EPA Clean Power Plan Low-and Zero-carbon Generating Capacity – Nuclear Power Plants

EPA Clean Power Plan Low-and Zero-carbon Generating Capacity – Nuclear Power Plants

Tritium And The Radioactive Contamination Of Ground And Surface Waters

Tritium is one of several radioactive wastes. Tritium is an isotopic form of hydrogen, the smallest and lightest of all the elements. It has a radioactive half-life of 12.3 years. It is found naturally in some geological formations. Tritium is also generated in nature by the interaction of cosmic radiation passing through the atmosphere. Naturally occurring tritium exists as part of the background radiation and is ubiquitously found in water at very low levels (6 to 24 picocuries per liter).

Tritium is generated at much higher levels and concentrated forms during the operations of the nuclear industry for electrical power as well as the production and detonation of nuclear weapons. The tritium at nuclear power plants for electrical generation is routinely generated and released as both a radioactive gas and liquid effluent.

Tritium in its radioactive gaseous form (HT) is routinely vented and escapes into the atmosphere during operations. It's liquid form, tritiated water (HTO), is chemically identical and physically similar to water in all its states (ice, water, and vapor) and is routinely diluted and discharged into a column of water which in turn is batch released to adjacent surface water in rivers, lakes and oceans. Both tritiated water and gas are able to permeate most kinds of materials, concrete, rubber and many grades of steel with relative ease. Through accidental or permitted allowable releases, tritium in the environment is very mobile and can go anywhere that water can go.

“Because tritium is identical to the hydrogen atom it is able to incorporate itself at the most intimate biological levels where it effectively delivers its biologically damaging energy. A unique chemical feature of tritium is that it rapidly exchanges with hydrogen atoms in nature including in the biological makeup of organic life. In the human body, all tissues and cells are composed of about 70% water. About 80% of the atoms in the human body are hydrogen atoms which, with chronic exposure, significant portion can be effectively replaced by tritium.”

Hydrogen is by far the most common element in the DNA molecule. Another unique feature is that tritium forms strong bonds with carbon to form organically bonded tritium (OBT). The organically bonded tritium is retained in the human body for a much longer period of time than tritiated water. Once ingested, inhaled or absorbed, the level of tritium exposure closely follows its cellular distribution in the body. Tritium can pass through the placenta barrier from mother to the fast growing cells of her fetus.

Tritium is clinically proven to cause cancers, mutations and birth defects and effectively toxic for 120 years (ten half-lives).

The currently “permissible” exposure or protective standard for tritium in drinking water is in controversy. Permitted exposure does not mean safe exposure. The United States EPA has currently set the federal protective limit for drinking water at 20,000 picocuries of tritium per liter.

A Canadian government advisory council concurred in its 2009 report that the permitted level of tritium discharged from Canadian nuclear power stations needs to be lowered to 540 picocuries per liter (20 becquerels/ liter) of drinking water. The current federal protective standard for tritium in drinking water is antiquated and permissible releases from nuclear power stations need to be drastically reduced.

While both the Nuclear Regulatory Commission and the nuclear power industry admit that tritium exposure health risks include increased occurrence of cancer and genetic abnormalities in future generations, they continue to trivialize how significant a health risk there is even to neighboring populations as the result of chronic exposure to undiscovered and non-remediated ground and surface water contamination. There is no remediation, except geologic filtration over time.

Tritium once absorbed, can effectively cause damage to the human biology i.e., the fetus and the human DNA.

The NRC fact sheet states, “Once tritium enters the body, it disperses quickly and is uniformly distributed throughout the soft tissues. Half of the tritium, in terms of it's biological half life, is excreted within approximately 10 days after exposure.”

But this is a significantly incomplete description of how tritium is biologically taken up by plants, animals and humans from these releases. It leaves out a more critical description of how tritium released into the environment. bonds with organic molecules and becomes “organically bonded tritium (OBT). It then has a biological half life between 21 and 76 days. Chronic environmental exposures increase the deleterious risks from the fixed binding of tritium to the carbon atom of DNA which is clinically documented with much longer biological half life of 280 to 550 days.

Organically Bonded Tritium Can Stay In The Body For Up To 15 Years

Although a comprehensive study was submitted to the Canadian stating that OBT remains in the body for 15 years. The 8 pages on Health Effects of Tritium by prepared as comments and submitted to the Canadian Nuclear Safety Commission (CNSC) at the invitation of the Citizens of Renfrew County and on behalf of the International Institute of Concern for Public Health, in Toronto, with respect to the re-licensing of the SRB Technologies, Inc. in Pembroke, Ontario, are a heady venture into medical specificity by Rosalie Bertell, Ph.D., GNSH.

Bertall's Doctorate Degree is in Biometrics, and she has worked in Environmental
Epidemiology for about 40 years, with a specialty in low dose ionizing radiation. Betrell was
one of the Founding Members of the International Institute of Concern for Public Health
in Toronto and served as its President between 1984 and 2000. Since her retirement, Rosalie Bertell has served as advisor/consultant to projects of the Institute.
http://beyondnuclear.squarespace.com/storage/health_effects_tritium_bertell.pdf

Exposure Risks

All of the usual comparative narratives like bananas, dental x-rays, and plane flights conveniently leave off one critical and unique characteristic of this radioactive form of hydrogen which can be incorporated (and cause damage) at the most intimate levels of biology; by replacing the most ubiquitous element in the human body, hydrogen.

Vulnerable Aquifers; Relationship to Groundwater System Evaluation

Tritium analysis may be used to estimate the time since recharge to the groundwater system occurred and the susceptibility of the groundwater system to contamination. Groundwater systems with recharge occurring prior to the 1950s will have a tritium level decreased by radioactive decay to levels at or below one TU. These groundwater systems are considered "not vulnerable." Conversely, groundwater systems which have been recharged after the early 1950s will contain tritium levels at, or significantly above, the natural "prebomb" background concentrations and are considered "vulnerable."
http://www.epa.state.il.us/water/tritium.html

Just days after it received a new 20-year license extension from the U.S. Nuclear Regulatory Commission, the Oyster Creek Nuclear Generating Station in New Jersey was found to be leaking radioactive tritium.
http://ecopolitology.org/2010/05/14/us-oldest-nuclear-power-plant-leaking-waste-into-aquifer/

Why Tritium is a Health Hazard?

The NRC continues to refer to 1979 safety data regarding tritium, more recent studies, from France and Canada have shown that tritium can have many health implications that include: developmental abnormalities, genetic and reproductive effects, cancer and cell death.

Other research indicates that “Tritium can cross the placenta and remain in fetal tissue. Tritium in water can break complex double strand DNA molecules and render then irreparable. This DNA sensitivity can alter the heredity and life of future organisms, posing higher risks for birth defects and miscarriage. Lower doses of tritium have shown more cell death, mutations and chromosome damage than higher doses. Beta emitters, like tritium are 2 times more damaging than x-rays or gamma rays in causing damage to human cell tissue.”
http://www.cleanwateraction.org/currents/njef/summer2010/what-tritium-and-what-it-doing-my-aquifer

Tritiated water was found underneath a nuclear power plant in southeast Georgia in 2011, but officials said that the leak did not pose any immediate threat to public health. "This water is totally contained right under the industrial footprint of our plant, "we really don't know what the rate is company officials stated, but we know it's more than a drip."

The maximum concentrations of tritium reported inside the monitoring wells was more than 200 times the limit set by the U.S. Environmental Protection Agency for drinking water, according to a report that Southern Co. officials filed with the U.S. Nuclear Regulatory Commission. Testing by the utility showed no signs that tritium from this leak has gotten into aquifers that supply drinking water or into the nearby Altamaha River, which provides cooling water for the nuclear plant.

200 x 20,000 picocuries per liter. That's 4 million picocuries per liter.

Oyster Creek Nuclear Power Plant Cleanup in 2009-2010 - the Press Relief

I mean, the Press Release made for mild reading. “So far, there is no sign of radioactive material outside the boundaries of the nuclear plant or near any potable water supply. Our goal is to make sure that never occurs.”

The plan called for pumping groundwater from the Cohansey aquifer, measuring the concentration of tritium in the water, discharging it into the Oyster Creek cooling-water intake structure, allowing the tritium to mix with the cooling water throughout the plant, and then letting it flow into the discharge canal. The groundwater dumped into the intake structure would be monitored daily for tritium and gamma radiation.

Geez, all one needs to monitor a solar array, or wind generator is a volt-meter.

Additionally, permissible does not mean safe.

The Nuclear Information And Resource Service states: The current U.S. Environmental Protection Agency standard for permissible levels of tritium in drinking water is 20,000 picocuries per liter. Please note: permissible does not mean safe.
http://www.nirs.org/radiation/tritium/tritiumhome.htm

The NRIS offers several links for further information:

Tritium Health Consequences:
http://www.nirs.org/factsheets/tritiumbasicinfo.pdf

Link to the State of Illinois Class Action Suit on Tritium Leaks from Exelon’s Braidwood nuclear station:
http://exelonclassaction.com/

United States Nuclear Regulatory Commission website on ground water contamination at US reactor sites:
http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html

Link to Institute of Environment and Energy Research (IEER) http://www.ieer.org/

The Tritium Report http://www.ieer.org/reports/tritium.html

And from a respected voice; Dr. Arjun Makhijani’s 2006 Statement on Tritium. Arjun Makhijani is president of the Institute for Energy and Environmental Research in Takoma Park, Maryland.

"Since tritiated water is processed by plants, animals and humans like ordinary water, the tritium in it can become transformed into other chemicals, such as proteins, needed by the body. It can become part of the DNA. It can affect developing fetuses. Unfortunately, many of these effects, such as miscarriages in early pregnancy that may be induced by exposure of pregnant women to tritiated water, have not been well studied. Further, the combined effects of in-utero exposure to substances such as tritium combined with endocrine disrupting chemicals such as dioxins or PCBs are also not well understood.”

“Nuclear power plants discharge a significant amount of tritium as part of their routine operations; sometimes more is discharged as a result of mishaps and incidents. The current drinking water standard for tritium of 20,000 picocuries per liter does not take non-cancer effects of tritium, such as miscarriages, into account. Given the particular properties and non-cancer risks of tritium (when it is organically bound or in the form of tritiated water), I am of the opinion that the Nuclear Regulatory Commission has not been vigilant enough in trying make reactor operators reduce their tritium discharges. It is noteworthy in this context that the surface water standard for tritium in the State of Colorado is 500 picocuries per liter, which is 40 times more stringent that the EPA drinking water standard.”
http://www.ieer.org/comments/health/tritium.html

Key Facts About Tritium

The Radioactive Isotope of Tritium Forms Radioactive Water

Tritiated water, HTO, where one of the hydrogen atoms in the water molecule is radioactive. It is not dissolved in the water; it is the water, so Tritium can’t be filtered out and moves faster than any other radionuclide in water. It is generally the leading edge of a contaminant plume.

The half life for Tritium is 12.3 years, while it remains dangerous to 250 years.

Probably the most well known Tritium Tale, is that of the contamination at the Boeing Rocketdyne site. Decades of releases of unknown quantities into the environment led to contamination of drinking water wells, health problems, and a devaluation in real estate.

Tritium Levels In Drinking Water

The EPA permissible level in drinking water is 20,000 pico-Curies per liter (pCi/L).
Background tritium levels are generally 6 to 10 pCi/L.

In “Regulatory Roulette”, the 2010 publication of the Union Of Concerned Scientists, author David Lochbaum relates a lax regulatory oversight of patterns and practices that bode serious concerns for the environment and public health. “The NRC’s Inconsistent Oversight of Radioactive Releases from Nuclear Power Plants” by D. Lochbaum is a thoroughly researched look into releases, contamination, and regulatory oversight of the nuclear power plant driven “low to zero-carbon emissions climate model” for the US energy sector.

Diversifying The U.S. Energy Economy Under The EPA Proposed Power Plant Rule
https://www.indybay.org/newsitems/2014/11/28/18764739.php
(comments due December 1, 2014)

From the Request For Comment By EPA - “30 states already have nuclear EGUs (with five units under construction) and the generation from these units is currently helping to avoid CO 2 emissions from fossil fuel-fired EGUs. Policies that encourage development of renewable energy capacity and discourage premature retirement of nuclear capacity could be useful elements of CO 2 reduction strategies and are consistent with current industry behavior.”

Avoid Premature Retirement Of Nuclear Power Plants – Don't Build Them

“Regulatory Roulette” by author David Lochbaum details 27 cases in which nuclear power plants accidentally released radioactive materials over the four years previous to 2010, the Nuclear Regulatory Commission allowed nuclear electrical generating units (EGUs under the current Proposed EPA Power Plant Rule) to violate regulations with impunity.

People and the environment have been harmed. In 2005 it was reported that over six million gallons of tritium-laden water leaked from the Braidwood nuclear plant in Illinois, and the specter of radioactive contamination depressed home prices of families in the plume’s path. On a related note, the State of Illinois just opened the door to fracking.

Radioactive Waste Management Systems - Radwaste

Radioactively contaminated gases, liquids, and solids are routine byproducts of nuclear
power plant operation. Radioactive waste management systems, commonly called radwaste
systems, collect, process, and either recycle or dispose of these radioactive materials. The design and operation of the radwaste systems are governed by Nuclear Regulatory Commission (NRC) regulations.

Allowed Releases - Radioactive Material Is Intentionally Discharged To The Environment

Such discharges are also regulated by the NRC. Plant owners are required to submit annual
reports to the NRC detailing the amounts and compositions of radwaste discharged, intentionally or accidentally from their facilities.

In pressurized water reactors, gaseous radwaste comes largely from the high pressure
water continuously removed from the primary loop that circulates water between the reactor vessel and the steam generators. The removed water is cooled so it can be purified and chemically treated as necessary, and the associated reduction in pressure allows gas bubbles to form. This gas is collected in large tanks, and once they are full, workers take a sample and measure its radioactivity level. If that level is below specified limits, the contents of the tank can be discharged through a vent pipe to the atmosphere. If not, the gas is allowed to sit to give the short-lived radionuclides some time to decay, and workers take another sample to determine if the radioactivity level has dropped enough to permit the gas to be released.

In boiling water reactors, 2 gaseous radwaste comes largely from the steam produced in
the reactor vessel and routed to the turbine-generator to make electricity. This steam carries
along with it radionuclides in gaseous form. The “offgas” system removes the radioactive gas
from the condensers located directly beneath the turbines. The offgas system removes small
radioactive particles from the flow and delays the release of radionuclides like the noble gases krypton and xenon to allow their decay. The treated flow, which is now significantly less radioactive, is discharged from a chimney that is hundreds of feet tall to promote mixing and dilution with the non-radioactive air.

In both types of reactors, liquid radwaste comes from floor drains that capture in-plant
spills, equipment drains that collect controlled releases from valve gaskets and relief valves, and water rejected from other systems due to chemistry problems (e.g., high or low pH levels, conductivity that is not within specifications, etc.). The liquid radwaste system has many tanks that store water from its initial receipt through various processing stages. Most of the water can be re-used in the plant after one or more cycles through the liquid radwaste system. However, there are times when the capacity of the liquid radwaste system to process
incoming water is reduced.

The radwaste system may not be able to repetitively process such large amounts
of incoming water until it is clean enough to be recycled. In this case, the radioactive water may be discharged instead.

When workers plan to release the contents of a liquid radwaste system tank to the
environment, they mix the contents of the tank to obtain a homogeneous mixture for sampling. After analysis of a representative sample confirms that the radioactivity levels are below specified limits, the tank’s contents can be discharged into the nearby lake, river, or ocean that provides the cooling water for the reactor.

Typically, the discharged cooling water is used to dilute the releases from liquid radwaste system tanks and promote mixing in the lake, river, or ocean waters.

Solid radwaste includes the resin beads used to purify the radioactive water circulating
through the reactor vessel, the steam generators, and the spent fuel pools. The resin beads
remove dissolved impurities by ion exchange and particles by filtration. Periodically, workers
replace the resin beads, and the used resin is dried and shipped offsite for burial in a licensed
low-level radwaste dump.

Braidwood plant, Illinois, 2005
The owner of the Braidwood nuclear plant in Illinois notified the NRC in December 2005
that tritium had been detected in a homeowner’s drinking well near the site. Further
investigation revealed several occasions over the prior ten years when more than six million
gallons of radioactively contaminated water leaked into the ground from the line intended to discharge that water into the river. About 250,000 gallons leaked in November 1996. About 3,000,000 gallons leaked in December 1998. Another 3,000,000 gallons leaked in November 2000. In June 2006, the NRC sanctioned the plant’s owner with a white finding for the failure to evaluate the potential radiation dose to members of the public from the large amount of radioactively contaminated water that went into their lands and drinking wells instead of into the river (NRC, 2006b).

The Braidwood spills caused significant financial harm to people. A representative of the
State of Illinois stated during the NRC’s groundwater protection workshop on April 20,
2010, that some residents were approaching retirement age and had plans to sell their
properties and use the proceeds to finance relocation to the retirement communities of their
lifelong dreams (Buscher, 2010). These plans were dashed when the specter of radioactive
contamination from the millions of gallons leaked from Braidwood sent real estate prices
spiraling downward. The NRC’s white finding was probably not much solace to those who
had their golden years tarnished by repeated leaks spanning a decade.

Dresden plant, Illinois, 2004
In August 2004, elevated tritium levels in monitoring wells at the Dresden nuclear plant in
Illinois triggered an investigation that led to the discovery of a leak in a buried pipe
connecting equipment in the plant with a large storage tank (UCS, 2006a). The plant’s owner estimated that about 267,000 gallons of radioactively contaminated water leaked into the ground. The Illinois Environmental Protection Agency reported that the leak  contaminated the local soil to more than 500 times the EPA limit for drinking water. The NRC found no violations and imposed no sanctions for this uncontrolled, unmonitored release of radioactively contaminated water.

NRC stopped enforcing regulatory requirements for releases of radioactively contaminated liquid after the massive Braidwood spills in 2005. The NRC has imposed no sanctions in response to the 27 accidental releases that have occurred over the past four years:

Just a sampling of more case studies:

LaSalle plant, Illinois, July 2010: Workers detected tritium concentrations of up to 700,000
picocuries per liter on the ground around the condensate storage tank.

Salem plant, New Jersey, April 2010: Workers detected tritium concentrations exceeding
1,000,000 picocuries per liter in the north storm drain system.

Vermont Yankee plant, Vermont, January 2010: The company informed the NRC about
tritium concentrations of up to 2,500,000 picocuries per liter in monitoring wells; workers
later discovered holes in two underground pipes.

Dresden plant, Illinois, June 2009: Workers detected tritium concentrations exceeded
3,000,000 picocuries per liter in a monitoring well near the condensate storage tank, and
tritium concentrations of 500,000 picocuries per liter in a nearby storm drain line.

Oyster Creek plant, New Jersey, April 2009: Workers detected tritium concentrations of over 100,000 picocuries per liter in water collecting in an underground cable vault; workers later identified the source of this contaminated water to be leaks in two separate buried pipes to and from the condensate storage tank.

Brunswick plant, North Carolina, March 2008: Workers detected tritium in 14 of 15
monitoring wells around the storm drain storage pond; samples from some monitoring wells
had tritium concentrations exceeding 30,000 picocuries per liter.

McGuire plant, North Carolina, February 2008: Approximately 100,000 gallons of
radioactively contaminated water leaked into the groundwater from a holdup pond.
River Bend plant, Louisiana, January 2008: Workers detected tritium concentrations of over
129,000 picocuries per liter in water leaking from a cooling tower pipe into a nearby creek
that empties into the Mississippi River.

And many leaks go undetected for years. From “Regulatory Roulette”, the 2010 publication of the Union Of Concerned Scientists, author David Lochbaum.

In Minnesota in 2012, a report was published stating she drinking water for 935,100 people in Minnesota could be at risk of radioactive contamination from a leak or accident at a local nuclear power plant, by the Environment Minnesota Research & Policy Center and the Minnesota Public Interest Research Group (MPIRG).

In 2013, in the State of Michigan, the news just got worse.

“Joseph Mangano, Executive Director of Radiation and Public Health Project, published a report, commissioned and endorsed by Beyond Nuclear, Don't Waste Michigan, Michigan Safe Energy Future, and Nuclear Energy Information Service. Based on government data and documentation on radioactivity releases from Palisades, as well as area health statistics, the report's major findings raise serious questions about the connections between radioactivity releases and increased overall death and cancer mortality rates.”
http://www.beyondnuclear.org/tritium/

Nuclear Contamination And Health Risks From The Entergy Palisades Nuclear Reactor
As stated in the press release:
"...Mangano’s main findings include that the Van Buren County death rate from all causes was 3 to 6 percent below the state in the 1970s and early 1980s, but has risen since, to a level 12.5% greater than Michigan (2003-2010). This change suggests that 1,330 “excess” deaths have occurred in the county since the Palisades atomic reactor started operating in 1971. Elevated levels were observed for all age groups (especially children/young adults), both genders, and all major causes of death...".
http://www.beyondnuclear.org/tritium/

According to the 2012 report, “Too Close to Home: Nuclear Power and the Threat to Drinking Water,” the drinking water for 49 million Americans is within 50 miles of an active nuclear power plant – the distance the Nuclear Regulatory Commission uses to measure risk to food and water supplies. Major cities, including New York, Boston, Philadelphia, San Diego, Cleveland and Detroit receive their drinking water from sources within 50 miles of a nuclear plant.
http://www.environmentamerica.org/news/ame/nuclear-power-plants-threaten-drinking-water-49-million-americans

“Routine tritium releases from operating nuclear power plants is one of the largest sources of radiation emissions from existing reactors, yet it is not subject to stringent monitoring and review requirements by the NRC,” said Christina Mills, a scientist with the Institute for Energy and Environmental Research. “Because tritium can create radioactive water, it can enter the local groundwater and drinking water supplies, exposing local communities to increased risks of cancer and other health impacts. This report helps bring to light the threats to millions of Americans from these routine and other non-routine releases of radioactivity at nuclear reactors across the U.S.”

Just the tip of the iceberg!

Sunshine And Wind, No Releases, No Contamination Of Surface Or Groundwater

11.25.14 Topaz, the Largest Solar Plant in the World, Is Now Fully Operational

Late last month, the Topaz Solar project achieved full commercial operation with the completion of its final 40-megawatt (AC) phase. This is the first 500-megawatt plus solar farm to come on-line in the U.S. and the largest solar plant on-line in the world. Two years ago, the millionth First Solar (FSLR) solar module was installed at the power plant owned by MidAmerican Solar. The project has installed 9 million solar panels across 9.5 square miles in San Luis Obispo County on California's Carrizo Plain. Construction began in 2012 and was expected to be complete in early 2015.
http://www.seia.org/news/topaz-largest-solar-plant-world-now-fully-operational

But the EPA Clean Power Plan - Proposed Power Plant Rule favors nuclear generation of electricity over wind and solar installations.

Comments open until December 1, 2014

Between now and December 1, there is a comment period for proposed rules limiting emissions from power plants. Unfortunately, the rules currently favor natural gas and nuclear electrical generating units (EGUs) over green renewables, thereby encouraging more fracking, and generating zero-emissions carbon credits from the nuclear (EGUs) for coal. In fact, if these rules go through as written, they could encourage unconventional natural gas development (fracking) burdening Americans with this toxic practice for decades to come. Consider the recent attacks by the fossil fuel industry on solar and wind. The EPA proposed ruling considers data on jobs in every energy sector except green renewables - solar and wind!
https://www.indybay.org/newsitems/2014/11/26/18764676.php

The green renewable energy job market scenario – is growing, adding long term employment at good wages! The solar industry continues to be an engine of job growth, creating jobs six times faster than the overall job market. The latest U.S. figures from The Solar Foundation, an independent research organization, show a 13 percent growth in high-skilled solar jobs spanning installations, sales, marketing, manufacturing and software development, bringing total direct jobs to 119,000 in the sector. DOE anticipates this robust growth to continue. SunShot Vision Study projections estimate that by 2030 more than a quarter million highly-skilled solar workers will contribute to the U.S. economy.

Clean Power Plan Nuclear Plants - Electrical Generating Units (EGUs)

“Low-and zero-carbon generating capacity provides electricity that can be substituted for generation from more carbon-intensive EGUs. More than half the states already have established some form of state-level renewable energy requirements, with targets calling on average for almost 20 percent of 2020 generation to be supplied from renewable sources. The EPA is unaware of analogous state policies to support development of new nuclear units, but 30 states already have nuclear EGUs (with five units under construction) and the generation from these units is currently helping to avoid CO 2 emissions from fossil fuel-fired EGUs.”

“Policies that encourage development of renewable energy capacity and discourage premature retirement of nuclear capacity could be useful elements of CO 2 reduction strategies and are consistent with current industry behavior.”

Atomic Cap And Trade: Whiners And Profit Motives

The Nuclear Industry Is Already Whining As A Chorus Of Virginia Lawmakers Complain:
Proposed EPA Rules Penalize States For Nuclear Energy Capacity
11/20/2014 Associated Press

RICHMOND, Va. “State lawmakers expressed concern on Wednesday 11.19.2014 that proposed federal regulations to cut carbon emissions from power plants will hurt Virginia's economic competitiveness. The Senate and House held a joint committee meeting Wednesday to hear from state officials, energy companies and environmentalists on the U.S. Environmental Protection Agency's Clean Power Plan.”

“Lawmakers said the EPA's current target levels for emission cuts penalize Virginia for its robust nuclear energy production. The zero-emission nuclear energy production accounts for 40 percent of the electric energy produced in Virginia and went on to state that the EPA proposed power plant rule target rate of carbon emissions per megawatt hour of energy production is unfair for Virginia in light of the higher target rates the federal agency has set for neighboring states that are more dependent on coal-fired gas plants.”

“The EPA has set a 2030 target of 810 pounds of carbon dioxide emitted per megawatt hour of electricity generated in Virginia, compared to 1,620 in West Virginia and 1,763 in Kentucky. "What they've done is said, "Hey, you're better off if you'd been polluting the hell out of the place,'" said Sen. Richard L. Saslaw, D-Fairfax County.

Sounds to me like Virginia wants the option of selling the extra carbon credits (were the State to have a higher target rate of carbon emissions allowed) to neighboring coal-fired units.

Deadline for comments - Monday December 1, 2014 – end of comment period for the EPA Clean Power Plan proposed rules limiting emissions from existing power plants. Unfortunately, the rules currently favor natural gas over green renewables, and thereby encourage more fracking. In fact, if these rules go through as written, they could encourage dozens of its power plants to switch to gas, shackling Americans to this toxic practice for decades to come.

This is a really, really good analysis on the subject. “EPA Clean Power Plan Underestimates Power of Renewable Energy to Reduce Carbon Emissions”
http://blog.cleanenergy.org/2014/10/17/epa-clean-power-plan-underestimates-power-of-renewable-energy-to-reduce-carbon-emissions/

The EPA states in it's request for comments: “that this rulemaking overlaps in certain respects with two other related rulemakings: The January 2014 proposed rulemaking that the EPA published on January 8, 2014 for CO 2 emissions from newly constructed affected sources, and the rulemaking for modified and reconstructed sources that the EPA is proposing at the same time as this rulemaking for existing sources of pollution. Each of these three rulemakings is independent of the other two, and each has its own rulemaking docket.”

“Accordingly, commenters who wish to comment on any aspect of this rulemaking, including a topic that overlaps an aspect of one or both of the other two related rulemakings, should make those comments on this rulemaking.”

Comments on the Clean Power Plan Proposed Rule must be received by December 1, 2014.

Make it easy on yourself!

Individuals, can sign-on to one of these actions:

Center for Biological Diversity
http://org.salsalabs.com/o/2167/p/dia/action3/common/public/?action_KEY=16490

Environmental Action
http://bit.ly/Un-FrackIt

Food & Water Watch
https://secure3.convio.net/fww/site/Advocacy

Friends of the Earth
http://action.foe.org/p/dia/action3/common/public/…

MoveOn
http://petitions.moveon.org/sign/climate-change-solutions/…

Public Citizen
http://action.citizen.org/p/dia/action3/common/public/…

Organizations, can sign-on to this letter:
http://bit.ly/OrganizationalSignon

If you are making your own comments to the EPA, be sure to reference:
Docket ID: EPA-HQ-OAR-2013-0602

Following the EPA instructions; copy and paste this link into your browser's address bar, and use the COMMENT button provided.
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001

Email: A-and-R-Docket [at] epa.gov

Fax: Fax your comments to: 202-566-9744.

Gina McCarthy, Administrator
U.S. Environmental Protection Agency
Email: A-and-R-Docket [at] epa.gov
Fax: 202-566-9744.
Comments on the Clean Power Plan Proposed Rule
Include Docket ID No. EPA-HQ-OAR-2013-0602 in the subject line of the message

When writing your own comments use an opening such as;
“I am submitting these comments in response to the administration's proposed rule for carbon emissions at existing power plants Docket ID: EPA-HQ-OAR-2013-0602”

Dear President Obama, EPA Administrator McCarthy
RE: Clean Power Plan for existing power plants Docket ID EPA-HQ-OAR-2013-0602

Tomas DiFiore

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STEAM INJECTION IS LITERALLY GLOBAL WARMING
constant comments, and informative research links;
http://banslickwaterfracking.blogspot.com/

Tomas DiFiore

Labels: EPA Clean Power Plan Low-and Zero-carbon Generating Capacity Nuclear Power Plants Radioactive Contamination Of Ground And Surface Waters Tritiated water Tritium Tritium Dead Aquifers