ML20245E577
| ML20245E577 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/31/2020 |
| From: | Galler J Blue Ridge Environmental Defense League |
| To: | Office of Administration |
| References | |
| 85FR46193 00005, NRC-2015-0039 | |
| Download: ML20245E577 (5) | |
Text
PUBLIC SUBMISSION As of: 9/1/20 5:17 PM Received: August 31, 2020 Status: Pending_Post Tracking No. 1k4-9ip6-uoo1 Comments Due: August 31, 2020 Submission Type: API Docket: NRC-2015-0039 Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility Comment On: NRC-2015-0039-0073 Westinghouse Electric Co., LLC; Columbia Fuel Fabrication Facility; Intent to prepare an environmental impact statement and conduct a scoping process Document: NRC-2015-0039-DRAFT-0075 Comment on FR Doc # 2020-16150 Submitter Information Name: Jennifer Galler Address:
2014 Mobley Way #403 Knoxville, TN, 37922 Email: jgaller1112@gmail.com Organization: Blue Ridge Environmental Defense League General Comment See attached file(s)
Attachments Columbia Fuel Fabrication Facility Comments Page 1 of 1 09/01/2020 https://www.fdms.gov/fdms/getcontent?objectId=090000648482f94f&format=xml&showorig=false SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Jessie Quintero, Sarah Achten, Diana Toro Diaz, Mary Neely Comment (5)
Publication Date:
7/31/2020 CITATION 85 FR 46193
Blue Ridge Environmental Defense League www.BREDL.org PO Box 88 Glendale Springs, North Carolina 28629 BREDL@skybest.com (336) 982-2691 Esse quam videri
- 1. Nuclear Power is not a Solution to Climate Change. Nuclear Free Northwest. http://nuclearfreenw.org/climate.htm The Feasibility of 100% Renewable Electricity Systems: A Response to Critics. Mark Diesendorf and Ben Elliston.
2018.
August 26, 2020 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 WEC_CFFF_EIS.resource@nrc.gov RE: Westinghouse Electric Company, LLC; Columbia Fuel Fabrication Facility
Dear U.S. Nuclear Regulatory Commission,
On behalf of Blue Ridge Environmental Defense League, we submit the following comments. We are writing in opposition to renew Westinghouse Electric Company, LLCs operating license for its Columbia Fuel Fabrication Facility (CFFF). We write in favor of the No-Action Alternative to not renew WEC's license. Under this alternative, the NRC would not issue the license renewal and CFFF would continue to operate under its current license until it expires in 2027. These written remarks are for the 30-day public notice and comment period and will supplement any virtual or oral public hearings.
Overview The U.S. Nuclear Regulatory Commission (NRC) will conduct a scoping process to gather information necessary to prepare an environmental impact statement (EIS) related to the review of Westinghouse Electric Company, LLC's (WEC) request to renew its operating license for its Columbia Fuel Fabrication Facility (CFFF) in Hopkins, South Carolina. The NRC had published a draft environmental assessment (EA) but determined it was not able to conclude the review in a finding of no significant impact.
Therefore, the NRC staff will prepare an EIS to document the potential environmental impacts from the proposed action (i.e., whether to renew WEC's CFFF operating license) and reasonable alternatives.
Comments Nuclear is Not a Solution to Climate Change Climate change is widely known as one of the most pressing issues for the global community. Many in the nuclear industry see climate change as a 'lever' by which to revitalize the fortunes of nuclear power. In various stages of the nuclear process huge amounts of energy are needed, much more than for less complex forms of electricity production. Most of this energy comes in the form of fossil fuels, and therefore nuclear power indirectly emits a relatively high amount of greenhouse gases. Emissions from the nuclear industry are strongly dependent on the percentage of uranium in the ores used to fuel the nuclear process, which is expected to decrease dramatically.
Former NRC chairman Dr. Gregory Jaczko declares nuclear power is not a solution to climate change, and says, "In California last year they added about 11 gigawatts of new solar, which is
Page 2 8/26/2020 about 11 nuclear power plants." Safety, economics, and the ability to execute are on the side of alternative energy sources. 1 Recent studies estimate that nuclear power production causes the emission of just 33% greenhouse gases than modern natural gas power stations. The process of nuclear energy requires a lot of uranium to make the fuel, and it produces a lot of radioactive waste in the process. Building and constructing reactors requires a lot of steel, concrete, and rare earth metals; there is a large carbon emissions footprint associated with just the construction of nuclear power plants. It depletes, takes, and pollutes the Earths resources and is not replenished.
Public Health Concerns Rising In the event of a nuclear disaster with the Columbia Fuel Fabrication Facility, health concerns would be paramount. Exposure to radioactive fallout would lead to an increased risk of genetic disorders, cancer and leukemia.
In the event of a nuclear disaster the health concerns are obvious. Exposure to radioactive fallout would lead to an increased risk of genetic disorders, cancer and leukemia. In some areas of Belarus, for example, national reports indicate that incidents of thyroid cancer in children have increased more than a hundred-fold when compared with the period before the Chernobyl accident (UN-IHA, 2004). However, there are also health risks associated with the day-to-day production of nuclear power. Employees working in power plants are exposed to low-level radioactivity. According to a study by the University of California, based on research at the DOE/Rocketdyne nuclear facility, the risk of employee exposure to low-level radioactive waste is 6 to 8 times higher than was previously presumed (Mechtenberg-Berrigan, 2003). One should realize that there is no such thing as a safe limit. Any amount of radiation can cause serious health damage. 2 There are also health risks associated with the day-to-day production of nuclear power. Employees working in power plants are exposed to low-level radioactivity.
Nuclear is a Struggling Industry Economically Nuclear power plants have been proven to be so expensive that half of them were abandoned during construction. Those that were completed saw huge cost overruns, which were passed on to utility customers in the form of rate increases. Uncertain costs continue to plague nuclear power today.
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- 2. Nuclear Power: No Solution to Climate Change. A Publication of World Information Service on Energy (WISE) and the Nuclear Information & Resource Service (NIRS), incorporating the former WISE News Communique. February 2005.
Page 3 8/26/2020 The Wedge analysis posits 15 possible methods of reducing greenhouse gases, only eight of which are needed to achieve an overall 200 billion ton reduction. Nuclear is one of the wedges.
However, it requires the tripling of global nuclear power, an ill-advised and economically impractical goal. The rate of installation required for the nuclear wedge is equal to the global rate of nuclear expansion from 1975-1990. Just on an economic basis, nuclear would consume an inordinate amount of energy capital for one wedge, thereby bankrupting the other 7 needed to halt global warming. 3 Nuclear energy needs expertise and overview to operate as a functioning nuclear facility. Proposals for more than 30 new nuclear reactors have been submitted to the Nuclear Regulatory Commission, but nearly all of those have now been cancelled or dropped for lack of interest and/or money. Nuclear is expensive and no need to spread it further with new and better technology available now.
Dangers Associated with Nuclear In addition to the risks posed by terrorist attacks, human error and natural disasters can lead to dangerous and costly accidents. The 1986 Chernobyl disaster in Ukraine led to the deaths of 30 employees in the initial explosion and has had a variety of negative health effects on thousands across Russia and Eastern Europe.
Nuclear power entails substantial safety and security risks, waste disposal challenges, and water requirements. These risks also make nuclear power vulnerable to public rejection (as seen in Japan and Germany following the Fukushima disaster of 2011). We advocate the continued prohibition of reprocessing and a ban on the use of plutonium-based fuels. 4 A massive tsunami bypassed the safety mechanisms of several power plants in 2011, causing three nuclear meltdowns at a power plant in Fukushima, Japan, resulting in the release of radioactive materials into the surrounding area. In both disasters, hundreds of thousands were relocated, millions of dollars spent, and the radiation-related deaths are being evaluated to this day. Cancer rates among populations living in proximity to Chernobyl and Fukushima, especially among children, rose significantly in the years after the accidents Effects of Nuclear Energy on Nuclear War and Terrorism Damage More nuclear power means more radioactive materials that may be diverted. By dispersing them with conventional explosives, a terrorist attack can contaminate a city.
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- 3. Stabilization Wedges Introduction. Princeton University. 2007 https://cmi.princeton.edu/resources/stabilization-wedges/
- 4. Nuclear Power & Global Warming. Union of Concerned Scientists. November 8, 2018.
https://www.ucsusa.org/resources/nuclear-power-global-warming
Page 4 8/26/2020 Because the production of nuclear weapons material is occurring only in countries that have developed civilian nuclear energy programs, the risk of a limited nuclear exchange between countries or the detonation of a nuclear device by terrorists has increased due to the dissemination of nuclear energy facilities worldwide. As such, it is a valid exercise to estimate the potential number of immediate deaths and carbon emissions due to the burning of buildings and infrastructure associated with the proliferation of nuclear energy facilities and the resulting proliferation of nuclear weapons. The number of deaths and carbon emissions, though, must be multiplied by a probability range of an exchange or explosion occurring to estimate the overall risk of nuclear energy proliferation. Although concern at the time of an explosion will be the deaths and not carbon emissions, policy makers today must weigh all the potential future risks of mortality and carbon emissions when comparing energy sources. 5 Further, no barrier exists between the civilian and military uses of nuclear materials: any nation possessing nuclear reactors can develop an atomic bomb and use it. It is estimated that a limited nuclear conflict between Pakistan and India, whose vital supplies of drinking water from the Himalayan glaciers are threatened by global warming, would expose 2 billion people to famine. 6 Conclusion Blue Ridge Environmental Defense League is in opposition to the U.S. Nuclear Regulatory Commission renewing Westinghouse Electric Company, LLCs operating license for its Columbia Fuel Fabrication Facility (CFFF) for the following reasons: nuclear is not a solution to climate change, public health concerns rising, nuclear is a struggling industry economically, dangers associated with nuclear, and effects of nuclear energy on nuclear war and terrorism damage.
Submitted Respectfully, Jenn Galler, Campaign Coordinator Blue Ridge Environmental Defense League PO Box 88, Glendale Springs, NC 28269 Esse quam videri
- 5. Mark Z. Jacobson. Review of solutions to global warming, air pollution, and energy security. Department of Civil and Environmental Engineering, Stanford University. June 12, 2008. https://thesolutionsproject.org/
- 6. Even a limited India-Pakistan nuclear war would bring global famine, says study. Science Daily. March 2020.
https://www.sciencedaily.com/releases/2020/03/200316152211.htm