists of 3,316 square miles. Furthermore, a partial loss of pool water could be even more dangerous than a total loss because of the potential of exothermic reactions between the cladding of the waste fuel and water steam. This reaction could result in the production of hydrogen.

The result of the government's inability to find a safe storage site has been applications by utilities around our country for onsite storage of nuclear waste. Most of the proposed onsite storage facilities could never pass a rigorous test for a nuclear waste site. Yet, no other options are made available. And here in our coastal zones, high level radioactive waste continues to mount and will likely remain for many more decades - endangering its citizens and environment. Additionally, the present practice of high-density storage of fuel assemblies in the pools has created additional and unacceptable risks to the surrounding communities. Low density pools and hardened dry cask storage are essential as a pre-condition of re-licensing to protect public safety until all the radioactive fuel can be removed to a safe off-site location.


If onsite storage for high level radioactive waste is proposed as a "temporary" solution, then the NRC is obliged to consider the eventual transportation of this waste. When original license proceedings for Diablo Canyon Units 1and2 were held over 20 years ago, the NRC did not allow full evidentiary hearings on the subject of transportation of nuclear waste. This error has resulted in the application of PG&E for a site-specific license for nuclear waste storage in an earthquake prone coastal zone.

Scenarios for transport of nuclear waste include trucks on our major highways, trains, and barges. Seven million Californians live within one mile of proposed routes, and none of these modes can be protected from terrorist strikes or accidents. In California alone there were 1,880 tractor-trailer accidents between1994 and 2000 and 4,264 train wrecks from 1990 to2001. These statistics represent a fraction of the accidents across our nation, and the tragedy of just one accident involving nuclear waste would be devastating.

As recently as July 8, 2003, California requested a halt to medium-waste shipments of nuclear materials. This action was taken to protect California residents and "first responders" from the inherent dangers of nuclear waste spills arising from accidents and/or sabotage - and supported by California's Senator Feinstein.[3] Nuclear power plant license renewals increase the necessity of a greater number of shipments and thus the odds of such a lethal accident.

To quote from the Los Angeles scenario of the Environmental Working Group: "Given the unanimous agreement that train or truck accidents are inevitable during the tens of thousands of radioactive waste shipment to Yucca Mountain, we believe people have a right to know what would happen if one of those accidents led to a release of radioactive materials in their town. ?The number of people exposed to unsafe doses of radiation is entirely dependent on the timing and location of the accident or attack."[4]

The NRC must consider the full consequences of high-level radioactive waste transportation before it can determine the GEIS of nuclear power plant license renewals.


Emergency planning for reactor facilities involves many assumptions that may prove to be inaccurate. A recent study commissioned by Entergy Nuclear Northeast, determined that "?the evacuation of the 10 mile zone around the Indian Point nuclear power plant would take roughly nine hours and 25 minutes, almost double the time previously allotted."[5]

Add to this report the fact that emergency planning for communities along proposed transport routes is virtually non-existent, and it becomes clear that new studies are needed. A recent train accident in the City of Commerce resulted in the loss of several homes. Imagine that tragedy coupled with high level radioactive waste as its cargo.

Extensive and realistic emergency planning upgrades must take into account accidents resulting from terrorist attacks and attacks on spent fuel sites. Such accidents are fast breaking and of considerable consequence spreading well beyond the current 10 mile EPZ. Consideration of these scenarios must be made mandatory to protect the residents of this state and must be included in any GEIS for license renewal.


Most people think of the impacts of the oil and coal industry when global warming is mentioned. However, for coastal reactors global warming is increasing the temperature of cooling waters, eroding coastlines, corroding components. Climate changes must be included in the GEIS for nuclear power license renewal.


The two nuclear power plants in California use ocean water for their cooling systems, and the results of this are devastating to the marine life. The water taken in entrains and impinges fish and larvae, decreasing adult fish populations and effecting the ecology of the area and commercial and recreational fishing. The heated water going out forces changes upon the indigenous environment; plants and animal species that survive or move in are ones that can tolerate the elevated temperature. The abalone is an example of one species that cannot tolerate the elevated temperature.

When considering operating license renewals, the NRC must examine the damage that has already occurred in the coastal waters and the degradation that would continue with plant operation.


The true costs of nuclear power from uranium mining, processing, insurance, temporary and permanent storage of high level radioactive waste, and decommissioning must be placed on the table. In order for this state to plan its energy future, a candid disclosure of all costs of nuclear power is required. Any EIS update on this issue must be made retroactive for nuclear plants that have already received license renewals under the NRC's current, but extremely outdated, GEIS.


All critical issues (detailed above) involving the extended operation of a nuclear facility must be adequately addressed and resolved before any license renewals are granted. Additionally, the NRC has an obligation to update all Environmental Impact Statements for License Renewal with meaningful stakeholder input. The issues of safety and cost-effectiveness must be granted full public hearings. Complete and detailed analyses of the true cost of continued operation must be paramount in NRC decision-making. Safer and less expensive energy alternatives must also be given serious consideration. The NRC must abide by its mandate to protect public health and safety when considering the issues of continued operation of aging nuclear plants.

July 15, 2003

Respectfully Submitted,

Rochelle Becker
San Luis Obispo Mothers for Peace


Letter from Atty. General Bill Lockyer to the NRC, Feb 29, 2003 and Letter from Senator Dianne Feinstein March 3 , 2003

Federal Register Notice.

AP July 9, 2003 AP-WS-07-0903 1809 EDT

What if ... A nuclear waste accident scenario in Los Angeles, CA Richard Wiles, James R. Cox, June 27, 2002 www.mapscience.org

Greenwire, July 3, 2003