Whistle-blower Accuses Nuclear Regulatory Commission of Corruption in New Reactor Design.

Artist rendition of the Westinghouse AP 1000 nuclear reactor at Bellefonte, Al.

Investigate Whistleblower’s Reactor Warnings, NC WARN Urges Nuclear Inspector General


Anonymous insider twice alleges criminal misconduct in NRC approval of Westinghouse’s new reactor design and says safety systems would be destroyed by airliner impact

Statement by Executive Director Jim Warren:

DURHAM, NC – Twice since January, NC WARN has received anonymous letters containing stinging allegations regarding the U.S. Nuclear Regulatory Commission’s integrity and its design certification process for the Westinghouse AP1000 reactor. In both instances, we forwarded the information to NRC Inspector General Hubert Bell, although the anonymous source had alerted both Bell and NRC Chairman Gregory Jaczko in November.

We assume the information was sent to NC WARN attorney John Runkle because, as part of the AP1000 Oversight Group, we have raised numerous criticisms about the AP1000 design, based in part on expert reports by engineer Arnie Gundersen of Fairewinds Associates. Neither Bell nor Jaczko have confirmed receipt of the information, nor whether they are investigating the charges. Therefore, we decided to make the letters and memo public (below), while emphasizing that NC WARN cannot verify or refute the whistleblower’s charges, which include:

-- In anticipation of monetary rewards and promotions, named NRC officials rigged the design approval process to confuse Congress and the NRC’s own science advisors, thus speeding approval due to industry pressure.

-- Design shortcomings that were pushed through without full review or while ignoring industry standards involve passive emergency cooling, the shield building, and the containment structure.

-- “The AP1000 design will not survive an airplane attack similar to WTC because scenarios that will bring down the shield wall and the containment all together have not been considered and not analyzed using computer codes that have been validated by our own US test data.”

It is evident that the person has inside knowledge of NRC-industry machinations and has taken personal risk to air the concerns, and the allegations coincide with thorny design problems made public in recent months. Last Friday, Chairman Jaczko conceded that design problems persist, and as noted by the New York Times, that the NRC is now “asking Westinghouse not only to fix its calculations but also to explain why it submitted flawed information in the first place” involving the all-important reactor shield building.

The whistleblower implored us to intervene on behalf of public safety, and said the NRC will not correct design “loopholes” unless ordered to do so by President Obama.

Jim Warren, Executive Director, NC WARN
Waste Awareness & Reduction Network
Durham, NC 919-416-5077  http://www.ncwarn.org/

Journalists expose highly corrupted U.S. nuclear agency: http://www.ncwarn.org/2011/05/new-release-corrupted-u-s-nuclear-agency/

Scientific American Article on the AP1000 Design: "New Reactor Design Faces Further Scrutiny in U.S."  http://www.scientificamerican.com/article.cfm?id=new-reactor-design-faces-further-scrutiny-us

Group challenges design of new nuclear plant - timesfreepress.com

AP 1000 reactors on the right of the artist concept photo. Photo by TVA.

Group challenges design of new nuclear plant - timesfreepress.com

TVA's Nuclear $inkhole

All about RADIATION http://www.nirs.org/radiation/radiationhome.htm Please do not leave our children and grandchildren a radioactive legacy in remembrance of our generation!

$$$$$$$$$--RADIOACTIVE MONEY $INKHOLE--$$$$$$
You will notice on the right side of the picture the 2 proposed AP1000 radioactive nuclear reactors. The proposed radiation producing plants are to be located dangerously close to large sinkholes. The entire nuclear site is located over porus limestone rock which contains caves and sinkholes, this terrain is called Karst Terrain. The Sequatchie fault line, earthquake zone, is located approximately 1 mile west of the radiation producing plant.

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The cost of one 1200 mega watt Westinghouse Nuclear Reactor at Bellefonte is estimated to cost between $8 and 9 billion dollars. Exact costs are unknown as the TVA, Tennessee Valley Authority, refuses to release cost information. I have asked for the costs thru the Freedom of Information Act, FOIA request. The TVA claims a commercial proprietary privilege. So much for an open Federal Government. However, this link lists costs as high as $12 billion per reactor, that's $24 billion dollars for 2 Westinghouse AP1000 Radioactive Nuclear Plants. http://scitizen.com/stories/Future-Energies/2008/11/How-Much-Will-New-Nuclear-Power-Plants-Cost/

What could you do with $82,000? That is the amount TVA has spent on every man woman and child in Jackson County Alabama without generating 1 kilowatt of electric power at the Bellefonte Nuclear Power Plant $inkhole. Total amount- $4,500,000,000, 4.5 billion dollars.

Problems plague TVA. Today's press release reflects poor engineering and design flaws at TVA Radioactive Nuclear Facilities. http://blog.al.com/live/2009/11/tva_nuclear_plant_has_fire_res.html Other problems at Browns Ferry: http://arklite.blogspot.com/2009/09/tva-browns-ferry-reactor-scram.html
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As reported in the link above from the Mobile Press Register. "The Tennessee Valley Authority's (TVA) Browns Ferry Nuclear Plant in north Alabama has a fire response problem that could lead to a Nuclear Regulatory Commission (NRC) civil penalty."
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"In a letter to TVA, the NRC said inspectors this year found that the plant near Athens, Ala., potentially violated four safety standards, the Chattanooga Times Free Press reported Thursday."
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Edwin Lyman, senior scientist for the Union of Concerned Scientists, told the newspaper that most of America's 103 reactors were designed before the NRC adopted its current fire safety standards. He said most don't have the desired cable separation and firewalls between parts of the plants."Almost no plants meet all of the NRC's physical standards, but the regulators have allowed plants to use manual steps like fire watches and walk-downs to compensate for the inadequate plant design," he said. "For a long time, the NRC was not issuing violations for fire safety issues. But lately the commission seems more determined to enforce these rules, which we believe is long overdue."
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No civility about a fire at a radioactive nuclear facility. That "nuclear feeling" equates to "death hanging in the air." That is not stopping the TVA at Bellefonte, Alabama, although the proposed nuclear reactor is an old design and the current incomplete plants have been stripped of parts and equipment. Excellent article from the Chattanooga Times Free Press on Bellefonte. The article opens, " When TVA canceled plans to finish its Bellefonte Nuclear Plant here in 2006, contractors began ripping out steel tubes and pipes from heat exchangers, steam generators and main condensers to sell for scrap metal." http://www.timesfreepress.com/news/2009/mar/29/alabama-salvaging-bellefonte/

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TVA notice of hearing about Bellefonte in Scottsboro: http://blog.al.com/breaking/2009/11/tva_to_accept_comments_on_prop.html
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Nuclear Power plants suck up valuable dollars available for Sustainable Energy projects. New technology is on our doorstep and is knocking to enter. The radioactive nuclear industry and their political puppets lock the doors.

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There is progress, such as the recent Solar Plant in Arcadia, Florida. http://sweetness-light.com/archive/largest-solar-power-plant-opens-in-fl

A 1200 mega watt solar plant of a larger but similar design would cost $7.5 billion dollars with no worry concerning nuclear waste.

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1 radioactive nuclear reactor contains 100 tons of radioactive uranium pellets which are placed in the core of a 1000 mega watt nuclear reactor for its operation. The amount of long-life radioactive material in a 1000 mega watt nuclear power plant is equivalent to the explosion of 1000 Hiroshima sized bombs. (Reference:"Nuclear Power Is Not The Answer" pg 53-54 by Helen Caldicott,, New Press)

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Can we afford radioactive power?? Besides the inherent radiation risks, particularly dangerous for our children and pregnant mothers, http://www.nirs.org/radiation/radiationhome.htm , nuclear reactors are very expensive as indicated in the below linked article. The financial risks are extremely high, private financial institutions will not build these risky radiation producing power plants, they must rely on the taxpayers, U.S. Government, to pay for the risky radiation producing power plants. http://scitizen.com/stories/Future-Energies/2008/11/How-Much-Will-New-Nuclear-Power-Plants-Cost/

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Other options available. The TVA has studied other options such as a Conversion to Natural Gas Combined Cycle (NGCC) Units. This was TVA's preferred option as noted in the Executive Summary. Link: http://www.tva.gov/environment/reports/bellefonte/ The Natural Gas plant is much less expensive with fewer risks than a radioactive nuclear reactor. The Combined Cycle Natural Gas plant costs are less than $900 million. http://www.allbusiness.com/energy-utilities/utilities-industry-electric-power/12609408-1.html

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There is a better way, the TVA recognizes there is a better way to provide citizens power. http://www.tva.gov/news/releases/aprjun08/draft_plans.htm The answer for our future is Energy Efficiency and Sustainable Energy. Combined Cycle Natural Gas provides a temporary solution while sustainable energy solutions are being further developed and placed on line to serve the citizens of the Tennessee River Valley area with safe, efficient, electrical power. Encourage the TVA and your elected representatives to support Energy Efficiency and true Sustainable Energy Solutions for our future. Our children and grandchildren deserve safe energy, not radioactive poisons.

Bellefonte Nuclear Project--Revisited

TVA's Bellefonte Dream, 4 nuclear power plants which estimates show will cost the citizens and rate payers of the TVA service area in excess of $20 billion dollars for the 4 proposed reactors It is important to point out that none of this project has been approved by the TVA Board. Yet, billions of dollars have been spent and the entire project has been wrapped in controversy and mismanagement since its conception over 30 years ago. Not one kilowatt of power has ever been produced from the reactors at Bellefonte.

Update Dec 1, 2015 - cost estimates are now between $10 billion and $15 billion per unit for construction and updates at this time. 6 years after my writing of this article the total costs are estimated at $40 billion for the 4 units at TVA's Bellefonte, Alabama.
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Units 1 & 2 were over 50% complete when construction was halted in the mid 1980's. When the construction permits were cancelled by the TVA a few years back the plant was stripped of usable and expensive metals which were sold as scrap or utilized at other facilities.
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Now, the TVA and nuclear construction contractors have unduly influenced the Nuclear Regulatory Commission, NRC, to reinstate a cancelled construction permit in violation of NRC policy and protocol. The NRC Commissioners reinstated the construction permit with out one, 1, vote of approval from the NRC, The Commission voted 1-disapproved, 3 jointly approved-disapproved. This unprecedented and ILLEGAL vote, in contravention of Atomic Licensing Authority for construction of nuclear reactors, has resulted in legal action being filed against the NRC, the case has been filed in the Washington D.C. Federal Court of Appeals. This is where we are at now with Bellefonte.

The debate concerning Bellefonte and nuclear power will continue for many years. The TVA, the nations largest utility and one of the nations largest governmental, corporate, socialist organizations. The TVA was created by President Roosevelt during the depression in order to provide jobs and power in the southeastern U.S. The TVA program worked marvelously to help end the Great Depression.

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Unfortunately the government's premier example of socialism did not end after World War 2, it has continued and now masses an enormous debt load of over $26 billion, primarily due to mismanagement of enormously expensive nuclear construction.

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The TVA should have been sold to private enterprise after WW2, that has not happened and now the TVA has become a massive governmental bureaucratic monster which is not accountable to the people which it was designed to serve nor has Congress chosen to offer meaningful oversight of this bureaucratic crystal palace.

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There are positive aspects of TVA, they provide continuous power to the Tennessee Valley area. In economic troubled times the cost of power is increasing. The TVA was once the least expensive source of power in the southeast. It continues to provide economical power to customers of the southeastern U.S. in its service area.

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Unfortunately, with expensive nuclear power additions the economic benefits of TVA power will end as electric rates will soar to pay for the expensive nuclear power projects. Already power companies in Kentucky and Georgia are at par with TVA power rates

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The issue continues, in Scottsboro's local paper, The Daily Sentinel, this report was filed concerning a recent press conference with Congressman Parker Griffith at Bellefonte. http://www.thedailysentinel.com/story.lasso?ewcd=2d6a28bbd22452e6

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My reply to this report was sent as a Letter to the Editor which was published in today's The Daily Sentinel. Below is a copy of my letter in it entirety. Their title to my letter was "Totally Against Nuclear Power and Bellefonte," I prefer to think of my letter as " The Rest of the Bellefonte Story." Many thanks to the Daily Sentinel for publishing my letter. The Daily Sentinel News site link for todays article, weekend addition, concering Bellefonte. http://thedailysentinel.com/story.lasso?ewcd=c0c787b560976aa6

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Dear Editor,

"Bellefonte process progressing" is the headline in Fridays Daily Sentinel. "Griffith says clean, safe nuclear power is the key to becoming energy independent." Many would disagree with the statements made by the TVA and its supporter, Congressman Griffith.

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Inaccuracy and propaganda have been the continuing trend of those who support the construction of nuclear power plants at Bellefonte. It seems the truth of the risks are not told, politicians and TVA/nuclear construction propaganda meisters intentionally mislead the public. It would be nice if the complete story would be told. I submit the "rest of the story" for your consideration.

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Nuclear power is not safe nor is it clean. There are over 40,000 workers, many are our neighbors in the southeast, who are sick and dying from the nuclear fuels manufactoring process. The facts concerning the sick and dying workers are the "secret" which nuclear power proponents attempt to keep from the public. An act of Congress entitled Energy Employees Occupational Illness Compensation Program Act was passed in 2000. Facts concerning these good folks who have gave so much of their lives may be found on the Internet at http://www.wildclearing.com/ice-ages/the-exposed.html There are 163,000 claims that have been filed of which 43,000 have been approved by DOL, Department of Labor. God Bless the 1200, 1 in 17, and their families who have died before one cent of money was paid. Individual payments per claim is approxiamately $94,000 per worker. The claims involve atomic weapons materials workers and nuclear fuels workers.

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Other inaccuracies originating from the TVA and Congressman Parker Griffith. 1) According to Dr. Griffith, " The opponents of Bellefonte are usually from out of state." That statement is not true, there are 85 local citizens who reside within 45 miles of the Bellefonte facility who have signed legal documents in opposition to the proposed nuclear plant. Many of the 85 reside in Alabama. 2) Safety. The Bellefonte site sits on a geologically unstable area consisting of Karst Terrain, cave terrain and sinkholes. The construction of unit 3 is proposed to sit near a very large sink hole. Hydrology is a serious issue, the reactor vessels will actually rest below Guntersville Reservoirs low water lake level. Fissures and channels in the Karst Terrain would surround the reactor vessels. The reactors at Bellefonte are approximately 1 mile from the Sequatchie Fault Line, coupled with the Karst Terrain Bellefonte is being constructed over an unstable geological area. 3) Renewable fuel. Nuclear fuels are not renewable as Dr. Griffith suggests. However, there are proposals to reprocess spent nuclear fuels. Nuclear fuels reprocessing is a hazardous and dangerous business which results in the creation of plutonium which may be used in nuclear weapons. Does Dr. Griffith support Nuclear Proliferation? 4) Waste. What are you going to do with the nuclear waste that will be created. Is it Dr. Griffith, the TVA and local politician's wish to create a nuclear waste repository at Bellefonte. That is exactly what will occur. Nuclear Waste must be stored on site for an indefinite period of time. 5) Cost. No one likes to discuss the cost, not even the TVA. TVA is $26 billion dollars plus in debt, their debt is growing. How will the TVA afford the nuclear reactors? Completion of Units 1 & 2 will cost $4-$8 billion dollars, possibly more. The minimum cost of Units 3 & 4 will be $16 billion with cost overruns, units 3 & 4 may come in at $20 billion. The TVA has a $30 billion Congressional mandated cap on their debt. Where are they going to get the additional funds? Raise your electric rate to double or triple current electrical rates? 6) Approval of Construction. The reinstatement of the Construction Permits for units 1 & 2 violated the Nuclear Regulatory Commission's, NRC's, own policy and protocol. My military experience in Nuclear Reliability Programs makes me very, very concerned of the NRC's flagrant violation of protocols and policy in this matter. There was not one vote of approval for the reinstatement of construction permits for units 1 & 2 at Bellefonte. Again I repeat, the NRC Commissioners did not vote to reinstate the construction permit. They voted, 1 vote disapproved and 3 votes jointly approved-disapproved, an unprecedented vote and scheme to intentionally violate the NRC's own protocol and policy. This unprecedented action on the part of the NRC has landed them into a legal action in the Washington D.C Court of Appeals. From my stand point of military experience there can be no violations of law, policy or protocol concerning nuclear programs, including the construction process. If the very commissioners and authorities who are required by law to provide for nuclear safety and protect the public from unscrupulous actions of nuclear operators, contractors and government entities violate policy and protocol, they themselves stand as a liability to Nuclear Reliability and Safety programs. 7) There is no demand for the power that a Bellefonte Nuclear plant would produce. The TVA has reported its power demand and sales are down. This is the exact reason Bellefonte construction was previously ended. Do our political representatives wish to repeat the mistakes of 20 plus years ago and waste another $5 billion dollars or more?

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In summary, TVA is experiencing decreasing power demand according to their own reports. This is what led to the previous cancellation of Bellefonte Units 1 & 2. We who depend on TVA power cannot afford another series of poorly planned and unnecessary nuclear projects. The utilization of energy efficiency programs would end further expensive, risky nuclear expansion and will result in cost savings for customers and reduced impacts across the Tennessee River Valley. Use the money that Bellefonte would cost to update an antiquated power generation and distribution system and begin investing in Solar Power alternatives.

Garry Morgan, Scottsboro

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I am a member of the Blue Ridge Environmental Defense League, BREDL, its local sub-chapter- Bellefonte Efficiency and Sustainability Team, BEST and The Southern Alliance for Clean Energy, SACE.

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These organizations are concerned about our environment and the ecological impacts of nuclear power on our environment and other environmental issues. There is strength in numbers. Any meaningful effort in opposition to nuclear power or to assure the accountability of our government in nuclear licensing costs money. The nuclear industry has poured millions into the coffers of politicians and attorneys to insure nuclear construction continues, even if it is not warranted. The TVA has the backing of the U.S. Government in its efforts to continue with its unwise decisions concerning nuclear power. If you as a citizen believe that government accountability is needed concerning nuclear construction or oppose the continuation of nuclear construction at Bellefonte or other sites we welcome your participation in our cause. Information concerning BREDL and membership http://www.bredl.org/ information concerning SACE and membership http://www.cleanenergy.org/

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Other articles on my blog concerning the TVA and nuclear energy. http://arklite.blogspot.com/search/label/TVA

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A short history of nuclear corruption and deceit, the "whistle-blowers": http://www.nytimes.com/1995/02/12/nyregion/paying-the-price-for-blowing-the-whistle.html http://www.frankmckinnon.com/nuclear_industry_bribes.htm http://www.time.com/time/magazine/article/0,9171,1101960304-135575,00.html http://www.wbir.com/news/local/story.aspx?storyid=60199&catid=2

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A reminder of how nuclear power began, the Atomic Bomb. http://www.youtube.com/watch?v=H1sS1TmXF38&feature=related

Letter to the Editor of Scottsboro's The Daily Sentinel, Weekend Edition.

Sustainable energy solutions are the answer, not new outrageously expensive nuclear construction . (Stop Sign Photo by Tom Moss, BEST/BREDL)

>>>>>>>>>>>>>>>TVA's Bellefonte Dream

Dear Editor,

I thought Mr. Shurett's Editorial in Saturday/Sunday's The Daily Sentinel this past week concerning nuclear power was interesting but wrong on several points. I want to address a few points he listed in the Editorial.

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There is never a reason to dismiss a viable proposal but I ask all to consider these facts along with the references listed. There is no conspiracy theory, no exaggeration, just the facts. 10 reasons I think nuclear power is a bad idea for our community.

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The following facts are presented, I will list references at the end of this writing. (1) The Nuclear Regulatory Commission (NRC) has documented nearly 200 “near misses” to serious reactor accidents in the US since 1986, eight of which involved a risk of a core meltdown that was greater than one in 1,000. (2) A recent report by the Union of Concerned Scientists has shown that of the 104 nuclear power reactors in the United States, severe problems have caused 41 to shut down for a year or longer, with some registering multiple shutdowns. Such extended shutdowns reveal the degree to which cumulative decay and unattended maintenance issues allow safety margins to deteriorate to levels so low that reactor operations must cease. (3) Nuclear power is the slowest and costliest way to reduce CO2 emissions when compared to efficiency, distributed generation and some renewable sources. (4) Children living near nuclear power plants suffer from higher level of birth defects. A study of medical records found that infant death rates near 5 U.S. nuclear plants increased within two years after the plants opened. The study also found that infant death rates decreased from 15-20% once the plants closed. The decreases in cancer and birth defects continued for 7 years after plant closure. (5) Nuclear power threatens our water supply. According to Bellefonte's Application for a license, it is expected to withdraw 71 million gallons of water per day and loose 46 million gallons per day due to evaporation. The remaining 1/3rd will be returned at much higher temperatures resulting in thermal pollution that severly stresses the surrounding ecosystem. (6) There is no safe level of radiation, no safe dose. Radiation exposures damage reproductive cells and can lead to mutations from generation to generation in humans and animals. Each new exposure to radiation adds to the risks of abortion, mental retardation, spina bifada, heart disease, leukemia and other cancers. (7) TVA debt increased from $22.685 billion 1st quarter 2008 to $23.035 billion 2nd quarter 2008; interest on the debt increased from $20.724 billion 1st quarter to $21.878 billion 2nd quarter; total commitments increased from $55.659 billion 1st quarter to $57.193 billion 2nd quarter. TVA's Bond-debt/interest is in excess of $44.9 billion dollars, $14.9 billion dollars over the TVA Act's $30 billion debt limit. (8) The prospects for nuclear energy as an option are limited by many "unresolved problems," of which "high relative cost" is only one. Others include environment, safety and health issues, nuclear proliferation concerns, and the challenge of long-term waste management. (9) From 2000 through October 2007, nuclear power plant construction costs -- mainly materials, labor and engineering -- have gone up 185 percent! That means a nuclear power plant that would have cost $4 billion to build in 2000 would have cost more than $11 billion to build last October, costs continue to climb. (10) The TVA refuses to release costs of construction of a Bellefonte Nuclear Plant, stating that the costs are "proprietary information." The TVA is an organization of the Federal Government, what type of proprietary information do they need to hide?

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In short, nuclear power is not clean, it is not safe and it is not cheap.

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The answer to our problems of energy for the future rests in sustainable energy solutions, not future nuclear construction, we can not afford it. One man, T. Boone Pickens has come up with an idea that many think is workable, I agree. If you have not seen his site and read what he has to say I strongly suggest everyone do so. http://www.pickensplan.com/ His wind power plan is workable. The plans usage of natural gas also makes sense, it also moves us away from foreign oil dependance. A natural gas infra-structure also may be utilized to "break ground" for a hydrogen fuel infra-structure for our children's future economy. The future looks bright, if we do not place all our "eggs into the nuclear basket." Placing all those multi billion dollar "eggs into the nuclear basket" may very well have disastrous effects for the TVA and certainly will result in much higher electric bills in each of our mail boxes.

Garry Morgan

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References: The Pickens Plan- http://www.pickensplan.com/theplan/ ; Nuclear Information and Resource Service- http://www.nirs.org/ ; BREDL- http://www.bredl.org/ ; Union of Concerned Scientists- http://www.ucsusa.org/nuclear_power/ ; salon.com- http://www.salon.com/news/feature/2008/06/02/nuclear_power_price/ ; Dangers of Nuclear Power- http://www.ccnr.org/open_letter.html ; Bloomberg.com- http://www.bloomberg.com/apps/news?pid=20601103&sid=agGMCRlWdMyU&refer=us ; Committee to Bridge the Gap, NRC's Dirty Secret/Security- http://www.committeetobridgethegap.org/pdf/articles/dirtysecret.html ; TVA Financial Filings- http://www.tva.gov/finance/reports/forwardlooking_sec.htm

Limited Appearance Letters to the NRC, Financial and Nuclear Waste Issues

>>>>>>>>>>>>>The Answer, Sustainable Energy Solutions

The following is a Limited Appearance Letter forwarded to the NRC by an Attorney from Cookville, Tn. More reasons why the TVA must not proceed with the Bellefonte Nuclear Plant project. This is an important Limited Appearance Letter and deals with important financial issues of the TVA as well as waste storage issues.

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Limited Appearance Bellefonte Nuclear Plants Units 3 and 4

Docket No. 52-014--COL and 52-15-COL

Honorable Paul Bollwerk,

I am an attorney licensed in Tennessee and several other jurisdictions. I am a member of the Upper Cumberland Electric Membership Corporation, a distributor in the upper Cumberland of electricity produced (or purchased) by TVA.My wife and I participate in TVA's "Generation Partners" and return to the grid some of the electricity produced by the 4 kW solar PV array which I have installed on the roof of my home in Jackson County.We have studied TVA since the time the new Board first proposed a Strategic Plan which completely omitted any reference top electrical efficiency, conservation and the generation of power from renewable sources.We respectfully direct the presiding officer's attention to the July 16, 2008 testimony of Dr. Joseph Romm, Senior Fellow, Center for American Progress Action Fund Before the Committee on Environment and Public Works Subcommittee on Clean Air and Nuclear Safety. We ask that a copy of this statement be included in the record of these proceedings. An electronic copy can be found at http://www.americanprogressaction.org/issues/2008/pdf/romm_testimony.pdf. I have attempted a preliminary review of the NRC's draft Environmental Impact Statement. Unfortunately large portions of that document as posted on the internet are not available for public review. This certainly violates the instruction to allow informed public input found in the National Environmental Policy Act and the Council on Environmental Quality regulations.A critical omission is any documentation by TVA of a reliable forward projection on energy demand that would justify the proposed Bellefonte nuclear plants. TVA's rates are steadily rising and are to be increased again by 10 to 20 percent on October 1, 2008. These rate increases have lead to reduced demand. TVA is to lose 4 to 5 % of the base demand when the USEC gaseous diffusion nuclear fuel processing facility in Paducah is scheduled to cease operations in 2012 as an industrial customer of TVA. In any event, TVA should not be allowed to make a new and financially very risky multi-million dollar re-entry into nuclear plant construction in order to provide subsidized power to a few industrial direct customers while putting the repayment costs and risks on all of the other users of TVA power. TVA faces prohibitively high costs for construction and does not have the financial strength to complete this project. The federal financing bank will not loan federal funds to TVA for nuclear construction. The proposals for Bellefonte on their face violate the "no new major generation" promise TVA made to the taxpayers, Congress and the GAO following the collapse of TVA's last foray into nuclear power. ("TVA Plans to Reduce Debt While Meeting Demand for Power" GAO-06-810 Report, August 2006.) Private financing for nuclear plants, even with federal loan guarantees, has not appeared. Private financing of such a risky venture appears even less likely as our bank credit system continues to shrink and becomes more risk averse. Government loan guarantees, the renewal of the Price-Anderson Act and subsidies only make the risk more self-evident. See: http://www.rmi.org/sitepages/pid467.php At the same time TVA faces steadily and rapidly increasing construction costs. The skyrocketing costs of steel, concrete and other construction materials and the limited availability of skilled craftsman and knowledgeable supervisors and managers make any projection costs and all timetables extremely speculative. Undertaking a project with no prospect that costs and implementation schedule can be controlled is foolish. In any case the excessive cost per unit of electricity generated makes further nuclear investment by TVA unwise and as well as unnecessary. The return on investment for conservation, efficiency and co-generation to achieve demand reductions has been demonstrated many times in many places. There appears to be no reason that demand for TVA power could not be reduced from the current high per capita use figures by 30% or more with a much smaller investment than is proposed for the Bellefonte plants. The (declining) costs of renewable generation from wind and solar are known. Private investors have already offered to capitalize additional wind generation at Buffalo Mountain in TN but TVA has declined to contract for the power that would be produced despite the fact that it would cost less than the cost of much of the other purchased power, particularly peaking power. It looks like the "standard design" paradigm for the AP 1000 has already been sacrificed to applicant plans for customization and continued discovery of design defects as more detailed engineering documents are presented to the NRC. It does not appear the NRC will succeed in finding suppliers for all key components which it can certify in advance. I suspect that Westinghouse, like General Electric soon will start to discard business lines. As the financing of reactor design and construction is recognized as extremely risky in risk averse capital markets, the AP 1000 may disappear from the U.S. market. We have not solved the problem of spent fuel storage. It looks more and more like Yucca Mountain will never be available, which at the same time the U.S. taxpayers are being bled in actions for damages by operators of existing (and even decommissioned) reactors. Of course, TVA's Bellefonte plants will have no right to the use of Yucca Mountain and in this respect the spent fuel disposition aspect of its plans are incomplete and cannot be approved.

Respectfully submitted,
Brian Paddock
Cookeville, TN 38501