[ RadSafe ] emergency petition with the NRC

[James Salsman]

9 July 2008

R. William Borchardt
Executive Director for Operations
U.S. Nuclear Regulatory Commission

Dear Mr. Borchardt,

I request an emergency proceeding pursuant to 10 CFR section 2.202 to
modify the licenses of all dry cask spent fuel storage facilities with
dry casks rated for less than 72 hours submerged.

I ask that the Department of Energy's Yucca Mountain application filed
June, 2008 be approved for construction on a tentative basis. If the
Yucca Mountain application is still under review when the facility is
ready, I ask that the licenses of all dry cask spent fuel storage
facilities with dry casks rated for less than 72 hours submerged be
allowed to transport their spent fuel to the Yucca Mountain on a
tentative basis in accordance with the Department of Energy's
application for Yucca Mountain.  The following facts form the basis of
this request:

1.  Uranium is a mutagen and a teratogen.  Soluble uranium entering
drinking water supplies causes birth defects, leukemia, and immune
system disorders. (Alexandria C. Miller and David McClain, 2007 and
earlier National Research Council reviews.)

2.  Dry cask storage uses casks rated for less than 72 hours
submerged.  Many have been rated at less than 10 hours submerged. (10
CFR 54.19 applications and other NRC publications)

3.  Flood risk is increasing at a greater basis than when current cask
storage and the procedure for approving national storage facilities
were designed.
http://www.noaanews.noaa.gov/stories2008/20080619_climatereport.html

4. Recent events, such as the tunnel fires, have shown that the design
specifications of the spent fuel storage cask may be typically
overcome by real-world conditions.
http://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr6886/

Therefore, it is in the best interests of the people of the United
States and the Commission to immediately approve construction of the
Yucca Mountain national storage facility on a tentative basis.

Thank you.

Sincerely,

James Salsman