Comments needed to NRC ASLB in opposition to Fermi 3 proposed new reactor in MI!
October 23, 2013 As instructed in a U.S. Nuclear Regulatory Commission press release, those opposed to a proposed new reactor in Monroe County, Michigan can submit oral or written comments to the Atomic Safety and Licensing Board (ASLB) overseeing the application.
But written comments can also be submitted, via these ASLB instructions:
"Those who cannot attend the sessions in Monroe can submit written statements via mail to Administrative Judge Ronald M. Spritzer, Atomic Safety and Licensing Board Panel, Mail Stop T-3F23, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; via fax to 301-415-5599, or via email to onika.williams@nrc.gov and ronald.spritzer@nrc.gov. Copies of written submissions should also be sent via mail to Office of the Secretary, Rulemaking and Adjudications Staff, U.S. Nuclear Regulatory Commission, Washington, D.C. 20444-0001; via fax to 301-415-1101 or via email to hearingdocket@nrc.gov."
Sample comments, in bullet point form, are provided below. You can use them to compose your own comments.
An environmental coalition has fought for over five years for its day in court, in opposition to the risky Fermi 3 proposal. An NRC Atomic Safety and Licensing Board (ASLB) panel will hear two of the coalition's remaining four intervention contentions next week.
SAMPLE COMMENTS
---It costs too much. Fermi 3's price tag is around $20 billion and climbing. That money should be invested in renewables, such as wind power and solar photovoltaics, as well as efficiency, instead. Renewables and efficiency are the future, they are the solution to the climate crisis, not a new atomic reactor.
---It takes too long. Fermi 3's 1,550 Megawatts of electricity are not needed. Fermi 3 would take years, if not decades, to build. As electricity demand in the area increases over time, efficiency and renewables can meet it better than such a large, centralized plant. (In fact, Detroit Edison itself has just indicated it would much more likely build natural gas fired plant, instead of Fermi 3.)
---Weapons proliferation risks. Fermi 3 would be General Electric-Hitachi (GEH) so-called "Economic Simplified Boiling Water Reactor" (ESBWR) design. GEH also runs a new laser-based uranium enrichment facility in North Carolina, which would likely supply enriched uranium fuel to Fermi 3. The spread of laser enrichment technology worldwide, which GEH and NRC have thus encouraged, will worsen risks of nuclear weapons proliferation, due to its easily hidden small size, and its high efficiency for achieving weapons-grade highly enriched uranium (HEU).
---Accident risks. The brand new Fermi 3, co-located with the age-degraded Fermi 2, would place "break-in phase" risks beside "break-down phase" risks. The 1966 "We Almost Lost Detroit" Fermi 1 meltdown, the 1979 Three Mile Island meltdown, and the 1986 Chernobyl nuclear catastrophe all occurred at new reactors, where the "bugs" in design, construction, and operator performance got "work out" the "hard way." Fermi 2 is the identical same design as Fukushima Daiichi Units 1 to 4 -- General Electric Mark I Boiling Water Reactors. But Fermi 2 is nearly as big as Fukushima Daiichi Units 1 and 2 put together. As shown by the Fukushima Daiichi itself, co-locating reactors and radioactive waste storage can lead to cascading, large-scale catastrophes.
---Attack risks. Fermi 3 would be located on the shore of Lake Erie. The Great Lakes provide drinking water for 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Native American First Nations. Such mega-risks should not be located next to such an irreplacable natural resource.
---Radioactive waste. The mountain of commercial high-level radioactive waste is now over a half-century tall, and we don't even know what to do with the first cupful. Fermi 2's Mark I storage pool contains well over 600 tons of HLRW, multiple times more than Fukushima Daiichi Unit 4's, on the brink of collapse, which would unleash a catastrophic radioactive waste fire. Fermi 2 and Fukushima Daiichi Unit 4's storage pools have something in common: the HLRW is stuck, they are not able to unload it. At Fermi 2, because structural welds were never installed in the adjacent structures. At Fukushima, because of the explosion that devastated Unit 4. Fermi 3 would only add to the HLRW woes on the Lake Erie shore. NRC should have no confidence in the safety and soundenss of HLRW storage at Fermi. Electricity would be the fleeting byproduct at Fermi 3. The actual product would be forever deadly radioactive waste. The only solution to the HLRW problem is to not make it in the first place.
---"Routine" radioactivity releases. Fermi 3 would add to the radiological burden in the environment, due to "permitted" or "allowed" releases of radioactivity into the air and water. Uncontrolled and unmonitored leaks should also be expected, as there is an epidemic of such leaks at U.S. reactors today. In addition to radioactivity releases, Fermi 3 would release toxic chemicals, as well as waste heat, into Lake Erie. This will worsen the already bad toxic algal blooms marking Lake Erie's demise.
---Fermi 3's construction would mark the biggest impact on fragile Great Lakes coastal wetlands in the history of applicable environmental protection laws, according to the State of Michigan. This will significantly harm the threatened Eastern Fox Snake, an indigenous constrictor species, which calls those Great Lakes coastal wetlands home. In fact, numerous threatened and endangered species would be harmed by Fermi 3's construction and operation. This would be made worse by tens of miles of associated new transmission lines that would be built as part of the Fermi 3 project, including through fragile forested wetlands.
Farouk D. Baxter, PE, an expert/specialist in nuclear power plant electrical systems based in Sudbury, MA, has also submitted comments, regarding Fermi 3 transmission corridor and other electrical systems problems, that can also be used as a model.