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Comment Due Jul 23, 2018 11:59 PM ET (10:59 CDT) https://www.regulations.gov/docket?D=NRC-2017-0141. This is for comment on the US NRC’s Environmental Impact Statement for relicensing River Bend Nuclear Power Station near St. Francisville (and Baton Rouge) Louisiana from midnight August 29, 2025 to 2045. Include Docket ID NRC-2017-0141 in the subject line of your comment.

According to the US NRC, 14% of Louisiana’s electricity in 2015 came from nuclear power. There are two nuclear power stations in Louisiana – Waterford near New Orleans, and River Bend, near Baton Rouge. River Bend is smaller, apparently in dangerously bad condition, and has been offline a lot. Even if one is generous and assumes that 7% of Louisiana’s electricity is from River Bend, the chart below still clearly shows that it could be more than replaced by solar PV. In fact, both Waterford and River Bend could be replaced. Additionally, due to improvements in solar PV making them smaller, lighter and more efficient, and based on a US National Renewable Energy Lab graph, the potential is probably twice this, as well as contantly improving. (Additionally, River Bend could now be quickly and easily replaced with natural gas from a nearby pipeline, which is currently produced in Louisiana and exported elsewhere, or a combination of biofuels and non-renewable natural gas.)

Here’s the one image that proves River Bend can easily be replaced by solar which could provide at least 25-35% of Louisiana’s electricity. This image is assuming an efficiency of 16% (apparently based on 2014 median average). If we assume the 32% given in the second image (graph), then it would be double (50-70%), if usage remains the same. What is lacking is political will, including the need to hold the nuclear industry responsible for the full cost, including accidents and waste. Nuclear power cannot survive in a free market economy, but only with governmental subsidies of all varieties, and government ownership as in Russia and France.

https://www.nrel.gov/pv/ https://www.nrel.gov/pv/assets/images/efficiency-chart-20180716.jpg
According to the US NRC, Generic Environmental Impact Study for River Bend Nuclear Power Station: “The electric industry in Louisiana provided approximately 108 million megawatt hours (MWh) of electricity in 2015. This electrical production was dominated by natural gas (61 percent), nuclear (14 percent), coal (14 percent), petroleum (4 percent), and biomass (3 percent). Hydroelectric and other miscellaneous energy sources collectively produced the other 4 percent of the electricity in Louisiana (EIA 2017d)“. https://www.regulations.gov/contentStreamer?documentId=NRC-2017-0141-0008&contentType=pdf

According to the US NREL: “These results are sensitive to assumptions about module performance, which is expected to continue improving over time. For example, this analysis assumed a module efficiency of 16% to represent a mixture of various technology types. If a module efficiency of 20% were assumed instead, which corresponds to current premium systems, each of the technical potential estimates would increase by about 25% above the values stated in this report. Furthermore, our results are only estimates of the potential from existing suitable roof planes, and they do not consider the immense potential of ground-mounted PV. Actual generation from PV in urban areas could exceed these estimates by installing systems on less suitable roof area, mounting PV on canopies over open spaces such as parking lots, or integrating PV into building facades” “This report focuses on quantifying the technical potential of photovoltaic (PV) systems deployed on existing suitable roof area in the United States. Rooftops provide a large expanse of untapped area for solar energy generation, and onsite distributed generation could potentially reduce the costs and losses associated with the transmission and distribution of electricityhttps://www.nrel.gov/docs/fy16osti/65298.pdf

Google on Louisiana’s solar potential: https://www.google.com/get/sunroof/data-explorer/place/ChIJZYIRslSkIIYRA0flgTL3Vck/

The Mall of Louisiana is the largest solar project in the state and could be much, much bigger if they would cover parking areas and put solar panels on top.

As seen below, the US NRC simply dismissed solar power without even bothering to write anything half intelligent. The utility, Entergy, did a slightly better job. From the US NRC’s so-called Generic Environmental Impact Statement for River Bend (the document which people need to comment upon.)
Alternatives Considered but Eliminated

The NRC staff considered, but then ultimately eliminated for detailed study, a number of alternatives to the RBS license renewal. The staff eliminated these alternatives because of technical reasons, resource availability, or current commercial or regulatory limitations. Many of these limitations will likely still exist when the current RBS license expires in 2025.

2.3.1 Solar Power

Solar power, including solar photovoltaic (PV) and concentrating solar power (CSP) technologies, produce power generated from sunlight. Solar photovoltaic components convert sunlight directly into electricity using solar cells made from silicon or cadmium telluride. Concentrating solar power uses heat from the sun to boil water and produce steam that drives a turbine connected to a generator to ultimately produce electricity (NREL 2014). To be considered a viable alternative, a solar alternative must replace the amount of electricity that RBS provides. Assuming capacity factors of 25 to 50 percent (DOE 2011), approximately 2,380 to 4,750 MWe of additional solar energy capacity would need to be installed in the region of influence.

Solar generators are considered an intermittent resource because their availability depends on ambient exposure to the sun, also known as solar insolation (EIA 2017e). Insolation rates of solar photovoltaic resources in Louisiana range from 4.5 to 5.5 kilowatt hours per square meter per day (kWh/m2/day) (NREL 2017). Due to higher solar insolation requirements associated with concentrating solar power, utility-scale application of this technology has only occurred in western States with high solar thermal resources (i.e., California, Arizona, and Nevada) (EIA 2016d).

Nationwide, rapid growth in large solar photovoltaic facilities (greater than 5 MW) has resulted in an increase from 70 MW in 2009 to over 9,000 MW fully online at the end of 2015 (Mendelsohn et al. 2012, Bolinger and Seel 2016). However, Louisiana is one of only a few States having no utility-scale solar generating capacity (EIA 2017e). In 2015, the State’s small amount of solar generation was limited to small-scale solar photovoltaic units distributed at customer sites. Further, Louisiana does not have a mandatory renewable portfolio standard that would require generators to consider solar power (EIA 2016b). Considering the above factors, the NRC staff concludes that solar power energy facilities would not be a reasonable alternative to RBS license renewal….” https://www.regulations.gov/contentStreamer?documentId=NRC-2017-0141-0008&contentType=pdf

Excerpt from our scoping comment on Entergy’s Environmental Impact Statement:
Community; individual; utility owned rooftop solar (& PVs on parking lots) options must be considered, not only utility scale on virgin land. Even for virgin land, a 20,000 acres est. for PV solar must be compared to the 5,026,400 acres within 50 mi of RB which may be a permanent no-go zone (over 1 million acres for Chernobyl). Acres need for solar is declining, too.

Comparison must consider socio-economic and environmental costs of major nuclear disasters, especially the area being a permanent no-go exclusion zone. Both renewable and oil-gas alternatives then are best.

Some posts discussing the many problems plaguing River Bend Nuclear Power Station:

Our scoping document appears to have been mostly and maybe entirely ignored:
“River Bend, Unit 1 Scoping Environmental Impact. ID: NRC-2017-0141-0004

Need to thoroughly evaluate:
Short, medium, long, very long-term evacuation-abandonment (100 yrs plus) within 10 to 50 mile radius:

The combined environmental and socio-economic impact of a nuclear disaster impeding ops in the nearby petro-chemical corridor out to 50 miles must be evaluated. WHY IS ENTERGY USING A 6 MILE ZONE ON ITS MAPS?

If workers at petro-chemical plants must be evacuated due to nuclear disaster, the environmental impacts evaluation should include a combination of nuclear, fire and radiological and chemically toxic fumes (apart from the fact that most radionuclides are both radiologically and chemically toxic).

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

Impacts on tourism and irreplaceable cultural sites, including the historically significant ones noted on the RB site, which will be lost forever in a nuc disaster. Entergy is hiding info with a blank page on what seems to be a site of incredible significance to Native American history, likely including burial grounds; significant cultural artifacts.

Impacts of BOTH the accumulation of ongoing nuclear discharges on the regional environment, some very long-lived, and nuclear accident upon the environment-population must be properly evaluated. These must include contamination cost and purification costs of groundwater; river-Gulf-ocean water; land; air. Your dilute to deceive scam fails over time.

Impacts upon colleges-universities: Southern in Baton Rouge, LSU, and any others; likely impacts upon UL Lafayette just outside the 50 mile zone must be reported.

Renewable Alternatives must be properly evaluated. They are not. Renewables must be evaluated in combination, as well as with improved insulation, rather than Entergy’s either-or.

Increasing CF (Capacity Factors) for PV and other renewables must be considered, and compared to the declining CF of RB nuclear – offline for months at a time due to defects-need of repair. CF for current solar PV and PV CF in 8 years time must be the comparision. Ditto for algae fuels, wind, etc. RB may be at 0 for 5 mths plus per year like Grand Gulf has been.

Insulation-new films which keep heat out must be considered in combo with renewables-other non-nuclear alternatives.

Community; individual; utility owned rooftop solar (& PVs on parking lots) options must be considered, not only utility scale on virgin land. Even for virgin land, a 20,000 acres est. for PV solar must be compared to the 5,026,400 acres within 50 mi of RB which may be a permanent no-go zone (over 1 million acres for Chernobyl). Acres need for solar is declining, too.

Comparison must consider socio-economic and environmental costs of major nuclear disasters, especially the area being a permanent no-go exclusion zone. Both renewable and oil-gas alternatives then are best.

Impact of RB nuclear disaster on the French speaking minority of Louisiana must be considered. The 50 mi radius backs into Lafayette, cutting across native French speaking area, i.e. cultural genocide.

For environmental justice impacts on African Americans, the proper comparison is to the national avg – NOT the Louisiana or MS avg., nor the region. US avg. African American population is 13.3%; population in the 50 mile radius is 36.4%, meaning 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 govt BEIR report puts increased cancer rate at 1% per 100 mSv exposure. A more recent US govt funded study suggests that it is higher-15% or greater. Using the outdated ICRP percentage is unacceptable. What is the financial & psychological cost for fertility treatments due to radiation induced infertility? The psychological cost when they are ineffective? Not all feel that more immigration is a fair substitute for having their own children. Immigrants replacing locals is actually defined as genocide.

What about the largest maximum-security prison in the United States with 6300 prisoners & 1,800 staff, about 25 miles from RB, 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?

What about the consequences of a nuclear waste accident on site, either spent fuel fire or crack within the unmonitored 1/2 thick Holtec spent fuel canisters? Entergy and Holtec have requested that important information be withheld: See: ML052280428

Ref to Entergy Enviro Impact for RB: ML17174A531
License renewal documents: https://www.nrc.gov/docs/ML1715/ML17153A282.html