ML18200A424
| ML18200A424 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 07/13/2018 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NRO/DLSE |
| NRC/NRO/DLSE | |
| References | |
| 83FR18554, +reviewed | |
| Download: ML18200A424 (3) | |
Text
1 ClinchRiverESPEISCEm Resource From:
DENNIS R. NELSON, Naturalist/Energy-Environmental Researcher <dennisnelson987
@yahoo.com>
Sent:
Friday, July 13, 2018 12:28 PM To:
ClinchRiverESPEIS
Subject:
[External_Sender] Public Comment--Clinch River DEIS (Docket 52-047)/NO SMALL MODULAR REACTORS (SMRs) WITHOUT ADEQUATE EVACUATION PLANS!!
Dear NRC staff:
Ever since around the very first "EARTH DAY" (Wednesday, April 22, 1970), which was more than 48 years ago, I have spent literally thousands of hours of time in researching, writing, speaking, and organizing about solving a host of energy-environmental problems. My main-stay, stomping ground issue has been stopping commercial nuclear power, and promoting a non-nuclear future. My comments are specifically about the proposed siting of experimental Small Modular Reactors (SMRs) at the Clinch River site in Oak Ridge, Tennessee. The Tennessee Valley Authority (TVA) is seeking an early site permit (ESP) to construct two or more reactors, with up to 800 megawatts (MWs) of electricity generation capacity.
The U.S. Nuclear Regulatory Commission (USNRC) issued a Draft Environmental Impact Statement for the TVAs permit application on April 26, 2018 (which was, ironically, only four days after "EARTH DAY). The USNRCs analysis is DEEPLY FLAWED AND BIASED toward approving this unnecessary, expensive, and counterproductive project.
THE USNRC MUST REJECT THE TVAs PROPOSAL TO DRAMATICALLY REDUCE THE EMERGENCY PLANNING ZONE (EPZ)
FROM 10 MILES TO JUST TWO MILES (OR LESS). The EPZ requirement defines the scope of evacuation plans and other emergency response measures MUST BE IN PLACE in the case of a major release of radioactive material. There is NO POSSIBLE JUSTIFICATION for reducing emergency planning requirements on the basis of reactor designs that have not even been approved.
The reality is that the TVAs proposed Small Modular Reactor project is a THINLY DISGUISED SUBSIDY to the nuclear power industry. The TVA has NO NEED to build more nuclear reactors, with a surplus of electricity and declining demand from its customers. The proposed project would be ENTIRELY UNECONOMICAL, with estimated costs 3-5 times more than the current cost of wind-electric turbines and solar photovoltaics (PVs). Increased energy efficiency is yet more cost-effective.
The USNRC must consider the recent experience with other proposed new reactor projects, using untested new designs.
South Carolina utilities abandoned building new reactors last year, but only after spending nearly a decade and about $9 billion on them. South Carolina ratepayers are paying 18% of their electricity costs for partially-built reactors that will never generate a watt of electricity. Had the utilities invested in solar, wind, and/or efficiency ten years ago, South Carolina would be saving $$$ and reducing carbon emissions, with no radioactive waste.
These and other biases in the DEIS amount to promoting unsustainable nuclear power over other truly sustainable energy sources. This is CONTRARY to the USNRCs statutory mission to be a neutral regulator with the purpose of ensuring nuclear safety, not promoting nuclear power. The USNRC MUST IMMEDIATELY WITHDRAW THE DEIS, AND PERFORM A NEW, FAIR, ACCURATE, AND OBJECTIVE ANALYSIS OF THE TVAs SITE PERMIT APPLICATION, as well as the real sustainable alternatives of increased energy efficiency and appropriate renewable energy technologies.
2 Mr. DENNIS R. NELSON, Naturalist/Energy-Environmental Researcher 1429 West Lunt Avenue,
- 107 Chicago, IL 60626 1-773-640-3296
Federal Register Notice:
83FR18554 Comment Number:
869 Mail Envelope Properties (24304132.2443.1531499309696.JavaMail.tomcat)
Subject:
[External_Sender] Public Comment--Clinch River DEIS (Docket 52-047)/NO SMALL MODULAR REACTORS (SMRs) WITHOUT ADEQUATE EVACUATION PLANS!!
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7/13/2018 12:28:31 PM From:
DENNIS R. NELSON, Naturalist/Energy-Environmental Researcher Created By:
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