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Written Statement of

 

Derry Bigby

Vice President

African American Environmentalist Association

 

For the

Nuclear Regulatory Commission Meeting To Discuss The Draft Supplemental Environmental Impact Statement

For

License Renewal

For the

Indian Point Nuclear Power Plant

 

 

 

Presented to the

 

 

 

U.S. Nuclear Regulatory Commission

 

Office of Nuclear Reactor Regulation

 

 

 

 

February 12, 2009

 

 

 

          

 

 

Introduction

My name is Derry Bigby and I am the Vice President of the African American Environmentalist Association (AAEA).  AAEA, founded in 1985, is an organization dedicated to protecting the environment, enhancing human, animal and plant ecologies and promoting the efficient use of natural resources.  AAEA includes an African American point of view in environmental policy decision-making and resolves environmental racism and injustice issues through the application of practical environmental solutions.  The New York Office was established in 2003.

  AAEA supports the 20-year License Renewal for the Indian Point nuclear power plant located in Buchanan, New York.  AAEA expressed public support for nuclear power for the first time in 2001 after a two-year internal process of studying and debating the issue. AAEA was the first environmental organization in the United States to support nuclear power.  My comments today address the Generic Environmental Impact Statement for the License Renewal of Nuclear Plants, Supplement 38, Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3.

AAEA has members worldwide.  New York members of AAEA live and work – and breathe the air in a Clean Air Act Nonattainment Area.  Of particular import to AAEA is the promotion of clean air in African American communities.  Because nuclear power is emission-free and has a demonstrated safety record, whereas fossil-fuel power contributes to numerous health issues, AAEA seeks to promote the safe use of nuclear power.  AAEA specifically supports the Indian Point 2 and 3 nuclear power facilities because these facilities provide significant electrical capacity to the State of New York with minimal human, animal, air, water, and land impacts.  My comments will address specific environmental justice, air pollution, and global warming issues.


AAEA agrees with the preliminary recommendation of the NRC staff:

“…that the Commission determine that the adverse environmental impacts of license renewals for IP2 and IP3 are not so great that not preserving the option of license renewals for energy planning decision makers would be unreasonable. This recommendation is based on (1) the analysis and findings in the GEIS, (2) the ER submitted by Entergy, (3) consultation with other Federal, State, and local agencies, (4) the staff’s own independent review, and (5) the staff’s consideration of public comments received during the scoping process.”[1]

 

Environmental Justice

Environmental justice is defined by AAEA as the fair treatment of all people regardless of race or income with respect to environmental issues.  AAEA is deeply concerned with any policy or measure that impacts the air quality of the communities where it is based, or that affects the health of its members. Although AAEA is concerned about air quality in all areas, we are particularly concerned with promoting clean air in African American communities because, in many instances, those communities suffer a disproportionate amount of total pollution.

We agree with the NRC conclusion in the GEIS on the environmental justice impacts if IP 2 and IP 3 are relicensed for another twenty years, which states:

“Based on the analysis on environmental health and safety impacts presented in this draft SEIS for other resource areas (contained in Chapters 2 and 4 of this SEIS), there would be no disproportionately high and adverse impacts to minority and low income populations form continued operation of IP2 and IP3 during the license renewal period.”[2]

 

            We totally disagree with the environmental justice conclusion that, “the overall environmental justice impacts of constructing and operating a closed-cycle cooling system at the IP2 and IP3 site are likely to be SMALL.”[3]  The impacts would be devastating because we believe Entergy would shut the facility down before building cooling towers and that would lead to significantly more air pollution in minority communities that are already inundated with a disproportionate amount of pollution sites.  We support the alternative proposal that would combine the existing once-through cooling system with modified intake retrofits that would be equivalent to a new closed-cycle cooling system. Requiring a closed-cycle cooling system is essentially the No-Action Alternative (shut down).  

Supercritical Coal-Fired Generation

 

The GEIS concludes that even a more efficient supercritical four-unit coal-fired power plant could cause LARGE impacts depending on the site location.[4]  Although we approve of supercritical boilers, they cannot replace the emission free nature of IP2 and IP3.  Emissions from these plants would still have large negatives impacts on already impacted communities in environmental justice areas.

Fossil-Fuel Power Causes Serious Adverse Health Effects

            In 1999, coal-fired power plants in the United States emitted into the environment 11.3 million tons of sulfur dioxide (“SO2”), a criteria air pollutant that is correlated to asthma and impaired lung functions, 6.5 million tons of nitrogen oxides (“NOx”) which, when combined with other pollutants and sunlight, forms ozone, another lung irritant linked to asthma, and 1.9 billion tons of carbon dioxide (“CO2”), yet another contributor to increased ozone levels and global climate change.[5]  This equates to approximately 60% of all SO2 emissions, 25% of all NOx emissions, and 32% of all CO2 emissions nationwide.[6]

            These and other airborne pollutants emitted by fossil-fuel power stations may have a direct and significant effect on human health.  In a study by Abt Associates, one of the largest for-profit government and business research consulting firms in the world, it was found that over 30,000 deaths each year are attributable to air pollution from U.S. power plants.[7]  Another study found that air pollution from power plants was a contributing factor to higher infant mortality rates and higher incidences of Sudden Infant Death Syndrome (“SIDS”).[8]  Research has further shown that pollutants from fossil-fuel power plants form tiny  particles (called fine particulate matter) that are linked to diseases of both the respiratory and cardiovascular systems.[9] 

            Not surprisingly, air pollution has been characterized as one of the largest threats to public health.[10] 

Negative Health Effects of Fossil-Fuel Power Borne Disproportionately by Blacks

            Sadly, these serious health effects disproportionately fall on the shoulders of low-income and minority communities, including African American communities.  For instance, the percentage of African Americans and Hispanics living in areas that do not meet national standards for air quality is considerably higher than that of whites.[11]  Correspondingly, respiratory ailments affect African Americans at rates significantly higher than whites.  Asthma attacks, for example, send African Americans to the emergency room at three times the rate of whites (174.3 visits per 10,000 people for African Americans versus 59.4 visits per 10,000 people for whites), and African Americans are hospitalized for asthma at more than three times the rate of whites (35.6 admissions per 10,000 people for African Americans versus 10.6 admissions for every 10,000 people for whites).[12]  Similarly, the death rate from asthma for African Americans is almost three times that of whites (38.7 deaths per million versus 14.2 deaths per million).[13]

Conclusion

            AAEA supports the 20-year License Renewal (ESP) for the Indian Point nuclear power plant located in Buchanan, New York.  We support this renewal because the facility is a positive structure for mitigating ground level air pollution, global warming and environmental injustice.

 


[1] U.S. NRC GEIS for License Renewal of Nuclear Plants, Supplement 38, Regarding IP2 & 3, Draft Report For Comment, Main Report, Executive Summary, p. xvii.

[2] GEIS, 4.4.6 Environmental Justice, p 4/45-4-46.

[3] GEIS, Section 8.1.1.2 Environmental Impacts of the Closed-Cycle Cooling Alternative, Environmental Justice, p. 8-16.

[4] GEIS, 8.3.1 Supercritical Coal-Fired Generation, Environmental Justice, p 4-44.

[5] Rachel H. Cease, Adverse Health Impacts of Grandfathered Power Plants and the Clean Air Act: Time to Teach Old Power Plants New Technology, 17 J. Nat. Resources & Envtl. L. 157, 158 (2002-2003); Martha H. Keating, Air Injustice, at 4 (October 2002) (attached hereto as Exhibit B).

[6] Nat. Resources & Envtl. L. at 158.

[7] Nat Resources & Envtl at 159.

[8] Martha H. Keating, Air Injustice,  (October 2002).

[9] Air Quality in Queens County: Opportunities for Cleaning Up the Air in Queens County and Neighboring Regions, at S-6, Synapse Energy Economics, Inc. (May 2003) (“Air Quality in Queens County”) (“Epidemiological studies tell us that on days when air pollution levels are high, more people get sick or die.”) (available at http://www.synapse-energy.com/Downloads/Synapse-report-queens-air-quality-exec-summary-05-29-2003.pdf); Children at Risk: How Pollution from Power Plants Threatens the Health of America’s Children, at 2, Clean Air Task Force (May 2002) (“Power plant emissions and their byproducts form particulate matter, ozone smog and air toxics.  These pollutants are associated with respiratory hospitalizations, lost school days due to asthma attacks, low birth weight, stunted lung growth and tragically, even infant death.”) (available at http://cta.policy.net/fact/children/).

[10] Allison L. Russell, Urban Pollutants: A Review and Annotated Bibliography, New York City Environmental Justice Alliance 2000 (http://www.nyceja.org/pdf/Urban.pdf).

[11] Urban Pollutants.

[12] Urban Pollutants.

[13] Urban Polutants.