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Rosedown in St. Francisville Louisiana, near River Bend Nuclear Power Station.

All comments can be seen here: https://www.regulations.gov/docket?D=NRC-2017-0141. Although the deadline is past you can send them a comment by email (or mail), but to be anonymous you will have to make a disposable email. More info at link. If it is late they do not have to consider it, but it’s still worthwhile. Comment is on the US NRC’s Generic Environmental Impact Statement for relicensing River Bend Nuclear Power Station near St. Francisville (and Baton Rouge) Louisiana from midnight August 29, 2025 to 2045. https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/supplement58/

Short version posted. See expanded version further below and short version as text at post bottom. NB: If LSU merited the name university, professors and students would be working on this case. Perhaps they should just forget the university part and call themselves Louisiana State football team. But, there’s far more at stake than LSU.

This is an expanded version of the shorter comment, above, which we posted. The relicensing impact study is supposed to be a socio-economic and environmental impact study, but NRC calls it Generic Environmental Impact Statement (GEIS).

River Bend Nuclear Reactor, GEIS ID: NRC-2017-0141
NRC’s Generic Environmental Impact Study is even more incomplete than Entergy’s.

The NRC and Entergy should do, but have not done, a serious and complete evaluation of the socio-economic, cultural, environmental and health impacts within the 50 mile fallout zone, designated by the US government as where food should not be eaten. Evaluation should be for both routine nuclear operations and nuclear disaster. Short, medium, long, and very long term scenarios should be evaluated. These should include scenarios ranging from evacuation to abandonment for over 100 years due to the long-lived nature of many radionuclides (radioactive materials).

Bear in mind: “The Chernobyl exclusion area is huge… Radiation contamination from the Chernobyl nuclear power plant accident in May 1986 lasts longer and spread further than most of us can imagine. After explosions at the plant, people in the surrounding area were evacuated and had to settle elsewhere. An exclusion or no-go zone was established in Ukraine and Belarus that stretches over 4,700 km2 (1,814 square miles). Much of this vast area cannot be repopulated for tens of thousands of years. To give an idea of the scale of the abandoned area, this map shows how it compares to other places on the planet. See how the Chernobyl exclusion area matches to a city or region you know. Thirty years on, the Chernobyl disaster continues. More than 5 million people still live in contaminated areas outside these exclusion zones. Families are exposed to radiation on a daily basis through their food, water and land. But their governments are trying to cut protection programs that ensure much needed monitoring, medical treatment and contamination-free food.” https://www.greenpeace.org/archive-international/en/campaigns/nuclear/nomorechernobyls/exclusion-zone-comparison-map
Chernobyl nuclear no-go exclusion zone. The exclusion zone depends on the wind direction, so the zone could be stretched in different directions. Areas 1000 miles or more away were highly contaminated by Chernobyl. Wind direction and rainfall, along with distance, influence where higher levels of radioactive materials fall.

Read more and find original interactive map here: https://www.greenpeace.org/archive-international/en/campaigns/nuclear/nomorechernobyls/exclusion-zone-comparison-map/

Topics which the US NRC should include for the impacts of a nuclear disaster at River Bend are found below. There are certainly more. Some of these are transferable to other sites; others not.

1. Impeding or halting the operations in the nearby petro-chemical corridor. What happens to petrochemical facilities in the event of a nuclear disaster? Can they be safely shut-down? How quickly and for how long? What are the impacts of fire, radioactive and toxic fumes on both the general population and the petro-chemical workers in a worst case scenario? How long-lasting and how widespread across the country would the impacts be? This appears to be an even greater issue for Waterford nuclear power station. Shutdown of the petrochemical corridor may lead to a US fuel shortage, among other things.

2. US and local transportion routes. What are the repercussions of shutting down state and interstate highways, Mississippi river shipping and port facilities, whether temporarily or permanently on the local, US and even world economy. The documentation on some, or all, of this is available, but the NRC fails to use it.

3. Tourism and historic-cultural sites, including the ones on the River Bend site. Tourism is important to the area and there are many historic and cultural sites including historic plantation homes, American Indian and French colonial sites. There are cemeteries, as well. While many are listed in the environmental impact studies, their value to the local economy and the repercussions of an accident upon them were not evaluated. Although they cannot be replaced, some attempt at placing a value on them should have been carried out. Additionally, the fact that they cannot be replaced and hence should not be endangered by a nuclear facility should be pointed out.

According to Entergy, Cottonmouth American Indian Mound Complex and the Causeway American Indian Site are on River Bend grounds. Entergy hid the map and the NRC fails to mention these 1000 year or older sites. The LSU mounds were only recently learned to be over 5000 years old. Without research no one will know. They must be of incredible significance, likely including American Indian and other historic burial grounds, or Entergy wouldn’t be hiding their location, and the NRC their very existence. Are they in the area where Entergy wants to expand the nuclear waste facility? Without a map we don’t know.

One of LSU’s American Indian mounds

4. Impacts of accumulation of ongoing nuclear discharges, both legal and illegal-accidental, on the regional environment, Mississippi River, and Gulf of Mexico, and on people should be seriously evaluated. The nuclear discharges include long-lived radionuclides (radioactive material).

5. Purification costs of groundwater; Miss River-Gulf-Ocean water; land; air should be evaluated. NRC-Nuclear dilute to deceive scam fails over time, as long-lived radioactive materials accumulate in the environment. Water is becoming a scarce resource, and clean water even more scarce.

6a. Impacts on colleges and universities: LSU, Southern, Baton Rouge Community College are all within 50 miles of River Bend; UL Lafayette is just outside the 50 mi zone. An evaluation should include student health, but also the economic impact of the universities to the area. There is also the value to the buildings themselves, some very historic.
6b. Impacts on Louisiana State government

7. Ethnic & Cultural Genocide:
The 50 mile radius cuts across native French speaking area; the Tunica-Biloxi American Indian Reservation within 50 miles. NRC claims to have consulted with the Tunica-Biloxi but we find no response by them included in the NRC documents.

8. Environmental justice:
The NRC and Entergy cheat on this. Comparison must be to US national average of African American population and NOT to the Louisiana nor Mississippi nor regional average. When people are evacuated they end up spread across the entire country. Is the US a country or not? If the US is a country, then the comparison must be of the country. Funny when it comes to exporting oil and gas both from and through this region to the northeast and abroad, there is no question of if it is the United States. If this region kept more of its oil and gas, then there would be no need for nuclear. The US average African American population is 13.3%. Within the 50 mile radius the African American population is 36.4%

9. Evacuation costs must be evaluated for more than the 75 days at $210 ($15,905) given by Entergy. Evaluation of the feasibility and the cost of evacuation of 1.5 million people must be carried out. This is Entergy’s estimate based on future population. NRC low-balls the population based on 2016. Entergy and NRC fail to evaluate loss of career, loss of wages and pain and misery.

10. Health care cost burden should be evaluated:
Plus, who will pay?

11. Life-shortening effects of radiation, including social and economic impact of loss of middle aged family care-givers for children and the elderly should be discussed.

12. US BEIR report puts increased cancer rate at 1% per 100 mSv exposure. A more recent US goverment funded study suggests that it is 3%-15% or even higher. Use of outdated ICRP percentage-rates is unacceptable.

13. The largest max-security prison in the United States with 6300 prisoners and 1800 staff is 25 miles from RB. What are the security and other consequences of either leaving them – probably without staff supervison or evacuating them and to where?

14. Nuclear waste accident on site, either spent fuel pool fire, low-intermediate waste fire, or leak-explosion-fire of the unmonitored 1/2 inch thick Holtec spent fuel canisters. Entergy & Holtec have requested that info be withheld: ML052280428

NRC fails to properly evaluate alternatives. Renewable Alternatives must be properly evaluated, both separately and in combo. Rooftop solar could provide 25%-35% of Louisiana energy (NREL, ca 2013). Solar cells have since improved & continue to improve, in constrast to the declining Capacity Factor of RB nuclear – offline for months at a time due to defects-need of repair. Insulation-new films which keep heat out must be considered in combo with renewables-other non-nuclear alternatives (natural gas and ag waste produced in Louisiana). Community; individual or 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 become a permanent no-go zone (over 1 million acres for Chernobyl). Acres need for solar is rapidly declining, too, so 10,000 acres or less may be a better estimate. Given the socio-economic & environmental costs of major nuclear disasters, esp. the area as a permanent no-go exclusion zone, as well as accumulation of routine nuclear discharges into the environment and the lack of solution for nuclear waste, the renewable & oil-gas alternatives are clearly best. Offshore wind could more than replace all nuclear power in the USA, according to NREL estimates: 86 MILLION GW offshore wind compared to 99 GWe for all 99 US reactors. In the immediate future, pending expansion of renewables, River Bend should be shutdown and replaced by expansion of the Big Cajun site across the river with natural gas (currently produced in Louisiana) and biofuels (ag waste), unless all nuclear waste is removed from the River Bend site, or placed at an adequate distance from a natural gas facility in case of fire-explosion. Forget relicensing of River Bend nuclear. It must be shutdown now, before it’s too late.

Short Version text
River Bend Nuclear Reactor, GEIS ID: NRC-2017-0141
NRC’s Generic Environmental Impact Study is even more incomplete than Entergy’s.
NRC must seriously & completely evaluate 10 – 50 mi radius (& beyond) socio-economic, cultural, environmental & health impacts for both routine nuclear ops & nuclear disaster (short, medium, long, very long term-evacuation & abandonment for 100 + yrs ):
1. Impeding or halting ops in the nearby petro-chemical corridor: fire, radioactive, & chem toxic fumes on pop & petro-chem workers; US fuel shortage.
2. US (& local) transport routes – interstate highways, river shipping & port facilities temporary or permanent shutdown; repercussions on local, US & even world economy.
3. Tourism & historic-cultural sites, including the ones on the RB site:
Cottonmouth American Indian Mound Complex and the Causeway American Indian Site. Entergy hid map & NRC fails to mention these 1000 yr or older sites of incredible significance, likely including American Indian and other historic burial grounds.
4. Accumulation of ongoing (legal) nuclear discharges on the regional environment (some very long-lived) & nuclear leaks & accident upon both environt & pop.
5. Purification costs of groundwater; Miss River-Gulf-Ocean water; land; air.
NRC-Nuclear dilute to deceive scam fails over time, as long-lived radioactive materials accumulate in the environt.
6. Colleges-universities: LSU, Southern, Baton Rouge CC within 50 mi; UL Lafayette just outside 50 mi zone.
7. Ethnic & Cultural Genocide: 50 mi radius cuts across native French speaking area; Tunica-Biloxi American Indian Reservation within 50 mi.
8. Environmental justice: comparison must be to US national avg of African American population & NOT the Louisiana nor MS nor region avg. US avg. African American pop. is 13.3%; in the 50 mi. radius African American pop. is 36.4%
9. Evac costs must be eval. for more than the 75 days at $210 ($15905) given by Entergy; feasibility eval-cost of evac of 1.5 million people (Entergy est.) NRC low-balls pop. Entergy & NRC exclude loss of career/wages & pain and misery
10. Health care cost burden
11. Life-shortening effects of radiation, incl. loss of middle aged family care-givers for children & elderly
12. US BEIR report puts increased cancer rate at 1% per 100 mSv exposure. A more recent US govt funded study suggests that it is 3%-15% or even higher. Use of outdated ICRP % is unacceptable.
13. Largest max-security prison in the United States with 6300 prisoners & 1800 staff is 25 miles from RB: security & other consequences of either leaving them – probably without staff supervison or evacuating them & to where?
14. Nuclear waste accident on site, either spent fuel pool fire, low-intermediate waste fire, or leak-explosion-fire of the unmonitored 1/2 inch thick Holtec spent fuel canisters. Entergy & Holtec have requested that info be withheld: ML052280428

NRC fails to properly evaluate alternatives. Renewable Alternatives must be properly evaluated, both separately and in combo. Rooftop solar could provide 25%-35% of Louisiana energy (NREL, ca 2013). Solar cells have since improved & continue to improve, in constrast to the declining Capacity Factor of RB nuclear – offline for months at a time due to defects-need of repair. Insulation-new films which keep heat out must be considered in combo with renewables-other non-nuclear alternatives (natural gas and ag waste produced in Louisiana). Community; individual or 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 become a permanent no-go zone (over 1 million acres for Chernobyl). Acres need for solar is rapidly declining, too, so 10,000 acres or less may be a better estimate. Given the socio-economic & environmental costs of major nuclear disasters, esp. the area as a permanent no-go exclusion zone, as well as accumulation of routine nuclear discharges into the environment and the lack of solution for nuclear waste, the renewable & oil-gas alternatives are clearly best. Offshore wind could more than replace all nuclear power in the USA, according to NREL estimates: 86 MILLION GW offshore wind compared to 99 GWe for all 99 US reactors. In the immediate future, pending expansion of renewables, River Bend should be shutdown and replaced by expansion of the Big Cajun site across the river with natural gas (currently produced in Louisiana) and biofuels (ag waste), unless all nuclear waste is removed from the River Bend site, or placed at an adequate distance from a natural gas facility in case of fire-explosion. Forget relicensing of River Bend nuclear. It must be shutdown now, before it’s too late.

Rosedown photo released to public domain via Wikipedia, color adjusted by MA: https://commons.wikimedia.org/wiki/File:Rosedown_Plantation_2008.jpg
LSU Indian mound photo released to public domain via Wikimedia: https://commons.wikimedia.org/wiki/File:Lastateindian.jpg