ML21064A372
| ML21064A372 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/03/2021 |
| From: | Michetti S - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 86FR7747 00129, NRC-2020-0277 | |
| Download: ML21064A372 (12) | |
Text
3/5/2021 blob:https://www.fdms.gov/fd0ac409-5bcd-42b2-a6e3-52176a344a5a blob:https://www.fdms.gov/fd0ac409-5bcd-42b2-a6e3-52176a344a5a 1/1 PUBLIC SUBMISSION As of: 3/5/21 11:09 AM Received: March 03, 2021 Status: Pending_Post Tracking No. klt-fo44-n3fk 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-0134 Comment on FR Doc # 2021-02001 Submitter Information Name: Susan Michetti Address:
Mount Horeb, WI, 53572 Email: sunlightrising@gmail.com Phone: 6083343515 General Comment See attached file(s)
Attachments PtBeachUntrustworthy SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Phyllis Clark, Bill Rogers, Mary Neely Comment (129)
Publication Date:2/1/2021 Citation: 86 FR 7747
1 I strongly oppose unsafe and untrustworthy extension of extremely aged Point Beach license extension, also without sufficient insurance for the damages.
Instead, Point Beach should be put on the schedule to be decommissioned, as its age and increasing embrittlement makes its parts unreliable and unsafe. Its operation is a gamble for a major catastrophe contaminating Lake Michigan.
Culture of untrustworthiness or lacking in integrity is completely unacceptable for public safety:
Any license extension for Point Beach nuclear point is extremely unreasonable and unacceptable for the best interests of Wisconsinites in practically every aspect. First and foremost, Point Beach has an unacceptable culture of untrustworthiness that has been documented by NRC itself in terms of the most major public safety violations in the form of Red Warnings history, demonstrating by the excessive number of these Red Warnings far in excess of any other US plant and I believe far in excess of all other US nuclear power plants. It is an undisputable fact that Point Beach has the worst history of violations and close calls to catastrophe that exists within the entire USA.
Given this history, it would be unscientific for the NRC to proceed forward with the licensing extension at Point Beach simply for the fact that it has the worst history of violations, but that is not the only unacceptable problem at Point Beach.
Worse yet, it has a record of being untrustworthy in terms of integrity and reliability of its information, and this also is another unacceptable area where Point Beach fails to be acceptable. There is evidence in the documentation that indicates a culture of fraud exists to the extent that discrimination by management/ownership occurs against employees who provide more information to regulators and/or to the public. When the full and rigorous information is withheld by Point Beach representatives from the regulators and oversight decision-makers who are responsible for public safety by monitoring safety through the scientific methods, then Point Beach has bypassed scientific operations and has begun to operate Point Beach nuclear plant using unscientific methods that constitute unacceptable betrayal to the NRC and to the public and to the entire planet. Point Beach representatives have blocked rigor and full actual debate required for timely public safety in the past. Given that behavior in the past, anybody who would trust Point Beach now is a gullible fool who should be expecting to be harmed again. Unethical behavior stems from an unethical culture, and these are always unacceptable. Society has relied in the past upon Point Beach to be honest, reliable, and trustworthy in terms of its operations and its behavior and its communications, but Point Beach has showed the public that it cannot be trusted to be considerate of the publics best interests and to be honest and forthcoming timely with information that may adversely impact the public. This is absolutely unacceptable.
This is unredeemable. It is unacceptable to allow untrustworthy business interests to be in charge of nuclear operations.
On August 22, 2006, the NRC wrote Point Beach a warning letter that charged that a senior reactor operator was discriminated against by the companys management for identifying potential technical violations. The discrimination was an apparent violation of employee protection requirements. NRC, Point Beach Summary, Inspection Procedure 95002, <nrc.gov/reactors/operating/ops-experience/degraded-cornerstone/pt-beach-summary.html>
I consider any discrimination against any employee that infringes upon freedom of expression, especially internal affairs at Point Beach that pertain to the identification of potential technical violations, which of course may impact public and environmental safety in a potentially catastrophic way, given the characteristics of radioactive substances, to be such a serious violation of Point Beachs responsibility to the public that a warning letter is only a step in the right direction but insufficient if NRC didnt take this to a higher level beyond this, which is what I expect of enforcement.
I consider that any company that punishes an employee who, in effect, whistle-blows about violations of public trust, including potential technical violations, to be so ethically and morally corrupt to have acquired the status of showing evidence of being untrustworthy in terms of public confidence when Point Beach coerces staff to hide information from its regulators.
2 However, it is also unconscionable for NRC to not have a clear regulation that evidence of a nuclear plant withholding potential violations should automatically call for a very high financial fine as part of a first warning (if this was the first warning) with the promise of suspension of operations license for repeated failure to provide proper information to NRC timely as well as a requirement that the nuclear plant provide the NRC within 10 days a written plan and agreement to ensure that such coercive conduct against any employees full disclosure of potential concerns to the NRC is never repeated. The seriousness of a non-coercion rule against employees should take high priority for the public good.
On December 16, 2005, Point Beach paid a $60,000 fine imposed on January 13, 2006 after two workers deliberately provided NRC inspectors with inaccurate information about the critique of an emergency preparedness drill at the Point Beach reactor in August 2002. The two were fired, and one was convicted in federal court of knowingly making false written statements to the NRC. 3/4 NRC News, No. III-05-046, Dec. 19, 2005 On December 13, 2005, a manual reactor trip shut down Point Beach Unit 1, due to loss of a condenser vacuum caused by failure of the running circulating water pump. Decay heat was being removed by atmospheric dump valves. The backup feed-water system was required. The operator, Florida Power & Light, said there are no known steam generator tube leak issues. 3/4 Notification to NRC, Dec. 13, 2005. It is contradictory to say there are no known steam generator tube leak issues when Point Beach knew that radioactive substances were vented into the external atmosphere for cooling during a pump failure requiring a manual shut down of the reactor. This is blatantly untrustworthy and dishonest.
The NRC needs to create a regulation resulting in a very high financial fine for blatant dishonesty, which includes contradictory information, in order to strictly enforce the seriousness of not hiding information, not covering up dangerous problems, and not behaving unprofessionally as if staff appear to be unqualified for their jobs if they fail to understand the basics. It is unacceptable to the public for any nuclear plant employees to provide safety information lacking in its full integrity and full trustworthiness.
On December 1996, Point Beach owner WEPCO was fined $325,000 for 16 safety violations and a 1996 explosion inside a loaded high-level waste cask. The NRC said WEPCO was inattentive to their duties, starting up a power unit while one of its safety systems was inoperable, and had failed to install the required number of cooling pumps. 3/4 Milwaukee Jrnl Sntl, Aug. 12, 1997, and Dec. 5, 1996.
This shows a culture of recklessness in which hopefully the NRC investigated the possibility of drug use inside the control room may have been a factor, given the fact that drug use was known to be a serious problem causing inattentive work duties in the 1980s and 1990s at Zion Nuclear Plant, also on Lake Michigan in the State of Illinois.
The fact that Point Beachs has a history of untrustworthiness creates a foundation that puts all proprietary secretiveness under this same history. I believe proprietary secrets being put forth by any untrustworthy entity are untrustworthy, by logical extension. It is unacceptable that Point Beach (and apparently the industry) is attempting to place the safety of aging reactor brittleness under proprietary information if I correctly understood the pages and pages of proprietary disclaimers pertaining to the otherwise needed requirement to share important information with the public and by extension I suspect with independent peer review. Any part of these examples of the lack of integrity and lack of trustworthiness is unacceptable when it comes to enforcing public safety which must be the highest priority.
This most aged US plant should have applied for decommissioning, not operating extension:
Point Beach is the most aged deteriorated nuclear plant in the entire USA, not scheduled to be decommissioned. Palisades, which is roughly equally in age to Point Beach, has already been scheduled for decommissioning. Point Beach should be applying to be decommissioned, not for a ridiculous operating extension which can be predicted in advance to likely result in a world-wide catastrophe involving the poisoning of Lake Michigan. As the oldest, most aged, deteriorated, embrittled reactor core, leaking cooling pipes, and other aged materials, Point Beach will likely suddenly encounter multiple failing systems in the case of an actual accident or sudden loss of the power grid.
Such a probable accident is not IF but WHEN, given Point Beachs extreme age and naturally degraded deterioration of critical components. Such an accident would likely degrade and destroy the use of Lake Michigan, similar to the way the Pacific Ocean has been irreparably damaged by Fukushima, as its
3 poisonous radiation can now been found in food from the Pacific Ocean and grown near the Western coast of the USA as well as in food grown in select places all over continental US, depending on where the jet stream carried it.
If some people prefer to not face this horrid threat to the future of humanity and prefer to live only a fake world of wishful thinking that everything will be always great, particularly the owners of Point Beach, it does not change the scientific facts of horror. The facts as measurements of Fukushimas radioactive isotopes found in critical resources unfortunately are facts of horror. The facts of aging and embrittlement at Point Beach and the fact that Point Beach has already been on line beyond its reasonable lifetime is proven by its massive history of NRC Red Warnings. There is no magic wand that can put Fukushima back together again and make the poisonous exposures stop. There is no magic wand that can put Point Beach back together after its aging parts fail into a predictable catastrophe that will poison the people who need to be protected right now by refusing to rubberstamp dangerous and unscientific operations extensions. NRC must stop using rules and timelines that were adopted in the past with flawed scientific considerations, particularly when such rubberstamping violates the most basic safety tenants of science in the way that Point Beach absolutely does simply by its extreme age and faulty parts and faulty components in systems.
Humanity requires radioactive-free water, seafood, and food for its survival. Radiation exposure compromises functionality. This is the hard cold reality of science and rationality. Humanity cannot afford more nuclear poisoning of the planet on which we must live. Very few Wisconsinites will be able to leave this poisoned planet Earth to try to live in the circular city in the sky without sufficient gravity that Elon Musk built in 2020. Our living space, which is planet earth, must be protected from harm for humanitys survival into the future.
Lets not overlook and minimize the fact that radioactive source ingestion from water and food sources is far worse in terms of adverse health impacts than airborne background radiation; this is due to the sources alpha, beta, and gamma radiation qualities of internally becoming a constant radioactive emitter to adjacent cells, tissues, and organs, which, in turn, harms the membranes, mutates RNA expression (often cancer), and permanently damages DNA inside the nucleus of each cell resulting in permanently reproductive mutations that will manifest in the first, second, third, or fourth generation of offspring.
Point Beach is a very old nuclear plant which is leaking unacceptably. Nearby residents objected to actual drinking water contamination with known tritium during Point Beachs first 20-year operating extension, when I believe NRC failed to properly consider the adverse health damage of these residents or considered the health of these residents drinking tritium expendable. The first 20-year operating extension was unacceptable. As a result, the presence of Point Beach has caused a population exodus from the obvious danger zone around Point Beach.
Point Beach unacceptably is now seeking a second extension request, after this egregious harm to residents combined with an atrocious record of unsafe operations at Point Beach that have been extensively documented as red warnings, further compromised as being the most embrittled nuclear power plant in the entire USA.
Radiation is measured in Curies. For example, a large medical center with 1000 labs using radioactive materials may only have 2 curies combined inventory. To ground radiation in reality, the average operating nuclear plant has about 16 billion curies in its reactor core = long lived rad of at least 1000 Hiroshima bombs.
Fuel rods, pipes, tanks, and valves can leak. Mechanical failure and human error also cause leaks. As plant ages, so does its equipment. Leaks increase with age and aging equipment. Each of these physical parts must be physically inspected as the health and safety of Wisconsinites depend upon a carefully documented physical inspection.
Kelly Lundeen and John LaForge at NukeWatch in Wisconsin have identified some of the mechanical failures and human errors that has caused leaks with documented unreliability and untrustworthiness that is of serious concern to public safety. Point Beach reactors have suffered frequent unplanned shutdowns caused by accidents, resulting in official warnings, fines, and even criminal convictions. I agree that it is fair that if a company wants to continue to create tons of high level radioactive waste, they need to prove that they will be doing something different so that none of these accidents will happen again.
As of 2008 three RED findings the highest failure warning issued by the Nuclear Regulatory Commission (NRC) were issued to Point Beach, cumulatively identifying it, in effect, as the worst operating nuclear plant in the US.
At issue were safety procedures that were declared inadequate by NRC inspectors who said the failures existed for many years and that the licensee had seven prior opportunities to identify these
4 inadequacies. The failures and inaction were of high safety significance (a Red finding) under NRC rules.
NRC inspectors found that Point Beachs owners continuously compromised the auxiliary [cooling] feed-water pumps between 2001 and 2007. I appreciate that the NRC issued these red warnings. It is unconscionable to not repair a cooling pump, for example, in a vehicle and then to expect to not overheat the car engine and cause it to be turned off. And that analogy holds with Point Beachexcept that Point Beachs owner is gambling with the future viability of Lake Michigan and a large part of the State of Wisconsin. This reckless gamble is part of the operating experience at Point Beach which has the worst operating experience in the entire nation.
This conduct and culture will likely will cause a future catastrophe, and I do not have faith that Point Beach will make it to the end of its 60th year of operations without causing a planetary catastrophe. These are serious inadequacies when the operating experience of a nuclear plant does not show the professional conduct needed to proactively make standard safety pump repairs timely to basic catastrophe-preventers such as pumps needed to cool the reactor core in an emergency. I can only characterize it as blatant unacceptable gambling and risk-taking.
If NRC hasnt already adopted regulations that put reckless, untrustworthiness, and unprofessional conduct under criminal charges that automatically revoke all previous licensing authorizations, then shouldnt the NRC officially put such regulations in writing to stress the seriousness of enforcement of endangerment of the public and the planet?
On January 15, 2008, Pont Beachs Unit 1 experienced an Unusual Event emergency that was prompted by the complete loss of all offsite electric power to essential buses for more than 15 minutes, mandating a notification of the Nuclear Regulatory Commission. A supply breaker opened for unknown reasons, was being investigated and preparations were made for a Unit 1 shutdown. 3/4 NRC Event 43907, Jan. 15, 2008.
On December 8, 2006, at Point Beach, the Control Room Emergency Filtration System was declared inoperable. The Control Room Charcoal Filter Fan tripped during a surveillance test, an event or condition that could have prevented the filters performance during a contamination emergency or, in the NRCs words, could have prevented fulfillment of a safety function. 3/4 NRC Event 43040, Dec. 8, 2006 On August 22, 2006, the NRC wrote a letter to Point Beach that charged that a senior reactor operator was discriminated against by the companys management for identifying potential technical violations. The discrimination was an apparent violation of employee protection requirements. NRC, Point Beach Summary, Inspection Procedure 95002, <nrc.gov/reactors/operating/ops-experience/degraded-cornerstone/pt-beach-summary.html> Corporate coercion against an employee for doing his legal job to report potential technical violations to their regulator is a serious indicator of untrustworthiness to the public and to the publics safety.
On December 16, 2005, Point Beach paid a $60,000 fine imposed Jan. 13, 2006 after two workers deliberately provided NRC inspectors with inaccurate information about the critique of an emergency preparedness drill at the Point Beach reactor in August 2002. The two were fired, and one was convicted in federal court of knowingly making false written statements to the NRC. 3/4 NRC News, No. III-05-046, Dec. 19, 2005. Any and all untrustworthy information provided to the regulator is a serious indicator that public safety is endangered, particularly when this was closely followed within less than a year with corporate coercion against a different employee reporting accurate information to the NRC (apparently in order to NOT get fired).
On December 13, 2005, a manual reactor trip shut down Point Beach Unit 1, due to loss of a condenser vacuum caused by failure of the running circulating water pump. Decay heat was being removed by atmospheric dump valves. The backup feed-water system was required. The operator, Florida Power & Light, said there are no known steam generator tube leak issues. 3/4 Notification to NRC, Dec. 13, 2005. When a water pump fails and triggers other failures, these are major indicators of inattentiveness to routine maintenance requirements and reckless conduct in terms of the potential dangers to the public across the board and negligent disregard if such reckless could lead to permanent contamination of Lake Michigan. For starters, radioactive contamination in Lake Michigan could lead to millions of gallons of bottled water needed to be provided on a daily basis to residents in 4 states who drink that water. Such a catastrophe would seriously setback the State of Wisconsin, but would also harm Lake Michigans other three shoreline States as well as the USA as a whole.
Eventually, the other Great Lakes and the Saint Lawrence Seaway would be contaminated. Contaminated water cannot be contained. It just flows and flows and finds its way into everything. The internal inconsistencies within the Point Beach narrative of this event consists of more evidence of apparent intent to mislead NRC or cover up information or mischaracterize the seriousness of this event, which at the very least
5 exudes unprofessional conduct. The contradictions between reality and the claim are evidence of untrustworthiness or at least unreliability. This event should not have happened. I believe that this event would not have happened if the owner and its employees were proactively doing preventive maintenance, making timely repairs. For them to also not be forthcoming about the full details is a huge indicator of unprofessional culture. I feel that this nuclear plant is not being operated in the best interests of the public safety and the world-class outstanding natural resources found within Lake Michigan.
On November 9, 2004, while operating at 100 percent power, Point Beach Unit 2 sprang a steam leak from a valve in the main steam flow transmitter. The leak of potentially contaminated steam forced an unplanned shutdown. The leak involved what is called containment penetration of the main steam line passing through the concrete containment building. Accordingly, operators declared a Technical Specification Condition not met, forcing operators to isolate 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 />. Operators were unable to meet the allowed completion time for this task. 3/4 NRC Event 41212, Notification, Nov. 19, 2004. When a valve fails, it is an indicator that routine maintenance is not being done timely and preventively. I suspect employee contamination accompanied this event. This was a serious event, and the shutdown was required.
On April 8, 2004, Point Beach paid a $60,000 fine imposed March 20, for last summers problems with the reactors backup cooling pumps. 3/4 The Capital Times, March 20, 2004. On February 11, 2004, the ongoing risk of a breakdown in Point Beachs cooling feed-water pumps results in a NRC RED finding, the agencys most severe safety failure warning. 3/4 NRC News, Feb. 11, 2004. This is an indicator that NRC appropriately enforced the seriousness of the failure of Point Beach to timely inspect and maintain and replace crucial aged and degraded cooling pumps because this could have led to a public catastrophic recklessness by failure for Point Beach to be responsible. Point Beach was not behaving professionally when it did not properly maintain its facility. This makes it untrustworthy for public safety.
On October 2002, a RED finding was issued by the NRC against Point Beach for problems with cold water circulation for cooling the reactor. 3/4 NRC News, Feb. 11, 2004. Point Beach is not professionally maintaining its reactor for public safety.
November 18, 1997, Point Beach Unit 2 was hastily shut down because of electrical problems. 3/4 Milwaukee Jrnl Sntl, Nov. 18, 1997. Electrical experts should not be having electrical problems. I view this as an indicator of unprofessional conduct, perhaps inattentive employees at work or worseperhaps suggestions of a drug culture present among employees, similar to known drug culture that was attempted to be covered up because it was causing a series of inattentive problems involving events at Zion Nuclear Plant in the 1980s and 1990s, about 100 miles south, also on Lake Michigan.
August 12, 1997, the NRC recorded 21 violations at Point Beach in the 90-day period between Dec.
1996 and Feb. 1997. 3/4 St. Paul Pioneer Press, Aug. 12, 1997. This is a strong indicator of unprofessional conduct to the extent that the public should not put trust in Point Beachs ability to run safely.
July 25, 1997, Reactor 2 at Point Beach was shut down when a cooling water pump failed. 3/4 Milwaukee Jrnl Sntl, Aug. 25, 1997. Water pumps go out when the mechanism age and get too old and fail.
This is an indicator that the plant is not only aging to the point where it is no longer safe as when it was first put on-line, but it is also an indicator that Point Beach ignored doing its professional maintenance safety checks timely. All the various parts and systems should be physically inspected for integrity as part of the EIS, which should address replacements and an inspection schedule for the future.
February 18, 1997, Reactor 1 at Point Beach was shut down when a cooling water pump defect required the pumps replacement. This is a warning that Point Beach is getting too old and its parts will routinely begin to fail and as time goes on the risk goes up and up for a catastrophic accident based on warnings that began prior to Point Beach reaching its 40-year original lifetime where it was considered safe. The very fact that this water pump went out prior to reaching its 40-year lifetime of estimated safety contradicts a fantastic claim I read that the 40-year lifetime was a very conservative calculation by which this declaration created new life on this reactor that contradicted the mechanical evidence in 1997. Pumps are major repairs in terms of their function. If the pumps are going bad, then the cooling pipes are almost certainly going bad, if you ask a mechanic. This reactor was reaching the end of its safe lifetime a few years early in1997 by these facts showing the water pumps going bad. Unit 2 was only a few months behind Unit 1 to have a failing pump.
Anyone making claims that Point Beach still is within the original safety lifetime which isnt limited to 40 years, and who claims that safety lifetime extends beyond 40 years, is making claims inconsistent with the mechanical malfunction history at Point Beach that tells a different story of physical reality. The owners may
6 have replaced and upgraded some parts from necessity after breakdown, but parts such as pumps do not break down and stop functioning, when the owner is attentive timely and proactively to proper maintenance. After a first pump is replaced, there is no excuse to not immediately question the reliability of the other pumps, particularly if they are all about the same age. A lack of physical inspection and lack of timely replacement of worn and degraded parts, especially following the first pump failure, are unacceptable, reckless, and unprofessional.
December 1996. Point Beach owner WEPCO was fined $325,000 for 16 safety violations and a 1996 explosion inside a loaded high-level waste cask. The NRC said WEPCO was inattentive to their duties, starting up a power unit while one of its safety systems was inoperable, and had failed to install the required number of cooling pumps. 3/4 Milwaukee Jrnl Sntl, Aug. 12, 1997, and Dec. 5, 1996. This is unprofessional conduct at the very least, which is an indicator that the plant has crossed over into excessive risk-taking.
Explosions inside of a spent fuel cask could have become catastrophic. Turning on a reactor with an inoperable safety system could have become catastrophic.
May 28, 1996, at Point Beach, a potentially catastrophic explosion of hydrogen gas, powerful enough to up-end the three-ton lid, pushed aside a 6,390-pound cask lid while it was atop a storage cask filled with high-level waste. The lid was being robotically welded to the cask. 3/4 Milwaukee Jrnl Sntl, June 8, 1995. This is an indicator that the spent fuel storage has issues need to be revisited in this EIS.
March 30, 1995, a Point Beach reactor was shut down due to instrument failure in the emergency generator system used to circulate cooling water when regular power is cut off during emergencies. 3/4 Wisconsin State Journal, March 30, 1995. This is an indicator of the failure to timely check crucial components of the emergency system on a proactive basis. This is unacceptable for public safety.
Radioactive contaminated water is often intentionally removed from a nuclear reactor in order to reduce the amount of radiation and corrosive chemicals that are known to cause extensive damage to valves and pipes. This contaminated water is either filtered and recycled back into the nuclear cooling system or released into the natural environment.
Typical 1000 megawatt Pressurized Water Reactor (PWR) without a cooling tower can take in 500,000 gallons per minute from the Lake Michigan for cooling purposes. This water circulates through 50 miles of pipes, likely buried in cement under the plant without a cooling tower, but returns at least 5000 gallons per minute to the water body, and releases the rest as vapor into the atmosphere. The EIS must address the actual gallons per minute of intake of Lake Michigan water using daily water intake temperature, the amount of pipe circulation mileage, the miles of pipes buried in cement, and the actual amount of water released daily back into the Lake at a measured temperature. The EIS must revisit the possibility of adding water cooling tower(s),
given the pipe leakage history in terms of tritium plume and the excessive breakdowns involving circulating the cooling water as well as the need to better control the temperature of water being released into Lake Michigan to avoid impacts.
At Point Beach, the water is taken from Lake Michigan and returned to Lake Michigan in a decreased amount. The return amount would be at least 5,000 gallons per minute, but could be much higher in actuality.
The rest is released as vapor into the atmosphere, and the EIS should address that actual amount and its potential contamination with radioactive substances that should be quantified and identified. The discharge water at Point Beach is contaminated with radioactive elements in amounts that I believe may not be precisely tracked as to their final disposition or spread, but nevertheless are potentially biologically damaging where-ever they land in the external environment. The EIS should address optional methods that should exist to map each daily release individually and then cumulatively over time in the external environment.
Some radioactive fission gases, stripped from reactor cooling water apparently are retained in decay tanks for days before being released into atmosphere thru filtered rooftop vents. Some gases leak into plant buildings interiors and are released during periodic purges and ventings. These airborne gases contaminate the air and then fall-out on soil and water. This is where the term radioactive Fall-out originates. The EIS should address optional methods that should exist to map each daily release and then cumulatively over time and place within the plant buildings interiors of working space.
Radiation releases from routine operation apparently are not fully detected or reported. Accidental releases may not be completely verified or documented. Certainly, Point Beach has a history of not properly reporting accidental radiation releases, which is a huge unacceptable problem, because the cumulative exposure history for nearby residents and others must be as accurate as possible out of human decency, because the public depends upon accurate information in order to make the best informed decisions according to their best
7 interests, including their best medical interests. The EIS must address that Point Beachs data must contain much more detailed information and must be readily available to the public without having to go through time-delays with FOIA in order to know the exposure levels that pertains to ones-own-body. It is unacceptable that Point Beach has releases that expose the public and wildlife and the environment downwind, but those harmed living beings do not have ready access to this data on Point Beachs own web site that may pertain to their own medical exposure calculations. Point Beach plant should be serving the peoples needs, not obfuscating its conduct that harms them perhaps much more than it meets their needs.
Accurate economical and feasible filtering and monitoring technology does not exist for some major reactor by-products, e.g., radioactive hydrogen (tritium) and noble gases (krypton & xenon). Some liquids and gases are retained temporarily in tanks in order to allow shorter lived radioactive materials to be able to break down before the batch is released to environment. The EIS must address this data in quantification descriptions, particularly of batches released to the environment.
Government regulations allow radioactive water containing permissible levels of contamination to be released to environment. It is important to remind that permissible does not mean safe. Detectors at reactors are set to allow contaminated water to be released unfiltered, if the detector indicates that the contamination is below permissible legal levels. At least three types of detectors are required in order to detect the three basic types of radiationalpha, beta, and gamma, each of which has different characteristics of detection. The EIS must verify that each of these detector types is fully functioning, and must verify that they are providing accurate data, and that the public has access at least to the external release identities and radiation wavelength type, quantification, dates of release by given location, and cumulation at given location.
NRC relies upon self-reporting and computer modeling from reactor operators to track radiation releases and projected dispersion. Significant portion of environmental monitoring data is extrapolated. It is virtual, not real. First, there can be issues with virtual data that can only be identified when the information is scientifically physically measured to check the virtual data. Second, self-reporting at Point Beach is a major concern given Point Beachs extraordinary history of being untrustworthy to self-report and to accurate report and to apparently engage in coverups.
Computer modeling of daily and cumulative buildup of radioactive fallout contains likely flaws that miss unique aberrant patterns of wind flow carrying radiation and thereby misjudge theoretical fallout locations. Physical measurements at sites shown by computer modeling verify actual fallout and the degree of the reliability of the computer modeling. As a result, computer modeling must be considered a theoretical tool, and physical measurements are required to be certain that the working data is actually correct, as opposed to theoretical.
Accurate accounting of all radioactive wastes released to air, water, soil from the entire reactor fuel production system is not available. The entire reactor fuel production system includes uranium mines, uranium mills, chemical conversion, enrichment and fuel fabrication plants, nuclear power reactors, rad waste storage pools, casks, and trenches, and decommissioning of that system. The situation is always worse in reality than what is characterized on paper because so many releases remain unknown or unmeasured or undisclosed.
As a result, the situation is repeatedly underestimated. Health and safety measures are also underestimated to the extent that people tend to use underestimated data. All health and safety data must be corrected in the EIS to eliminate underestimated bias of data by determining a calculation formula for the unknown, unmeasured, and undisclosed.
It is no longer acceptable to minimize or to hide the actual extent of a potential catastrophe by claiming the use of conservative figures for damages. People tend to use conservative figures for credibility, even when they know that those numbers are lower than reality. For example, I often see people citing thousands of people using Lake Michigan for drinking water, but Milwaukee has more than a million, and Chicago has 6 million, and Gary Indiana has millions, and we arent counting all the smaller cities that merge into each other between from Point Beach to Milwaukee to Chicago to Gary. This results in gross distortions of impacted individuals. This can be tricky. We also do not want numbers that are exaggerated.
The numbers we need to use should be close to reality.
Increased economic pressures to reduce costs, due to deregulation of the electric power industry, could further reduce already unreliable monitoring and reporting of radioactive releases. Deferred maintenance can increase radioactive releases and risks. Point Beach has a history of Red Warnings from inappropriately deferring maintenance that led to serious problems.
8 The EIS must ensure that monitoring and reporting will be absolutely guaranteed to be up to the standards and the rules, or that some mechanism be put in place to immediately assure that Point Beach will not be allowed to corrupt the integrity of the data and the reporting of releases in the future without the consequence of deterring fines, criminal charges, and permanent loss of operating license from that point forward. Corrupted data deters academic and research discoveries of important associations and causal effects.
If NRC does not have a mechanism in place to pull operating license from untrustworthy and dangerous nuclear generation operations, then the NRC should not be granting extensions past the originally recognized safe lifetime for those operations. A mechanism needs to be in place to stop dangerous nuclear plants from operating past their safe lifetimes, and the various events and warnings given to Point Beach are more than sufficient indicators to show that Point Beach is operating beyond its safe lifetime already, and has been operating beyond that safe lifetime going back to the 1990s, prior to its turning 40 years of age.
Worse yet, many of the reactors radioactive by-products continue giving off radioactive particles and rays for great extraordinary long periods that live-on much longer than the humans that created such radioactivity, which is described as series of decreasing half-lives that varies by each elements structure. A radioactive material gives off hazardous radiation for at least 10 1/2 lives. Iodine-129 has a half-life of 16-million years; technetium-99 of 211,000 years, and plutonium-239 of 24,000 years. Xenon-135 is a noble gas that decays into cesium-135 with 2.3-million-year half-life. These are the toxic poisons being created by operating Point Beach.
When the actual timetable of hazardous generated substance is quantified, it is irrational to create these substances for miniscule human convenience for just a brief blip that barely registers in the actual timetable of the planet.
There is no way to rationally or honestly justify this brief period of toxic production that will poison this planet longer than it has already been in existence. This absurdity alone should disqualify renewal of the Point Beach extension into 80-years of operations to merely provide electricity which humans have managed to live without for thousands of years until 100 to 200 years ago. Other alternatives, such as wind, solar, combined with other sources and technology, are now affordable. If wind and solar hybrids had been subsidized to the extent that nuclear and fossil fuel industries have been subsidized, their affordability in the marketplace would already have brought their natural domination of the worlds energy industries, but they have been politically held back for the most part in comparison. When the playing field is leveled, wind and solar hybrids should be able to supply the publics needs in terms of being most affordable cradle to grave and certainly without the permanent lethal and mutation toxicity combined with catastrophic meltdown potential of nuclear. Heavy metals are problematic, but not as problematic as long-term permanent radiation.
Any exposure to radiation increases the risk of damage to tissues, cells, DNA, and other pivotal molecules, potentially causing programmed cell death (apoptosis), genetic mutations, cancers, leukemias, birth defects, and reproductive dysfunctions and mutations, immune system dysfunctions, Cardio Vascular Disease (CVD), and endocrine system disorders.
Since there does not exist any threshold of radiation below which does not cause some damage to living organisms and to humans, those looking under a high-powered microscope can observe that radiation can be observed indirectly starting with its effect that cause damage to the membranes of the cells. Radiation compromises the critical function of the membrane through which all nutrients must pass into the cell and through which all wastes must leave, if they are not otherwise to become trapped within that cell to the extent that they exert toxicity upon that cell. Radiation in this minimum way causes cells to die (apoptosis) or to mutate over time into cancers or other distortions away from proper function. The cells are basic to tissues, and tissues are basic to organs. Damage at the membrane level is the first step in systemic damage, if the cells do not have sufficient incoming nutrients to do repairs which appears to require sufficient sleep for the timeframe during which membrane and cellular repairs can be done.
Individual variability is considerable and widespread.
As the radiation exposure increases in proximity and/or timespan, as well as increasing in curies or sieverts or other radioactive measurement system, radiation burns and deaths can occur as exposure cumulates from the brief exposure that only harmed the membranes. This was identified in the science that studied the victims of Hiroshima and Nagasaki. Membrane damage being caused by radiation exposure was repeatedly
9 replicated after that, and agreed upon by peer review to have no safe threshold below which damaging effects did not occur.
For example, Red Blood Cells clump together misshapen when their membranes are damaged from radiation; we can call this a rouleau formation (there are other names), where the RBCs bunch up together like a stack of coins lying on its side inside the arterial, where the oxygen coming into the blood flow in the vein from the alveoli by the lungs is blocked from entering the RBCs membrane which first is damaged and which then becomes misshapen and often sticky as a result of the membrane being damaged from the radioactive exposure and the waste inside the cell being stuck inside the cell to poison it along with the extra impacts of invisible radioactivity. Different biologists and scientific researchers call this thickening of blood, or coagulation of blood, or clotting of blood. Alternative medical professionals call it sticky blood. The radiation cannot be seen, but its direct impacts can be observed repeatedly to cause the same misshapen membranes on the cell surface observed when a scientific study controls for dosage and distance and other pertinent factors.
These misshapen Red Blood Cells tend to slow down within the circulation system, as they no longer retain their flexibility to shape-change through tiny veins and arterioles, building up blood pressure as the cells require more and more force to push these misshapen RBC cells through the arteries, especially around the lungs. This is an example of classical radiation poisoning, starting with varying degrees of damage to the cell membranes, which include the cell membranes of the red blood cells which are required to keep circulating oxygen for vitality and energy.
Also, pregnancies so exposed to significant doses deliver too many mutated babies, often developmentally deformed and close to a vegetative state, except containing mammalian protein ratios, often missing ears, mouths, noses, and other critical anatomy required to be self-functioning. Thousands and thousands of photographs of different Chernobyl-exposed offspring document the impacts of radioactive doses from Chernobyl upon off-spring of the exposed pregnant population around Chernobyl as well as that offspring of exposed people who became pregnant later.
The genetic damage is permanent, but it might take 4 generations for these mutations to become visibly observed in offspring. Humanitys gene pool is becoming degraded from cumulative doses of radiative exposure from all sources, and this damage is permanentnot reversible.
This is not an optional matter that humanity can choose to ignore and pretend that this awful truth does not exist and ridiculously hope that such inaction might provide a magic wand to make it disappear. That type of denial in face of the actual physical and measurable fact demonstrates modern mental illness. We as members of humanity are recognizing that we must evaluate adverse and harmful things as disadvantages that we simply cannot allow to harm us, making them unacceptable.
Unsafe, aging nuclear power plants like Point Beach is too risky for humanitys habitat on this planet.
We only have this planet to which our physiology is completely adapted. There are strong indicators that our physiology will not adapt to differences in gravitational fields and other important cradles of our health and physiological systems that when removed from earth experience dysfunctions in major organs and systems required for optimal health. We only have this planet where we can actually live with sufficient health to be truly happy. We are finely tuned to this planets gravitational force, its oxygen and hydrogen levels, its ubiquitous water, the solar rays ability to create Vitamin D, and the Schumann grounding frequency. I disagree with Elon Musk and Bill Gates that half-a-million humans could live in their city in the sky long-term without getting very sick. We must re-evaluate the irrationality of continuing to create toxic waste without any long-term safe storage solution because we are irreversibly poisoning the only place we truly have to live.
This is the most important consideration that should be under evaluation when we start at the most basic thought process to determine the scientific validity of expanding the nuclear operating license a second 20-years when it increases the irreversible poisoning of this planet.
I will remind everyone that the genuine scientific process must allow issues to remain on the table for discussion until all participants form a concensus, or at least the overwhelming majority. Anything less than the ability to go back to the start in order to revisit earlier flawed processes or conclusions will always be pseudo-science. Shouldnt NRC revisit any rules or regulations that may block or interfere with the genuine scientific process?
10 NRC staff acknowledged that Point Beach Unit 2 and Palisades in Michigan are the worst embrittled reactor pressure vessels in the entire nation on April 18, 2013, as documented by Kevin Kamp of Beyond Nuclear.
The NRC identification that Point Beach Unit 2 (along with Palisades in Michigan) are the WORST EMBRITTLED reactor pressure vessels in the entire nation occurs in the J. Geissner, Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant that 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.
I agree with Kevin Kamp that 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. The value of Lake Michigan is far beyond this value as a non-replaceable precious world high quality water resource comprising the largest system of inland fresh water lakes on the planet.
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.
On slide #9 in its slideshow, NRC stated that Operating Experience (OE) is one of several bases for NRC's Safety Review of NextEra's proposal to operate Point Beach for 80 years.
Point Beach's OE, Operating Experience, leaves a lot to be desired. This century, the two reactors at Point Beach, in certain years, had a majority of the NRC's "red findings" -- the agency's highest safety violation designation, amongst the entire U.S. fleet of operating reactors -- then numbering 104 -- combined.
Similarly, at the very same time, Wisconsins Kewaunee reactor -- a short distance from Point Beach (about the same distance as between the now infamous Fukushima Daiichi and Daini nuclear power plants in Japan) -- had a majority of the NRC's "yellow findings," the agency's second highest risk designation, more than the rest of the 103 operating reactors combined. Kewaunee's permanent closure was announced in late 2012, and implemented in early 2013. In fact, Kewaunee's closure commenced a record-breaking number of atomic reactor shutdowns across the U.S. since.
Another such reactor that has closed for good, Fort Calhoun in Nebraska, was given a red finding in the aftermath of a climate change-induced natural disaster: historic flooding on the Missouri River in the spring and summer of 2011. Fort Calhoun never recovered, and was permanently shut down.
Given Point Beach's very bad OE, and the ever increasing risks of breakdown phase age-related degradation accidents and disasters, shouldn't Point Beach simply be shut down for good, and replaced with safer, cleaner, more secure, more affordable renewables sources, such as wind power and solar power, as well as
11 efficiency and energy storage, such as batteries and compressed air energy storage? This is readily achievable, considering the decade or longer left on the two Point Beach reactors' 60-year operating licenses. A decade or longer is plenty of time to achieve such a just energy transition in WI. Especially so, when considering that WI hosts the cutting edge Midwest Renewable Energy Association.
I agree with Kevin Kamp that the supplemental license extension, allowing 80 years of operations at Point Beach, should not be permitted, given its bad OE, and the additional degradation this likely inflicted on the aged reactors' safety-significant systems, structures, and components.
Science relies upon physical inspections of physical reality, not merely theoretical computer modeling with AI guessing and filling-in missing criteria.
I ask NRC to do physical inspections on all aging parts and components that could breakdown and cause safety problems, rather than using only Computer modeling. This includes embrittlement concerns and cooling piping leakages, but goes far beyond those concerns to all embrittled parts that are potentially in danger of suddenly malfunctioning, as it is insane to act as if all these parts will properly function without a physical inspection. The danger is actual, and we need actual physical inspections.
Computer modeling is theoretical, not actual, and we need actual physical inspections for actual physical danger.
Computer modeling is only a first step that may be used to try to predict what may be observed in reality, but computer modeling must not be used as a replacement for inspecting physical reality. We do not live a virtual world. We live in a physical world. The virtual world contains as many flaws as were held in the conceptions of those who claim sufficiency of virtual modeling.
Computer modeling is less accurate than, for example, a much simpler PCR test of an actual piece of physical something claimed to be a virus; or is it an exosome? If the virus is foreign, and the exosome is me, we need a scientific public debate about this inconsistency because Im not foreign to me. Computer modeling uses a lot more assumptions than a PCR test. It is unscientific to use either a PCR test or computer modeling without a rigorous public and scientific debate about the advantages and disadvantages of its inconsistencies and flaws. Those who block the debate and censor the scientific discussion are unprofessional and the antithesis of scientific thinking, which identifies who the practitioners of pseudo-science actually are. We must struggle to ensure that all necessary advantages and disadvantages are thoroughly and rigorously debated in order to identify ALL the danger zones. My point here is that computer modeling is only an initial exploratory tool to provide theoretical information, but it does not provide actual reality.
Computer modeling should only be used to help predict what should be tested in physical reality, which often is quite different than the computer modeling. For example, the early global warming computer modeling said that the maximum change would come from ground zero and outward in radius extensions on the north shore of Lake Superior in Canada by Thunder Bay in 1994, but this computer modeling was faulty, in ways that remained unknown at the same time it was being treated by academics as scientific fact, but this was inaccurate theory. This faulty computer modeling is no longer used, but it did accurately predict many aspects of global climate change, but the human emphasis was off. Computer modeling is an aid to help scientists look for the facts and the anomalies that point to different facts than the computer modeling would have us believe.
Computer modeling is not the end of the scientific process. It is a potential start point, but it does not replace physical testing that likely will contradict some of the findings of computer modeling.
Facts come from physical testing. Theories come from computer modeling, and NRC must never forget that those theories often change when subjected to physical measurements of reality, which can totally change the conclusion. The NRC must not base safety conclusions upon theoretical computer modeling, but upon physical testing.