ML14098A028
| ML14098A028 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/03/2014 |
| From: | Sierra Club National Nuclear Free Campaign |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 79FR13079 00007 | |
| Download: ML14098A028 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 7--
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NUCLEAR POWER MAKES CLIMATE CHANGE WORSE The nuclear industry has been selling the world a story that nuclearpower is a solution to climate change because it does not generate carbon dioxide (C02), a majorgreenhouse gas. While this is true of the nuclear chain reaction itself,the front and back ends of nuclearpower generate a large volume of C02 and leave a trail of endlessly dangerous radioactivityalong the way.
" Nuclear power has a bi& carbon footprint. At the front end of nuclear power, carbon energy is used for uranium mining, milling, processing, conversion, and enrichment, as well as for transportation, formulation of rods and construction of nuclear reactors (power plants). At the back end, there is the task of isolation of highly radioactive nuclear waste for millennia-a task which science has so far not been able to address.
All along the nuclear fuel chain, radioactive contamination of air, land and water occurs. Uranium mine and mill cleanup demands large amounts of fossil fuel. Each year 2,000 metric tons of high-level radioactive waste and twelve million cubic-feet of low-level radioactive waste are generated in the U.S.
alone. None of this will magically disappear. Vast amounts of energy will be needed to isolate these dangerous wastes for generations to come.
- Nuclear power takes too long to deploy. Construction of the 1500 new reactors that the nuclear industry claims are needed to address global warming would mean opening a new reactor once every 2 weeks for the next 60 years. Reactors can take 10-15 years to build with an estimated cost of $12-15 billion each. In the past, cost and time needed for construction have each more than doubled from original estimates. We need to supply low-carbon energy sources NOW.
- Nuclear power is not suited for warmin2 climates. Nuclear reactors need enormous amounts of cool water to continually remove heat from their cores. Reactors have been forced to close during heat waves due to warmth of sea, lake or river water
-just when electricity is being used most. Low water levels during heat and drought have also forced reactors to shut down. In addition, cooling causes serious damage to aquatic life, killing millions of fish and untold numbers of macroinvertebrates and fish fry.
- Six times as much carbon can be saved with efficiency or wind.
Benjamin Sovacool from the Institute for Energy and Environment at Vermont Law School averaged the high and low estimates of carbon pollution from nuclear power. His study revealed that nuclear power's carbon emissions are well below scrubbed coal-fired plants, natural gas-fired plants and oil. However, nuclear emits twice as much carbon as solar photovoltaic and six times as much as onshore wind farms.
Energy efficiency and some of the cheaper renewables also beat nuclear by sixfold or more.
- Nuclearpower is not flexible. Nuclear is all-or-nothing power. A reactor can't be geared to produce less power as electricity from renewables (like wind and solar) increases. This can make it challenging to increase renewables past a certain point.
When a reactor shuts down due to accident, planned upgrade or permanent closure, a large amount of power has to be found elsewhere. And nuclear plants are being closed, not opened - some because they no longer are making a profit.
" Nuclear subsidies rob research on renewables. Nuclear power has been subsidized throughout most of its fuel chain. In 2011 the Union of Concerned Scientists published NuclearPower, Still Not Viable without Subsidies. This report shows that in some cases subsidies were greater than the value of the electricity produced. Subsidies are supposed to be for new innovations - not for propping up outdated technologies like fossil fuels and nuclear. Nuclear power could also be called a fossil fuel, because like coal, oil and gas, nuclear depends on a limited supply of natural resources in the ground.
If some of the tens of billions spent on nuclear were funneled to national- and state-planned programs for clean energy and efficiency, we could achieve a fully renewable energy supply, a more democratized energy grid and energy independence much sooner.
" Cost of nuclear is going up, while cost of renewables is going down. Estimates for new reactors are, on average, four times higher than estimates from just eight years ago. Estimates for new reactors are invariably far less than the final cost, with the final cost often doubling. Costs of renewables continue down while their efficiency increases. Sometimes, as in the case of the Columbia Generating Station, Cherokee, and Perry, billions were spent for reactors that were never finished.
RENEWABLES ARE THE REAL ANSWER!
Mitigating climate disruption demands sound investment in economical, expedient, clean and, most of all, safe technologies.
Wind and solar are getting cheaper and more efficient by leaps and bounds. Advances are being made in energy storage. Geothermal energy is being tapped extensively.
Wind farms added about 13 gigawatts of new power in the U.S. in 2012. Solar photovoltaic (PV) plants added 4.2 gigawatts of electricity in 2013. And that's just solar PV.
Solar water heaters have become very economic and popular. There are also concentrated solar power plants that generate electricity directly from the sun's heat, so the total amount of solar power is actually higher than the PV number alone.
Back in 2007, nuclear engineer Arjun Makhijani of the Institute for Energy and Environmental Research wrote the book Carbon Free and Nuclear Free: A Roadmapfor U.S. Energy Policy. In the book he outlined how the United States, with the political will, could generate its energy needs with renewables by the year 2040. The phasing out of nuclear power and coal is now well underway, and the switch to wind, solar and efficiency is quickly gaining momentum.
Check out the Nuclear Free Campaign of the Sierra Club Facebook Group.
Follow @NuclearFreeSC on Twitter.
SIERRA CLUB NUCLEAR FREE CAMPAIGN SIE 85 Second Street, Second Floor CLUB San Francisco, California, 94105 FOUNDED 1592
" Taxpayers on the hook if something goes wrong
- More expensive energy than other energy sources
- Uncontrollable costs including design issues, maintenance problems, "We envision an energy efficient world, powered by clean, waste disposal and cleanup have caused nukes to run over budget.
renewable technologies, free from dirty, dangerous,costly nuclearpower and its legacy of toxic waste". Waste Confidence We oppose all aspects of the nuclear fuel chain from the environ- A recent court ruling overturned the Nuclear Regulatory mental justice tragedy of uranium mining and reprocessing to the Commission's (NRC) long-standing yet unsubstantiated Waste relicensing of old nuclear plants, and the public subsidies involved in Confidence Decision, which claimed that the high level radioactive the construction of new plants.We want safe, secure transport and waste problem would be solved. Now, the NRC cannot license new storage of radioactive waste. Most of all, we want the United States nukes until it establishes a defensible policy, so it has frozen to stop generating nuclear power, weapons and the unavoidable new licensing and renewals.
radioactive waste that is the result of the fuel chain.
" No new nukes should be built without a viable radioactive We are convinced that renewables and energy efficiency are the waste solution future of energy generation. We support diverting the billions of " The current radioactive waste stream is already unmanageable dollars budgeted for nuclear projects to research, to create energy and dangerous efficiency in industry and to develop storage capacity for renewables. " No new waste should be produced when there is no solution We are concerned after the nuclear disaster in Fukushima that we for the old waste which is piling up dangerously. Pools are have reactors with similiar designs on-line in the United States. Many overfull, creating a dangerous hazard.
of these reactors are located in seismic and flood zones that provide " Cleanup for old plants has not even been properly addressed additional risk of disasters to people and the environment.We need to replace the power generated by these plants in order to protect Dangerous & Untested New Models our families and our economies.
Experimenting with new reactor models doesn't lead to a secure energy future.
" Major catastrophic accidents at 3 Mile Island and Chernobyl occurred when they were new plants Why Are We Building New Ones When There Is So Much
- New Designs (AP1000) are unproven technology that have never Trouble With The Old Ones? been built. Fukushima design concerns are not addressed.
New Nuclear Plants
- The proposed plants are not needed
- We have sufficient power now. Efficiency is already coming on board (as much as 40%), buying enough time to allow renewable energy to provide new source replacement.
- Extremely expensive nuclear energy would rob financial resources from clean energy efforts Bad Econornics Wall Street doesn't want this risk. Why should we?
- Costs are paid by taxpayers and ratepayers through Loan Guarantees and CWIP (ConstructionWork in Progress), leaving little fiduciary responsibility and accountability for the energy company
tax breaks for uranium mining and loan guarantees for uranium REIR OL NUKE enrichment to special depreciation benefits and lucrative federal tax breaks for every kilowatt hour from new plants, nuclear is heavily subsidised at every phase.The industry also bilks taxpayers when plants close down with tax breaks for decommissioning plants. Further, it is estimated that the cost to taxpayers for the disposal of radioactive nuclear waste could be as much as $ 100 bn" Sanders, B.and Alexander, R. (2012).
Price-Anderson was first passed in 1957. This law lets nuclear pow-er operators off the hook from paying the high insurance premiums that would be justified by the risks of operating a nuclear plant.
This means that, if there is a Fukushima-type disaster here, U.S.
taxpayers will be the ones writing the checks.
Why are we risking our own Fukushima with outdated E"ON OF N L POW power plants thatcontinue to createradioactivewaste?
Why is nuclearnot the answer to climate change?
Sierra Club When the nuclear industry talks about nuclear power, they don't The Sierra Club is focused on changing our energy sources to go tell you about what goes on at the "front end'-that is, how a beyond coal, natural gas and oil. Phasing out nuclear power plants is nuclear power plant gets its fuel. Front-end industries are not only the next phase in this campaign. Nuclear power is not clean power. dangerousand expensive, but they also irreversiblypollute our We propose that nuclear power plants can be replaced by energy lands and endanger public health and workers. Mining, mill-efficiency and renewables within our lifetimes.We propose that the ing, enrichment and fuel manufacturing consume large quantities of U. S. follow in the steps of Germany, Italy and Switzerland by phas- fossil fuel energy, making nuclear power anything but "green".
ing out our nuclear reactors.
Vintage isn't Cheap Many of the U.S. plants were constructed at least forty years ago.
Their equipment is often old and in need of expensive overhauls.
Crucial parts like boilers need to be replaced.This aging inventory is not only expensive to maintain, but also prone to equipment fatigue, creating a high risk of emergency events that endanger workers and neighboring communities.
Risky Design There are 23 plants in the US that have the same containment design as the Fukushima plants.This brings up the question as to whether nearby communities are in jeopardy for disaster when the design fails again. Experts report that plants are being operated Uranium Mining beyond the capability of their original design. Should we continue Uranium occurs naturally in the ground, but when it is mined and to take a chance? exposed to air and water, radioactivity is released into the envi-ronment. In the United States, large-scale mining takes place chiefly Bad Siting in the West, where it heavily impacts Native American, Latino and The location of nuclear power plants became an issue after low-income communities. Open-pit mines scar the land, while Fukushima. We need to examine how many of our plants are in-situ mines pollute aquifers and put communities' water located in a seismic zone, in a flood plain or on a coast. Poorly sited supplies at risk. Mining accidents, loss of traditional lands, declin-energy plants put large populations of people at risk. ing property values and public health concerns plague mining and milling communities.
Environmental Disaster Uranium Ore Milling The fuel for nuclear power plants contaminates the environment before it reaches its destination. After being used in a nuclear After uranium ore is mined, the milling process treats the ore to reactor, the fuel becomes highly radioactive.There is no definitive extract uranium from the rock. Over 99% of the rock is left over answer to safely storing the radioactive waste. The Sierra Club from this process, in the form of a toxic sludge referred to as tail-supports waste stored in place in hardened casks. The club ings.Tailings are radioactive for 800,000 years and contain 85% of advocates not creating any more waste. the ore's original radioactivity - plus other rock substances such as heavy metals and arsenic - along with the processing chemicals.
Economic Nightmare Over the past 70 years, most uranium tailings were dumped into large, unlined piles. Cleanup and maintenance of tailing piles is cost-To quote Senator Bernie Sanders of Vermont, "R&D and Price-ing taxpayers billions.
Anderson insurance are still just the tip of the iceberg. From
Uranium Enrichment Enrichment is a technically complicated and energy-guzzling process that involves converting uranium to uranium hexafluoride and then "enriching" or increasing the amount of fissionable ura-nium-235 in the product-Taxpayers heavily subsidize enrichment for nuclear power plants, and totally subsidize enrichment for nuclear weapons. Enrichment plant waste is known as "depleted" uranium (DU), which has been used in armor-piercing shells and bunker-buster bombs.
Additional Front-End Processes Fuel fabrication consists of forming enriched uranium into pel-lets, placing the pellets into fuel rods and putting the rods into assemblies. Special plants are built for de-conversion of chemical-ly-reactive DU hexafluoride waste back to uranium oxide. Some Irradiated fuel is stored in pools, in buildings with commercial nuclear fuel manufacturers down blend highly-enriched minimum containment. The pools require active uranium from dismantled nuclear weapons.
maintenanceand control.Loss-of-coolant accidentswould Mixtures of radioactive and chemical pollutants have so releasehuge amounts of radiation.
contaminated many front-end operations that some have become Superfund sites and others have been declared Permanent Storage public health hazards by federal health agencies. The real question is what to do with this waste permanently.
Originally, the expectation was that several permanent geologic
'HIHmL VE WAS repositories would be located and built. In 1987, Congress des-ignated Yucca Mountain, Nevada, as the final and only National NuclearWaste Repository. Due to serious technical difficulties as Why do we continue to make deadly waste? well as environmental, environmental justice and political problems, In the United States, High Level Radioactive Waste, or HLW, is the site has not been licensed, and is not likely to be licensed.The mainly defined as the irradiated, or spent, nuclear fuel that comes current 2012 national inventory of 70,000 tons of irradiated fuel out of a reactor.The irradiated fuel is the number one source of has nowhere to go and no permanent solution.
HLW and must be remotely handled very carefully, as a single rod Sierra Club Policy can give a lethal dose in a few seconds.
The Sierra Club opposes consolidating waste at any central Every year, each of the 104 U.S. reactors produces 25-30 tons of "interim" storage site due to concerns about transport, cost, and the irradiated fuel. As the uranium fuel undergoes the fission process, temptation it poses to promoters of reprocessing (which Sierra atoms are split, heat is released, and new radioactive atoms are Club also opposes), and advocates instead that waste be kept at the created.When the fission process slows down, the fuel is "spent", reactors sites in Hardened On Site Storage, (HOSS) a more robust, or "irradiated" and must be removed. secure and long lasting form of dry cask storage.
Reactors Shut Down Sierrans around the country opposed Yucca Mountain because it was poorly sited. It could well be at least a century before Reactors are shut down periodically to allow for removal of the irradiated fuel, and for new fuel to be loaded.When the irradiated enough repository space is ready to receive these casks. And ifwe fuel is removed, it is loaded into a pool of water, to cool thermally continue to make waste at the current rate or more, if we build and allow some of the dangerous radioactivity to decay.The water new reactors, several repositories will need to be built. The costs in the pool contains a large amount of dissolved boric acid which is continue to mount, along with questions about the ethics of leaving a heavy absorber of neutrons; this assures that the fuel assemblies deadly waste for generations millions of years from now.
in the pool will not go critical and begin the fission process again. It is critical that the water levels remain consistent to avoid a serious accident and release of radiation.The fuel remains in the pool at least 5-7 years. "Surely there are better, cheaper, Interim Storage safer ways to boil water that do not Once the fuel has cooled in the pools for 5 years, it can be removed leave this toxic legacyfor the world and placed in casks, called "dry cask storage". These casks can be arranged in bunkers and stored relatively safely for the short term. of the future."
Most of the nation's operating reactors are using dry cask storage as a way to manage the high level waste. - Arjun Makhi]ani
the bans to make it cheaper to "clean up" the weapons complex.
" L A Sierra Club of Canada, in coalition with numerous organizations in both US and Canada, has taken a leading role in preventing radioac-Why is any radioactivewaste considered"low-level"? tive metal steam generators from the Bruce nuclear reactors being shipped through the Great Lakes and across theAtlantic to Sweden, "Low-Level" Radioactive Waste to be melted and released into the international metal supply.The Despite the low misleading description, "low-level" radioactive consequences of this made the news when they found radioactive waste is not low risk. It includes the same radioactive elements and tissue containers at a national home goods retailer.What is next?
isotopes (radionuclides) as high level waste - including the irradi- Children's toys?
ated fuel rods in the core of nuclear power and weapons reactors.
In fact, the same Plutonium atom that is "high level" waste if it is Sierra Club Action in a fuel rod becomes so-called "low level" waste when it leaks In the 1980s, the Sierra Club adopted its "low-level" radioactive out through cracks or tiny holes in the cladding of the rods into waste policy, calling for a redefinition of the term to exclude any-the cooling water.The whole nuclear reactor itself, except the fuel thing radioactively hazardous longer than the 100 year "institutional rods, becomes so-called "low-level" radioactive waste. control period" required by the Nuclear Regulatory Commission (I OCFR 61.59) for disposal sites.
Deadly Waste "Low Level" Dumps Filters and resins used to remove radioactive materials from nuclear power reactor cooling water can become so heavily loaded After hundreds of millions of dollars were spent searching for new that they can kill a person if exposed for just 20 minutes without waste disposal sites in 18 states over 3 decades, no new dump has shielding. Ifthe Plutonium atom makes it past the filters and resins, it opened - until April 2012 in Andrews County, West Texas. Sierra becomes a legal,"routine release" to the river, lake or ocean.The Club continues to challenge this troubled dumpsite.
legal (not safe) levels are based on nuclear industry needs, not on protecting humans or other species.
Radioactive Waste in the Food Chain Some radioactivity comes from splitting of the uranium atoms when they release their binding energy to turn the turbines and make electricity. These get into the food chain and the body and irradiate from within (example: Cesium- 137 concentrates in muscle, Strontium-90 concentrates in bone and teeth displacing calcium, Iodine- 129 concentrates in the thyroid). Very heavy radioactive elements like Plutonium, Neptunium and Americium are incred-ibly long-lasting and especially dangerous if inhaled or ingested because they emit alpha particles which are 10 to 20 times or more dangerous than gamma rays when lodged in the body. Once they escape from the fuel rods, they become "low-level." Other Kick and roll burial technique: This may not be done any-
"low-level" waste comes from activation by neutrons hitting more - barrelsare now stackedin the ditches andno more nonradioactive materials and making them radioactive. cardboardboxes-- but the long-lastingwaste from decades ago buried this way is still radioactively hazardous and "There is no safe level of exposure and could be leaking today.
there is no dose of radiationso low The Sierra Club Nuclear Free Campaign is an offshoot of the Sierra Club Activist Network. Volunteers from the United States that the risk of a malignancy is zero." and Canada are working together to make a difference on these issues.We are interacting on the Activist Network through the No
- Dr.Karl Z. Morgan, dubbed Nukes Activist Team, conference calls on specific issues, national the father of Health Physics action alerts, our act-net list serve, regional and national meetings.
Radioactive Consumer Products Iffac you thet inyu akadrjs att DOE makes all our nuclear bombs. In 2000, it banned metal from make Not Am er.icua Nuclea ree,Frr sign
,jup forXth radiation areas going to commercial recycling (to make everyday capag toa at: s.ogn --nuke household and personal items), but in 2012-2013 DOE is reversing 85~~~~~~ SeodSreScn lo
I ULAR WAST ISFREE YCA MONAI Waste generatedby the nuclearindustry Yucca mountain was a complete will be deadlyfior millions oJ'years. failure as a permanent solution.
Over the past 50 years, the commercial nuclear industry has generated over 70,000 tons of deadly, high level nuclear waste in the form of irradiated or "spent" nuclear fuel. There is no way to dispose of this fuel. The industry and the government have been desperately seeking a solution. But there is none. Nuclear waste is forever!
Every reactor creates high level nuclearwaste as it burns its ura-nium fuel. Irradiated orspent nuclearfuel is deadly. A singlefuel rod would deliver a lethal dose in seconds. This fuel must be handled remotely and stored safely to avoid deadly releases of cancer- and birth defect-causing radiation. Transportation of irradiated fuel on our highways and through our cities poses a serious threat to our communities. We must halt this madness!
When the irradiated fuel is removed from the reactor, it is so The Federal government spent billions of taxpayer dollars on hot and radioactive, it must be stored in a spent fuel pool for a location that was never suitable to isolate this deadly waste 5-7 years to cool down. The water in these pools must con- from the biosphere for the next million years. The site never stantly circulate to keep the fuel cool. Any loss of coolant, should have been selected; it has only made it more apparent accident or power outage that would stop the flow of water how difficult it will be to find a permanent disposal location, would cause the irradiated fuel to melt and burn, releasing if any exists at all. Yucca was forced on the people of Nevada, enormous amounts of deadly radiation into the environment. without good science or the consent of the people, or the Native tribes on whose land it exists. Nuclear power is an envi-ronmental justice issue in that minority communities are more adversely impacted and have no say in the process.
OTHR-AD SOLTI S Reprocessing is not "recycling"
- it just creates more waste anid separatesout Once the fuel is removed from the fuel pools, it is stored at the reactorin "dry caskstorage. This is a temporarysolution ONLY. weapons-usable phltonium.
A few countries have chosen to reprocess their irradiated fuel, but this has only complicated the situation. Reprocessing creates huge volumes of liquid high level waste, while sepa-rating out weapons-usable materials like plutonium. Security The Sierra Club's solution to nuclear waste is first, to stop becomes a huge risk. Reprocessing is expensive, dirty, and making waste, period. Nuclear power should be phased does not negate the need for a permanent repository. The out as soon as possible, and no new plants built. In the short French dump large amounts of liquid radioactive waste in the term, we recommend a more robust form of dry cask storage ocean. They have not solved their waste problem, and have called Hardened On Site Storage (HOSS), keeping the waste large stockpiles of weapons-usable materials as a result. at the reactors, until a safe, scientific and environmentally sound solution is offered. There should be no transportation of deadly waste across our country on trucks and rails for some short term fix. Only when all parties and impacted com-munities agree upon a responsible solution should the waste be transported, and then using the safest methods possible.
Join the Sierra Club Nuclear Free Campaign to replace nuclear power with energy efficiency and clean, renewable power.
You can join our campaign at: sc.org/nonukes Images from NRCgov, Steve Miller, and D.O.E.
_: 1?ia.L- , .r 1-The HanfordTank Farmshouse 53 million gallonsof high-level radioactiveand chemicalwaste thatis the by-product of "repro-cessing" spentnuclearfuel. One million gallons of this waste is offi-cially acknowledgedto have leaked from the tanks,contaminating the groundwaterandthreateningthe Columbia River.Learn more:
hanfordchallenge.org/the-big-issues/tank-waste/