In addition to the NRC's new data on risks, the groups also pointed out that the Commission has concluded spent reactor fuel could be transferred out of high-density storage fuels (where the fire risk is the greatest) in a cost-effective manner.
The groups pointed to the findings of an unpublicized NRC study of spent fuel storage at Peach Bottom, a reactor in Pennsylvania. This investigation showed that if even a small fraction of the inventory of a Peach Bottom reactor pool were released to the environment in a severe spent fuel pool accident, an average area of 9,400 square miles (24,300 square kilometers) would be rendered uninhabitable for decades, displacing as many as 4.1 million people.
As the groups point out in their petition, the NRC has never before acknowledged such dire pool fire risks in its reactor licensing decisions. The information undermines the NRC's conclusion in prior environmental studies for reactor licensing and re-licensing that the impacts of spent fuel storage during reactor operation are insignificant.
In the Peach Bottom study, the NRC also revealed for the first time that the costs of transferring spent fuel out of risky high-density storage pools could be economically feasible, given the enormous damage that a pool fire could cause. Additionally, the NRC concluded for the first time that the likelihood of spent fuel pool fires could be affected by reactor accidents, and committed to study the problem.
The groups are requesting that the NRC conduct a new environmental impact study that incorporates the new and significant information generated as part of the post-Fukushima investigation into the risks of severe accidents in the reactor pools where spent fuel is stored. They contend that, in the meantime, the NRC should suspend all reactor licensing and re-licensing decisions.
Diane Curran, an attorney with Harmon, Curran, Spielberg & Eisenberg, L.L.P., and Mindy Goldstein, director of the Turner Environmental Law Clinic at Emory University, are filing the petition on behalf of the groups. Diane Curran has represented San Luis Obispo Mothers for Peace for 15 years.
Curran said: "If a pool fire accident occurs such as was studied in the Peach Bottom case study, the resulting widespread contamination and displacement of people could have enormous socioeconomic impacts, matching or exceeding the devastating effects of the Fukushima accident on Japanese society."
The NRC has concluded that the "safety" benefit of reducing the density of spent fuel in storage pools would not be great enough to justify an order requiring all operating reactor licensees to thin out their pools. But the NRC focused on the risk of cancer, which is only one effect of a pool fire. The groups contend that NRC must protect not only public health and safety but the environment as well. The environment includes a host of broader values, such as ecological health and socioeconomic well-being. The Fukushima accident illustrates the fact that land contamination and dislocation of people can have enormous effects on society and the environment, regardless of the number of deaths or cancers.
The 34 groups filing the petition are: Alliance to Halt Fermi 3, Beyond Nuclear, Blue Ridge Environmental Defense League, Center for a Sustainable Coast, Citizens Allied for Safe Energy, Citizens' Environmental Coalition, Don't Waste Michigan, Ecology Party of Florida, Friends of the Coast, Friends of the Earth, Georgia Women's Action for New Directions, Green State Solutions, Hudson River Sloop Clearwater, Missouri Coalition for the Environment, NC WARN, National Parks Conservation Association, Nevada Nuclear Waste Task Force, New England Coalition, No Nukes Pennsylvania, Northwest Environmental Advocates, Nuclear Energy Information Service, Nuclear Information and Resource Service, Nuclear Watch South, Physicians for Social Responsibility, Public Citizen, Promoting Health and Sustainable Energy, Radiation and Public Health Project, Riverkeeper, SEED Coalition, San Clemente Green, San Luis Obispo Mothers for Peace, Snake River Alliance, Southern Alliance for Clean Energy, and Vista 360.
A copy of the petition can be found at: http://www.nirs.org/radwaste/atreactorstorage/fuelstoragepetition21314.pdf