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Category:General FR Notice Comment Letter
MONTHYEARML23005A2082022-12-29029 December 2022 Comment (14) of B. Iris Potter on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A1982022-12-27027 December 2022 Comment (8) of Terry Lodge on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A1972022-12-27027 December 2022 Comment (7) of Kraig Schultz on Behalf of Schultz Engineering on Holtec Decommissioning International, LLC, Palisades Nuclear Plant, Post-Shutdown Decommissioning Activities Report ML23005A2012022-12-27027 December 2022 Comment (9) of Kathryn Barnes on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2022022-12-27027 December 2022 Comment (10) of Mark Muhich on Behalf of Sierra Club Nuclear Free Michigan on Holtec Decommissioning International, LLC, Palisades Nuclear Plant, Post- Shutdown Decommissioning Activities Report ML23005A2032022-12-27027 December 2022 Comment (11) of the Council on Intelligent Energy & Conservation Policy and Promoting Health & Sustainable Energy on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2052022-12-27027 December 2022 Comment (12) of Michael J. Keegan on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2062022-12-27027 December 2022 Comment (13) of Kevin Kamps on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2102022-12-27027 December 2022 Comment (15) of Kay Cumbow and Victor Mcmnemy on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2112022-12-27027 December 2022 Comment (16) of Terry J. Lodge on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A2132022-12-27027 December 2022 Comment (17) of Kevin Kamps on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A1932022-12-26026 December 2022 Comment (5) of Steve Smith on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML23005A1952022-12-26026 December 2022 Comment (6) of Ryan Pickering on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML22355A1482022-12-21021 December 2022 Comment (4) of Shawn Connors on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML22355A1422022-12-20020 December 2022 Comment (2) from Karen Schaumann Re Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML22355A1472022-12-20020 December 2022 Comment (3) of Matthew C on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report ML21069A0392021-03-0303 March 2021 Comment (173) of Kevin on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Unit Nos. 1 and 2 ML21041A1262021-02-0909 February 2021 Comment (4) of Cathy Sayre on Palisades Nuclear Plant and Big Rock Point Plant Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments ML21040A2152021-02-0808 February 2021 Comment (2) of Stephen C. Brown on Palisade Nuclear Plant and Big Rock Point Plant Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments ML21040A2172021-02-0808 February 2021 Comment (3) of Richard Barron on Palisades and Big Rock Point Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments ML21040A2112021-02-0707 February 2021 Comment (1) of Mark Muhich on Palisade Nuclear Plant and Big Rock Point Plant Consideration of Approval of Transfer of Control of Licenses and Conforming Amendments ML16015A3272016-01-0707 January 2016 Comment (2) of Jan Boudart Regarding Guidance: Subsequent License Renewal ML15139A0832015-05-12012 May 2015 Comment (10) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0822015-05-12012 May 2015 Comment (15) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0342015-05-12012 May 2015 Comment (12) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0332015-05-12012 May 2015 Comment (11) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0322015-05-12012 May 2015 Comment (9) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0302015-05-12012 May 2015 Comment (7) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML15139A0292015-05-12012 May 2015 Comment (6) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule ML14309A1912014-10-31031 October 2014 Comment (4) of Sandy Mccomb on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations ML14309A1922014-10-30030 October 2014 Comment (00002) of Michael Keegan on Behalf of Don'T Waste Michigan on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations ML0804203042008-01-21021 January 2008 Comment (1) of Tom Gurdziel Opposing the Inclusion of Vermont Yankee, Indian Point Unit 1, Indian Point Unit 2, and Indian Point Unit 3 in a Holding Company Owned by Entergy ML0636204232006-12-12012 December 2006 Comment (1) of K. A. Westlake on Behalf of EPA Re Generic Environmental Impact Statement for License Renewal of Nuclear Plant, Supplement 27: Palisades, Final Report, NUREG-1437 ML0625500622006-09-0505 September 2006 Comment (22) of Kimon Kotos on Nrc'S Low-Level Radioactive Waste Program. Supports Position Submitted by Nirs and Recommends Not to Renew Palisades License Extension ML0618600692006-06-22022 June 2006 Comment (16) of Terry J. Lodge Regarding Notice of Pertinent New Case Law Affecting Proceeding: Request for Redraft of EIS, Additional Comment Period, and for New Period for Receipt of Contentions on Terrorism ML0619204802006-06-19019 June 2006 Comment (17) of Martha Macfarlane Faes, Re ER-05-249, Palisades Nuclear Power Plant License Renewal, Covert Township, Van Buren County (NRC) ML0616401142006-05-26026 May 2006 Comment (14) of Kenneth A. Westlake on Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 27: Palisades Nuclear Plant, Van Buren County, Michigan, Draft Report, NUREG-1437 ML0615700222006-05-18018 May 2006 Comment (12) of Kevin Kamps on NUREG-1437, Supplement 27, Draft ML0615700422006-05-18018 May 2006 Comment (10) of Various, on NUREG-1437, Supplement 27 to Generic Environmental Impact Statement for License Renewal of Palisades Nuclear Power Plant ML0615700252006-05-15015 May 2006 Comment (13) of Michael T. Chezik for Renewing License for Palisades Nuclear Plant ML0615700202006-05-15015 May 2006 Comment (11) of Terry and Laura O'Brien on NUREG-1437, Supplement 27 Re Opposition of the Renewal of the Palisades Nuclear Power Plant License ML0613705092006-05-15015 May 2006 Comment (8) of P. Harden Draft Supplement 27 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG 1437, for Palisades Nuclear Plant License Renewal ML0613200362006-05-0101 May 2006 Comment (7) of Diane Byme, Re While for Safe, New, Nuclear Plants/Technology, Feels in Best Interest of Public for Safety Issues to Close Down Palisades and Not Renew License ML0612402062006-04-23023 April 2006 Comment (6) of Marguerite Callaghan for Renewal of License for Palisades Nuclear Facility ML0614601462006-04-19019 April 2006 Comment (9) of Morgan Dill, Opposing License Renewal of Palisades ML0612100512006-04-10010 April 2006 Comment (3) of Paul C. French, Jr., Supporting Renewing License for Palisades Nuclear Generating Plant for Another 20 Years ML0612100432006-04-0202 April 2006 Comment (5) of A. Hanson, Strongly Opposing the Proposed 20 Year License Extension at Palisades Nuclear Power Plant ML0612100442006-04-0202 April 2006 Comment (4) of N. Hanson, Strongly Opposing the Proposed 20 Year License Extension at Palisades Nuclear Power Plant ML0609000432006-03-20020 March 2006 Comment (1) of Ruben Dal Monte P.E., on NUREG 1437, Supplement 27 Draft, Re Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Palisades Nuclear Plant; Draft Report for Comments, Us NRC February 2006 ML0616502572006-02-23023 February 2006 Comment (15) of Connie & Jim Mcallister on Public Meeting to Discuss Draft Environmental Impact Statement for Palisades Nuclear Plant 2022-12-29
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b -He 4'P /0 ile April 19, 2006 Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 RULES A ES 1 ,, ,. 59 ,B Itt I 9 t-.10 8 5 To Whom It May Concem: I am writing regarding the proposed twenty-year license extension at PalisaJ lep ant ini isouthwest Michigan.
I oppose the license renewal because Palisades is an aging facility with a history of noncompliance, reactor pressure vessel embrittlement, radiation release, and other problems that have and will continue to affect the surrounding population beyond Covert Township, Michigan.
Many of those affected in the surrounding area are of low socioeconomic status, as well as minorities, raising the issue of environmental justice.License renewal should not be granted to the Palisades Nuclear Power Plant, because (1) both of the dry cask storage pads at Palisades are in violation of Nuclear Regulatory Commission's earthquake regulations (2) the_xisk-of radiation to-mino*iy populations is underestimated using census-blockgrouping, (3) radiativeffctsare only considered within a 50-mile radius; and (4) there is continued noncompliance of non-radiological persistent toxic chemicals to area water sources.Potential amplification of earthquakes through soil-structure interaction, and soil liquefaction potential or other soil instability due to vibratory ground motion are of great concern, especially considering the geological nature of sand increasing the likelihood of sand avalanches (Landsman 2005). The violation of the Nuclear Regulatory Commission's own standards in storage of radioactive material must be followed.'
Covert Township is one with high levels of minority populations and has many people who are of a low socioeconomic status. In the impact statement, these populations were taken into consideration, but large urban centers such as Battle Creek, Muskegon and Grand Rapids -where significant African American and Latin American communities live -were not considered.
Because less than fifty percent of these cities were within the 50-mile radius, they were eliminated, and therefore significant risks to the minority populations were not fully documented." The 50-mile radius considered in the impact assessment also fails to account for the movement of radiation with the wind. The radiation may expand and become less concentrated as it moves away from the epicenter (NRC 2006), but recent studies have shown that there is no safe level of ionizing radiation (NAS 2005). The effects beyond the radius cannot be ignored or discounted as negligible without serious ethical repercussions with this knowledge of toxicity of any level of radiation."'
The impact of 20 additional years of pollution by non-radiological toxic chemicals will directly affect water quality of nearby sources, including Lake Michigan.
In 2000, for example, Palisades was found to be in 'continuing nonro plianceflbXs&apparentmultiple-misuses-ofBetz-Cbm-Trol in Lake Michigan for-the dispersion of mussels and clams affecting the reactor's water intakes (EPA 2004). The public health risks imposed by Betz Clam-Trol (Alkyl Dimethylbenzyl Ammonium Chloride)
-immunological, neurological, respiratory, dermal and gastrointestinal
-are counter to the Nuclear Regulator Commission's upimary mission to protect public health and safety." (ATSDR 2004 and NRC 2004)v'For these reasons, I oppose the renewal of the Palisades Nuclear Power Plant license for an additional twenty years. The plant is a danger to not only our precious natural resources in Michigan, but to countless people who are affected by its daily operation, and many more who would be affected should a disaster occur.Thank you for your consideration, Morgan ill 3779 140e Avenue Holland, Ml 49424-...: ..n i ::AJ d:,(d -C (D3U It &O (9X 3)v -Av -e9 / -3 a 0 Page 2 April 19, 2006 Appendix with Additional Information
' 10 CFR Part 72.212(b)(2)(i)(B) is the law that regulates earthquake standards.
The more casks loaded on the storage pads at Palisades, the more risk of erosion to the sand supporting the pads, given the large weight of the casks themselves (VSC-24 casks weigh 132 tons each), weather related erosion of the sand dunes, as well as the erosion that will occur due to more severe weather impacts from the global climate crisis and climate de-stabilization.
Arresting erosion at both pads is important to safety and radiation containment over the long haul, given the proximity of the waters of Lake Michigan.
The State of Michigan and the U.S. Army Corps of Engineers have designated the sand dunes upon which the older pad is located -so close to the waters of Lake Michigan -as a high-risk erosion zone. Though Michigan itself is a region of "low riskl for earthquake occurrence (Bricker 1977), this does not remove the chance that the event may occur, necessitating compliance with the law.it Census block groups are a combination of census blocks, which are statistical subdivisions of a census tract, which are intended to remove bias (USCB 2000). Though eliminating bias in collection of data, the full impact of the data is not demonstrated in regards to minority populations, in their elimination from the data set considered in the Environmental Impact Statement for Palisades (because <50% lay within the 50-mile radius).Wind has played a factor at other nuclear plants, notably at Three Mile Island. The effects of radiation were present at the epicenter, and upwind, throughout Pennsylvania and beyond. Increased incidences of cancer and other health problems pervaded, and the influence of wind cannot be ignored in the transportation of radiation (Momeni 1998).I'v Maintaining unclogged water intakes using Betz Clam-Trol falls within the scoping parameter of 10 CFR Part 54 that says: (a) Plant systems, structures, and components
... [including]
(2) All non safety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1) (i), (ii), or (iii) of this section (10 CFR 54.4 Scope). The International Joint Commission
-an independent binational organization that serves to help prevent and resolve disputes relating to the use and quality of boundary waters -stated in its "Ninth Biennial Report on Great Lakes Water Quality," that "[g]ovemments monitor toxic chemicals used in large quantities at nuclear power plants, identify radioactive forms of the toxic chemicals and analyze their impact on the Great Lakes ecosystem." The impact of Betz-Clam Trol is such that water resource quality is affected in a way that compromises the agreements made through the Boundary Waters Treaty of 1909, and subsequent Great Lakes Charter and Annex, that call for maintaining the integrity of the freshwater ecosystem.