ML110140553

Comment (11) of John Laforge Opposing Point Beach Extended Power Uprate (EPU) Proposal

ML110140553
Person / Time
Site:	Point Beach
Issue date:	01/05/2011
From:	Laforge J Nukewatch
To:	Rulemaking, Directives, and Editing Branch
References
75FR77010 00011
Download: ML110140553 (2)

Text

January 5, 2011 John LaForge SNukewatch Co-director 740A Round Lake Rd.

Luck, Wisconsin 54853 Chief, Rules and Directive Branch, TWB-05-BO1M Division of Administrative Services

-J

£2 Office of Administration, U.S. NRC Washington, DC 20555-0001 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:

The Federal Register notification for this proposal (<lit i p J /.'edocket-.acc es!s.- po. go*vo20 1-,0,:201]0 310. 85.-ht

>) 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 offsite 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."

It is a relief to see the licensee acknowledge that, "The primary sources of offsite dose to members of the public from the PBNP [Point Beach Nuclear Plant] are radioactive gaseous and liquid effluents."

Any and all exposure to ionizing radiation, internal or external, increases one's chances of cancer, birith deflects, immune system dysfunction and other illnesses. The consequences of radiation exposure are known 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 archaic, gender-biased and unscientific standard still used by the NRC to estimate radiation risk.

However the assertion, that "the proposed EPU conditions will not change the radioactive gaseous and liquid waste managernent systems' abilities to perform their intended functions" -- written with the sophistication of a fairytale --

must not be taken seriously.

The licensee's declarations of robustness in its operator's and waste management systems is completely without verification and is refuted even by the following partial record of its operating failures:

The Progressive Foundation - Nukewatch - 740A Round Lake Road, Luck, WI 54853

• (715) 472-4185 nukewatchl@lakeland.ws

• www.nukewatch.com

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• On January 15, 2008 PBNP Unit 1 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 fungion." (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/reactors/operating/ops-experience/degraded-cornerstone/pt-beach-summary.html)

• On December 13, 2005, a manual reactor trip shut down PBNP Unit I due to the loss of a condenser vacuum caused by the failure of the running circulating water pump. (Notification of NRC, Dec. 13, 2005, eyent date Dec. 13, 2005) Other emergency shutdowns caused by cooling water problems or electrical' accidents have occurred Nov. 18, 1997; July 25, 1997; and March 30, 1995. (Milwaukee Journal Sentinel, 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 fo this task. (NRCEvent Number 41212, Notification 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 feedwater 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 Sentinel, August 12, 1997 and Dec. 5, 1996)

Since the operators of the Point Beach reactor complex have already been convicted of and fined $60,000 in 2005 for providing false information to federal regulators - and, $325,000 for 16 other violations -- absolutely nothing claimed by the licensee in' Federal Register notification and in the -licensee's EA should be believed. Rather, unverified claims made by the licensee must be scrutinized with the utmost skepticism.

Because the two reactors in question are 40 years old, have a record of poor operations and accidents, have been convicted of harassing whistleblowers and of lying to government regulators, and cannot be expected to operate safely even at low power, the proposed power uprate should be denied with extreme prejudice.

With all due respect, John LaForge