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Secretary McDevitt <br />September 18, 1998 <br />Page 2 of 3 <br />The problem that most concerns us with the planned expansion is that fuel pools, <br />according to nuclear safety engineer, David Lochbaum, were designed for short <br />term storage of a small quantity of fuel. However, they are having to be modified <br />to take a much larger, more closely packed set of rods for an indefinite period of <br />time. This is because the federal Department of Energy, which is responsible for a <br />permanent disposal site has been unable to provide one and future prospects for a <br />site are very uncertain. The nuclear industry planned on sending their activated <br />fue! for reprocessing when the plants were designed, but that option was ruled out <br />by federal action to prevent the spread of nuclear weapons, after commercial <br />failures of early reprocessing plants. <br />In his book examining spent fuel storage safety, Lochbaum reports that <br />unfortunately, the three-layer defense-in-depth strategy of minimizing the chances <br />of an accident, mitigating the severity of an accident and containing the <br />consequences of an accident employed for reactor safety is not in place <br />consistently for fuel pool storage in this country. In addition he cites numerous <br />incidents where near-misses have occurred in fuel pools because of inoperable <br />equipment, personnel errors, seal failures, etc. that suggest that safety standards <br />are inadequate or not maintained. The consequences for the public within a 50- <br />mile radius of a loss of cooling water accident could be severe according to <br />Lochbaum. The NRC has stated a concern that deregulation or preparation for <br />deregulation will put financial pressures on the nuclear utility industry that could <br />compromise safety at nuclear plants. <br />If the application is approved by the NRC, the Hams site would apparently hold <br />one of the two largest concentrations of high-level waste in the United States from <br />nuclear power plants for an indefinite period until a permanent disposal site is <br />opened. <br />Because of the indeterminate length of storage, the questions on defense-in-depth <br />safety, and the large quantity of high-level waste that would be shipped into and <br />through North Carolina, we request the assistance of the state of North Carolina in <br />three matters: <br />1. Please assist us, with the expertise in radiation protection and engineering <br />at your disposal, in reviewing the fuel pool application and in then submitting <br />comments as warranted to the NRC in order to assure the safety of NC citizens. <br />We hope that review would be conducted as an open public process like DENR's <br />review of the low-level radioactive waste site license application. <br />2. Please ask the NRC to require an Environmental Impact Statement to fully <br />consider alternatives from the safety point of view, before it allows shipment of the <br />