ML25317A579
| ML25317A579 | |
| Person / Time | |
|---|---|
| Site: | 07007033 |
| Issue date: | 10/05/2025 |
| From: | Marida P - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-1007, 90FR42988 00007 | |
| Download: ML25317A579 (1) | |
Text
PUBLIC SUBMISSION As of: 11/13/25, 9:46 AM Received: October 05, 2025 Status: Posted Posted: October 29, 2025 Tracking No. mgd-tpqo-wub1 Comments Due: October 06, 2025 Submission Type: Web Docket: NRC-2025-1007 Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility, McCracken County, Kentucky; Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Comment On: NRC-2025-1007-0001 Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility; Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement Document: NRC-2025-1007-0008 Comment from Patricia Marida on Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility, McCracken County, Kentucky; Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Submitter Information Name: Patricia Marida Address:
Columbus, OH, Email:patmarida@outlook.com General Comment See the attached file for comments of Patricia Marida Attachments Marida PLEF Scoping Comments 10-5-25 11/13/25, 9:47 AM NRC-2025-1007-0008.html file:///C:/Users/BHB1/Downloads/NRC-2025-1007-0008.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Amy Minor, Mary Neely Comment (7)
Publication Date:
9/5/2025 Citation: 90 FR 42988
October 5, 2025 TO: Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 VIA email to GLE-PLEF-EIS@nrc.gov and submitted through https://www.regulations.gov/.
ATTN: Program Management, Announcements and Editing Staff RE: Proposed Paducah Laser Enrichment Facility (PLEF), Docket ID NRC-2025-1007 (NEPA scoping comments)
Dear NRC administrators and personnel,
Please accept these scoping comments pursuant to the National Environmental Policy Act (NEPA) concerning the proposed Paducah Laser Enrichment Facility (PLEF) sponsored by Global Laser Enrichment LLC (GLE), which is applying for a license from the U.S. Nuclear Regulatory Commission (NRC) to construct and operate PLEF to enrich uranium on land adjacent to the existing U.S. Department of Energy (DOE) Paducah Gaseous Diffusion Plant (PGDP) Site near Paducah, Kentucky.
The threat of nuclear weapons proliferation is the most important issue for NRC scoping. With smaller buildings and lack of heat signature, laser enrichment has a low profile that cannot be detected by air or satellite. Nations or other entities would be able to enrich uranium for nuclear weapons without being detected. This frightening scenario is compounded by the me-too effect of other countries wanting to match perceived power and/or feeling a security need develop this technology. An adequate scoping for a scenario that threatens global annihilation will be challenging. Particularly when the U.S. continues to fund and promote nuclear weapons, nuclear energy, and laser uranium enrichment. Because Wall Street wont invest.
Scoping for any threatened or endangered species is essential. The Indiana Bat, an endangered species, has been found in the area (ER pg. 3-63). Building the PLEF would disturb if not destroy their habitat. GLE maintains that no habitat mitigation is needed - the ER concludes the PLEF "May affect but not adversely affect" the Indiana bat (pg. 4-47).
Bats are extremely sensitive to radioactivity, as are birds. Turning a wildlife area into an industrial zone can have a profound effect on wildlife. Destroying habitat in a time of year when the endangered species are not there does not reduce the threat. Habitat is necessary for species survival. GLE is planning to destroy this habitat and at the same time refusing the responsibility of mitigation.
Scoping is needed for wetland areas and the creation of forest edges. "The quality of the contiguous forested wetland habitat abutting the PLEF to the northeast, east, and west would be indirectly impacted by the creation of forest edges. Changes in sources and direction of hydrology could create drier or wetter wetland conditions which could impact wetland species composition and habitat type." (ER pg. 4-36). The ER says the impact would be small, with no substantiation. Small is a mantra for industrial polluters. A search for "impact" within the ER turned up 1,760 times, with "wetland" showing up 245 times. There are likely many other reasons this land shouldn't be used for the PLEF, many of which show up in their ER.
Contiguous forests are critical in keeping out invasive and parasitic species and in mitigating noise, air, and water pollution. They also help to minimize human intrusion. Contiguous forests are an endangered species of a different kind, compounding the threat of loss of habitat. The effect of this loss is important to scope.
Changes made by creating an industrial landscape can affect the flow of water, as well as send chemical pollutants into contiguous streams and wetland areas. In the case of uranium enrichment, pollutants will include radioactivity, being not only isotopes of uranium but also transuranics, technetium, and other
radionuclides that have contaminated the stocks of depleted uranium hexafluoride (DUF6) slated to be re-enriched. Uranium from reprocessed radioactive waste would no doubt be brought into this facility to also undergo enrichment. This menu of radioactive contamination is very similar throughout the 3 types of enrichment, whether gaseous diffusion, centrifuge, or laser. This leads to the next point.
Scoping must also be done for the effects of radioactivity that will be spread onto and offsite of the PLEF. The area "To the south and east of the PLEF Project Area properties are zoned Rural Residential..." (ER pg. i). "The existing electrical lines that traverse the PLEF Project Area will need to be relocated to allow for construction of the PLEF" (ER pg. ii). Pollutants, most importantly radioactivity and PFAS, have been shown to travel far from the sites of their origin, particularly being airborne but also by water and being brought down by rain.
Dr. Michael Ketterer, professor emeritus of chemistry and biochemistry at Northern Arizona University (NAU), has found radioactivity in various places offsite of the Portsmouth Nuclear Site (PORTS) at Piketon, Ohio. Dr. Ketterer has access the newest and most accurate spectrophotometric equipment at NAU, where he has analyzed these samples. See:
7-4-24: Plant uptake of neptunium-237 in the riparian zone at the Little Beaver Creek - Big Beaver Creek confluence area near the former Portsmouth Gaseous Diffusion Plant https://drive.google.com/file/d/1yOBOKwkbmNftC1A4G1XwJSr953rPxMdz/view 4-28-21: Ketterer Letter to Pike County Health Commissioner Matt Brewster: Neptunium-237 in Groundwater at the X701 Contamination Plume, Portsmouth Gaseous Diffusion Facility.
Ketterers analysis identifies PORTS as the source of offsite radioactivity.
https://docs.google.com/document/d/13Zfe-3TQKIA3H-DPXEIO-ewA4YJZXpat3p8ShHxzds0/edit?tab=t.0 4-27-19: Investigation of anthropogenic uranium, neptunium, and plutonium in environmental samples near Piketon, Ohio. Spectrophotometric analysis identifies the Portsmouth Nuclear Site as the source of offsite radioactivity.
https://drive.google.com/file/d/1aB1tGb_miJVz-UH2uCjKxgES8Dw 2sXIV/view?usp=share_link See 20 links to Dr. Ketterers work in this compilation by the Ohio Nuclear Free Network. These include newspaper articles and stories about the Zahns Corner Middle School being closed due to the discovery of radioactivity at a Dept. of Energy air monitor outside the school, which is 4 miles from PORTS. Radioactivity was also found inside the school.
https://docs.google.com/document/d/1maeQJDtJQj wqhLHqnCVZDOwPTzIxiXxo/edit?usp=sharing&ouid=109363672510061702034&rtpof=true&sd=
true Epidemiologist Joseph Mangano, executive director of the Radiation and Pubic Health Project, has compiled three reports on cancers and premature death rates in Pike County, Ohio, and in Ohio counties close to PORTS, comparing them to Ohio Counties farther away from PORTS. All statistics came from the Ohio Department of Health and the U.S. Centers for Disease Control. See:
11-4-24: Latest Data Show Surge in Pike County Premature Death Rates. Pike County at that time had double the premature death rate (ages 0-74) of the nation.
https://radiation.org/wp-content/uploads/2024/11/Portsmouth-Pike-Co.-mortality-2021-23pdf.pdf 6-10-23: Mortality /Morbidity Study, 7 Counties Downwind of the Portsmouth Nuclear Site.
Mangano compared health statistics from 7 counties around PORTS (study counties) to those from 7 counties in eastern Ohio (control counties). In the late 1990s, cancer incidence in both areas was 0.4% below the U.S. rate. By 2015-2019, the study counties rate exceeded the U.S. by 17.5%, versus 8.8% in control counties.
https://radiation.org/wp-content/uploads/2023/06/Portsmouth-2nd-report-final.pdf 8-15-22 Health Risk to Local Residents from the Portsmouth Gaseous Diffusion Plant. In the 1950s and 1960s, county cancer mortality was 12% below the U.S. The gap closed, and by 1993, the Pike rate exceeded the U.S. Among persons 0-74, all-cause mortality in the county soared to 85.0%
above the U.S. in 2017-2020, nearly twice that of the nation.
https://radiation.org/rphp-report-finds-soaring-death-rate-near-ohio-uranium-plant/
Exposure to radioactivity for workers at nuclear sites is also of note and should be scoped. See this 5 23 article from the International Journal of Epidemiology: Ionizing radiation and solid cancer mortality among US nuclear facility workers. For the association between ionizing radiation exposure and all solid cancer mortality we observed an elevated rate (ERR Sv-1=0.19; 95% CI: -0.10, 0.52), which was higher among a contemporary sub-cohort of workers first hired in 1960 or later (ERR Sv-1= 2.23; 95% CI: 1.13, 3.49). Similarly, we observed an elevated rate for lung cancer mortality (ERR Sv-1= 0.65; 95% CI: 0.09, 1.30) that was higher among contemporary hires (ERR Sv-1= 2.90; 95% CI: 1.00, 5.26).
https://academic.oup.com/ije/article/52/4/1015/7186891 It is worth repeating here that the radionuclides to which workers and the public are exposed is and will continue to be very similar throughout the 3 types of enrichment, whether gaseous diffusion, centrifuge, or laser. It is yet to be seen just how quickly this radioactive contamination will spread from a large laser facility. It would be important for the government to test for radioactivity onsite and offsite of the GLE laser test loop facility in Wilmington, North Carolina.
In conclusion:
These comments are being written to put this information on the record for future generations of cockroaches to ponder.
The result of this giant technological step in nuclear warmaking and its front, nuclear energy, threatens civilization through:
wasting resources and funds that could be used for the good of humanity; robbing the public of our hard-earned tax dollars and putting the nation further in debt; impacting the land, air, and water - from the extraction of minerals to the building of facilities to the many facets of the operation of an unneeded industry; normalizing a war culture through fear of the other, distrust, hierarchy, and hate; compromising the moral sense of the nation, as well as affecting the conscience of those involved who understand the human health toll and other damage being exacted through their work; creating radioactivity that will last essentially forever, that makes everything it touches become radioactive, and that is beyond the capability of humans to contain; adding to a global heating catastrophe with the use of energy throughout construction and operation of these unneeded facilities and the manufacture of materials used in the process; and increasing the possibility of, and greasing the skids for, the finality of nuclear war, which must never happen, but which is increasingly talked about by world leaders as a possibility. Nuclear war appears to be one blustering leader or one internet-gaming trigger finger away. Perhaps the rest of us would like to have a say.
The NRC is encouraged to scope the points in the paragraph above.
Sincerely, Patricia Marida