Testimony of
Norris McDonald
Founder and President
African American Environmentalist Association
On the
Draft
Environmental Impact Statement
for an
Early Site
Permit (ESP)
at the
Grand Gulf ESP
Site
Draft Report for Comment
[NUREG 1817]
Presented to the
U.S. Nuclear
Regulatory Commission
Office of Nuclear Reactor Regulation
June 28, 2005
Introduction
My name is Norris McDonald and I am the founder and 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. AAEA supports the Early Site Permit (ESP) to build a new nuclear power plant at the Grand Gulf site.
AAEA supports the Nuclear Regulatory Commission (NRC)
staff recommendation, based on the draft environmental impact statement (DEIS),
that an ESP should be issued to System Energy Resources, Inc.(SERI) to build a
new nuclear power plant within the existing Grand Gulf Nuclear Station (GGNS). SERI submitted an ESP application on October
16, 2003 in accordance with 10 CFR 52.17(a)(2). If the ESP is approved, AAEA strongly urges SERI to submit a
combined license application in order to accelerate the construction and
operation of a specific NRC approved plant design.
AAEA expressed public support for nuclear power for
the first time in 2002 in Washington, D.C. after a two-year internal process of
studying and debating the issue. The fundamental reasons that AAEA supports
nuclear power are:
·
Nuclear power provides
electricity safely and reliably,
·
Nuclear power produces
no smog forming emissions,
·
Nuclear power produces
no greenhouse gases,
·
Spent fuel can be
reprocessed for reuse,
·
Yucca Mountain is
acceptable as a repository for non-recyclable products,
·
Nuclear power has an
excellent quarter century safety record, and
·
Nuclear power plants
can use nuclear bomb warhead material as a fuel.
Grand
Gulf is one of 102 other commercial nuclear power plants that provide 20
percent of our nation’s electricity needs and 27.2 percent of the electricity
generation in Mississippi. During
2000, Mississippi's nuclear power plants avoided approximately 58,000 tons of
sulfur dioxide emissions, 24,000 tons of nitrogen oxide emissions, and 2.47
million metric tons of carbon emissions.1
The plants also avoided emissions of mercury.
Avoiding these additional emissions is particularly important to areas
that are experiencing air quality problems due to traffic and industry.
The NRC quantified the environmental
impacts of this proposed action using the Council on Environmental Quality
(CEQ) guidance (40 CFR 1508.27) and established three levels of significance:
Small, Moderate, or Large. 2 A public hearing in Port Gibson, Mississippi
(Claiborne County), location of the GGNS, provides stakeholders and NRC staff
with an opportunity to discuss the DEIS.
AAEA’s comments in this statement are limited to the environmental
justice issues included in the DEIS.
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 was among
the participants at the U.S. Environmental Protection Agency in 1991 when
environmental justice polices were first being considered by the agency. AAEA is currently promoting environmental
justice locally, regionally and nationally.
The NRC adopted a specific numerical process in the
DEIS for defining minority populations. 4 The NRC also eliminated environmental
justice in the Atomic Licensing Safety Board process maintaining that it would
be adequately addressed in the National Environmental Policy Act (NEPA) process
(see 69 FR 52040). The DEIS addresses
environmental justice issues.
Charges of environmental racism will be injected into
these proceedings. We believe the
charge is inaccurate and unfair.
Entergy owns and operates nuclear plants in many locations that are not
in minority communities. Moreover, the mayor of Port Gibson, the county supervisor and
the Entergy vice president at Grand Gulf (George A. Williams), and Congressman
Bennie Thompson are all African-American and support a new plant. The elected representatives of the area
populations clearly have the best interests of their constituents in mind. They are not racists. City aldermen and the County Board of
Supervisors also support a new plant.
Although we do not have exact numbers, anecdotal evidence suggests that
many African American residents in Port Gibson and Claiborne County want the
project.
The African American Environmentalist Association
supports the new unit or units and we are an African American-led environmental
organization. We would not support the
ESP if we believed it was a racist proposal.
Our long history of fighting environmental injustice qualifies us to
conclude that the project is not racist.
The project will benefit African American communities in Port Gibson,
Claiborne County, the State of Mississippi and African American communities
downwind of the facility in the Eastern part of the United States.
4.0
Construction Impacts at the Proposed Site
AAEA concurs with the NRC staff position that the
Grand Gulf ESP site “would not result in disproportionate and adverse offsite
environmental impacts to minority and low-income populations.” We agree with the findings that impacts
during the construction would be temporary and insignificant. The NRC concluded that there would be a
MODERATE impact if tax revenues were not allocated to the local community to mitigate
for additional construction traffic and new residents. The city, county and state governments
should assure that any tax revenues generated by a new nuclear power plant
should be equitably distributed. The tax
considerations are included in EIS
Section 2.8: Socioeconomics. 3
5.0 Station Operation
Impacts at the Proposed Site
AAEA believes that the operation of a second nuclear unit at Grand Gulf
would be positive for the local, state, regional and national communities. The regional and national impacts would be
reductions in smog-forming and greenhouse gases that would be beneficial to
downwind states.
AAEA concurs with the conclusions in the report that operation of a new
facility would be beneficial to the local community and “the impacts to
minority and low-income populations from operating new units at the Grand Gulf
ESP site would be minor.” The tax
questions surrounding the operation of the facility will be determined at some
future date by the county and state legislatures. This is also the conclusion
of the NRC staff:
It is not clear how the new nuclear facility would be treated for property tax purposes, so it is not clear whether Claiborne County would receive property taxes, sales, and use taxes, or other taxes and public monies commensurate with the costs of its additional emergency management and public services obligations.
7.0 Cumulative Impacts
AAEA
concurs with NRC staff in concluding that, “the cumulative environmental
impacts related to environmental justice would be SMALL.” Concurrently, “If tax revenues dramatically
increase, the residents of Claiborne County (who are disproportionately
minority and low-income) would enjoy LARGE beneficial tax revenue impacts.”
8.5 Evaluation of Alternative Sites
The DEIS examines one alternative
region of interest (ROI) for considering environmental justice and it is
located near Baton Rouge, Louisiana.
The facility in this ROI is the River Bend Station. Entergy Nuclear has seven existing ROI sites
with operating nuclear power plants licensed by the NRC:
- Arkansas Nuclear One (near Russellville,
Arkansas)
- Grand Gulf Nuclear Station
- James A. FitzPatrick Nuclear Power Plant (near
Vicksburg, Mississippi)
- Indian Point Energy Center (Buchanan, New York)
- River Bend Station (near Baton Rouge, Louisiana)
- Waterford-3 (near New Orleans, Louisiana)
- Pilgrim Nuclear Station (near Plymouth,
Massachusetts)
The
ROI is the geographical area considered in searching for candidate ESP
sites. AAEA concurs with the NRC staff
findings that the impacts of a new unit or units at the River Bend site on
minority and low-income populations would be SMALL. No adverse or disproportionately high impacts were
identified. The city of Port Gibson and
the residents of Claiborne County should be aggressively petitioning SERI to
build the plant in their jurisdiction.
There is no ironclad guarantee that the Grand Gulf location will be the
site of the new plant. Stakeholders
should be aware that the competitive climate for new nuclear facilities is
increasing.
Recommendation
The
DEIS should contain racial and income demographic information in chart and
narrative forms early in the report (Section 2.8 Socioeconomics). Although the information is illustrated in
map form in Figure 2-12 and Figure 2-13, it would be beneficial for readers if
it were presented in chart form with narrative explanations. For instance, the following demographics
data should be included early in the report.
According to the 2000 Census, African Americans are 12.3% of the
population in the U.S., 36.3 % of the population in Mississippi, 84.1% in
Claiborne County and 80% in Port Gibson.
Conclusion
AAEA supports the ESP for the Grand Gulf
location. We encourage the facility
owner to accelerate its decision to apply for a construction and operating
license and to construct a new plant at the earliest possible date.