ML070660240: Difference between revisions

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==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.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 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~#:~  
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~#:~
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Revision as of 05:07, 13 July 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

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>

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 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~#:~

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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 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:

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Standard Route nrc.gov 47:05 PM 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