ML110100330

Comment (2) of Christopher Laforge, Opposing Point Beach Extended Power Uprate (EPU) Proposal

ML110100330
Person / Time
Site:	Point Beach
Issue date:	01/06/2011
From:	Laforge C Florida Power & Light Energy Point Beach
To:	Rulemaking, Directives, and Editing Branch
References
75FR77010 00002, NRC-2010-0380
Download: ML110100330 (2)

Text

01/01/1999 00:02 7157743374 CHRIS LAPORGE PAGE ý 01 Y~il _ 7 mIi 8:1 Janua/y6, 2011 Chief Rules and Directive Branch TWB-05-BO1M Division of Administrative Services Office of Administration U.S. NIRC Washington, DC 20555-0001 Christopher LaForge Great Northern Solar 77480 Evergreen Rd Ste. 1 Port Wing, WI 54865 Re.

Point Beach Extended Power Uprate (EPU) proposal Federal Register 10 Dec. 2010, Vol. 75, No. 237, page 77010-77017 Docket Nos. 50-266 and 50-301; NRC-2010-0380 To the Chief, Rules and Directive Branch:

Please deny the Point Beach's "extended power uprate" (EPU) proposal.

The "Uprate" will swress the already faulty systems of the 40-year-old reactors (see list of operating failures appendix 1).

The proposal admits that the "uprate" will increase radioactive exposure to the local population:

The Federal Register notification for this proposal (<htp,.//edcket.access._pogov/20IO12010-31085.htm>) admits that approval would cause a 17 percent increase in the radioactivity in the gaseous and liquid waste produced by the reactors (p. 77014). But surprisingly, the Environmental Assessment (EA) asserts that no improvements or alternations in current reactor or waste treatment machinery will be necessitated by the Extended Power Uprate (p. 77015).

The notice states:

"Offsite Doses at EPU Conditions:

"The primary sources of offaite dose to members of the public from the PBNP are radioactive gaseous and liquid effluents. As discussed above, operation at the proposed EPU conditions will not change the radioactive gaseous and liquid waste management systems' abilities to perform their intended functions. Also, there would be no change to the radiation monitoring system and procedures used to control the release of radioactive effluents in accordance with NRC radiation protection standards in 10 CFR Part 20 and Appendix I to 10 CFR Part 50.

."Based on the above, the offsite radiation dose to members of the public would continue to be within regulatory limits and therefore, would not be significant."

Plants like this should be phased out as soon a possible to reduce further public hazard. The plant creates exposure to ionizing radiation.

Any and all exposure to ionizing radiation, internal or external, increases one's chances of cancer, birth defects, immune system dysfunction and other illnesses. The consequences of radiation exposure are kmown to be far more severe in the case of women, children, infants, fetuses and persons with compromised immune systems than in the case of "Reference Man" the standard still used by the NRC to estimate radiation risk.

/-/-)-H3 C7ý63-

01/01/1999 00:02 7157743374 CHRIS LAFORGE, PAGE 02 Because the operators of the Point Beach reactor complex have already been convicted of and fined $60,000 in 2005 forprowindg false information to federal regulators.- and. $325,000 for 16 other violations - claims by the licensee in-the Federal Register notification and in the licensee's EA above should be closely scrnlinized.

Because the two reactors in question are 40 years old they cannot be expected to operate safely even at low power.

Forthese, important reasons theproposed.power, uprate should.be denied. and decommissioning of the entire fility Abulddbe put on-the ajenda, and fast tracked.

Energetica lly.

s Appendix 1: pa~rtial :record of its omperratinng fail

• On January 15, 2009 PBNP Unit I experienced a complete loss of all offsite electric power to essential buses for more than 15 minutes, an "Unusual Event" emergency mandating notification of the NRC. (NRC Event 43907)

• In December 2006, the PBNP Control Room Emergency Filtration System was declared inoperable. The breakdown, in the NRC's words, "could have prevented fulfillment of a safety fimction." (NRC Event 43040, Dec. 8, 2006)

• On August 22, 2006, the NRC charged in a letter to the PBNP that a senior reactor operator was discriminated against by PBNP management for identifying potential technical violations, in violation of employee protection requirements. (NRC, "Point Beach Summary," Inspection Procedure 95002,

<nrc.gov/reactorWoperating/opsc perience/degraded-comrerstonept-beach-summary.htn)

• On December 13, 2005, a manual reactor trip shut down PBNP Unit I due to the loss of a condenser vamcm caused by the failure of the running circulating water pump. (Notification of NRC, Der. 13, 2005, event date Dec. 13, 2005) Other emergency shutdowns caused by cooling water problems or electrical-accidents have occurred Nov. IS, 1997; July 25, 1997; and March 30. 1995. (Milwaukee Journal Sentinet, Nov. 18, 1997; August 25, 1997; and Wisconsin State Journal, March 30, 1995)

• In November 2004, while operating a 100 percent power, PBNP Unit 2 sprang a steam leak from a valve--

in the main steam-flow transmitter. Operators declared a Technical Specification Condition "not met,"

forcing the isolation of the "affected penetration flow path with a completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />." However operators were unable to meet the required completion time of this task. (NRC Event 41212, Notificatin date Nov. 11, 2004)

• PBNP was fined $60,000, imposed March 20, 2004, for problems with the reactor's backup cooling

.pumps, according to the Capital Times, March 20, 2004.

• On Feb. 11, 2004, the ongoing risk of a breakdown in the cooling feed-water pumps at PBNP resulted in a NRC "Red Finding", the agency's most severe safety failure warning. (NRC News, Feb. 11, 2004)

• In August 1997, the NRC recorded 21 violations of its regulations by PBNP in the 90-day period between December 1996 and Feb. 1997. (St. Paul Pioneer Press, September 12, 1997)

• PBNP was fined $325,000 for 16 safety violations and a 1996 explosion inside a loaded high0level waste cask The NRC said BPNP was "inattentive to their duties," "starting up a power unit while one of its safety systems was inoperable," and failed to install "the required number of cooling pumps." (Milwaukee Journal Seninel, August 12, 1997 and Dec. 5, 1996)