Sierra Club Nuclear Free Campaign
COMMENTS ON THE EPA CARBON RULE
TELL EPA: NUCLEAR POWER IS NOT PART OF THE CLIMATE SOLUTION!
On June 2, 2014, the U.S. Environmental Protection Agency announced its proposed rule for reducing carbon dioxide (CO2 ) emissions from existing electrical generation units. This is an important and historic step toward addressing climate change. But EPA’s support of nuclear power and underplaying of the importance of renewables and efficiency is of serious concern.
☢ The EPA Clean Power Plan Proposed Rule supports building new nuclear reactors (power plants) and maintaining existing reactors as an alternative to burning fossil fuels.
☢ The rule encourages states to prevent even the most uncompetitive nuclear reactors from closing.
☢ The rule underestimates the advantages of renewable energy and energy efficiency as the best alternatives for reducing carbon emissions. The rule should acknowledge that renewables and efficiency can produce the power we need without the use of fossil fuels or nuclear power AND they can remove more carbon per dollar spent in a shorter time. Numerous studies have shown that this transition needs only the political will to make it happen.
☢ New nuclear reactors cost billions of dollars and take many years to bring on line. Renewable energy, and especially energy efficiency, are much cheaper and their development is already underway.
☢ EPA incorrectly claims that nuclear power is reliable. This ignores the many times nuclear reactors had to shut for years due to warm water temperatures, flooding, and extreme weather events, all of which will worsen as the climate warms.
☢ Nuclear power is far from carbon-free. Fossil fuels are used for uranium mining, milling, processing, conversion, enrichment, transportation and construction of reactors. Huge amounts of energy will be needed to isolate nuclear waste for millennia—a task which science has so far not been able to address. Large amounts of water are also used to operate and cool the reactors.
☢ EPA seriously minimizes the problem of radioactive waste. In fact, they erroneously contend that radioactive waste avoids the problem of waste from coal-fired generation! Waste from coal is a serious problem but radioactive waste is extremely dangerous and remains so for millions of years. EPA also ignores the routine radioactive releases at all reactors and the several U.S. close calls to nuclear meltdowns. The Sierra Club maintains that the first step toward dealing with nuclear waste and radioactive pollution is to stop generating it.
☢ The proposed rule improperly calls for reductions in CO2 from 2005 levels. The problem is that CO2 levels in 2005 were the highest ever. In fact, current levels of CO2 are 15% less than in 2005. The proposed rule should at least use current levels, or more appropriately, 1990 levels.
☢ The nuclear industry is looking to gain carbon credits—we say these carbon credits are undeserved, but in any case the industry is asking for carbon credits for nuclear power. These very credits will allow the industry to burn more coal. How does EPA propose that we obtain our national energy supply if we cut carbon but do not strongly emphasize moving as quickly as possible to sustainable, renewable replacement sources such as wind, solar, geothermal and efficiency?
☢ Currently EPA has out an Advanced Notice for comments on Environmental Radiation Protection Standards for Nuclear Power Operations. Unless the current Radiation Protection Standards are strengthened, EPA will continue to have lower standards for protection from radioactivity than the standards they have for protection from other pollutants. EPA’s “acceptable” cancer risk range is 1 in a million to 1 in 10,000 for other pollutants. Their allowable limit for radioactive exposure is 25 millirems per year. If a person’s lifespan is 70 years, the risk becomes 1cancer per 500 persons for radioactivity. It is worrisome that EPA does not mention strengthening its standards in its Advanced Notice for Comments, leaving the public to wonder if they are planning to lower their standards even further. So on the one hand, EPA is encouraging economic subsidies to nuclear power, while on the other hand EPA might change standards to allow more radioactive pollution from the nuclear fuel chain.
EPA has extended the public comment period on the Clean Power Plan proposed carbon rule through December 1, 2014. The Sierra Club Nuclear Free Campaign strongly supports EPA’s move toward reducing CO2 emissions, but their inclusion of nuclear reactors as a reliable source of electricity is a mistake. Tell EPA to remove all support for nuclear power from its Carbon Rule and instead, strongly promote a speedy transition from fossil fuels and nuclear to renewables and energy efficiency.
Comments can be made online at www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001. Reference Docket ID EPA-HQ-OAR-2013-0602. There is reference in this link that comments are due by October 16. However, the deadline has been extended through Dec. 1, which the top of the right-hand column confirms.
Alternatively, fax to 202-566-9744 or mail to EPA Docket Center, Mailcode 28221T, Attn: Docket OAR–2013-0602, 1200 Pennsylvania Ave. NW, Washington, DC 20460.
NUCLEAR FREE CAMPAIGNNuclear Free Campaign | Grassroots Network
We envision an energy efficient world, powered by clean, renewable technologies, free from dirty, dangerous, costly nuclear power and its legacy of toxic waste.
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