ML070660240: Difference between revisions

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{{#Wiki_filter:11 Doris Mendiola -Comments -NUREG-1437, Supplement 29 Page 1 li~Doris Mendiola -Comments-NUREG-1437, Supplement 29 Page 1]From: Brian Thurber <bthurber@cleanwater.org>
{{#Wiki_filter:11Doris Mendiola - Comments - NUREG-1437, Supplement 29                                           Page 1li
To: <pilgrimeis@nrc.gov>
~Doris Mendiola - Comments-NUREG-1437, Supplement 29                                             Page 1 ]
Date: 02/28/2007 4:40:30 PM  
From:             Brian Thurber <bthurber@cleanwater.org>
To:                 <pilgrimeis@nrc.gov>
Date:             02/28/2007 4:40:30 PM


==Subject:==
==Subject:==
Comments -NUREG-1437, Supplement 29 Please find attached comments regarding NUREG-1437, Supplement 29.Best, Brian Thurber Brian Thurber, Energy Coordinator Clean Water Action 262 Washington St., Suite 301 Boston, MA 02108 617-338-8131, x209: phone 617-338-6449:
Comments - NUREG-1437, Supplement 29 Please find attached comments regarding NUREG-1437, Supplement 29.
fax bthurber@cleanwater.org This message (including any attachments) is intended only for the use of the person(s) to whom it is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you receive this communication in error, please notify me immediately by e-mail, telephone or fax and delete the original message from your records. Thank you.C-O C-"'J 66W's-'p23 (49 2~#:~
Best, Brian Thurber Brian Thurber, Energy Coordinator Clean Water Action 262 Washington St., Suite 301 Boston, MA 02108 617-338-8131, x209: phone 617-338-6449: fax bthurber@cleanwater.org This message (including any attachments) is intended only for the use of the person(s) to whom it is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you receive this communication in error, please notify me                   C-O immediately by e-mail, telephone or fax and delete the original message             C-"
[ c:\temp\GWJ00021.TMP Page I!I I c:\temp\GW}00021 .TMP Page 1 Mail Envelope Properties (45E5F6C0.A14:
from your records. Thank you.
14 : 64020)
                                                                                          'J 66W's
                                                                        -'p23           (49 2~#:~
 
[ c:\temp\GWJ00021.TMP                                                                       Page I!I I c:\temp\GW}00021 .TMP                                                                     Page 1 Mail Envelope Properties   (45E5F6C0.A14: 14 : 64020)


==Subject:==
==Subject:==
Comments -NUREG-1437, Supplement 29 Creation Date 02/28/2007 4:47:05 PM From: Brian Thurber <bthurber@cleanwater.org>
Comments - NUREG-1437, Supplement 29 Creation Date         02/28/2007 4:47:05 PM From:                 Brian Thurber <bthurber@cleanwater.org>
Created By: bthurber@cleanwater.org Recipients nrc.gov TWGWPO02.HQGWDO01 PilgrimEIS Post Office TWGWPO02.HQGWDOOI Files Size Date & Time MESSAGE 662 02/28/2007 4: Comments on Pilgrim EIS 2-28-07.pdf 10475 Mime.822 16625 Options Expiration Date: None Priority:
Created By:           bthurber@cleanwater.org Recipients nrc.gov TWGWPO02.HQGWDO01 PilgrimEIS Post Office                                                           Route TWGWPO02.HQGWDOOI                                                   nrc.gov Files                         Size               Date & Time MESSAGE                       662               02/28/2007 4: 47:05 PM Comments on Pilgrim EIS 2-28-07.pdf             10475 Mime.822                     16625 Options Expiration Date:             None Priority:                     Standard ReplyRequested:               No Return Notification:         None Concealed  
Standard ReplyRequested:
No Return Notification:
None Concealed  


==Subject:==
==Subject:==
No Security:
No Security:                     Standard
Standard Route nrc.gov 47:05 PM Clean Water Action
 
Clean Water Action
* Environment Massachusetts
* Environment Massachusetts
* Toxics Action Center February 28, 2007 Chief, Rules Division and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 Re: Comments on NUREG-1437, Supplement 29, draft To Whom It May Concern: Thank you for the opportunity to provide comments on the draft Environmental Impact Statement for Pilgrim Nuclear Power Station (NUREG-1437, Supplement 29).The three signatories strongly support the comments submitted by Pilgrim Watch. We concur that the draft Environmental Impact Statement ignores new and significant information and relies on incorrect assumptions about Nuclear Regulatory Commission (NRC) regulations as they relate to environmental and public health impacts.One particular point of concern is NRC's conclusion that the alternatives to relicensing would have a significantly higher negative impact on the environment than relicensing.
* Toxics Action Center February 28, 2007 Chief, Rules Division and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 Re: Comments on NUREG-1437, Supplement 29, draft To Whom It May Concern:
In Section 8.2.5.11, NRC downplays the potential of using energy efficiency to replace Pilgrim's capacity, citing federal and state forecasts that incorporate conservation measures and still show rising demand over the next several decades. The assumption that energy efficiency cannot reverse the trend of rising demand is incorrect.
Thank you for the opportunity to provide comments on the draft Environmental Impact Statement for Pilgrim Nuclear Power Station (NUREG-1437, Supplement 29).
Efficiency is becoming far more widely accepted as an alternative to supply, and New England is poised to ramp up efficiency investments significantly.
The three signatories strongly support the comments submitted by Pilgrim Watch. We concur that the draft Environmental Impact Statement ignores new and significant information and relies on incorrect assumptions about Nuclear Regulatory Commission (NRC) regulations as they relate to environmental and public health impacts.
Current regulatory barriers to efficiency will likely begin to fall as well -as they did last year in Rhode Island, when the state adopted legislation that will require utilities to look at efficiency as a cheaper alternative to supply. The low costs of efficiency  
One particular point of concern is NRC's conclusion that the alternatives to relicensing would have a significantly higher negative impact on the environment than relicensing. In Section 8.2.5.11, NRC downplays the potential of using energy efficiency to replace Pilgrim's capacity, citing federal and state forecasts that incorporate conservation measures and still show rising demand over the next several decades. The assumption that energy efficiency cannot reverse the trend of rising demand is incorrect. Efficiency is becoming far more widely accepted as an alternative to supply, and New England is poised to ramp up efficiency investments significantly. Current regulatory barriers to efficiency will likely begin to fall as well - as they did last year in Rhode Island, when the state adopted legislation that will require utilities to look at efficiency as a cheaper alternative to supply. The low costs of efficiency - approximately 1/3 the cost of wholesale power' - are no small reason for newfound enthusiasm in the region.
-approximately 1/3 the cost of wholesale power' -are no small reason for newfound enthusiasm in the region.In considering the alternatives to relicensing, NRC should consider a scenario with greatly expanded energy efficiency investments in the region. As proposed in Section 8.2.6, efficiency could be combined with other alternatives to replace Pilgrim's capacity.In general, the Pilgrim plant suffers from the same persistent problems of safety, security and storage as the nuclear industry in general. Even within the narrow scope of this review of the impacts of relicensure, there is ample evidence for denying the extension.
In considering the alternatives to relicensing, NRC should consider a scenario with greatly expanded energy efficiency investments in the region. As proposed in Section 8.2.6, efficiency could be combined with other alternatives to replace Pilgrim's capacity.
Daily radiation releases, the vast amounts of radioactive waste stored on site at the plant, damaged fisheries, and the risk of a terrorist attack are just some of the compelling reasons for letting the plant be decommissioned at the end of its planned lifespan -in 2012.'See "Energy Efficiency:
In general, the Pilgrim plant suffers from the same persistent problems of safety, security and storage as the nuclear industry in general. Even within the narrow scope of this review of the impacts of relicensure, there is ample evidence for denying the extension. Daily radiation releases, the vast amounts of radioactive waste stored on site at the plant, damaged fisheries, and the risk of a terrorist attack are just some of the compelling reasons for letting the plant be decommissioned at the end of its planned lifespan - in 2012.
The Smart Way to Reduce Global Warming Pollution in the Northeast." National Association of State PIRGs. August, 2005. http://www.newenglandclimate.o6rg/files/rggiefficiency2O05.pdf Given the many unanswered or inadequately answered questions about the environmental and public health impacts of extending the life of this plant, we respectfully ask that this commission approach the re-licensing of the Pilgrim nuclear plant with great caution and take into account the many concerns raised by the opponents of re-licensing.
'See "Energy Efficiency: The Smart Way to Reduce Global Warming Pollution in the Northeast." National Association of State PIRGs. August, 2005. http://www.newenglandclimate.o6rg/files/rggiefficiency2O05.pdf
We are confident that, taking the entire picture into account, there will be ample grounds for denying relicensure.
 
Given the many unanswered or inadequately answered questions about the environmental and public health impacts of extending the life of this plant, we respectfully ask that this commission approach the re-licensing of the Pilgrim nuclear plant with great caution and take into account the many concerns raised by the opponents of re-licensing. We are confident that, taking the entire picture into account, there will be ample grounds for denying relicensure.
Sincerely, Brian Thurber, Energy Coordinator Clean Wafer Action Frank Gorke, Director Environment Massachusetts Alyssa Schuren, Executive Director Toxics Action Center}}
Sincerely, Brian Thurber, Energy Coordinator Clean Wafer Action Frank Gorke, Director Environment Massachusetts Alyssa Schuren, Executive Director Toxics Action Center}}

Latest revision as of 09:46, 23 November 2019

Comment (13) of Brian Thurber, Frank Gorke and Alyssa Schuren Opposing the NUREG-1437, Supplement 29 Draft
ML070660240
Person / Time
Site: Pilgrim
Issue date: 02/28/2007
From: Gorke F, Schuren A, Thurber B
Clean Water Action, Environmental Massachusetts, Toxic Action Ctr
To:
NRC/ADM/DAS/RDB
References
71FR75280 00013, NUREG-1437
Download: ML070660240 (4)


Text

11Doris Mendiola - Comments - NUREG-1437, Supplement 29 Page 1li

~Doris Mendiola - Comments-NUREG-1437, Supplement 29 Page 1 ]

From: Brian Thurber <bthurber@cleanwater.org>

To: <pilgrimeis@nrc.gov>

Date: 02/28/2007 4:40:30 PM

Subject:

Comments - NUREG-1437, Supplement 29 Please find attached comments regarding NUREG-1437, Supplement 29.

Best, Brian Thurber Brian Thurber, Energy Coordinator Clean Water Action 262 Washington St., Suite 301 Boston, MA 02108 617-338-8131, x209: phone 617-338-6449: fax bthurber@cleanwater.org This message (including any attachments) is intended only for the use of the person(s) to whom it is addressed, and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you receive this communication in error, please notify me C-O immediately by e-mail, telephone or fax and delete the original message C-"

from your records. Thank you.

'J 66W's

-'p23 (49 2~#:~

[ c:\temp\GWJ00021.TMP Page I!I I c:\temp\GW}00021 .TMP Page 1 Mail Envelope Properties (45E5F6C0.A14: 14 : 64020)

Subject:

Comments - NUREG-1437, Supplement 29 Creation Date 02/28/2007 4:47:05 PM From: Brian Thurber <bthurber@cleanwater.org>

Created By: bthurber@cleanwater.org Recipients nrc.gov TWGWPO02.HQGWDO01 PilgrimEIS Post Office Route TWGWPO02.HQGWDOOI nrc.gov Files Size Date & Time MESSAGE 662 02/28/2007 4: 47:05 PM Comments on Pilgrim EIS 2-28-07.pdf 10475 Mime.822 16625 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

Subject:

No Security: Standard

Clean Water Action

  • Toxics Action Center February 28, 2007 Chief, Rules Division and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 Re: Comments on NUREG-1437, Supplement 29, draft To Whom It May Concern:

Thank you for the opportunity to provide comments on the draft Environmental Impact Statement for Pilgrim Nuclear Power Station (NUREG-1437, Supplement 29).

The three signatories strongly support the comments submitted by Pilgrim Watch. We concur that the draft Environmental Impact Statement ignores new and significant information and relies on incorrect assumptions about Nuclear Regulatory Commission (NRC) regulations as they relate to environmental and public health impacts.

One particular point of concern is NRC's conclusion that the alternatives to relicensing would have a significantly higher negative impact on the environment than relicensing. In Section 8.2.5.11, NRC downplays the potential of using energy efficiency to replace Pilgrim's capacity, citing federal and state forecasts that incorporate conservation measures and still show rising demand over the next several decades. The assumption that energy efficiency cannot reverse the trend of rising demand is incorrect. Efficiency is becoming far more widely accepted as an alternative to supply, and New England is poised to ramp up efficiency investments significantly. Current regulatory barriers to efficiency will likely begin to fall as well - as they did last year in Rhode Island, when the state adopted legislation that will require utilities to look at efficiency as a cheaper alternative to supply. The low costs of efficiency - approximately 1/3 the cost of wholesale power' - are no small reason for newfound enthusiasm in the region.

In considering the alternatives to relicensing, NRC should consider a scenario with greatly expanded energy efficiency investments in the region. As proposed in Section 8.2.6, efficiency could be combined with other alternatives to replace Pilgrim's capacity.

In general, the Pilgrim plant suffers from the same persistent problems of safety, security and storage as the nuclear industry in general. Even within the narrow scope of this review of the impacts of relicensure, there is ample evidence for denying the extension. Daily radiation releases, the vast amounts of radioactive waste stored on site at the plant, damaged fisheries, and the risk of a terrorist attack are just some of the compelling reasons for letting the plant be decommissioned at the end of its planned lifespan - in 2012.

'See "Energy Efficiency: The Smart Way to Reduce Global Warming Pollution in the Northeast." National Association of State PIRGs. August, 2005. http://www.newenglandclimate.o6rg/files/rggiefficiency2O05.pdf

Given the many unanswered or inadequately answered questions about the environmental and public health impacts of extending the life of this plant, we respectfully ask that this commission approach the re-licensing of the Pilgrim nuclear plant with great caution and take into account the many concerns raised by the opponents of re-licensing. We are confident that, taking the entire picture into account, there will be ample grounds for denying relicensure.

Sincerely, Brian Thurber, Energy Coordinator Clean Wafer Action Frank Gorke, Director Environment Massachusetts Alyssa Schuren, Executive Director Toxics Action Center