ML21063A080

Comment (81) of Kevin Kamps Opposing Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, Units 1 and 2

ML21063A080
Person / Time
Site:	Point Beach
Issue date:	02/28/2021
From:	Kamps K Beyond Nuclear, Don't Waste Michigan
To:	Office of Administration
References
86FR7747 00081, NRC-2020-0277
Download: ML21063A080 (2)

Text

3/4/2021 blob:https://www.fdms.gov/ad70d6b2-c568-4aaf-b6e6-928d0089085c blob:https://www.fdms.gov/ad70d6b2-c568-4aaf-b6e6-928d0089085c 1/2 PUBLIC SUBMISSION As of: 3/4/21 6:52 AM Received: February 28, 2021 Status: Pending_Post Tracking No. klp-vk6z-ktmm Comments Due: March 03, 2021 Submission Type: Web Docket: NRC-2020-0277 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 Comment On: NRC-2020-0277-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, Units 1 and 2 Document: NRC-2020-0277-DRAFT-0086 Comment on FR Doc # 2021-02001 Submitter Information Email: kevin@beyondnuclear.org Organization: Beyond Nuclear and Don't Waste Michigan General Comment Point Beach Unit 2 has the worst-embrittled reactor pressure vessel of any pressurized water reactor in the country. NRC staff acknowledged this in writing in 2013. On April 18, 2013, NRC released a summary of the Palisades embrittlement webinar it had held on March 19th, 2013. This document has been referred to as: J. Geissner, Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant. It is available at ADAMS Accession No. ML13108A336. The slides from the NRC Public Webinar, Basis for NRC Requirements on Pressurized Thermal Shock, are available at ADAMS Accession No. ML13077A156. Specifically, on Page 2 of Enclosure 2 of the Summary (Page 5 of 15 on the PDF counter), at point #4, NRC staff list Point Beach 2 and Palisades (in Michigan) as the worst embrittled reactor pressure vessels in the country.

Decades of additional neutron radiation bombardment will only increase the risk of a pressurized thermal shock, through-wall fracture, core meltdown, and catastrophic release of hazardous radioactivity.

To give an idea of how catastrophic, in terms of casualties and property damage, consider the U.S.

Nuclear Regulatory Commission's (NRC) own CRAC-II report. CRAC is short for Calculation of Reactor Accident Consequences. It is also known as "Technical Guidance for Siting Criteria Development," the 1982 Sandia (National Laboratory) Siting Study, NUREG/CR-2239, and/or SAND81-1549.

In the event of a core meltdown at Point Beach 2, CRAC-II predicted: 500 peak early fatalities (acute radiation poisoning deaths); 9,000 peak early (radiation) injuries; and 7,000 cancer deaths (latent cancer fatalities).

In terms of property damages, CRAC-II predicted $43.8 billion, expressed as Year 1982 dollar figures.

When adjusted for inflation alone, this figure would now be $119 billion, in Year 2020 dollar figures.

SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Phyllis Clark, Bill Rogers, Mary Neely Comment (81)

Publication Date:2/1/2021 Citation: 86 FR 7747

3/4/2021 blob:https://www.fdms.gov/ad70d6b2-c568-4aaf-b6e6-928d0089085c blob:https://www.fdms.gov/ad70d6b2-c568-4aaf-b6e6-928d0089085c 2/2 And as Associated Press investigative journalist Jeff Donn reported in June 2011, in the aftermath of the beginning of the Fukushima Daiichi nuclear catastrophe in Japan, in his four-part series "Aging Nukes,"

populations have soared around U.S. nuclear power plants like Point Beach, so casualty figures would now be even worse than CRAC-II predicted nearly 40 years ago.

Donn also cited neutron radiation embrittled reactor pressure vessel pressurized thermal shock risk as the top example of NRC regulatory retreat in the past number of decades.

And as Fukushima has also shown, reactor meltdowns can proceed domino effect at multi-reactor sites. A meltdown at Unit 2 could lead to a meltdown at Unit 1, or vice versa, in which case those casualty and property damage figures above would have to be doubled.

The supplemental license extension, allowing 80 years of operations at Point Beach, should not be permitted, due to this increasing risk of pressurized thermal shock through-wall fracture of the highly embrittled reactor pressure vessel.

Sincerely, Kevin Kamps Beyond Nuclear, radioactive waste specialist Don't Waste Michigan, board of directors member, representing the Lake Michigan chapter Citizens for Alternatives to Chemical Contamination, advisory board member Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 kevin@beyondnuclear.org www.beyondnuclear.org Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.