ML090641135
| ML090641135 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/05/2009 |
| From: | Public Commenter Public Commenter |
| To: | Division of License Renewal |
| NRC/NRR/DLR | |
| References | |
| 73FR80440 | |
| Download: ML090641135 (3) | |
Text
IPRenewalCEmails From: michel [ciecplee@verizon.net]
Sent: Thursday, March 05, 2009 2:05 PM To: IndianPointEIS Resource
Subject:
Indian Point: Submission of Comments to on Comments on Draft Generic Environmental Impact Statement for License Renewal of Indian Point Nuclear Generating Units No. 2 and 3
Subject:
Comments on Draft Generic Environmental Impact Statement for License Renewal of Indian Point Nuclear Generating Units No. 2 and 3 Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop TWB-05-B01 Washington, DC 20555-0001 To Whom it May Concern, The Draft Generic Environmental Impact Statement for License Renewal of Indian Point Nuclear Generating Units No. 2 and 3 (Draft EIS) is fatally defective in that it is inadequate, incomplete, and cursory.
Ten crucial problems are:
The Draft EIS utterly fails to evaluate the options for obtaining electricity by clean, sustainable forms of energy (e.g., through solar, wind, geothermal, small hydro) or for dramatically reducing consumption (e.g., through efficiency technologies, reducing energy waste, and green buildings). The final EIS must properly evaluate the No Action Alternative.
The Draft EIS fails to properly and fully evaluate the impact of Indian Point on the aquatic ecology of the Hudson River and related waterways, especially with respect to endangered species and the coastal zone.
The Draft EIS fails to properly and fully evaluate the long-term and cumulative effects upon human health of the planned and unplanned releases of radiation into the air, soil, groundwater and Hudson River. The Draft EIS further completely fails to look at the impact upon human health of the synergistic interactions of such radiation with other known toxins which are known to have been released into the regional environment, most notably the PCBs and mercury in the Hudson River.
The Draft EIS fails to evaluate the impact of global warming - including the projected warming of the Hudson River and the projected increase and severity of storms and flooding - upon Indian Point. Two examples: (1)
The warming of the Hudson River will exacerbate the impact of the hot plume of water expelled by Indian Point into the river. (2) Increased storms and flooding will exacerbate the corrosion, rusting, etc. of underground piping and other systems at the plant, thereby increasing the likelihood of more accidental radiation releases such as the one discovered in February 2009.
The Draft EIS fails to analyze seismic hazards. This is a manifest dereliction of the NRCs duty, especially in light of recent seismic activity in the region and recent studies conducted by Columbia Universitys Lamont-Doherty Earth Observatory which specifically note the potential threat to Indian Point.
The Draft EIS utterly and appallingly ignores the impact upon the environment and human health of keeping spent fuel and other nuclear waste on site indefinitely. The evidence available strongly supports the conclusion that the Indian Point site will, de facto, become a high level nuclear waste dump for the foreseeable future.
1
The cost/benefit analysis of the Draft EIS is incomplete and inadequate and constitutes a violation of NEPA.
Notably, it relies upon the preposterous conclusion that a major nuclear accident need not be of concern, and even if one occurred, it would not have a significant effect on the environment or public health. This flies in the face of the United States governments (including the NRCs) own former analyses. The NRC must include the postulation of a major radioactive release -- including the possibility of a meltdown and spent fuel fire - in its cost/benefit analysis.
The Draft EIS is defective in neglecting to evaluate the environmental risks inherent in the realities that the operator and the NRC have acknowledged that it is not feasible to fully inspect the fuel pools, the buried and embedded piping, critical electrical wiring, or the dome, where rust has already been detected.
The Draft EIS is defective in neglecting to evaluate the environmental risks inherent in an aging nuclear facility which has already demonstrably shown signs of deterioration. The NRCs disregard of aging as a separate crucial factor, and its reliance upon aging management as a failsafe for finding all potentially critical problems, not only flies in the face of standard engineering risk analysis, but is belied by the actual experience at the plant.
The Draft EIS is defective in neglecting to evaluate the environmental risks created by the fireproofing exemptions given by the NRC to Indian Point.
CONCLUSION: The failure of the NRC to acknowledge the above represents a deplorable disregard of the NRC mandate to protect human health and the environment and strongly suggests that the Draft EIS is merely a façade for rubberstamping Indian Points relicensing.
Sincerely, Michel Lee, Esq.
Chairman Council on Intelligent Energy
& Conservation Policy (914) 420-5624 ciecplee@verizon.net 2
Federal Register Notice: 73FR80440 Comment Number: 27 Mail Envelope Properties (0KG10001CRP24804)
Subject:
Indian Point: Submission of Comments to on Comments on Draft Generic Environmental Impact Statement for License Renewal of Indian Point Nuclear Generating Units No. 2 and 3
Sent Date: 3/5/2009 2:05:28 PM Received Date: 3/5/2009 2:05:51 PM From: michel Created By: ciecplee@verizon.net Recipients:
"IndianPointEIS Resource" <IndianPoint.EIS@nrc.gov>
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