ML110680515
| ML110680515 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/07/2011 |
| From: | Marida P Sierra Club, Central Ohio Group |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 75FR57299 00008 | |
| Download: ML110680515 (4) | |
Text
SIERR,A
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-;5 Ohio Sierra Club 131 Nor*h High,$Street Suite 605 Columbus,.OH 43215-3026
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vrn 614-461-0734 r
Subject:
Proposed 20-year Operatingextension for the Davis Besse nuclear.reactor
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My name is Patricia Marida and I am the chair of the Nuclear Issues Committee of the Ohio Sierra Club.
The Sierra Club opposes nuclear energy inWits entirety, citing serious environmental, healt and public expens,,
.. . .pii .ulc I.. Ig eiu, niomna h and expnse issues throughout the nuclear fuel cycle. The time frames needed to guard the radioactive nuclearwaste generated.
from this process are geological in nature. Isolating the radioactive nuclear waste will consume public time and money for generations to come., The only viable solution for radioactive waste is to stop generating it., Radioactive contamination and waste are a major reason to discontinue the use of nuclear power.
The risk and reality is that radioactive contaminationhas ,c'urred, is occurring and wyillcontinue to occurn... .
throughout the nuclear power cycle. Mining is leaving radioactive tailings exposed to the air and water.on First Nations landrin the US, Canada and Australia. Contamination ýccurs throughout the milling, refining, srspoýrt,:
conversion of uranium to uranium hexafluoride (UF6),..and *n eo.ichmentwhich in'the gaseous diffusion,.
process at Piketon Ohio took as much energy as a large city. Then the fissionable uranium must be formulated' into rods. An enormous waste stream is the depleted uranium hexafluoride (DUF6), which is 99% of the original uranium but is not fissionable and therefore not usable for energy, However, it is just as radioactive and must be-deconverted back to the more stable uranium oxide. A newly operating plant at Piketon will take 25 years running round-the-clock to deconvert the 40,000 14-ton canisters of DUF6 already on the site, not counting how much nmore will be generated from other enrichment facilities.
Enormous amounts of energy go into this process. Added together along with disposal, these supporting, industries cause nuclear power to also come with a heavy carbon price, which means that nuclear power will not address but will worsen global warming.
Centralized electric power, complete with centralized corporate profits for the nuclear and coal industries, has been heavily subsidized by the public for many years. Without public subsidies, loan guarantees and liability limits, for which the public must bear the burden, no nuclear power plant would have ever been built.
In Ohio, the use of electricity has been decreasing for a number of years. Now with progressive legislation like Ohio's SB 221, energy efficiency and conservation, combined with the renewable sources of solar, wind, and geothermal, are providing so much additional and conserved energy that all plans for new coal plants in our state have been cancelled and there is a strong movement to shut down the old polluting'coal-fired plants. The argument of US rising energy needs is irrational at best and at worst the resulting global warming would threaten our life-support system, and yes, our "way of life".
There is good reason why there are no new nuclear power plants coming online to replace the old ones. Wall Street will not support them. The enormous up-front costs and 12-20 year length of time for completion makes them financially uncompetitive with wind and solar. And the latter are decentralized, meaning that jobs are being created all over the state. As compared to Davis Besse's extended shutdowns, if the wind stops blowing or the sun is behind a cloud somewhere, there is likely not to be a serious or long-term power shortage problem.
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A 20-year extension of the Davis Besse operating license is unfounded on the grounds of future electric-generating needs. " .
Even without the aforementioned problems plaguing nuclear power in general, the DavidBesse, facility is in-tenuous condition to continue operation, even at the present. Continuing for 20.years past 20Q17 would constitute reckless disregard for public safety and environmental integrity. The history of failures and dangers atthis P i well known and well documented, so the Sierra Club will not reiterate them here.
However, the process by which First Energy and the Nuclear Regulatory Commission allowed a delay in'th6 inspection of the reactor head in 2002, coming within 1/8 inch of a nuclear disaster that would have left the Midwest uninhabitable and the Great Lakes, the world's largest supply of fresh water, filled with radioactive contamination shows that the public should have no confidence whatsoever in the ability of First Energy to self-regulate or in the NRC to rigorously enforce and inspect so dangerous an operation as a nuclear reactor. They were willing to take these incredible risks simply based on profits.- N6t only that, but corporate culture makes it difficult for any one person to buck the system or feel responsible for anything other than following the orders of their immediate superiors, Even the 40-year time frame for operation of a power plant does not have an engineering basis, but was based on the time needed to pay off constriiction bonds. Whatfhapplened to the engineering responsibility to oversee and advise an operation of this magnitude of danger?
Last butnot least, nuclear power is being used to keep the nuclear weapons industry afloat. Facilities and research for nuclear power can be transferred to Weapons uses. The USEC enrichment plant at Piketon is a prime example. More importantly, however, is the need for "legitimating" the nuclear industry. Without nuclear power, the nuclear industry would be only about weapons of mass destruction, giving a very'different light to university research, recruiting bright young students, and other jobs-and research in the industry' As the prospect of the current generation of nuclear power plants shutting down approaches, a weapons industry desperate for a non-military front is the tail Wagging the dog of the push for new and continued nuclear power.
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V' UNDID 19,2, Ohio Sierra lub 131 NoTqrh1i gh Street Site 65 Columbus,,0 H143215r3026
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614-4611,073 "-
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Sojject: -Proposed 20-year oýperatingextension for the.Davis Besse nuclear reactor My name is Patricia Marida and I am the chair of the Nuclear Issues Committee of the Ohio Sierra Club.
The LSierra Club oppose nu~ nryi t niey, citing serious environmnental, health,and pubi xes issues throughout the nuclear fuel cycle. 'The time frames' needed to guard the radioactive nmulear waste generated from this process are geological in nature. Isolating the radioactive nuclear waste will consume public time and money for, gene ons t, come. iThe, only. iable s qlinradi.av e for ,is-to.stopgetgit. .io~tie contamination and waste areamajor reasnto discontiqe,,the use* f nucleairpower. ,
The risk and raiyithtadotive cont inationhia9~urred,4 iocurgand wil ~o~n~tinue to occurý,
thro~ughoiut the nuiclear powerrcycle.' Miningiis laigradioactive ,tailings episdt the airand wteonirt Nationsland in the US, Canada and Australia.. Contamination,66cursmthroughou te'milnrfmin 1 taSPor',
conversion of uranium to uranium hexafluoride,,(UF6) aidýe nihment -whiCh in týhe gaseous diffusion~
process at Piketon Ohio took as much energy as a large city. Then th6 fissionable urainiwi must be formnulated'into rods. An enormous waste stream is the depleted uranium hexafluoride (DUF6), which is 99% of the original uranium but is not fissionable and therefore not usable for energy. However, it is just as radioactive and must be deconverted back to the more stable uranium oxide. A newly operating plant at Piketon will take 25 years running round-the-clock to deeonvert the 40,000 14-ton canisters of DUF6 already on the site, not counting how much more will be generated from other enrichment facilities.
Enormous amounts of energy go into this process. Added together along with disposal, these supporting industries cause nuclear power to also come with a heavy carbon price, which means that nuclear power will not address but will worsen global warming.
Centralized electric power, complete with centralized corporate profits for the nuclear and coal industries, has been heavily subsidized by the public for many years. Without public subsidies, loan guarantees and liability limits, for which the public must bear the burden, no nuclear power plant would have ever been built.
In Ohio, the use of electricity has been decreasing for a number of years. Now with progressive legislation like Ohio's SB 221, energy efficiency and conservation, combined with the renewable sources of solar, wind, and geothermal, are providing so much additional and conserved energy that all plans for new coal plants in our state have been cancelled and there is a strong movement to shut down the old polluting coal-fired plants. The argument of US rising energy needs is irrational at best and at worst the resulting global warming would threaten our life-support system, and yes, our "way of life".
There is good reason why there are no new nuclear power plants coming online to replace the old ones. Wall Street will not support them. The enormous up-front costs and 12-20 year length of time for completion makes them financially uncompetitive with wind and solar. And the latter are decentralized, meaning that jobs are being created all over the state. As compared to Davis Besse's extended shutdowns, if the wind stops blowing or the sun is behind a cloud somewhere, there is likely not to be a serious or long-term power shortage problem.
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A 20-year extension of the Davis Besse operating license is unfounded on the grounds of future electric-generating needs.
Even without the aforementiorned problems plaguing nuclear power in general;,the David Bese facility isin tenuous condition to continue operation, even at the present. Continuing for 20 )yearspast ý0 17 would 9onstiitute reckless disregard for public safety and environmental integrity. The history of failures and dn-gers at thi Is plant'is well known and well documented, so the Sierra'Club will not reiterate them here. .
However, the process by which First Energy andthe Nuclear Regulatory Commissioi allo*wý`d deay inthe inspection of the reactor head in 2002, coming within 1/8 inch of a nuclear disaster that would hl"eIleffth, Midwest uninhabitable and the Great Lakes, the world's largest supply of fresh water, filled with radioactive contamination shows that the public should have no confidence whatsoever in the ability of First Energy to self-regulate or in the NRC to rigorously enforce and inspect so dangerous an operation as a nuclear reactor. They were willing to take these mcrbdibleinslirsmply bsed'on profits. Not only ttiat; but corporate culttie makes it difficult for any one person to buck the system or feel responsible for anything other than following the orders of their immediate suveriors.
Even the 40-year time fframe for operation of a power plant does not have an engineering basis, but was based on the time ne~1ed~to payoff coistInoni6nbonds. Wliat happened-to theengmeermg responsibility-to oversee and ad~is~'anfpe Afitojhofthis-m" agxiitiide' of'danger SLast6urnotest, inuclearpower isbemglusedto keep the.nuclear weapons industryafloat. -Facdilities and :..
research for nuclear power can be transfe&rredto onsuses "The*USEC enritnent plantat Piketon is a prime example. More importantly, however, is the need for "legitimating" the nuclear industry. Without nuclear power, the nuclear indistry wuldbe on y ,aboutweapons'of mass dest ongivmg a-verydiffeent lit toiuniversity eCiiig brtyoun*
resea*rc, rcthertjing -odu stiits, and researchmin-the mAustry,' Asý the prospect ,of the';
current gener~atinof nuclear power platsI shuttmfig-dowxn approaehes; aweapons mdustry desperate.for a non-military front iS`Wietta [ ag the 'dog ofthepuiish for new and continued nuclear power.
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