ML14112A075
| ML14112A075 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/14/2014 |
| From: | Clemons V - No Known Affiliation |
| To: | Bladey C K Rules, Announcements, and Directives Branch |
| References | |
| 79FR13079 00008, NRC-2010-0298 | |
| Download: ML14112A075 (6) | |
Text
Page 1 ol As of: April 16, 2014 Received:
April 14, 2014 PUBLIC SUBMISSION IStatus: Pending-Post PUBLC S BMISIONTracking No. ljy-8bj2-125 Comments Due: April 21, Submission Type: Web Docket: NRC-2010-0298 Receipt and Availability of Application for License Renewal Comment On: NRC-2010-0298-0033 License Renewal Application for Davis-Besse Nuclear Power Station, Unit 1; Draft Supplemental Generic Environmental Impact Statement Document:
NRC-2010-0298-DRAFT-0032 Comment on FR Doc # 2014-05021 2014 Submitter Information Name: Victoria Clemons General Comment See attached file(s)Attachments Human Life Comment with sign-on_7 1iý*UF C--r-n C.)SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add=t-"* -d-I Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration Mail Stop: 3WFN-06-44M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: NUREG-1437, Supplement 52, Generic Environmental Impact Statement Regarding Davis Besse Nuclear Power Station, Docket ID NRC-2010-0298 Comment on the license renewal of Davis Besse and the DGEIS.My comments relate to both the Severe Accident Mitigation Alternatives or SAMAs used in the DGEIS and to postponing all Environmental Impact Statements for nuclear power plants until the Commission has revised their guidance on NUREG-1530.
The results of the evaluation of 167 "severe accident mitigation alternatives" or SAMA candidates for Davis Besse indicated no enhancements to be potentially cost-beneficial for implementation at Davis-Besse and none will be implemented at Davis Besse. Of the 167 safety measures considered, 107 were eliminated based only on a quantitative cost-benefit analysis.
That is, 107 recognized possible safety enhancements for continuing operations another 20 years will not be done, or required, because ... "they are not cost effective".
These safety features range from hardened containment vent filters to fire and flood safety measures.
All 107 safety enhancement actions were considered too"expensive" by both FENOC and the NRC. My comments today will try to focus on the quantitative data used to make these decisions, but the knowledge or qualitative data that is known leads to a discussion of ethical decisions that need to be made by regulators.
Should safety features be required even if they are expensive?
Seat belts were made mandatory to save lives and unleaded fuel was made mandatory for clean air even though they would add to the final cost to consumers.
Which, if not all of Davis Besse's SAMA considerations should be implemented regardless of cost?1 In order for cost-benefit calculations to be performed all costs and benefits must be expressed in a common measure, dollars, including things not bought and sold on markets, and to which dollar prices are therefore not attached.
The most dramatic example of such things is human life itself. Many of the other benefits achieved or preserved by environmental policy -such as peace and quiet, fresh-smelling air, clean water, spectacular vistas and the environment we share with other biological species -are not traded on markets either. The Nuclear Regulatory Commission (NRC) uses a dollar figure for the value of human life that is 1/2 to 1/3 the value used by other federal agencies -$3 million dollars is used by the NRC to calculate these cost-benefit analyses.The Food and Drug Administration declared that one human life in cost-benefit analyses was worth $7.9 million in 2010, up from $5 million in 2008, in proposing warning labels on cigarette packages featuring images of cancer victims.The Transportation Department uses a Value Statistical Life (VSL) figure of $9.1 million in current dollars and with wage forecasts from the Congressional Budget Office, there will be an expected 1.07 percent annual growth rate in median real wages over the next 30 years (2013-2043).
These estimates imply that VSL in future years should be estimated to grow by 1.07 percent per year. [1]The Environmental Protection Agency set the value of one human life at $9.1 million in 2010 when proposing tighter restrictions on air pollution.
The agency used numbers as low as $6.8 million during the George W. Bush administration.
These VSL numbers may keep climbing.
In 2010, the E.P.A. said it might set the value of life number for preventing cancer deaths 50 percent higher than other deaths, because cancer kills slowly.In sharp contrast the Nuclear Regulatory Commission (NRC) uses a dollar figure for the value of human life that is roughly one third of the value used by other federal agencies -$3 million dollars. The $3 million dollar price tag can be found in the NRC regulation, NUREG-1530 section 6.6, written 2 decades ago in 1995. The regulation then proffers a discussion (since not every one dies and that they may only get cancer) a conversion factor is set at $2100 per person-rem exposure to radionuclides which is then further discounted to $2000 per person-rem in section 8.So we see -the EPA finds cancer and cancer causing deaths to be more debilitating over time and they would like to raise the $9.1 million another 50%, while the NRC discounts the value of human life and discounts cancers. The NRC has not adjusted the VSL in 19 years for inflation or for new empirical studies. The nuclear industry is not being held to the same standards of safety for human life or the environment.
2 A White Paper prepared for the U.S. Environmental Protection Agency (EPA) in 2010 looked at four hedonic wage studies and an additional five have been published since the EPA White Paper was issued. See Table 1. [2] There is broad agreement among researchers that these newer hedonic wage studies provide an improved basis for policy-making.[3]
Table 1: VSL Studies Using CFOI Database (VSLs in millions of dollars)Study Year of VSL in Study- VSL in Comments Study Year-$ 2012$I 1. Viscusi (2004) 1997 $4.7M $7.17M Industry/occupation risk measure 2. Kniesner and Viscusi 1997 $4.74M $7.23M Industry/occupation risk (2005) measure 3. Evans and Smith 2000 $9.6M $12.84M Industry-only risk (2008) measure 4. Viscusi and Hersch 2000 $7.37M $9.86M Industry-only risk (2008) measure 5- Evans and Schaur 1998 $6.7M $9.85M Industry-only risk (2010) measure 6. Hersch and Viscusi 2003 $6.8M $8.43M Industry/occupation risk (2010) measure 7. Kniesner et al. (2010) 2001 $7.55M $9.76M Industry/occupation risk measure 8. Scotton and Taylor 1997 $5.27M $8.o4M Industry/occupation risk (2011) measure; VSL is mean of estimates from three preferred specifications
- 9. Kniesner et al. (2012) 2001 $4M -$1oM $5.17M -Industry/occupation risk$12.93M measure; mean VSL estimate is $9.o5M The use of cost-benefit analysis is a wonderful and informative tool to be used when several different courses of action can be compared, providing knowledge to choose between alternatives to obtain a desired end. When cost-benefit analysis is used to decide whether issues of safety or protecting the environment are "worth it" leads to both moral and ethical questions.
Moral and ethical alternatives are better answered with qualitative knowledge, your own intelligence and judgment."You can use all the quantitative data you can get, but you still have to distrust it and use your own intelligence and judgment" ... Alvin Toffler 3 The nuclear industry is an unsafe industry, which needs to pay the cost to keep the human race and the environment safe. You may argue then that the cost of the energy it produces will go up and that is a valid statement
-but as the true cost of nuclear energy comes apparent the cost of "safe" energy and alternative energy becomes more competitive and more desirable.
The decisions that must be made by government involve painful choices. These decisions affect not only the distribution of goods and benefits, but also of physical and mental suffering.
It's easy to understand why people would want to avoid making such choices and would rather rely on "the numbers" than with knowledge and responsibility for the consequences of their choices. While this may be understandable it is not an acceptable moral position.
To govern is to choose, and government officials-whether elected or appointed-betray their obligations to the welfare of the people who hired them if they adopt a policy of ignorance and non-responsibility for consequences.
It would be in the best interest of the environment and for human life itself that the Davis Besse DGEIS as well as all other nuclear power plant EISs be put on hold for revisions to the NRC VSL figures and SAMA cost analysis procedures which are expected to be revised by the end of 2014.[4]Respectfully, Victoria Clemons, R.Ph.Port Clinton, Ohio CC: Mark A. Satorius, Executive Director for Operations
[1] Memorandum
-Guidance on Treatment of the Economic Value of a Statistical Life in U.S. Department of Transportation Analyses.
http://www.dot.gov/sites/dot.dev/files/docs/VSL%20Guidance.doc
[2] U.S. Environmental Protection Agency (2010), Valuing Mortality' Risk Reductions for Environmental Policy: A White Paper (Review Draft). Prepared by the National Center for Environmental Economics for consultation with the Science Advisory Board -Environmental Economics Advisory Committee.
[3] A current survey of theoretical and empirical research on VSL may be found in: Cropper, M., J.K. Hammitt, and L.A.Robinson (2011). "Valuing Mortality Risk Reductions:
Progress and Challenges." Annual Review of Resource Economics.
3: 313-336. http://www.annualreviews.org/doi/abs/
10.1146/annurev.resource.012809.103949
[4] Update to Dollar per Person-Rem Conversion Factor Guidance:
Per SRM-SECY-12-0110, the staff continues its work to update NUREG-1530, "Reassessment of NRC's Dollar per Person-Rem Conversion Factor Policy." NUREG-1530 provides guidance for monetizing the health detriment resulting from radiation exposure.
Through interagency meetings, the staff is considering the knowledge developed by other federal agencies in this area. The staff will engage external stakeholders and seek approval from the Commission prior to finalizing this NUREG, which is expected in late 2014.http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2014/2014-0002scy.pdf 4
The following groups and individuals wish to add their names to this public submission for the Davis Besse Draft Generic Environmental Impact Statement (DGEIS).Connie Kline (by VC)Ohio Citizens Against a Radioactive Environment
-Ohio CARE Lake County, Ohio Jesse Collins (by VC)Citizens' Resistance At Fermi 2 Terry Lodge (by VC)316 N. Michigan St., Ste. 520 Toledo, OH 43604 Kay Cumbow (by VC)15184 Dudley Road Brown City, MI 48416 Janet Jodlowski (by VC)9150 Florence Road Kirtland, Ohio 44094 Dan Clemons (by VC)Port Clinton, Ohio Joe Holtzman (by VC)California Rick Noderer (by Vc)Port Clinton, OH Kathy Reed (by VC)Port Clinton, Ohio 5