ML061210044
| ML061210044 | |
| Person / Time | |
|---|---|
| Site: | Palisades, WM-00011  |
| Issue date: | 04/02/2006 |
| From: | Hanson N - No Known Affiliation |
| To: | NRC/ADM/DAS/RDB |
| References | |
| -nr, 71FR9383 00004 | |
| Download: ML061210044 (5) | |
Text
PalisadesEIS - I strongly oppose the proposed 20 Year License Extension at Palisades Nuclear Power Plant r-age I I From: <nhanson48@comcast.net> 7/,bC
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-D Xe To: <PalisadesElS @nrc.gov>
Date: Sun, Apr 2, 2006 10:47 PM 1
Subject:
I strongly oppose the proposed 20 Year License Extension at Palisade) Nuclear Power r-,
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Dear Chief,
Rules Review and Directives Branch, NRC: i/ '_1
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Radioactive Waste
--The NRC says in its "Nuclear Waste Confidence Decision" that a repository, or permanent dump, tr commercial irradiated nuclear fuel will open by 2025. But the only site under consideration for such a dump - Yucca Mountain, Nevada - is in remarkable disarray. Due to the site's scientifically unsuitable geology, as well as legal, political, and popular resistance and skyrocketing costs, the dump's opening has been delayed from 1998 to 2010, then 2012. Now the U.S. Dept. of Energy won't even hazard a guess as to when the dump will open, if ever, and at what cost.
In addition, the State of Nevada, adamantly opposed to becoming the country's atomic sacrifice area, has filed federal lawsuits against the proposal at every turn. One of them challenges NRC's "Waste Confidence Decision" directly. NRC is supposed to be the objective judge of whether or not Yucca Mountain should be opened, but if NRC sticks to its arbitrary 2025 deadline, its bias in favor of approving the dump at Yucca Mountain, despite its defects and dangers, is obvious.
Even if Yucca does open someday, it could only accommodate commercial wastes generated before 201 1, due to its capacity limit under the Nuclear Waste Policy Act for only 63,000 tons of commercial irradiated fuel. That much will have been generated in the U.S. by the end of 2010. Thus, any waste generated at Palisades during its license extension from 2011 to 2031 could not legally go to Yucca Mountain, even if the ever-more-doubtful dump opens.
How can the NRC approve 20 more years of waste generation and storage on the Lake Michigan shoreline when there is nowhere for those wastes to go? How can NRC declare such an essential issue to environmental and public health and safety to be gout of scope" during this environmental impact proceeding? The ongoing generation of nuclear waste at Palisades must be stopped as soon as possible.
--Palisades' dry cask storage installations - outdoor "parking lots" for gigantic 150 ton concrete and steel silos filled with high-level radioactive waste - are in violation of NRC's own earthquake safety regulations.
Dr. Ross Landsman, now retired NRC dry cask storage inspector for the Midwest region, has warned for well over a decade that the 13 year old concrete cask pad just 150 yards from Lake Michigan could fail during an earthquake, resulting in casks being buried under sand or being dumped into Lake Michigan.
Burial could result in the irradiated fuel overheating, damaging the containers, and releasing radioactivity.
Underwater submersion could result in a nuclear chain reaction in the fissile materials still present in the waste. Even the two year old pad further inland is in violation of NRC earthquake regulations. Despite claiming these alleged violations are "under review," NRC has allowed Palisades to continue loading casks onto these unsafe pads. How can NRC allow Palisades to generate 20 more years' worth of waste, when even its current storage facilities violate NRC safety regulations? (see http://www.nirs.org/reactorwatchlicensing/palisades.htm at Sept. 15, 2005 and at Feb. 17, 1994 for more information)
--How can NRC approve a license extension for Palisades when Consumers Energy and Nuclear Management Company nearly dropped a 107 ton nuclear waste container into the storage pool in October 2005? Such a drop could have punched a hole in the pool floor, draining away the cooling water, leading to a waste fire and radioactive inferno. Tens of thousands of people could have died from radiation-induced cancer downwind. The company cannot safely handle its radioactive wastes with its present workforce, a situation that can only get worse as experienced personnel leave the plant or are laid off as plant owner Consumers Energy tries to sell Palisades, and as plant operator Nuclear Management Company has already been told it will not be retained in the future. Instead of protecting the public health and safety and environment against such hazards as the near-drop of such a heavy load into the vulnerable waste pool, NRC helped the company keep the public in the dark about the incident for months!
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PalisadesEIS - I strongly oppose the proposed 20 Year Lcense Extension at Palisades Nuclear Power Plant Page 2,1 Severe Reactor Accidents
--Due to deterioration and degradation, old reactors are more likely to experience accidents than younger reactors. At 39 years, Palisades is one of the oldest operating reactors in the U.S., and has been considered a "nuclear lemon" since it began operations in the first place. The risk of a severe accident at this "geriatric" reactor is reason enough to close it down in 2011 at the end of its current license.
--Given the potential dire consequences of a major accident and radiation release at Palisades, how can NRC screen out "Severe Accident Mitigation Alternatives" because "the required extensive changes.. .would involve implementation costs known to exceed any possible benefit"? (EIS, p. 5-5) In 1982, in its CRAC-2 (Calculation of Reactor Accident Consequences) report, NRC calculated that a severe accident and catastrophic radiation release from Palisades would kill 11,000 people, injure 7,000, and do over $50 billion in damages. The population in the surrounding region has only grown since then (EIS, Table 2-7, p. 2-56), so casualty figures would be higher today. And adjusted for inflation, that property damage figure would top $100 billion, only $10 billion of which would be paid back by the nuclear power industry and its insurance companies (under the Price-Anderson Act, renewed in 2005, U.S.
taxpayers would have to pay the rest, or else damages wouldn't be compensated for at all). A major radiation release at Palisades would ruin Michigan's tourism and agriculture forever. How can NRC's EIS" cost/benefit" analysis ignore its earlier CRAC-2 report?
--By NRC's own reckoning, Palisades has one of the most embrittled reactor pressure vessels in the U.S.
Consumers Energy and Nuclear Management Company admitted in November, 2005 that in 2014, Palisades will surpass NRC embrittlement criteria. In fact, Palisades has surpassed NRC's limits on embrittlement a number of times - the earliest in 1981, just ten years into operations - only to see NRC weaken its standards, allowing Palisades to continue operating. Embrittlement makes the risks of "
pressurized thermal shock" (PTS) too great to keep operating this reactor. During an emergency, PTS could fracture Palisades' reactor pressure vessel like a hot glass under cold water. Since such a fracture is a 'beyond design basis" accident, there is no countermeasure to prevent a melt down. Operating Palisades till 2031 risks a Chernobyl on the Lake Michigan shoreline, a risk that only grows worse with time. (see environmental interveners' contentions and supporting documents at http:/Avww.nirs.org/reactorwatch/icensinglpalisades.htm at 1993, 2004, Aug. 8 and Sept. 16, 2005.)
Socio-economic and Environmental Justice Impacts
--NRC reports that 15 Native American archaeological sites have been identified by surveys within 1 mile of the Palisades site and its transmission lines, including a prehistoric village site. Another of the prehistoric sites is of "unknown type," just 0.3 miles south of the Palisades site, and a third is just outside Palisades' eastern boundary. (EIS, pgs. 2-62 to 63) This validates the environmental contention, arbitrarily dismissed by the NRC licensing board on March 7, that 20 more years of routine radiation emissions, potential accidental radiation emissions, and plant expansions such as additional waste storage pads could do irreversible harm to as-yet unidentified Native American burial sites, village sites, etc. at Palisades. Why did the licensing board dismiss this contention when NRC admits in this EIS that it is an issue? (see http://www.nirs.org/reactorwatch/licensing/palisades.htm at Aug. 8 and 30, 2005 for these Native American impact contentions).
NRC admits in its draft EIS that "[ijntact archaeological sites could be present within the remaining undeveloped areas as well as in soils below the depth of ground disturbance in most areas of the
[Palisades] site." It admits "no archaeological field surveys have been conducted either at the Palisades site or for original transmission line construction or maintenance.. .[and] without accurate knowledge of the cultural resources present at the Palisades site, it must be assumed that power plant construction has the potential to adversely impact significant resources that may exist on the plant site." Palisades' own cultural resource assessment 25 years ago recommended that "an intensive survey be undertaken of the undisturbed portions of the site." Despite all this, no extensive surveying was ever conducted. In its draft EIS, NRC simply brushes off the potentially disproportionate impacts upon Native American cultural resources and spiritual values that could occur with 20 additional years of operations at Palisades. The
PalisadesEIS - I strongly oppose the proposed 20 Year License Extension at Palisades Nuclear Power Pi-ant rage 3 intensive site survey must be performed, in close and meaningful consultation with affected Native American tribes, before NRC even considers granting Palisades a license extension. NRC granting an extension without requiring such a survey would itself represent an environmental justice violation, not to a mention a potential violation of the American Indian Religious Freedom Act.
--It is baffling NRC concludes that "offsite impacts from Palisades on minority and low-income populations would be SMALL (sic), and no special mitigation actions are warranted." (EIS, p. 4-31) Just three pages earlier, NRC admits that "[c]ensus block groups with a minority population...are located in Covert,"
Palisades' hometown. Figure 4-2 on p. 4-30 also identifies Covert's predominantly African American population as low-income." Why Covert's African American community is still low-income after 38 years of substantial profit-making at Palisades is quite troubling. In addition, Covert's community suffers the worst radiation doses from routine operations at Palisades, and would suffer the worst health impacts from accidental radiation releases. NRC even ignores the fact that Palisades' tax contributions to its neighboring community in Covert are dwindling over time - shown in Nuclear Management Company's 2005 Environmental Report -- so residents suffer worsening risks as the reactor deteriorates with age, while also receiving decreasing benefits such as tax income. (see http://www.astrongerkinship.com/ for a recent book about the African American history of Covert).
--NRC's treatment - or lack thereof - of Palisades' impact on the surrounding Latin American agricultural workforce is remarkably inconsistent and disconcerting. Regarding environmental interveners' contention that this community would suffer disproportionately from routine and accidental radiation releases from the reactor, NRC staff agreed that the company's license extension application does not sufficiently address the "adverse socio-economic impacts of a catastrophic radiation release.. .as they would be found among the low-income Latin American agricultural workforce of the Palisades area..." and that such a contention would not necessarily be out of scope. Likewise, NRC's licensing board stated that interveners' allegation of disproportionate impacts upon Latin American agricultural workers from an embrittlement/PTS core rupture might be pertinent and admissible in the proceeding to decide whether or not to grant Palisades 20 more years. Yet, the licensing board dismissed the contention, stating 'no facts that would tend to show impacts falling disproportionately on this community have even been alleged." (see pgs. 57-60 of the licensing board's March 7, 2006 ruling dismissing this and all other intervener environmental contentions; also see the contention itself, at Aug. 8, 2005 on the "Palisades Watch" website).
Isn't it obvious that a catastrophic radiation release at Palisades would ruin nearby agriculture for years, decades, centuries, perhaps even forevermore? Who would eat cherries, blueberries, grapes, peaches, apples, or other agricultural products from west Michigan after a large radiation release from Palisades?
(see EIS, p. 2-54 and 55; Table 2-6 shows that nearly half of Van Buren County's land base is devoted to agriculture!) Wiping out of agriculture would very likely impact the low-income, minority community of Latin American agricultural laborers more than any other segment of the surrounding population.
Yet, despite the NRC staff's and licensing board's statements to the contrary, NRC now dismisses any notion of disproportionate impacts upon - or even the existence of - a Latin American agricultural workforce near Palisades, in the space of two sentences. NRC now treats these real people as invisible (EIS, p. 2-57), which represents an environmental justice violation by NRC itself.
--NRC writes (on page Roman numeral xvi of its draft EIS) that "...there are factors, in addition to license renewal, that will ultimately determine whether an existing nuclear power plant continues to operate beyond the period of the current [operating license]." We would agree with that. A catastrophic accident would do that in a hurry. Last October, had the 107 ton fully loaded high-level radioactive waste container dropped onto the waste storage pool floor, Palisades' operations almost certainly would have ended for good - but how much of the Great Lakes and surrounding states would it have taken with it?
We want to make it clear to Consumers Energy, Nuclear Management Company, any potential purchaser of Palisades (such as Exelon Nuclear, Dominion Nuclear, or other nuclear utilities), and to NRC that a groundswell of popular opposition by the citizens of Michigan and neighboring states will, sooner rather than later, force the closure of this most dangerously deteriorated nuclear power plant.
As evidence that we mean what we say, I would like to list the two dozen organizations comprising a growing coalition, representing hundreds of thousands of Michiganders and residents of surrounding states and provinces, which oppose the 20 year license extension at Palisades...(see list at http://www.nirs.org/reactorwatch/licensing/palisadesbackgrounder.pdf)
PalisadesElS - I strongly oppose the proposed 20 Year License xten t Palisades Nuclear Power ant ry Of course, there are many other adverse environmental impacts 20 more years of operations at Palisades would cause. But in addition to all the negatives about Palisades, there are positive alternatives: energy efficiency, wind power, solar power, and biomass could be offered as alternatives to 20 more years of nuclear power and radioactive waste generation. But NRC shrugs off such notions in its draft EIS.
Sincerely, Natalie Hanson 1815 Briarwood Dr.
Lansing, Ml 48917-1773
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I strongly oppose the proposed 20 Year License Extension at Palisades Nuclear Power Plant Creation Date: Sun, Apr 2, 2006 10:46 PM From: <nhanson48@comcast.net>
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