Yesterday, to meet the U.S. Nuclear Regulatory Commission's (NRC) arbitrarily short 30-day deadline for public comments on its "Draft Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I Boiling Water Reactor" (NRC-2013-013), attorney Diane Curran and expert witness Dr. Gordon Thompson filed a blistering response on behalf of an environmental coalition of 26 groups, including Beyond Nuclear.
In her cover letter to NRC, Curran wrote: "...the Draft Consequence Study is not a credible scientific document. While the study purports to be a broad scientific inquiry into pool fire phenomena, in fact it is a very narrow study that ignores basic pool fire phenomena and important pool fire accident contributors. It misleadingly implies that a severe earthquake causing complete draining of a fuel pool is the primary source of risk to a spent fuel pool, and assumes that open-rack low-density pool storage is not advantageous without even examining it. In short, the Consequence Study appears designed to advance the authors’ pre-determined and unsupported conclusion that high-density pool storage is safe."
Thompson makes clear that a partial drain down of a high-level radioactive waste (HLRW) storage pool is an even worse-case scenario than a complete drain down, for air cooling provided by convection currents -- which might otherwise prevent ignition of the irradiated nuclear fuel's combustible zirconium cladding -- is blocked by the layer of water in the bottom of the pool. Thompson points out that any technically-competent analyst who has been paying attention to pool-fire risks since 1979 would have known that, and charges NRC with being deliberately misleading. He also points out the potentially catastrophic consequences of pool fires -- over 4 million people could be displaced, long-term, from their homes, as even NRC acknowledges.
Curran concluded: "We are appalled that after decades of avoiding and obfuscating this urgent safety issue, the NRC now proposes to rely on this biased and unscientific document to justify continued high-density
pool storage of spent fuel, both in its post-Fukushima safety review and in the Draft Waste Confidence Environmental Impact Statement. We join Dr. Thompson in urging you to withdraw the Draft Consequence Study and begin anew with a study of spent fuel pool fire risks that finally complies with basic principles of sound scientific inquiry."
Curran represented a coalition of environmental groups which, along with a coalition of state attorneys general, prevailed against NRC's Nuclear Waste Confidence at the second highest court in the land. The U.S. Appeals Court for the District of Columbia Circuit ruled that NRC must complete an environmental impact statement on the risks of on-site storage of HLRW at reactors, including in pools. NRC did not appeal the ruling, and quickly acknowledged that the completion of the EIS would prevent finalization of proposed new reactor license approvals, as well as old reactor license extension approvals, for at least two years (NRC had previously admitted that a Nuclear Waste Confidence EIS would take seven years to complete!).
Robert Alvarez, senior scholar at the Institute for Policy Studies, has heralded Dr. Thompson's work as a "devastating critique." Alvarez adds, "Gordon's comments systematically reveal the kinds of scientific malpractice the NRC is resorting to at a time when one of the nation's largest and oldest high-hazard enterprises faces a deepening economic crisis."
Alvarez, formerly a senior advisor to the Energy Secretary during the Clintion administration, knows what he's talking about. Along with Dr. Thompson, now-NRC Chairwoman, Ph.D. geologist Allison Macfarlane, and five more experts, Alvarez published "Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States," in Jan., 2003. This groundbreaking warning about the potentially catastrophic risks of HLRW pool fires was largely affirmed by a congressionally-ordered National Academy of Science study in 2005; NRC unsuccessfully attempted to block the security-redacted public release of NAS's findings. Alvarez also published a May 2011 report on the hazards of high-density pool storage across the U.S., in the aftermath of the Fukushima nuclear catastrophe. And in June, in a report commissioned by Friends of the Earth, Alvarez focused on the risks of HLRW pool storage at the now permanently shutdown San Onofre nuclear power plant.