ML20059J050

Comments on Louisiana Energy Svcs Application to Build U Enrichment Plant in Homer,La.Opposes Licensing

ML20059J050
Person / Time
Site:	Claiborne
Issue date:	01/15/1994
From:	Battle J, Battle O, Kennedy J AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9401310326
Download: ML20059J050 (12)

Text

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p y10 January 15, 1994 Chief, Enrichment Branch Division of Fuel Cycle Safety and Safeguards l

Office of Nuclear Material Safety and Safeguards Mail Stop 4-E-4 U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Proposed Site - CLAIBORNE ENRICHMENT CENTER L.P.

Homer, Louisiana

Dear Sirs:

Be advised that we own land located adjacent to the proposed site and as African-Americans and concerned citizens, we oppose this site selection for the following reasons:

1. The Center Springs and Forest Grove communities are all black areas and this plant has been pushed into our communities by big majority corporations.

It has been a historical trend l

to place these plants in minority communities across this nation without involving the minorities in the approval l

process of the community.

l The following excerpts from EPA - Environmental Equity.

Reducing Risk for all Communties, Volume 1 and 2, June 1992,

'j supports our findings of the overall location of these plants or similar facilities in minority communities.

Volume 1, Page 14.

3. RESIDENCE NEAR WASTE SITES There is evidence (GAO, 1983: UCC, 1987) to indicate that racial and ethnic minorities are more likely to live near a commercial waste treatment facility or an uncontrolled hazardous waste site than the general population.

Volume 1, Page 15.

4.

DIETARY EXPOSURE THROUGH FISH CONSUMPTION Consumption of fish can be an important route of exposure for certain pollutants.

PCBs, dioxins, and furans can bioaccumulate in fish tissues to high concerntrations, even when water concentrations are below detection limits.

Variations of fish consumption can affect exposure to those polluntants and hence, health risks.

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l United States Nuclear Regulatory Commission January 15, 1994 Page 2 Volume 1, Page 20.

1. OFFICE OF COLID WASTE AND EMERGENCY

RESPONSE

Siting and Permitting of Waste Facilities.

OSWER managers and staff recognize that the siting and permitting of hazardous and solid waste management facilities involve socioeconomic forces that are not related to technical concerns such as geohydrology and depth to groundwater.

The siting issue is very complex.

A result of the "not in l

my backyard (NIMBY)" syndrome is that such facilities will tend to be located in communities with the least ability to a

mount a protest.

a Volume 1, Page 21.

2. OFFICE OF AIR AND RADIATION The literature available illustrates that exposure, siting, sensitivity, and the distribution of air pollutants raise concerns about equity with respect to air pollution.

However, the literature examined suggest that racial minority and low-income populations have experienced poorer air quality because they tend to live in urban areas and 1

have in some cases lived in closer proximity to air polluting facilities.

Based on the limited data available, several population groups identified as being sensitive to the health effects of air pollution seem to be disproportionately composed of 4

low-income or racial minority individuals compared to the general population.

These groups include asthmatics, people with certain caridovascular diseases or anemia, and women at risk of delivering low-birth-weight fetuses.

Volume 2, Page 7 - 10.

2.2 EXPOSURES 2.2.1. Residence Near Waste Sites Evidence indicates that ethnic minorities are more likely to live near a commercial or uncontrolled hazardous waste site.

In 1982-83, the U.S. General Accounting Of fice conducted a study of offsite hazardous waste landfills in the eight southeastern states that comprise EPS's Region IV.

The study found that in three of the four communites where of fsite hazardous waste landills were located, blacks were the majority of the population.

2.2.2.

Lead Exposures Lead exposures can and often do occur through multiple pathways and routes (e.g., air, paint chips, water, soil, food and house dust).

's United States Nuclear Regulatory Commission January 15, 1994 Page 3 2.2.4.

Air Pollution Exposures A range of studies argue that air pollution disproportionately impact the poor and racial and ethnic minorities.

One study (Zupan, 1973) found that three of the major indicators of unhealthful outdoor air quality-(i.e., carbon monoxie, sulfur dioxie, particulate matter) were positively correlated with low-income areas.

In a national study of carbon monoxide in the blood, African Americans were shown to have higher levels than Whites (DOE, 1982).

A study of the distribution of total suspended

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particulates from 1970 to 1984 found that Blacks experienced higher average exposures and higher average risk reduction benefits (from air pollution controls).

i The poor experienced a much lower relative decrease in exposure than the rich.

Volume 2, Page 14.

2.3 ENVIRONMENTAL HEALTH EFFECTS Most of the work has emphasized difference in disease rates between various groups where a-strong likelihood j

exists that environmental exposure plays a causative role.

Lung cancer and Chronic Obstructive Pulmonary Disease are two health outcomes for which environmental exposures may have a cause effect.

Volume 2, Page 16.

3.0 EPA PROGRAMS 3.1.2.

Specific Problem Areas Siting and Permitting of Waste Facilities.

OSWER managers recognize that the siting and permitting of hazardous and solid waste management facilities raise depth to groundwater, etc).

They also believe that one result of the "not in my back yard, results in locating such sites in my commnities with the least ability to mount a protest.

They pointed out that this commercial hazardous waste management from Superfund sites are brought to commercial hazardous waste management facilities as a result of commttnity opposition to incineration of the hazardous waste at the Superfund site.

3.2.1.

Composition of Populations Sensitive to Air Pollution Based on the limited data available, several population groups identified as being sensitive to the health j

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4 United States Nuclear Regulatory Commission January 15, 1994 Page 4 effects of air pollution seem to be disproportionately comprised of low-income or racial minority individuals.

These groups include asthmatics, people with certain cardiovascular diseases or anemia, and women at risk of delivering low-birth weight fetuses.

Schwartz et al. found that, in children between six months and 11 years of age, asthma prevalance was 7.2 percent in Blacks verus 3.0 percent in Whites. Even after adjusting for factors such as young maternal age at birth, low birth weight and income, Blacks were still at higher risk for asthma and frequent wheeze attacks than were White.

2.

The Center Springs and Forest Grove communities lack adequate transportation if evacuation occurs.

Resident homes are scattered whereby making urgent evacuation impossible.

3.

Upon reviewing DRAFT ENVIRONMENTAL IMPACT FOR THE CONSTRUCTION AND OPERATIONS OF CLAIBORNE ENRICHMENT CENTER, Homer, Louisiana, Docket No. 70-3070, November 1993, we note the following findings.

(1)

Phase 2-38, 2.7. The Site Selection Process.

The road access is inadequate.

Conditions are two lanes, curves, hilly, cattle crossing, busing of school children.

Draft indicates plant should be located in an area without severe winds and tornadoes.

NOTE:

Based upon your findings, Sheet 2-44, Figure 2.9, indicate the propose site is within 70 m.p.h. wind speed zone.

Secondly we have witnessed huge trees toppled within 1.5 miles of proposed site on LA 9 and a tree was topple on the homestead of the late Mr. & Mrs. Sellus Williams' house located less than 1/2 mile.of propose site on Parish Raod

1. 39.

(See Sketch "A" for location of homestead).

A torando touched down and caused property damage on US Highway 79, approximately five (5) miles south of Homer approximately 2 years ago.

Also a tornado caused recent damages in the town of Arcadia, Louisiana.

(2)

Sheet 2-49 indicates "WANTS".

(a)

Local support does not include Center Springs and Forest Grove citizens.

(3)

Table 2.14 does not indicate racial population ratio within the communities rejected as the site selection.

United States Nuclear Regulatory Commission January 15, 1994 Page 5 (4)

Sheet 2-55, 2.7.3 Potential Sites Around Homer, La.

The building of this proposed plant inhibits the operation of instutions such as schools, hospitals, and nursing facilities.

Several citizens within the 5 mile radius requires home health care.

(5)

Sheet 7-1, 7 Agencies Consulted.

The following local churches / organizations / groups were excluded.

Center Springs CME Church Forest Grove CME Church NAACP (Local Chapter)

Masonic Fraternal Organizations Eastern Star Fraternal Group Forest Grove Hunting Club In summary, this proposed facility is not an asset to the Center Springs and Forest Grove communities taxation without representation from the Forest Grove and Center Springs

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communities, and long term health problems.

The location of this proposed site impacts this and future generations around the Center Spring and Forest Grove communities, based upon the referenced NP 3

E.P.A.

findings.

African Americans have owned properties within the Center Springs j

and Forest Grove communities over the past 100 plus years.

We, as ancestors, ask that you will not allow this proposed plant to be located in our quiet and proud community and destroy what has been f

God given.

Your appreciation toward this matter will be highly appreciated.

Sincerely, PROPERTIES OWNERS AND CONCERNED CITIZENS cny attachments:

A - Sketch B - Signatures cc:

President of the United States William Clinton Hazel O' Leary, Secretary, Department of Energy Dan Rather, CBA News, 524 W. 57th Street, New York, N.Y.10019

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