nuclear-news

The News That Matters about the Nuclear Industry Fukushima Chernobyl Mayak Three Mile Island Atomic Testing Radiation Isotope

France’s EDF company is trying to ‘restore trust’ in the nuclear industry

EDF unveils plan to ‘restore trust’ in French nuclear industry, Move comes as utility’s next-generation plant is beset by ballooning costs and delays, 

Michael Pooler in Paris , Ft.com, 13 Dec 19,
EDF has drawn up a plan to “restore trust” in France’s nuclear power industry after a government-commissioned report lambasted failings at the energy group’s troubled flagship nuclear project. The state-backed company said it would spend €100m on measures including a skills programme, a scheme for selecting suppliers and initiatives to improve project management and industrial standards. This came after the French government, which owns 84 per cent of EDF, gave the utility a month to draw up a scheme to fix problems at Flamanville after the flagship project stumbled into delays and cost overruns.
  A government-commissioned report into the failings at Flamanville, published in October, also pointed to a loss of skills in France’s nuclear sector. “We want to restore more trust in the ability of the French nuclear industry to deliver according to its objectives, in terms of cost, time and schedule,” said EDF’s chairman and chief executive Jean-Bernard Lévy.  ……
Flamanville is considered a litmus test for next-generation European Pressurised Reactor technology, which supporters say will be a bigger, safer and more efficient type of nuclear plant. But the plant’s construction, which was supposed to last four-and-a-half years, is now expected to take 15 years to complete at about four times its originally projected cost of €3.3bn. This follows problems such as faulty weldings. Once a leader in atomic power, France will not decide whether to build more EPRs until Flamanville is up and running.
  To address the sector-wide issues identified in October’s damning report, EDF will seek to change how risks are shared with suppliers and set up a college dedicated to “nuclear disciplines” where there are shortages, such as welding. ……

EDF’s plans come during a turbulent period for the group. Not only is it under fire for delays at another planned EPR site in the UK, but it is heading towards a corporate reorganisation.
This would create a government-owned mother company, EDF Bleu, containing its nuclear and hydroelectric assets. Bleu’s main subsidiary, EDF Vert, will house renewable energy, networks and services businesses, and will have a stock market listing. Under an energy planning law enacted this year, France must reduce its share of electricity produced by nuclear from 72 per cent to 50 per cent by 2035, with the rest coming from renewables. However, new atomic power stations may need to be built to replace ageing facilities, which will also need investment for retrofitting and maintenance. ….https://www.ft.com/content/9a33d12a-1da5-11ea-97df-cc63de1d73f4

December 14, 2019 Posted by | France, spinbuster | Leave a comment

Sound the alarm on deadly US-Russia nuclear threat

Sound the alarm on deadly US-Russia nuclear threat, by Jill Dougherty December 12, 2019  CNN, As I looked around the large square conference table, I watched the faces settle into worried frowns. Russians and Americans, several of whom once had responsibility for their nations’ nuclear weapons, all members of the Dartmouth Conference, the oldest continual bi-lateral dialogue between Americans and Russians, founded almost 60 years ago during one of the darkest periods of the Cold War.

For a long minute, no one spoke. Then, one of them broke the silence: “Someone needs to sound the alarm.”
Now, profoundly concerned that the United States and Russia are on the verge of a new arms race, they are speaking out, issuing an urgent appeal to keep arms control alive:
“… for the first time in our history we are compelled by the urgency of the situation to issue this public appeal to our governments, founded on our view that the clear threat of an uncontrolled nuclear arms race has re-emerged with the collapse in recent years of key elements of the post-Cold War arms control architecture.”
Members of the Dartmouth Conference meet twice a year to discuss ways of improving — and, at this point, salvaging — the US/Russia relationship. Several are former top-level military and diplomatic officials. Some are religious leaders or physicians. All are concerned citizens.
They’ve watched as the arms control agreements, which helped prevent nuclear war between our countries, were dismantled — the Anti-Ballistic Missile Treaty signed by former President Richard Nixon and Soviet General Secretary Leonid Brezhnev, and the Intermediate Nuclear Forces agreement signed by former Presidents Ronald Reagan and Mikhail Gorbachev.
Now, the New START agreement — the last remaining arms control agreement between the US and Russia — hangs in the balance. …….
It could get worse, both I and other Dartmouth Conference members believe. Neither country wants to start a nuclear war, which would imperil the entire planet, but it could start by mistake, by misunderstanding, by escalation of tensions, as it almost did during the Cold War……..
In their appeal, Dartmouth members say the dialogue on strategic stability should be broadened to include other nuclear powers. But that doesn’t mean that, in the interim, New START can’t be extended for another five years, as the treaty provides. Extending it beyond 2021 would provide some breathing space to work on future global security agreements. We can do both.
New START not only led to steep reductions of nuclear arsenals on both sides but it strengthened confidence and trust between our countries and our militaries by providing for inspections and data exchanges that verify compliance. Transparency is key; Not knowing what weapons the other side might have can ignite suspicion.
At this very moment both countries are developing new, highly advanced conventional arms and delivery systems.
A cyberattack could knock out early warning systems. Both countries keep most of their nuclear weapons on hair-trigger alert, ready to be fired within minutes. Our presidents have only a few minutes to decide whether to respond. A missile launched in Russia can hit an American city in less than 30 minutes — and vice versa. A single warhead can kill millions of people.
……… together, we had just written: “The immediate imperative is extension of the New START Treaty … We see this as a paramount moral obligation of both our governments before our own peoples, and the world at large. We respectfully urge our governments to begin discussions immediately to this end.” https://edition.cnn.com/2019/12/12/opinions/new-start-treaty-dougherty/index.html

December 14, 2019 Posted by | politics international, Russia, USA, weapons and war | Leave a comment

UK Conservatives get big donations from fossil fuel and weapons companiess

Unearthed 11th Dec 2019, The Conservative election campaign has received hundreds of thousands of pounds from wealthy investors in the global fossil fuels industry, according to a new analysis by Unearthed. Some of the companies and projects benefiting from donors’ investments are opening up new fossil fuel reserves – even as the world battles climate change and the UK
prepares to host a crunch summit next year.

One of the Tory’s major donors also runs a hedge fund that holds significant investments in a major weapons manufacturer and a mining giant. Meanwhile the Liberal Democrats have taken a significant donation from a subsidiary of a hedge fund that has a major stake in the energy firm being blamed for California’s deadly wildfires and another stake in a French oil services firm.

The analysis looked at donations to political parties over £50,000 during the first three weeks of the election campaign and the financial holdings of
investment companies, as collected and presented by Bloomberg.

https://unearthed.greenpeace.org/2019/12/11/donations-election-campaign-investments-fossil-fuels/

December 12, 2019 Posted by | politics, UK | Leave a comment

Floating small nuclear reactors bring serious risks

nuclear experts have highlighted crucial negatives that cast doubt on the floating nuclear utopia.Jan Haverkamp, Greenpeace Netherlands senior expert nuclear energy and energy policy, sees the three main disadvantages of Akademin Lomonosov to be the big human factors risk, its problematic construction, and the pollution of the Arctic region with nuclear waste.

this project is reintroducing a major pollution risk in an area which functions as a climate regulator for the globe – “the Arctic pristine area, which is a very important natural area for the entire balance on the planet,”

Is floating nuclear power a good idea?  Power Technology  By Yoana Cholteeva, 9 Dec 19,  Floating nuclear power promises to provide a steady source of energy at hard-to-reach locations, but at the same time the dangers inherent in nuclear power make some question whether it’s safe enough for areas where help is hard to find. Is floating nuclear power really a good idea? Yoana Cholteeva investigates.

Russian nuclear company Rosatom announced the arrival of the world’s first floating nuclear power plant, Akademik Lomonosov, in September 2019 when the technology was transported to the port of its permanent location in Russia’s Far East. The 144m-long and 30m-wide vessel has now docked at the port in Pevek, off the coast of Chukotka, where it will stay before its commissioning next year.

Akademik Lomonosov will use small modular reactor technology and is equipped with two KLT-40C reactor systems with 35MW capacity each. It has been designed to access hard-to-reach areas where it can operate for three to five years without the need for refuelling. It also has an overall life cycle of 40 years, which may be extended to 50 years Continue reading

December 10, 2019 Posted by | ARCTIC, Russia, safety, technology | Leave a comment

Britain, France, and Germany press Iran over its ballistic missile program

December 8, 2019 Posted by | EUROPE, Iran, politics international | Leave a comment

France’s nuclear industry in dire straits

The French nuclear revolution is rusting away, December 6, 2019, THE AUSTRALIAN, Henry Ergas “……..France’s nuclear power industry faces a future that is more uncertain than ever.  The problems gripping the industry were highlighted late last month in an official report prepared by the former president and chief executive of PSA Peugeot Citroen, Jean Martin Folz.

While the report’s focus is on the difficulties that have plagued the construction of a new reactor at Flamanville in northwestern France, its implications reach much further.

With nuclear power plants accounting for more than 70 per cent of its overall electricity generation, no country is as dependent on nuclear energy as is France.

The decision to rely so massively on nuclear energy was taken in 1974, after the oil shock of the previous year had underlined France’s vulnerability to Middle Eastern oil. Prime minister Pierre Messmer launched a crash program that led to the construction of 56 reactors in just 15 years.

…….. however, most of France’s generators are approaching the final decade of their useful life. Planning for their replacement has been a stop-start affair, with the Greens’ increasingly strident opposition to nuclear power deterring successive governments from taking action.

As a result, only the Flamanville plant received the go-ahead, with construction beginning in 2007 for an expected entry into service in 2012. Virtually from the outset, the project was beset by woes. At this stage, the total costs of construction are four times greater than initially estimated, while the plant will not enter service before the end of 2022.

The problems stem partly from the sheer complexity of the new reactor, which is the first of its kind to be built in France.

Additionally, the catastrophe at Fukushima in 2011 led to regulatory changes that necessitated costly redesigns. And the project has suffered more than its fair share of mismanagement, aggravated by a byzantine allocation of responsibilities between EDF, the main French electricity utility, which oversaw the project, and many layers of subcontractors.

However, as the Folz report shows, the primary cause of the difficulties lies in the erosion of the industry’s skill base during the long hiatus from the end of the crash program in 1990 to the initiation of Flamanville………

There is, at this point, no prospect of France scaling up its nuclear program ………The cost blowout at Olkiluoto drove Areva, the “national champion” of France’s nuclear industry, into bankruptcy.

Even with an injection of $7.3bn in public funds EDF, which acquired Areva, lacks the balance sheet strength to underwrite new projects, while the French government’s borrowing ability is hampered by its already too high levels of debt.

To make matters worse, the regulated prices at which EDF has to sell the power it generates mean that it cannot charge its European clients the full value of the baseload it supplies.

As for global investors, who might provide the debt financing EDF would require, they are wary of projects that are risky in themselves ….

Given those constraints, the government has announced a modest plan to eventually build six additional reactors. So far, however, there are no actionable decisions beyond the completion of Flamanville. And work on the next generation of reactors….. has been quietly downgraded, making it likely that there will no fourth generation reactor of French design.

The consequences for France itself are far-reaching. Beginning in the late 1950s, French firms succeeded in one high-technology market after the other by developing or acquiring a rather basic design (including the Westinghouse Pressurised Water Reactor, the Mirage jet fighter and the TGV high-speed train) that they up­graded while producing it on a large scale.

That era is over, and there is every sign France is struggling with almost all the major projects it has in train.

The Folz report should therefore come as an ominous warning for Australia’s submarine project, as it identifies French industry’s serious managerial and technological weaknesses in a range of areas, such as precision welding, that are crucial to that project’s success……. https://www.theaustralian.com.au/commentary/the-french-nuclear-revolution-is-rusting-away/news-story/afe4546ed799939cf117d71f05035c5e

December 7, 2019 Posted by | business and costs, France, politics | Leave a comment

Nuclear power headed to be excluded from EU green finance scheme

‘Do no harm’: Nuclear squeezed out of EU green finance scheme, By Frédéric Simon | EURACTIV.com Dec 6, 2019 European Greens claimed victory on Thursday (5 December) after EU negotiators reached agreement on a green finance taxonomy aimed at channelling billions of private investor’s money into clean technologies. Coal, and – in principle – nuclear power, are out.

The deal, reached by national envoys and EU Parliament negotiators yesterday evening, marks a stunning defeat for France, which lobbied hard to win recognition for nuclear energy as a low-carbon source of energy…….

Do no harm” test

But the European Parliament “resisted attempts from national governments to politicise the environmental criteria” underpinning the EU’s new sustainable finance classification scheme, the Greens said in a statement.

A strengthened “do no harm” principle means nuclear power will – in all likelihood – be excluded from the EU’s green finance taxonomy when experts sit down to agree detailed implementing rules next year, they said.

The ‘no-harm’ test “will help avoid nuclear energy from being considered an environmentally sustainable investment,” the Greens said in a statement to the press.

The taxonomy will provide investors, pension funds and private equity firms with “a common definition of what is green and what is not” in order to channel more capital into sustainable businesses and prevent “green-washing,” the European Commission said last year when it tabled the proposed new regulation.

The deal creates three categories for sustainable investments: “green”, “enabling” and “transition”. It also obliges companies with more than 500 employees to disclose how much of their activities are compliant with the three new categories, the FT reported.

“Today’s compromise will shift financial flows away from dirty, carbon intensive investments and into sustainable economic activities,” said Bas Eickhout, a Dutch Green MEP who was the European Parliament’s lead negotiator on the draft EU regulation.

“Any investment in coal cannot be considered sustainable,” he said in a statement……..

EU experts will now have to sit down and lay out thresholds to determine which economic activities can qualify as green. These will include CO2 emission limits for power production, which EU experts have tentatively set at 100g of CO2 per KWh – a threshold that would, in principle, exclude natural gas.

Here again, the Greens claimed they won guarantees ensuring those implementing rules “will be prepared by a balanced platform of experts” – not national envoys.

During the negotiations, France pushed for technical thresholds to be decided by a group of experts appointed by EU national governments. But the Greens resisted those attempts, saying that would have exposed the group to political pressures.

“The key part of the agreement is the strong independent governance structure,” Jess said.

“The text establishes an independent Platform on Sustainable Finance who will be responsible for developing and maintaining the full taxonomy going forward,” he explained. The expert group will also be responsible for monitoring capital flows and advising governments in their economic transition.

The agreement still needs to be formally endorsed by EU member states and the European Parliament. https://www.euractiv.com/section/energy-environment/news/do-no-harm-nuclear-squeezed-out-of-eu-green-finance-scheme/

December 7, 2019 Posted by | EUROPE, politics | Leave a comment

Significant obstacles to Rolls Royce’s fantasy of “clean” nuclear-supplied jet fuel

Rolls-Royce Touts Nuclear Reactors as Key to Clean Jet Fuel, Bloomberg, 

By Christopher Jasper,December 6, 2019, 
  • Synthetics, biofuels to be mainstay of aviation, CEO says
  •  Small reactors to be used to generate required electricityRolls-Royce Holdings Plc is pitching nuclear reactors as the most effective way of powering the production of carbon-neutral synthetic aviation fuel without draining global electricity grids.

    Drawing on technology developed for nuclear-powered submarines, the small modular reactors or SMRs could be located at individual plants to generate the large amounts of electricity needed to secure the hydrogen used in the process, according to Chief Executive Officer Warren East…….

    The proposals face significant obstacles, including widespread public concern about radiation leaks and the safe disposal of nuclear waste, as well as question marks over U.K. plans to revive the sector after Hitachi Ltd. and Toshiba Corp. withdrew from major projects.Rolls aims to minimize regulatory barriers by building an initial network of 16 SMRs on the sites of former U.K. nuclear power stations still approved for atomic use.

    The plants, costing 1.8 billion pounds ($2.4 billion) apiece, would feed the national grid and come online from the 2030s, with all complete by 2050. https://www.bloomberg.com/news/articles/2019-12-06/rolls-royce-pitches-nuclear-reactors-as-key-to-clean-jet-fuel

December 7, 2019 Posted by | Small Modular Nuclear Reactors, UK | Leave a comment

Putin offers US to extend key nuclear pact

Putin offers US to extend key nuclear pact   https://www.heraldsun.com.au/news/breaking-news/putin-offers-us-to-extend-key-nuclear-pact/news-story/e88b576c31aaa9f2e81843b5f306dfc7. Associated Press, December 6, 2019 Russian President Vladimir Putin claims Moscow is prepared to immediately extend a pivotal nuclear arms reduction pact with the United States.

Speaking at Thursday’s meeting with military officials, Putin said that Russia has repeatedly offered the US to extend the New START treaty that expires in 2021 but as yet he hasn’t heard back.

“Russia is ready to extend the New START treaty immediately, before the year’s end and without any preconditions,” Putin said.

The pact, which was signed in 2010 by former President Barack Obama and then Russian President Dmitry Medvedev, limits each country to no more than 1,550 deployed nuclear warheads and 700 deployed missiles and bombers.

Putin and other Russian officials have repeatedly voiced concern about Washington’s reluctance to discuss the treaty’s extension.

December 7, 2019 Posted by | politics international, Russia, weapons and war | Leave a comment

New ship to handle all nuclear waste from Rosatom’s Arctic operations.

Barents Observer 5th Dec 2019, New ship to handle all nuclear waste from Rosatom’s Arctic operations.
The new special purpose vessel will serve the new icebreakers and the
floating nuclear power plants and possible other reactor installations.

https://thebarentsobserver.com/en/industry-and-energy/2019/12/new-ship-will-take-care-all-nuclear-waste-rosatoms-arctic-operation

December 7, 2019 Posted by | ARCTIC, Russia, wastes | Leave a comment

Another shutdown at French nuclear power station Golfech

France Bleu 2nd Dec 2019. A nuclear reactor again shut down at the Golfech power station after a leak. The production unit number 2 of the Tarn-et-Garonne power plant was stopped this Monday, December 2 in the morning, after the discovery of a steam leak in a non-nuclear part. This reactor had just been restarted just four days ago.

https://www.francebleu.fr/infos/sante-sciences/un-reacteur-nucleaire-de-nouveau-arrete-a-golfech-apres-une-fuite-1575296981

December 5, 2019 Posted by | France, safety | Leave a comment

Need for scrutiny of troubled Hunterston nuclear reactor before restarting it

 Largs & Millport Weekly News 3rd Dec 2019, A WATCHDOG’S vital scrutiny meeting scheduled to take placed before troubled reactors are switched back on at Hunterston Power Station has been cancelled – because of the general election. The Hunterston Site Stakeholders Group had been due to meet on December 5 where they would have quizzed EDF on the decision to reactivate two reactors blighted by safety concerns. It was revealed this week that reactor four is due to go back online fully from February 15 and reactor three on January 15.
At the quarterly meetings, held in public, councillors and local community council groups can question nuclear chiefs about the power plant and its operation.
Councillor Ian Murdoch believes that it is imperative that a scrutiny
meeting takes place before the reactors are switched back on after cracks
were found in their graphite cores. The acceptable threshold of cracks has
been extended from 350 to 700 by regulators ONR, who recently gave
permission for Hunterston reactor 4 to be brought back online for a four
month spell.

https://www.largsandmillportnews.com/news/18060410.anger-hunterston-watchdog-scrutiny-meeting-cancelled/

December 5, 2019 Posted by | safety, UK | Leave a comment

Technical fault shuts down Belgian nuclear reactor

Belgian nuclear reactor shuts down after technical fault   https://www.brusselstimes.com/belgium/81820/nuclear-reactor-at-belgian-power-station-goes-into-automatic-shutdown-after-technical-fault-safely-electricty-doel/ Evie McCullough
The Brussels Times, 04 December 2019 
 A reactor at the Tihange nuclear power station in the town of Huy went into shut down on Wednesday morning after a technical problem automatically triggered the process, the plant’s operator Engie Electrabel confirms.

Tihange 1 went into shut down because of a problem with a pump in the “non-nuclear” part of the reactor, the operator explained in a Tweet.

The shutdown was carried out safely and procedures were followed throughout, with investigations into the fault still taking place at around 12:50 PM.The reactor is currently scheduled to stay in shut down mode until Thursday evening, although this could change depending on the results of the analysis of the fault that triggered the shutdown, Le Soir explains.

Tihange, which represents about 15% of total electricity production capacity in Belgium, is one of two nuclear energy production sites in the country- the other is located in Doel.

 

December 5, 2019 Posted by | EUROPE, safety | Leave a comment

UK election. Nuclear power is a hot topic in Wales

December 3, 2019 Posted by | politics, UK | Leave a comment

Germany must now face up to its nuclear waste problem

Germany is closing all its nuclear power plants. Now it must find a place to bury the deadly waste for 1 million years

By Sheena McKenzie, [excellent diagrams]. CNN https://edition.cnn.com/2019/11/30/europe/germany-nuclear-waste-grm-intl/index.html   When it comes to the big questions plaguing the world’s scientists, they don’t get much larger than this.

Where do you safely bury more than 28,000 cubic meters — roughly six Big Ben clock towers — of deadly radioactive waste for the next million years?
This is the “wicked problem” facing Germany as it closes all of its nuclear power plants in the coming years, according to Professor Miranda Schreurs, part of the team searching for a storage site.
Experts are now hunting for somewhere to bury almost 2,000 containers of high-level radioactive waste. The site must be beyond rock-solid, with no groundwater or earthquakes that could cause a leakage.
The technological challenges — of transporting the lethal waste, finding a material to encase it, and even communicating its existence to future humans — are huge.
But the most pressing challenge today might simply be finding a community willing to have a nuclear dumping ground in their backyard.

Searching for a nuclear graveyard

Germany decided to phase out all its nuclear power plants in the wake of the Fukushima disaster in 2011, amid increasing safety concerns.
The seven power stations still in operation today are due to close by 2022.
With their closure comes a new challenge — finding a permanent nuclear graveyard by the government’s 2031 deadline.
Germany’s Ministry for Economic Affairs and Energy says it aims to find a final repository for highly radioactive waste “which offers the best possible safety and security for a period of a million years.”
The country was a “blank map” of potential sites, it added.
Currently, high-level radioactive waste is stored in temporary facilities, usually near the power plant it came from.
But these facilities were “only designed to hold the waste for a few decades,” said Schreurs, chair of environmental and climate policy at the Technical University of Munich, and part of the national committee assisting the search for a high-level radioactive waste site.
As the name suggests, high-level radioactive waste is the most lethal of its kind. It includes the spent fuel rods from nuclear power plants. “If you opened up a canister with those fuel rods in it, you would more or less instantly die,” said Schreurs.
These rods are “so incredibly hot, it’s very hard to transport them safely,” said Schreurs. So for now they’re being stored in containers where they can first cool down over several decades, she added.
There are dozens of these temporary storage sites dotted across Germany. The search is now on for a permanent home at least 1 kilometer underground.

Between a rock and a hard place

The location will need to be geologically “very very stable,” said Schreurs. “It can’t have earthquakes, it can’t have any signs of water flow, it can’t be very porous rock.”
Finland, which has four nuclear power plants and plans to build more in the future, is a world leader in this field. Work is well underway on its own final repository for high-level waste — buried deep in granite bedrock.
Germany’s problem is “it doesn’t have a whole lot of granite,” said Schreurs. Instead, it has to work with the ground it’s got — burying the waste in things like rock salt, clay rock and crystalline granite.
Next year the team hope to have identified potential storage sites in Germany (there are no plans to export the waste). It’s a mission that stretches beyond our lifetimes — the storage facility will finally be sealed sometime between the years 2130 and 2170.
Communications experts are already working on how to tell future generations thousands of years from now — when language will be completely different — not to disturb the site.
Schreurs likened it to past explorers entering the pyramids of Egypt — “we need to find a way to tell them ‘curiosity is not good here.'”

People power

For now, nobody wants a nuclear dumping ground on their doorstep.
Schreurs admitted public mistrust was a challenge, given Germany’s recent history of disastrous storage sites.
Former salt mines at Asse and Morsleben, eastern Germany, that were used for low- and medium-level nuclear waste in the 1960s and 1970s, must now be closed in multibillion-dollar operations after failing to meet today’s safety standards.
The fears around high-level waste are even greater.
For more than 40 years, residents in the village of Gorleben, Lower Saxony, have fought tooth-and-nail to keep a permanent high-level waste repository off their turf.
The site was first proposed in 1977 in what critics say was a political choice. Gorleben is situated in what was then a sparsely populated area of West Germany, close to the East German border, and with a high unemployment rate that politicians argued would benefit from a nuclear facility.
Over the decades, there have been countless demonstrations against the proposal. Protesters have blocked railway tracks to stop what they described as “Chernobyl on wheels” — containers of radioactive waste headed for Gorleben’s temporary storage facility.
An exploratory mine was eventually constructed in Gorleben, but it was never used for nuclear waste. And in the face of huge public opposition, the government in recent years decided to start afresh its national search for a dumping ground.

December 2, 2019 Posted by | Germany, wastes | Leave a comment