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Impact Scoping Comment Deadline Monday Night, 10.59 Central Daylight Time: “River Bend Station, Unit 1; Intent to Conduct Scoping Process and Prepare Environmental Impact, Due Oct 23, 2017 11:59 PM ET, ID: NRC-2017-0141-0004” Comment can be Anonymous. It is a government web site. It is easy. No need to put email and so spam-free. Comment here: https://www.regulations.gov/docket?D=NRC-2017-0141 While they will almost certainly ignore you, it still goes into the public record so that future generations, if there are any, know that someone cared. There are limitations to the comment length, but the form will tell you if you are over and allow you to cut it down. Alternatively, you can attach a pdf file, or both. Some people put a short text and attach a file.

Entergy’s “River Bend, Appendix E , Applicant’s Environmental Report, Operating License Renewal Stage” found here: https://www.nrc.gov/docs/ML1717/ML17174A531.pdf

An environmental impact study is supposed to include socio-economic impacts.

All evaluations should be done for very short, short, medium, long and very long-term abandonment (100 years plus) of areas within both the 10 mile and 50 mile radiuses, as well as beyond.

There is a need to thoroughly evaluate:

The combined environmental and socio-economic impact of a nuclear disaster impeding operations in the nearby petro-chemical facilies/petro-chemical corridor for both the smaller and larger evacuation-fallout zones (10 and 50 mi radius) must be evaluated. WHY IS ENTERGY USING A 6 MILE ZONE NOT IN THE REGULATIONS ON ITS MAPS?

If the workers at the petrochemical facilities must be evacuated due to nuclear disaster-fallout, the environmental impacts could be even more devastating – a combination of nuclear, fire and radiological and chemically toxic fumes (beyond the fact that most radioactive materials are both radiological and chemical poisons.)

Impacts of a nuclear disaster on the major US transportation routes crossing the area – interstate highways, rail and river shipping and port facilities within the 50 mile radius and beyond must be evaluated.

Impacts on both tourism and the many irreplaceable historic-archaeological-cultural sites, including more than one historically significant site on the River Bend Nuclear site itself, which would be lost forever. A large number of places within the 10 and 50 mile radius zones are listed on the National Register of Historic Places. Additionally, Entergy is hiding information on what appears to be at least one site of incredible significance to an understanding of Native American history and culture, including likely a burial ground and significant cultural artifacts behind blank pages in its environmental report. They report an ancient Native American mound on site, and so the blank page must hide something truly significant about the mound complex.

Impacts of BOTH the accumulation of ongoing nuclear discharges, some of which are very long-lived, and nuclear accident upon the environment and population in the region must be thoroughly evaluated. These should include contamination cost to the environment and population, along with purification costs of groundwater-River-Gulf of Mexico-ocean water, as well as to the land and air. The US NRC-Nuclear Industry and US EPA’s dilute to deceive scam can but fail over time due to the long timescale over which some radioactive materials remain radioactive.

This must include the impacts upon colleges and universities in the 50 mile zone such as Southern in Baton Rouge, LSU, and any others. And most likely impacts upon UL Lafayette just outside the 50 mile zone.

Renewable Alternatives must be properly evaluated by Entergy. They are not in their report. Renewables must be evaluated in combination, not separately, and improved insulation should be included in the evaluation as part of the combination. Renewables are not separate either-or cases, as presented by Entergy.

Increasing CF (Capacity Factors) for PV cells (solar panels) and other renewables must be considered, and compared to the declining CF of River Bend nuclear station, which has been been forced offline for months at a time due to defects-needs for repair. River Bend may operate at zero output for 5 months or more per year as the similar reactor at Grand Gulf has been over the last year. CF should be evaluated for current solar PV and PV CF in 8 years time, when the license is set to expire/up for renewal. This must be the comparision. The same can be said for algae fuels, wind, etc. River Bend’s assumed Capacity Factor must be that of the old reactor that it is, and an old reactor with often defective parts (e.g. defective breakers, open phase problems.)

Insulation and new films which keep heat out of buildings must be considered in conjunction with renewables and other non-nuclear alternatives.

Community and individual and even utility owned rooftop solar (and PV solar panels over parking lots) must be considered, not simply utility scale on virgin land. Even for virgin land, the 20,000 acres estimated for PV solar must be compared to the over 5 million acres (5,026,400 acres) in the 50 mile radius from River Bend which may become a permanent no-go radioactive exclusion zone, making 20,000 acres less than 1% of land lost to a nuclear disaster. This excludes impacts which extend beyond the 50 mile radius. In the case of Chernobyl the no-go exclusion zone is over 1 million acres spread out in a splotchy manner. However, serious impacts extend hundreds of miles beyond. Acres need for solar is declining, too, as PV cells decrease in size. Within the next 8 years, the CF of PV cells may increase so that 20,000 acres of space is 10,000 acres.

Note the map scale in miles (and Km) at the bottom righthand corner. A Ci (Curie) is 37 billion becquerels, i.e. Radioactive disintegrations (shots) per second.

The comparative evaluation must take into consideration socio-economic and environmental costs of major nuclear disasters, especially the region becoming a no-go exclusion zone. This can be done using both the inner 10 mile radius fallout zone and the outer 50 mile one. Both must consider the possibility that the exclusion zone may be well over a lifetime. Clearly, both the renewable and the oil and gas alternatives would win hands down.

Impact of a River Bend nuclear disaster on the French speaking minority of South Louisiana must be considered. The 50 mile radius backs into Lafayette, thus cutting across native French speaking territory – pointing to cultural genocide.

As far as environmental justice impacts on the African American population, the proper comparison is to the national average and not to the Louisiana average; not to the Mississippi average, nor to the regional average, as long as there is a United States. The percentage of African Americans in the US (national average) is 13.3%; the percentage of African Americans in the 50 mile River Bend fallout zone is 36.4%, meaning that there is an environmental justice issue.

Cost of evacuation of populations from the 10 mile radius and from the 50 mile radius must be evaluated, along with feasibility. Financial and social costs should include but not be limited to health care.

Impacts of life-shortening effects, including loss of family care-givers must be included. The US government BEIR report puts the increased cancer rate in a population at 1% per 100 mSv exposure over the course of a lifetime. A more recent US gov funded study suggests that it is higher-15% or greater per 100 mSv. Using the outdated ICRP percentage is unacceptable. This is cancer alone and excludes other health impacts, one of the most common of which is early cataracts. The ICRP’s callous statement that if a baby dies due to radiation in the first few weeks of life after conception (well before birth) it don’t matter would be very shocking to those would be parents who are undergoing costly treatments to conceive. It should enrage those who believe in life from conception, as well. And, what is the financial and psychological cost for fertility treatments due to radiation induced infertility? The psychological cost when they are ineffective? Not everyone feels that allowing more immigration is a fair substitute for having their own children. These impacts must be properly and seriously evaluated, including by what right the US NRC and Entergy hold the power of life and death over a population, and even the right to have children?

What about the largest maximum-security prison in the United States with 6,300 prisoners and 1,800 staff, which is around 25 miles from River Bend, in the event of a nuclear disaster? What are the security and other consequences of either leaving them – probably without staff supervison or evacuating them and to where? The 50 mile food fallout zone includes the Louisiana State Prison farm, as part of the prison.

What about the consequences of a nuclear waste accident on site, either a spent fuel pool fire or crack within the unmonitored 1/2 thick Holtec spent fuel canisters? Entergy and Holtec have requested that important information be withheld: https://www.nrc.gov/docs/ML0522/ML052280428.pdf

Interactive map of evacuation-fallout zones: http://www.psr.org/news-events/press-releases/psr-cites-flawed-evacuation-zones-nuclears-health-risks.html
Location of Louisiana State Pen – Angola Prison exported from here: https://en.wikipedia.org/wiki/Louisiana_State_Penitentiary

More about River Bend Nuclear Power Station


Near Misses at U.S. Nuclear Power Plants in 2015“. http://www.ucsusa.org/nuclear-power/whos-responsible-nuclear-power-safety/near-misses-2015 http://www.ucsusa.org/sites/default/files/attach/2016/03/Near-Misses-US-Power-Plants-2015-full-report.pdf

UCS Annual Review of U.S. Nuclear Reactor ‘Near Misses’ Finds More than 60 Percent of Safety Violations at Entergy Plants, Faulty Repairs Threaten Aging Reactors“, March 16, 2016: http://www.ucsusa.org/news/press_release/annual-nuclear-safety-review-0680

Special Nuclear Inspection: River Bend Loss of Shutdown Cooling
DAVE LOCHBAUM, DIRECTOR, NUCLEAR SAFETY PROJECT | MAY 24, 2016, 5:41 PM EDT, http://allthingsnuclear.org/dlochbaum/special-nuclear-inspection-river-bend-loss-of-shutdown-cooling

Special Inspection at River Bend: The Chiller Thriller
DAVE LOCHBAUM, DIRECTOR, NUCLEAR SAFETY PROJECT | FEBRUARY 24, 2016, 4:51 PM EDT http://allthingsnuclear.org/dlochbaum/special-inspection-at-river-bend-the-chiller-thriller

River Bend fined $140,000 because control room operators were surfing the internet: https://www.nrc.gov/docs/ML1200/ML120090313.pdf