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Fermi 3 Comments for Environmental Impact Review by NRC
January 14, 2009
Sandy Bihn
Western Lake Erie Waterkeeper
Western Lake Erie Association

Comments for hearing may be supplemented by additional written comments.

When the permit for Davis Bess was granted, the Ohio Sea Grant people made the following statement:
"No new plants(power) should be constructed anywhere in the Western Basin of the Lake(Erie).  If these suggestions are followed, new plants can be constructed on Lake Erie Without harming the valuable and growing fishery."  J.M. Reutter and C.E. Herdendorf, Environmental Impact Appraisal of the Davis Besse Nuclear Power Plant 1979
Since the statement clearly says that no new power plants should be constructed in Western Lake Erie, then the only place that new power plants should be considered would be in the Central and Eastern Basins of Lake Erie.
The Fermi 3 nuclear power plant is planned to be located in the shallowest, fishiest waters of Lake Erie and the Great Lakes.  Lake Erie has more consumable fish than all the other Great Lakes combined and a majority of Lake Erie’s fish are in the Western Basin of Lake Erie(which includes Maumee Bay and the Maumee River).  The average depth of Lake Erie in the area of the plant is but 24’ and the average depth of the Maumee Bay estuary is only 5’.  The proposed Fermi 3 nuclear power plant would draw up to 49million gallons of water a day from Lake Erie and Maumee Bay and kill millions more fish.  Fermi 3 would be the 6th power plant killing more fish and heating more water causing 
added ecological impacts on already stressed green waters.  When I was driving down traveling on Bayshore Rd. last night, I could visibly see the Consumer’s Whiting Plant, the DTE Monroe Plant, Fermi 2, First Energy Bayshore and the smoke from Davis Besse.  Obviously, the plants are within a 20 mile radius and the use of the water, fish kills and thermal plumes from the power plants impact the shallow waters of Lake Erie and Maumee Bay. Please have DTE analyze and report on these facts and the following comments in the Environmental Impact Statement:

1.  Climate change is predicted to decrease water levels in Lake Erie from a little less than 3' to up to 6' in the next 60 - 70 years.  Predicted decreases in water levels would literally mean that there would be no water in Maumee Bay which is water that is used by other power plants and proposed for Fermi 3.  Climate change projected impacts on Western Lake Erie and projected decreasing Lake Erie water levels should be part of the environmental review.
2.  The application says there are no estuaries near the plant.  This is not true. The shallow fishy average 5’ depth Maumee Bay estuary exists west of the plant and needs to be assessed as part of the environmental impact study.
3.  The cumulative impact of fish kills from the five existing power plants and the impacts of adding Fermi 3 should be assessed.  There needs to be a determination of the cumulative impacts of the fish kills at the existing five operating power plants in the far Western Basin of Lake Erie and Maumee Bay and then a determination of how many more fish Fermi 3 would kill and what the impacts on the fishery and aquatic life would be. 
4.  The Environmental Impact analysis should likewise determine the impact to the ecosystem from heating the billions of gallons at the existing operating five power plants.  Then a determination should be made on the impacts of the up to 49 million gallons of additional heated discharge waters from the proposed Fermi 3.  The application uses all of Lake Erie as the source of water available and impacted when in fact the waters used and needed for the plant lie entirely with the Western Basin of Lake Erie.  The assessment needs to look at water quantities in Western Lake Erie and Maumee Bay – not all of Lake Erie.  Western Lake Erie holds only 5% of the volume of Lake Erie.
5. The Environmental Impact should look at mitigation if this permit is to be allowed at the DTE Monroe’s Coal Fired Power Plant, the 4th largest power plant in the U.S.  Water use, thermal impacts, fish kills and mercury and other emissions to at the nearby Monroe coal fired power plant should be mitigated as part of this permit to reduce the 1.9 billion gallons of day of water used by DTE at this plant.  Mitigation should require installing a cooling tower  and mercury pollution control equipment at the Monroe plant if Fermi 3 is to get a permit.
6.  The Environmental Impact should assess the risk of an attack on the power plants in the area and the impacts on the water and the population.  What is a fair level of risk from so many power plants to the water and population?  How much power does this area need to generate to serve the population and businesses in Southeast Michigan and Northwest Ohio?  Is there a point where the area is saturated with power plants and additional power plants should be located elsewhere?
7.  The environmental impact statement should also assess the impact on sediments and water quality by adding a 6th power plant  to the existing three coal fired power plants and two nuclear power plants in the Western Basin of Lake Erie.  Sediments and water quality in the areas of the existing coal fired power plants and nuclear plants should be assessed for radiation, mercury and other pollutants and then the estimated additional impacts from the proposed Fermi 3 to the sediments and the water should be added.  What percentage of water in Maumee Bay is currently used by the existing power plants and how much more would be used by Fermi 3? (Assess the % with the climate change estimated reductions of 3’ to 6)
8.  The application talks about the influence of the Detroit River on Toledo's water intake and then fails to include the Toledo water intake in its environmental analysis.  This analysis needs to be conducted as part of the environmental assessment. 

9.  The application does not mention the practice of open lake dumping up to 800,000 cubic yards of sediments by the Army Corps of Engineers for the Toledo shipping channel.  The turbidity from the open lake dumping would impact the intake of Fermi 3 and should be reviewed.
10.  The application uses phosphorous data from 1997 – 2003 and says phosphorous(algal blooms) is not a problem.  Not true.  Research clearly shows that since 1995 dissolved phosphorous and algal blooms including microcyctis, in the Maumee River and Western Lake Erie are increasing.  Ohio EPA has a Phosphorous Task Force trying to find ways to reduce the increasing green waters.  The Lake Erie Protection Fund and the USEPA Great Lake’s office are currently seeking grant proposals to find ways to reduce phosphorous and algal blooms in Western Lake Erie.   The environmental assessment needs to include impacts on phosphorous and nutrient growth and algal blooms from the thermal use of up to 49 million gallons a day.
11.  A new form of algae – lyngbya wollei – is in Maumee Bay and Western Lake Erie.  This benthic algae is spreading in Maumee Bay and Western Lake Erie.  It appears that the lyngbya thrives in what is known at Warm Water Bay at DTE’s Monroe coal fired 1.9 billion gallons per day warm water discharge.  The warm water combined with the sewage from the River Raisin appear to provide the ideal environment for lyngbya to thrive.  What will the impact of Fermi 3 be on the spread of lynbya?  Should DTE be required to do mitigation at the Monroe coal fired plant because of the lyngbya problem?
12.  The application only looks at Monroe County for Surface Water – the surface water analysis should include Lucas(Ohio), Ottawa(Ohio), Monroe(Michigan) and Wayne(Michigan). 
13. The fish impingement/entrainment discussion needs to be updated from  Fermi 2 estimates.  The assessment needs to look at the cumulative impact of adding one more fish killing source.. and the decreasing yellow perch populations and the increased controls on commercial fishermen in Ohio.  The environmental assessment should include these factors.
14.  The impact on keeping the shoreline from freezing and mixing zones caused by thermal impacts should be assessed.  Also, the extent and overlapping of the mixing zones at existing power plants from thermal impacts and the proposed Fermi 3 should be mapped and reviewed.  This assessment should include the amount of shoreline that is kept from freezing from existing power plants and the additional amount.  Mitigation should be required for additional impacts.
15.  An EIS should include an assessment of alternate sites and a no build.  Consumers Power evaluated the site they have here in the Western Lake Erie watershed and instead chose Midland, Michigan.  It is hard to imagine that given the shallow fishy waters of Western Lake Erie already burdened by water use from three coal fired power plants and two nuclear plants, that other locations would be a better choice for minimizing water and environmental impacts.  Simply put, this is the wrong location for a power plant.  These waters are already green again and limits on fish catches are in place because of dwindling quantities.  These waters can simply not afford another hit of 498 million gallons a day .

Advisory BoardResearch Associates
Rosalie Bertell, PhD, GNSHAgnes Reynolds, RN
Samuel S. Epstein, MDJanette Sherman, MD
William Reid, MDSusanne Saltzman, MD

The following is a statement by Joseph J. Mangano
Joseph J. Mangano, MPH, MBA, is Director, Secretary, and the Executive Director of the Radiation and Public Health Project.
Mr. Mangano is a public health administrator and researcher who has studied the connection between low-dose radiation exposure and subsequent risk of diseases such as cancer and damage to newborns.
He has published numerous articles and letters in medical and other journals in addition to books, including Low Level Radiation and Immune System Disorders: An Atomic Era Legacy. There he examines the connection between radiation exposure and current widespread health problems.


January 14, 2009 - The cancer death rate in Monroe County has been rising since the late 1980s, when the Fermi 2 nuclear reactor began operating, according to a new analysis.

The rise in cancer has been sharpest among children and adolescents, who are most susceptible to the harmful effects of radiation exposure.  The analysis uses official data from the U.S. Centers for Disease Control and Prevention.

"The increasing cancer death rate among Monroe County residents, especially young people, suggests a link with the radioactive chemicals emitted from the Fermi reactor," says Joseph J. Mangano MPH MBA, Executive Director of the Radiation and Public Health Project research group.  "Because Monroe County has a low risk population that is well educated, high income, and has few language barriers, rising cancer rates are unexpected, and all potential causes should be investigated by health officials."

Fermi 2 reactor began “operating” June 21, 1985. However, it ran very little after the initial low-power start-up until a warranty run in January of 1988, marking the commercial start-up of the reactor.  In the early 1980s, the Monroe County cancer death rate was 36th highest of 83 Michigan counties, but by the early 2000s, it had moved up to 13th highest.  From 1979-1988, the cancer death rate among Monroe County residents under age 25 was 21.2% below the U.S. rate.  But from 1989-2005, when Fermi 2 was fully operational, the local rate was 45.5% above the U.S.

All nuclear reactors produce electricity by splitting uranium atoms, which creates high energy needed to heat water.  This process also creates over 100 radioactive chemicals, not found in nature, including Strontium-90, Cesium-137, and Iodine-131.

While most of these chemicals are retained in reactors and stored as waste, a portion is routinely released into the local air and water.  They enter human bodies through breathing and the food chain, and raise cancer risk by killing and injuring cells in various parts of the body.  They are especially harmful to children.

The findings come at a time when a new nuclear reactor has been proposed at the Fermi plant.  The original Fermi 1 reactor, which was the site of a “Partial Core-Melt Accident” in 1966, shut permanently in 1972.


- The Fermi 2 reactor is located in Monroe County, and started on June 21, 1985, not becoming fully operational until January 1988.

- Fermi 2 came close to a meltdown on March 28, 2001 and August 14, 2003. (1)

- Fermi 2, like all reactors, routinely emits over 100 radioactive chemicals into air and water.

- Each of these chemicals causes cancer, and is most harmful to infants and children.

- For cancer deaths for all ages (whites only), Monroe County ranked
36th highest of 83 Michigan counties in 1979-1983 (before startup)
13th highest of 83 Michigan counties in 2000-2005 (latest data) (2)

- The Monroe County cancer death rate age 0-24
was 21.1% below the U.S. in 1979-1988 (before/during startup)
  was 45.5% above the U.S. in 1989-2005 (after startup) (3)

Monroe County has no obvious cancer risk.  It has a high income, low poverty, well educated population with few language barriers and access to excellent medical care in nearby Detroit. (4)  Thus, an increase in cancer (especially to children) is unexpected.  This change should be investigated, and one potential cause should be radioactive emissions from Fermi.

1. Fermi 2 incurred “near miss” accidents on March 28, 2001 (emergency diesel generator was inoperable for over 7 days) and August 14, 2003 (loss of offsite power due to northeast blackout).  Source: Greenpeace USA.  An American Chernobyl: Nuclear “Near Misses” at U.S. Reactors Since 1986., April 26, 2006.

2.  U.S. Centers for Disease Control and Prevention,, underlying cause of death.  Death rates are adjusted to 2000 U.S. standard population.  Includes ICD-9 codes 140.0-239.9 (1979-1983) and ICD-10 codes C00-D48.9 (2000-2005).  Whites account for over 95% of Monroe residents.

3. Cancer Death Rates, Monroe County vs. U.S.
1979-1988 and 1989-2005, age 0-24

Monroe CountyDeaths/100,000 Pop.
PeriodCancer DeathsAvg. Pop.  Monroe    U.S.  %vs. US
1979-198822                 56,2343.91 4.96- 21.2%
1989-200542                 51,4074.86 3.79+45.5%

Source: U.S. Centers for Disease Control and Prevention,, underlying cause of death.
Includes ICD-9 codes 140.0-239.9 (1979-1983) and ICD-10 codes C00-D48.9 (2000-2005). Increase in rate significant at p<.05.

4. Demographic Comparison, Monroe County vs. U.S.

Indicator                   MonroeU.S.
2006   Population             155,035299,398,484
2000   % Foreign Born          1.911.1
2000   % Language other than English  4.017.9
spoken at home, age 5+
2000   % High School graduates, age 25+     83.180.4
2000   % Homeownership             81.066.2
2004   Median Household Income       $53,838$44,344
2004   % Below Poverty                 8.712.7

Source: U.S. Census Bureau,, 2000 population, State and County Quick facts

If you would rather not download the file, it is in plain text below. Be sure to scroll down to the blue page text of an environmental statement by S.Bihn.
Great resources on uranium compiled by:

Paul Robinson, Research Director,
Southwest Research and Information Center
PO Box 4524
Albuquerque, NM USA 87196-4524
phone: 505-262-1862 fax: 505-262-1864
web site:
ROUTINE RELEASES --- tritium AND noble gases.   -- Jan. 2009  
Some notes from Kay Drey, a board member of Beyond Nuclear, Takoma Park MD.

To quote from the pamphlet:  “Routine Radioactive Releases from Nuclear Power Plants in the United States --- What are the Dangers?”   [ Beyond Nuclear – 2009, and NIRS – 2005 ] 

    “Radioactive releases from a nuclear power reactor’s routine operation often are not fully detected or reported.  Accidental releases may not be completely verified or documented.  Accurate, economically-feasible filtering and monitoring technologies do not exist for some of the major reactor by-products, such as radioactive hydrogen (tritium) and noble gases, such as krypton and xenon.  . . .  Government regulations allow radioactive water [and gases] containing ‘permissible’ levels of contamination to be released to the environment.  Permissible does not mean safe.   . . .  The Nuclear Regulatory Commission relies upon self-reporting and computer modeling from reactor operators to track radioactive releases and their projected dispersion.  A significant portion of the environmental monitoring data is extrapolated -- it’s virtual, not real.”

It’s important, I think, for the public to know that radioactive waste products not only can leak from nuclear reactors, but they are also contained in planned and unplanned releases to the atmosphere and (dissolved) to the reactor’s cooling water source ---  the river, lake or ocean. 

Since there is no economically feasible technology to filter out tritium and noble gases from a nuclear reactor’s liquid and gaseous releases, the U.S. Nuclear Regulatory Commission does not require that they be filtered.    For example:

Noble gases:    Krypton-89 and -90 that become rubidium, and then strontium-89 and -90 --- and
                        Xenon-137 that becomes cesium-137.  Xenon-135 becomes cesium-135.

Strontium-90 and cesium-137 were two of the three most-often-discussed, most radiotoxic isotopes in atmospheric atom bomb test fallout.  (The third was iodine-131, also a reactor fission product.)  Cesium-135 has a 2.3-million-year half-life.

Nuclear power plants cannot operate without regular, deliberate releases of radioactive water and gases.  The releases from the reactor building are needed to control the pressure, temperature and humidity and to keep radioactivity from exceeding government limits for workers.

Think of water boiling in a kettle.  The escape of steam relieves pressure inside.  A nuclear power plant operates in much the same way:  hot, radioactive gases inside the reactor building must be purged or vented* into the atmosphere.  This is done through the vents that are built into the building.  The vents have filters that stop some of the radioactive gases and particulates from being released. 

Purged is when a fan is used to push the atmosphere from a Reactor Building.  

Vented is when a valve is opened to allow internal pressure to push out the atmosphere from within the Reactor Building.  Most people do not know that a pressurized water reactor Containment Building comes complete with a vent in its roof.                                                                          

#  #  #


Cancer questions grow around Fermi nuclear plant

State health report shows 31 percent increase in cancer rate among young people in Monroe County since 1996
Dedicated to stopping another nuclear reactor
Warning to Taxpayers, Investors: Nukes May Become Troubled Assets

Part Two in a Series on a New Nuclear Cost Study

By Joseph Romm | January 7, 2009

Nuclear plants with such incredibly expensive electricity and “out of control” capital costs, as Time put it, obviously create large risks for utilities, their investors, and, ultimately, taxpayers. Congress extended huge loan guarantees to new nukes in 2005, and the American people will be stuck with another huge bill if those plants join the growing rank of troubled assets (see “ Nuclear energy revival may cost $315 billion, with taxpayers’ risking over $100B”).

The risk to utilities who start down the new nuke path is also great. A June 2008 report by Moody’s Investor Services Global Credit Research, “New Nuclear Generating Capacity: Potential Credit Implications for U.S. Investor Owned Utilities” (PR here), warned that “nuclear plant construction poses risks to credit metrics, ratings,” concluding:

The cost and complexity of building a new nuclear power plant could weaken the credit metrics of an electric utility and potentially pressure its credit ratings several years into the project, according to a new report from Moody’s Investors Service....

Moody’s suggests that a utility that builds a new nuclear power plant may experience an approximately 25% to 30% deterioration in cash-flow-related credit metrics.

And this would likely result in a sharp downgrading of the utility’s credit rating.

The application by Florida Power & Light (FPL) for a large nuclear plant came in at a stunning $12 to $18 billion, and the utility concedes that new reactors present “unique risks and uncertainties,” with “every six-month delay adding as much as $500 million in interest costs.”

The report Climate Progress published this week, " Business Risks and Costs of New Nuclear Power" by power-plant cost expert Craig Severance, has an extended discussion of the business risks to utilities and hence investors:

In its 2003 study “The Future of Nuclear Power”, MIT included a 3% risk premium in its calculations of projected Cost of Capital for nuclear projects, because of the extra business risks projected for nuclear. MIT’s concerns were valid.

Florida Power & Light has stated: “In general, the rating agencies (such as Moody’s Investor Services) view new nuclear construction as a higher risk than other technologies. This view is primarily driven by the long approval and construction process associated with new nuclear construction as well as the size of the capital requirements in relation to the utility as compared to capital requirements for other generation technologies. Rating agencies also recall the difficulties of the 1970’s and 1980’s.”

On June 2nd of this year, Moody’s Investor Services Global Credit Research issued a public announcement entitled “Moody’s: Nuclear Plant Construction Poses Risks to Credit Metrics, Ratings.” Per the Announcement: “Moody’s examines the effects of a new nuclear facility on the credit metrics of “NukeCo”, a hypothetical electric utility. Through this illustrative model, Moody’s suggests that a utility that builds a new nuclear power plant may experience an approximately 25% to 30% deterioration in cash-flow-related credit metrics. In the case of “NukeCo”, cash flow from operations as a percentage of debt falls from roughly the 25% level to the mid-teens range.”

The Moody’s simulation begins with the fictional utility “well-positioned within the single-A ratings category before building a nuclear plant....”, however “ ... in years 5-10, when construction costs reach their peak and key credit metrics begin to deteriorate significantly, the fictional company would be better positioned in Baa-rating category.”

In today’s nervous credit climate, downgrading a corporation to a more risky Baa rating (the lowest tier of investment grade debt) may carry serious consequences. Moody’s Seasoned Baa Corporate Bond Yield: Percent [], shows that in October 2008, the Baa yield climbed to 8.88 percent, compared to only 7.31 percent in September 2008, the highest relative monthly jump since the table began in 1919, indicating investors have extreme default risk concerns. The fact a Baa bond will have a higher effective interest rate is not even the biggest concern. The very ability to sell downgraded bonds in a credit market already termed “dysfunctional” may be the more critical factor.

The Moody’s Announcement also notes a risk to the shareholders of the utility: “The technology is very costly and complex, and the 10- to 15-year duration of these construction projects can expose a utility to material changes in the political, regulatory, economic and commodity price environments, as well as new alternatives to nuclear generation. These potential changes in the landscape could prompt regulators to disallow certain cost recoveries from ratepayers after a plant is built, or lead to market intervention or restructuring initiatives by elected officials.”

Industry commentators have also noted these financial risks. Nuclear Engineering International noted on 22 August 2008: “Companies that build new nuclear plants will see marked increases in their business and operating risks because of the size and complexity of these projects, the extended time they take to build, and their uncertain final cost and cost recoveries. To the extent that a company develops a financing plan that overly relies on debt financing, which has an effect of reducing the consolidated key financial credit ratios, regardless of the regulatory support associated with current cost recovery mechanisms, there is a reasonably high likelihood that credit ratings will also decline. So ‘thinking caps’ must now certainly go on amongst US boards of management — credit ratings are important and taking a punt on a new nuclear plant may not be the first priority of a CEO in his late 50s with a distinguished career behind him.”

Severance’s conclusion:

Credit ratings are very important. The prospect that undertaking a single project could have such a major impact on a utility company’s balance sheet and cash flow that company credit ratings would be downgraded, should give pause to any executive, or oversight regulator, contemplating the wisdom of undertaking such a project.

The full study is here.

Part One: The Staggering Cost of New Nuclear Power

Part Two: Warning to Taxpayers, Investors: Nukes May Become Troubled Assets

This article was originally published in Climate Progress.


Most people do not understand how much radiation is given off from radionuclides that are released intentionally or unintentionally. Many releases are simply not reported, or under reported. However, of those reported, it doesn't sound like much when the figure released is 1.54 E-0l curies. It's sounds like a NEGATIVE number! So here is the mighty becquerel conversion factor. 

One becquerel = one disintegration per SECOND = 27 picocuries. picocuries-conversion.html

one picocurie = 2.22 disintegrations per MINUTE = 0.037 disintegrations per SECOND = 0.037 becquerels

one curie = 37 billion becquerels.

So, for example:   1.54 E-01 curies = 0.154 curies = 154,000,000,000 picocuries = 5.7  billion becquerels or 5.7 billion disintegrations per second!

one becquerel = one disintegration per second

one curie = 37 billion disintegration per second = 37,000,000,000 

one picocurie = one-trillionth of a curie = 0.037 disintegrations per 
second = 0.037 bequerels

one picocurie = 2.22 disintegrations per MINUTE

one becquerel = 27 picocuries.
one becquerel = one disintegration per SECOND = 27 picocuries.

The NRC and DOE should release all their findings in becquerels!

Reports should also contain accurate measures for bioaccumulation in the environment. A complete and accurate record should account for each release in addition to previous releases.


The Staggering Cost of New Nuclear Power

Part One in a Series on a New Nuclear Cost Study

By Joseph Romm | January 5, 2009

Part One: The Staggering Cost of New Nuclear Power
Part Two: Warning to Taxpayers, Investors: Nukes May Become Troubled Assets

A new study puts the generation costs for power from new nuclear plants at 25 to 30 cents per kilowatt-hour—triple current U.S. electricity rates!

This staggering price is far higher than the cost of a variety of carbon-free renewable power sources available today—and 10 times the cost of energy efficiency (see “ Is 450 ppm possible? Part 5: Old coal’s out, can’t wait for new nukes, so what do we do NOW?”

The new study, “ Business Risks and Costs of New Nuclear Power,” is one of the most detailed cost analyses publicly available on the current generation of nuclear power plants being considered in this country. It is by a leading expert in power plant costs, Craig A. Severance. A practicing CPA, Severance is co-author of The Economics of Nuclear and Coal Power (Praeger 1976), and former assistant to the chairman and to commerce counsel, Iowa State Commerce Commission.

This important new analysis is being published by Climate Progress because it fills a critical gap in the current debate over nuclear power—transparency. Severance explains:

All assumptions, and methods of calculation are clearly stated. The piece is a deliberate effort to demystify the entire process, so that anyone reading it (including non-technical readers) can develop a clear understanding of how total generation costs per kWh come together.

As stunning as this new, detailed cost estimate is, it should not come as a total surprise. I detailed the escalating capital costs of nuclear power in my May 2008 report, “ The Self-Limiting Future of Nuclear Power.” And in a story last week on nuclear power’s supposed comeback, Time magazine notes that nuclear plants’ capital costs are “out of control,” concluding:

Most efficiency improvements have been priced at 1¢ to 3¢ per kilowatt-hour, while new nuclear energy is on track to cost 15¢ to 20¢ per kilowatt-hour. And no nuclear plant has ever been completed on budget.

Time buried that in the penultimate paragraph of the story!

Yet even Time’s rough estimate is too low, as “ Business Risks and Costs of New Nuclear Power” quantifies in detail. Here is the executive summary:

It has been an entire generation since nuclear power was seriously considered as an energy option in the U.S. It seems to have been forgotten that the reason U.S. utilities stopped ordering nuclear power plants was their conclusion that nuclear power’s business risks and costs proved excessive.

With global warming concerns now taking traditional coal plants off the table, U.S. utilities are risk averse to rely solely on natural gas for new generation. Many U.S. utilities are diversifying through a combination of aggressive load reduction incentives to customers, better grid management, and a mixture of renewable energy sources supplying zero-fuel-cost kWh’s, backed by the KW capacity of natural gas turbines where needed. Some U.S. utilities, primarily in the South, often have less aggressive load reduction programs, and view their region as deficient in renewable energy resources. These utilities are now exploring new nuclear power.

Estimates for new nuclear power place these facilities among the costliest private projects ever undertaken. Utilities promoting new nuclear power assert it is their least costly option. However, independent studies have concluded new nuclear power is not economically competitive.

Given this discrepancy, nuclear’s history of cost overruns, and the fact new generation designs have never been constructed any where, there is a major business risk nuclear power will be more costly than projected. Recent construction cost estimates imply capital costs/kWh (not counting operation or fuel costs) from 17-22 cents/kWh when the nuclear facilities come on-line. Another major business risk is nuclear’s history of construction delays. Delays would run costs higher, risking funding shortfalls. The strain on cash flow is expected to degrade credit ratings.

Generation costs/kWh for new nuclear (including fuel & O&M but not distribution to customers) are likely to be from 25 - 30 cents/kWh. This high cost may destroy the very demand the plant was built to serve. High electric rates may seriously impact utility customers and make nuclear utilities’ service areas noncompetitive with other regions of the U.S. which are developing lower-cost electricity.

I am not saying here that nuclear power will play no role in the fight to stay below 450 ppm of atmospheric CO2 concentrations and avoid catastrophic climate outcomes. Indeed, I have been including a full wedge of nuclear in my 12 to 14 wedges “solution” to global warming here. It may, however, be time to reconsider that, since it is increasingly clear achieving even one wedge of nuclear will be a very time-consuming and expensive proposition, probably costing $6 trillion to $8 trillion and sharply driving up electricity prices.

Given the myriad low-carbon, much lower-cost alternatives to nuclear power available today—such as efficiency, wind, solar thermal baseload, solar PV, geothermal, and recycled energy (see “ An introduction to the core climate solutions”)—the burden is on the nuclear industry to provide its own detailed, public cost estimates that it is prepared to stand behind in public utility commission hearings.

What is unique about this new analysis is its transparency: “all assumptions, and methods of calculation are clearly stated.” As Severance explains:

In contrast to this transparency, many nuclear promoters have adopted a “Black Box” approach. It has unfortunately been the case over the last couple of years that some utilities have begun to claim that even rudimentary basics of their nuclear cost estimates must be hidden from the public as “trade secrets.” For instance, in the South Carolina Electric & Gas proposal to build two reactors now under consideration by the South Carolina PSC, there is literally a large “box” obscuring the bulk of the calculations in the SC E&G Exhibit which presents the utility’s projection of construction and financing costs for the proposed two-unit facility. In a different case, Duke Energy claimed that it does not even have to disclose its new cost estimates for a proposed nuclear facility in Cherokee County, S.C.. In the Duke case, C. Dukes Scott, South Carolina’s consumer advocate, who represents the public in utility rate cases, noted, “If the cost wasn’t confidential in February,” Scott said, “how is it confidential in April?”

Even when no effort to conceal information is apparent, the very terminology used when projections are presented can be confusing or misleading. For instance, in 2007 when a number of new nuclear proposals began to advance, it was common for “Overnight Cost” estimates to be quoted. For a project (such as solar or wind) whose construction period may be as short as several months, the difference between an “overnight” cost and the full cost to complete the project may not be significant. However, for a nuclear project that may typically take a decade to complete, cost escalations that occur during this long construction period, plus the financing costs during construction, may easily double the total cost of a project compared to its “overnight” cost. When the full picture is presented, some may perceive the total cost estimate has mysteriously doubled. However, it simply should have been stated clearly to begin with that major escalation and financing costs cannot be avoided when it takes a long time to complete a project. Failure to do so is tantamount to selling someone a house with “teaser” initial mortgage payments and failing to make clear that the mortgage payments will later reset to a much higher level.

Another mysterious “black box” presentation method is to fold the overall costs of the new facility into the general rate base of the utility, without ever mentioning what the generation costs per kWh of the nuclear unit will be. Instead, it is often only presented how total costs per kWh for all ratepayers will increase—which includes kWh’s generated by existing generation units. (For instance, if a nuclear unit is to supply 20% of the kWh’s for the utility when it comes on line, any cost increase per kWh appears to only be 1/5 as large because the additional costs are also spread over the 80% of kWh’s generated by other facilities, even though those other facilities did not cause the rate increase.) While it is important to know the impact on final overall retail electric rates, it is also important to know the generation costs per kWh from the nuclear facility. If this step is “skipped” in public presentations, the nuclear units (or any new generation power source that is more expensive than existing units) can appear far cheaper than their real impact.

The Paper takes the approach that it is best to lay out in detail “how you got that number” at each step of the way. All parties can then proceed to have discussions based upon real numbers rather than mysterious “Black Box” secrets.

So feel free to criticize the analysis, but anyone offering different all-in cost estimates for power from new nuclear plants should detail their own assumptions and calculation. And simply pointing to the operating costs of existing paid-off nuclear plants doesn’t count as detailed analysis—my home would be very cheap to live in if I didn’t have a mortgage.

Also, it’s fine to call for aggressively developing fourth generation nuclear plants (as James Hansen does)—I’m all for such R&D—but that won’t help us meet 2020 climate targets, and probably won’t help us significantly meet 2030 targets. In any case, it is impossible to accurately project the real world all-in costs of noncommercial technologies that are still largely sitting on the drawing board.

Radionuclides are persistent toxic substances as summarized by the Nuclear Task Force of the International Joint Commission on Great Lakes Water Quality in its 1998 report.

The Nuclear Task Force of the International Joint Commission on Great Lakes Water Quality concluded the following in its Inventory of Radionuclides of the Great Lakes in 1998:


"Various facilities used in the fuel cycle for nuclear energy are the primary human source of radionuclides in the Great Lakes basin. There are 11 nuclear power plants with 16 reactors in the U.S. portion and four nuclear power plants with 21 reactors in the Canadian portion of the basin, all of which emit radionuclides to the basin. Other large sources include a tritium removal plant at Darlington, uranium mines and their mill tailings that enter the Serpent River region, and uranium refining and conversion at Blind River and Port Hope in the Ontario portion of the basin. Also included are weapons facilities and auxiliary operations at Ashtabula , Ohio in the U.S. portion of the basin.

        Commercial, industrial, medical and research institutions also use radionuclides in the Great Lakes basin. While these sources use small quantities of radioactive materials, they are numerous and the total quantities may contribute significantly to the burden of radioactive materials in the environment.

        The Task Force identified tritium, carbon-14, iodine-129, isotopes of plutonium and radium-226 as radionuclides that merit separate studies and further reporting because of their patterns of use and discharge; their physical, chemical and biological properties; and the special monitoring needs of lakes."

Because of the dangers of existing contamination and risks of catastrophic accidents and leaks, Michigan must take the lead in phasing out all nuclear reactors, monitoring and further studying of existing radioactive materials and devising effective containment and cleanup research and projects.


Nuclear Power: Hope or Hoax?
9-part series: Professor Gordon Edwards speaking at U of Alberta 2008