ML14112A075

Comment (8) of Victoria Clemons on NUREG-1437, Supplement 52, Generic Environmental Impact Statement Regarding Davis Besse Nuclear Power Station

ML14112A075
Person / Time
Site:	Davis Besse
Issue date:	04/14/2014
From:	Clemons V - No Known Affiliation
To:	Bladey C K Rules, Announcements, and Directives Branch
References
79FR13079 00008, NRC-2010-0298
Download: ML14112A075 (6)

Text

Page 1 olAs of: April 16, 2014Received:

April 14, 2014PUBLIC SUBMISSION IStatus:

Pending-Post PUBLC S BMISIONTracking No. ljy-8bj2-125 Comments Due: April 21,Submission Type: WebDocket: NRC-2010-0298 Receipt and Availability of Application for License RenewalComment On: NRC-2010-0298-0033 License Renewal Application for Davis-Besse Nuclear Power Station, Unit 1; Draft Supplemental GenericEnvironmental Impact Statement Document:

NRC-2010-0298-DRAFT-0032 Comment on FR Doc # 2014-05021 2014Submitter Information Name: Victoria ClemonsGeneral CommentSee attached file(s)Attachments Human Life Comment with sign-on_71iý*UFC--r-nC.)SUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add=t-"* -d-I Cindy BladeyChief, Rules, Announcements, and Directives BranchOffice of Administration Mail Stop: 3WFN-06-44M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: NUREG-1437, Supplement 52, Generic Environmental Impact Statement Regarding Davis Besse Nuclear Power Station, Docket ID NRC-2010-0298 Comment on the license renewal of Davis Besse and the DGEIS.My comments relate to both the Severe Accident Mitigation Alternatives or SAMAsused in the DGEIS and to postponing all Environmental Impact Statements for nuclearpower plants until the Commission has revised their guidance on NUREG-1530.

The results of the evaluation of 167 "severe accident mitigation alternatives" or SAMAcandidates for Davis Besse indicated no enhancements to be potentially cost-beneficial for implementation at Davis-Besse and none will be implemented at DavisBesse. Of the 167 safety measures considered, 107 were eliminated based only on aquantitative cost-benefit analysis.

That is, 107 recognized possible safetyenhancements for continuing operations another 20 years will not be done, orrequired, because ... "they are not cost effective".

These safety features range from hardened containment vent filters to fire and floodsafety measures.

All 107 safety enhancement actions were considered too"expensive" by both FENOC and the NRC. My comments today will try to focus on thequantitative data used to make these decisions, but the knowledge or qualitative datathat is known leads to a discussion of ethical decisions that need to be made byregulators.

Should safety features be required even if they are expensive?

Seat beltswere made mandatory to save lives and unleaded fuel was made mandatory for cleanair even though they would add to the final cost to consumers.

Which, if not all ofDavis Besse's SAMA considerations should be implemented regardless of cost?1 In order for cost-benefit calculations to be performed all costs and benefits must beexpressed in a common measure,

dollars, including things not bought and sold onmarkets, and to which dollar prices are therefore not attached.

The most dramaticexample of such things is human life itself. Many of the other benefits achieved orpreserved by environmental policy -such as peace and quiet, fresh-smelling air,clean water, spectacular vistas and the environment we share with other biological species -are not traded on markets either. The Nuclear Regulatory Commission (NRC) uses a dollar figure for the value of human life that is 1/2 to 1/3 the value usedby other federal agencies

-$3 million dollars is used by the NRC to calculate thesecost-benefit analyses.

The Food and Drug Administration declared that one human life in cost-benefit analyses was worth $7.9 million in 2010, up from $5 million in 2008, in proposing warning labels on cigarette packages featuring images of cancer victims.The Transportation Department uses a Value Statistical Life (VSL) figure of $9.1million in current dollars and with wage forecasts from the Congressional BudgetOffice, there will be an expected 1.07 percent annual growth rate in median realwages over the next 30 years (2013-2043).

These estimates imply that VSL in futureyears should be estimated to grow by 1.07 percent per year. [1]The Environmental Protection Agency set the value of one human life at $9.1 millionin 2010 when proposing tighter restrictions on air pollution.

The agency used numbersas low as $6.8 million during the George W. Bush administration.

These VSL numbersmay keep climbing.

In 2010, the E.P.A. said it might set the value of life number forpreventing cancer deaths 50 percent higher than other deaths, because cancer killsslowly.In sharp contrast the Nuclear Regulatory Commission (NRC) uses a dollar figure forthe value of human life that is roughly one third of the value used by other federalagencies

-$3 million dollars.

The $3 million dollar price tag can be found in the NRCregulation, NUREG-1530 section 6.6, written 2 decades ago in 1995. The regulation then proffers a discussion (since not every one dies and that they may only getcancer) a conversion factor is set at $2100 per person-rem exposure to radionuclides which is then further discounted to $2000 per person-rem in section 8.So we see -the EPA finds cancer and cancer causing deaths to be more debilitating over time and they would like to raise the $9.1 million another 50%, while the NRCdiscounts the value of human life and discounts cancers.

The NRC has not adjustedthe VSL in 19 years for inflation or for new empirical studies.

The nuclear industry isnot being held to the same standards of safety for human life or the environment.

2 A White Paper prepared for the U.S. Environmental Protection Agency (EPA) in 2010looked at four hedonic wage studies and an additional five have been published sincethe EPA White Paper was issued. See Table 1. [2] There is broad agreement amongresearchers that these newer hedonic wage studies provide an improved basis forpolicy-making.[3]

Table 1: VSL Studies Using CFOI Database (VSLs in millions of dollars)Study Year of VSL in Study- VSL in CommentsStudy Year-$ 2012$I1. Viscusi (2004) 1997 $4.7M $7.17M Industry/occupation riskmeasure2. Kniesner and Viscusi 1997 $4.74M $7.23M Industry/occupation risk(2005) measure3. Evans and Smith 2000 $9.6M $12.84M Industry-only risk(2008) measure4. Viscusi and Hersch 2000 $7.37M $9.86M Industry-only risk(2008) measure5- Evans and Schaur 1998 $6.7M $9.85M Industry-only risk(2010) measure6. Hersch and Viscusi 2003 $6.8M $8.43M Industry/occupation risk(2010) measure7. Kniesner et al. (2010) 2001 $7.55M $9.76M Industry/occupation riskmeasure8. Scotton and Taylor 1997 $5.27M $8.o4M Industry/occupation risk(2011) measure; VSL is mean ofestimates from threepreferred specifications

9. Kniesner et al. (2012) 2001 $4M -$1oM $5.17M -Industry/occupation risk$12.93M measure; mean VSLestimate is $9.o5MThe use of cost-benefit analysis is a wonderful and informative tool to be used whenseveral different courses of action can be compared, providing knowledge to choosebetween alternatives to obtain a desired end. When cost-benefit analysis is used todecide whether issues of safety or protecting the environment are "worth it" leads toboth moral and ethical questions.

Moral and ethical alternatives are better answeredwith qualitative knowledge, your own intelligence and judgment.

"You can use all the quantitative data you can get, but you still have to distrust itand use your own intelligence and judgment"

... Alvin Toffler3 The nuclear industry is an unsafe industry, which needs to pay the cost to keep thehuman race and the environment safe. You may argue then that the cost of theenergy it produces will go up and that is a valid statement

-but as the true cost ofnuclear energy comes apparent the cost of "safe" energy and alternative energybecomes more competitive and more desirable.

The decisions that must be made by government involve painful choices.

Thesedecisions affect not only the distribution of goods and benefits, but also of physicaland mental suffering.

It's easy to understand why people would want to avoidmaking such choices and would rather rely on "the numbers" than with knowledge and responsibility for the consequences of their choices.

While this may beunderstandable it is not an acceptable moral position.

To govern is to choose, andgovernment officials-whether elected or appointed-betray their obligations to thewelfare of the people who hired them if they adopt a policy of ignorance and non-responsibility for consequences.

It would be in the best interest of the environment and for human life itself that theDavis Besse DGEIS as well as all other nuclear power plant EISs be put onhold for revisions to the NRC VSL figures and SAMA cost analysisprocedures which are expected to be revised by the end of 2014.[4]Respectfully, Victoria

Clemons, R.Ph.Port Clinton, OhioCC: Mark A. Satorius, Executive Director for Operations

[1] Memorandum

-Guidance on Treatment of the Economic Value of a Statistical Life in U.S. Department of Transportation Analyses.

http://www.dot.gov/sites/dot.dev/files/docs/VSL%20Guidance.doc

[2] U.S. Environmental Protection Agency (2010), Valuing Mortality' Risk Reductions for Environmental Policy: A WhitePaper (Review Draft). Prepared by the National Center for Environmental Economics for consultation with the ScienceAdvisory Board -Environmental Economics Advisory Committee.

[3] A current survey of theoretical and empirical research on VSL may be found in: Cropper, M., J.K. Hammitt, and L.A.Robinson (2011). "Valuing Mortality Risk Reductions:

Progress and Challenges."

Annual Review of Resource Economics.

3:313-336.

http://www.annualreviews.org/doi/abs/

10.1146/annurev.resource.012809.103949

[4] Update to Dollar per Person-Rem Conversion Factor Guidance:

Per SRM-SECY-12-0110, the staff continues its work toupdate NUREG-1530, "Reassessment of NRC's Dollar per Person-Rem Conversion Factor Policy."

NUREG-1530 providesguidance for monetizing the health detriment resulting from radiation exposure.

Through interagency

meetings, the staff isconsidering the knowledge developed by other federal agencies in this area. The staff will engage external stakeholders andseek approval from the Commission prior to finalizing this NUREG, which is expected in late 2014.http://www.nrc.gov/reading-rm/doc-collections/commission/secys/2014/2014-0002scy.pdf 4

The following groups and individuals wish to add their names to this publicsubmission for the Davis Besse Draft Generic Environmental ImpactStatement (DGEIS).Connie Kline (by VC)Ohio Citizens Against a Radioactive Environment

-Ohio CARELake County, OhioJesse Collins (by VC)Citizens' Resistance At Fermi 2Terry Lodge (by VC)316 N. Michigan St., Ste. 520Toledo, OH 43604Kay Cumbow (by VC)15184 Dudley RoadBrown City, MI 48416Janet Jodlowski (by VC)9150 Florence RoadKirtland, Ohio 44094Dan Clemons (by VC)Port Clinton, OhioJoe Holtzman (by VC)California Rick Noderer (by Vc)Port Clinton, OHKathy Reed (by VC)Port Clinton, Ohio5