ML110110353

Comment (4) of Dennis Dums and Katie Nekola, on Point Beach, Units 1 & 2 Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed Extended Power Uprate

ML110110353
Person / Time
Site:	Point Beach
Issue date:	01/07/2011
From:	Dums D, Nekola K Citizens' Utility Board, Clean Wisconsin
To:	Rulemaking, Directives, and Editing Branch
References
75FR77010 00004, NRC-2010-0380, TAC ME1044, TAC ME1045
Download: ML110110353 (6)

Text

01/07/11 FRI 16:48 FAX 6082517609 CUB zoo1 Date: January 7, 2011 To:

Chief, Rules and Directives Branch TWB-05-BOIM Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C.

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Subject:

Point Beach Nuclear Plant Units 1 and 2 Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed Extended Power Uprate

01/07/11 FRI 16:49 FAX 6082517609 CUB o002 January 7, 2011 Chief, Rules and Directives Branch (RDB)

TWB-05-BOI M Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C.

20555-0001 To the Chief, Rules and Directives Branch:

The following comments refer to subject matter: Point Beach Nuclear Plant (PBNP),

Units I and 2 - Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed Extended Power Uprate (TAC Nos. ME1044 and ME1045).

Please also refer to Federal Register, December 10, 2010, Volume 75, No. 237, pages 77010-77017, Docket Nos. 50-266 and 50-301, NRC-2010-0380.

These comments on the Point Beach Nuclear Plant Uprate Draft Environmental Assessment and Finding of No Significant Impact (DENFONSI) are being submitted by Citizens Utility Board of Wisconsin (CUB), a non-profit organization that protects utility customers from unreasonable rate irncreases; and by Clean Wisconsin (CW), a non-profit organization that protects the natural resources of the State of Wisconsin.

Point Beach Uprate DEA/FONSI Statement Renardinl Enerav Need Page 3 of the Point Beach Uprate DEA/FONSI states:

The Need for the Proposed Action:

The need for the additional power generation is based upon the goals and recommendations of Wisconsin's 2007 Final Report on "Strategic Energy Assessment Energy 2012" for maintaining a robust energy planning reserve margin of 18 percent. In this report, the State of Wisconsin, Public Service Commission, forecasted an annual growth rate of over 2 percent in demand for electricity.

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01/07/11 FRI 16:49 FAX 6082517609 CUB 0003 CUB/CW Comment 1 The primary "need" for the proposed action as described by the DENFONSI is outdated and inaccurate. Wisconsin does not require an 18 percent energy planning reserve margin. In fact, the "Strategic Energy Assessment Energy 2012", issued in 2007 states:

18 Percent Reserve Margin -

...The Commission will open a docket to review the 18 percent planning reserve margin to see if the requirement best serves Wisconsin given the implementation of the Day 2 Market and other developments focused on better pooling of generation resources regionally..-..The Commission will look to see if reliability can be maintained for Wisconsin customers at a lower reserve margin and help to lower costs. (Wisconsin PSC ERF Ref # 69877, p. 10/100)

The Public Service Commission began its investigation of Wisconsin's energy reserve margin issue in Docket 5-EI-141 on February 18, 2008, and issued an Order on October 10, 2008 with the following determinations and conclusions of law:

"The Commission has reviewed the various studies and the comments and has determined that the planning reserve margin of 18 percent set in 1997 is no longer a reasonable reserve margin figure given the immense structural changes in the wholesale electric market that have occurred since 2001. (Wisconsin PSC ERF Ref # 102692, p. 5)

"The effective 18 percent planning reserve margin requirement established in docket 5-EP-8 is eliminated." (Wisconsin PSC ERF Ref # 102692, p. 7)

Docket 5-El-1 41 established a new planning reserve margin of 14.5 percent for construction or acquisition of electric resources. (Wisconsin PSC ERF Ref #

102692, p. 7)

CUB/CW Comment 2 The statement in the DENFONSI that the forecasted energy annual growth rate in the State of Wisconsin is over 2 percent is outdated and inaccurate.

The draft Wisconsin "Strategic Energy Assessment Energy 2016" (SEA 2016) states:

"The economic downturn in the past two years coupled with the state's generation construction in the past several years creates a current state of excess capacity." (Wisconsin PSC ERF Ref # 139556, p.8/60); and, 2

CONTINUE FROM PREVIOUS PAGE 001 "The recent economic downturn has translated into lower peak demand growth in Wisconsin...peak demand growth has fallen to 1.00 percent per year."

(Wisconsin PSC ERF Ref # 139556, p. 8/60)

Wisconsin has so much excess electrical generating capacity that the Public Service Commission has opened an investigation to review the matter. In June, 2010, the Commission opened Docket 5-El-150 to determine Wisconsin's excess electric generating capacity and the potential mothballing or retirement of existing electric generating units in Wisconsin. (Wisconsin PSC ERF Ref # 133008)

The Nuclear Regulatory Commission (NRC) should update the "need" section of the DEA/FONSI to reflect the current electrical energy surplus in Wisconsin.

Point Beach Uprate DEA/FONSI Statement Regardina Transmission Page 3 of the DEA/FONSI states the following:

The Need for the Proposed Action:

The proposed action provides the licensee with the flexibility to increase the potential electrical output of PBNP Units 1 and 2 from its existing power station, and to reduce Wisconsin's dependence on obtaining power from Illinois via a congested transmission grid connection.

CUB/CW Comment 1 The DEAIFONSI statement regarding the proposed PBNP uprate "reducing" Wisconsin's dependence on obtaining power from Illinois via a congested transmission grid connection is outdated. The American Transmission Company (ATC), the entity responsible for providing reliable transmission services in Wisconsin, has invested $2.2 billion in new and upgraded transmission assets and infrastructure investments. (ATC 10-Year Transmission System Assessment, Summary Report, September 2010) SEA 2016 states that as "...new transmission and generation have come online, many of the (transmission) congestion and loss issues have been relieved." (Wisconsin PSC ERF Ref # 139556, p. 39/60) SEA 2016 also states: "Other states may not be as well-positioned with capacity in their near futures, and Wisconsin utilities may serve as energy exporters...to aid capacity-strapped states." (Wisconsin PSC ERF Ref #

139556, p 25/60)

The NRC should update the DEAIFONSI statements regarding transmission to reflect the current status of transmission in Wisconsin, and that the proposed PBNP uprate is not needed to reduce congestion on Wisconsin's transmission grid connection.

01/07/11 FRI 16:51 FAX 6082517609 CUB CUB/CW Comment 2 The DEA/FONSI statement that implementing the PBNP uprate would "reduce...congested transmission grid connection" is opposite of what would happen if the uprate was implemented. The proposed PBNP uprate would actually result in needing to build more transmission in Wisconsin to enable the PBNP licensee to export the uprate power out of state. The PBNP uprate would require a $173 million investment by Wisconsin ratepayers to pay for the cost of a major 345 kV and 138 kV transmission build-out in and around Manitowoc County, Wisconsin to provide an outlet path for the energy generated by the proposed uprate. (Wisconsin PSC ERF Ref #

142365, p. 17/70)

The NRC should update the DEAIFONSI to address the need to construct transmission to accommodate the energy output from the proposed PBNP uprate and assess the environmental impacts associated with the need to construct transmission facilities.

Point Beach Uprate DEAIFONSI Statement Regarding Wisconsin's Energy Goals Page 3 of the DEA/FONSI states the following:

The Need for the Proposed Action:

The additional 90 MWe provided by each unit would contribute to meeting the goals of the State of Wisconsin to provide efficient and stable nuclear electrical generation.

CUB/CW Comment 1 The DEA/FONSI's statement regarding Wisconsin's "goals" for "nuclear electrical generation" is inaccurate. Wisconsin law does not promote nuclear power as a supply resource. Nuclear power is not listed as a supply resource in Wisconsin's energy priority law. The NRC should revise its DENFONSI to state that Wisconsin does not have a goal of promoting nuclear power.

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CONTINUE FROM PREVIOUS PAGE 001 CUB and Clean Wisconsin respectfully request the NRC to revise the Point Beach Uprate DEA/FONSI to reflect the above comments and concerns.

Sincerely, Dennis Dunms Dennis Dums Citizens Utility Board 16 North Carroll Street, Suite 530 Madison, Wisconsin 53703 Katie Nekola Katie Nekola Clean Wisconsin 122 State Street, Suite 200 Madison, Wisconsin 53703