ML100840638

E-mail from Kristen Eide Tollefson for the PINGP Study Group, Submitting Additional Documents. Submitted with Comments on Draft Generic Environmental Impact Statement for Prairie Island Nuclear Generating Plant, Units 1 and 2, Supplement 39

ML100840638
Person / Time
Site:	Prairie Island, 06300001
Issue date:	01/31/2010
From:	Eide-Tollefson K - No Known Affiliation
To:	Office of Nuclear Reactor Regulation
References
NUREG-1437
Download: ML100840638 (2)

Text

53 Keegan, Elaine From: healingsystems69@gmail.com on behalf of Kristen Eide-Tollefson

[healingsystems@earthlink.net]

Sent: Sunday, January 31, 2010 1:26 AM To: PrairielslandEIS Resource Cc: Kristen Eide-Tollefson

Subject:

Re-sending Comments on DEIS - PINGP Study Group Attachments: PINGP ADVISORY BRIEF(08-509,08-510,08-690).pdf; PINGP Conversion Feasibility Study Exhibit 57.pdf; Sequence of Events for Extended Dry Cask Storage EPRI.pdf; Adaptive Management.doc Please note: 3 attachments were not sent with initial transmission. Please advise if there is any problem accepting these comments. Thank you.

Dear Sir:

When Xcel's application was made, and NRC's review was begun - the fate of Yucca Mountain was still uncertain. Secretary Chu's January 15th announcement that "Yucca Mountain is off the table" (Reuters) confirms a long line of administrative moves throughout 2009 -- which have culminated in the elimination of Yucca Mountain as the nation's permanent repository. This is new, significant information -- and a changed circumstance that fundamentally alters the landscape of license renewal for the Prairie Island plant. The NRC DEIS must evaluate and address it.

If there is no repository, host states, local and tribal governments cannot count on completion of decommissioning, and removal of the waste within decommissioning time lines, or even within the time frame of the nuclear waste confidence decision. Without this assurance, land cannot be reused. And deterioration of temporary nuclear waste storage facilities will create safety, health, ecological costs and hazards -- that are neither described nor estimated in the DEIS. The combined strategies of the NRC GEIS and site specific evaluation for reactor refurbishment and relicensing -- and therefore the current DEIS -- are inadequate to address this new development. NRC must consider applying CEQ's NEPA's recommended Adaptive Management strategies to long term, at reactor storage.

Please find attached the PTNGP Study Group Advisory Brief to the Minnesota PUC dockets on expanded storage to accommodate the relicensing of the PINGP reactors 1 & 2.

The study group finds that the elimination of Yucca Mountain from consideration as a permanent repository, requires additional considerations from NRC in the EIS. Specifically, the EIS should address:

1. Cumulative effects of skyshine radiation with larger numbers of casks, as discussed in our brief,

2. Additional monitoring as discussed in our brief to support a long term strategic adaptive management plan;

3. Environmental Justice considerations as discussed in our brief; The development of additional information and analysis to address and mitigate indefinite at reactor site 1

storage is essential:

1. A full Environmental Site Assessment to support strategic long term management;

2. Convening of an Adaptive Management Workgroup (see attachment: Adaptive Management);

3. A recommended timeline for cask and facility replacement, using the Yucca Mountain No-action engineering studies on factors for cask and facility degradation;

4. Discussion of provision for wet and dry transfer capacity for long term storage as per attached EPRI diagrams on Sequence of Events for Extended Dry Cask Storage. Also for security and safety for extended storage - from the 100 to 500 years discussed in the recent GAO report;

5. Discussion of what an Adaptive Management Plan for long term waste storage at PINGP would look like (see attachment: Adaptive Management);

6. Reevaluation of alternatives, specifically conversion, replacement or repowering of the PINGP with combined cycle gas turbines, in light of irreversibility of committment of resources (see attachment: PINGP Conversion Feasiblity Study Exhibit 57);

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