ML21064A510
| ML21064A510 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/03/2021 |
| From: | Lish C - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 86FR7747 00130, NRC-2020-0277 | |
| Download: ML21064A510 (6) | |
Text
3/5/2021 blob:https://www.fdms.gov/9c4db9a5-e969-46e4-b8cd-27fcac9dee41 SUNI Review Complete Template=ADM-013 As of: 3/5/21 2:31 PM E-RIDS=ADM-03 Received: March 03, 2021 PUBLIC SUBMISSION ADD: Phyllis Clark, Bill Rogers, Kevin Folk, Status: Pending_Post Tracking No. klt-jr6d-l8w3 Stacey Imboden, Mary Comments Due: March 03, 2021 Neely Comment (130) Submission Type: Web Publication Date:2/1/2021 Docket: NRC-2020-0277 Citation: 86 FR 7747 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-0135 Comment on FR Doc # 2021-02001 Submitter Information Name: Christopher Lish Address:
San Rafael, CA, General Comment See attached file(s)
Attachments 210303_nrc-2020-0277-0001_reject_point_beach_nuclear_power_plant_license_extension blob:https://www.fdms.gov/9c4db9a5-e969-46e4-b8cd-27fcac9dee41 1/1
Wednesday, March 3, 2021 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff
Subject:
Reject Point Beach nuclear power plant 80-year license extension -- 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 (Docket ID: NRC-2020-0277-0001)
To U.S. Nuclear Regulatory Commission Chairman Hanson and commissioners:
The supplemental license extension, allowing 80 years of operations at the Point Beach Nuclear Plant, should not be permitted, due to the increasing risk of pressurized thermal shock through-wall fracture of the highly embrittled reactor pressure vessel. Point Beach Unit 2 has the worst-embrittled reactor pressure vessel of any pressurized water reactor 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. I strongly urge the U.S. Nuclear Regulatory Commission (NRC) to produce a comprehensive Environmental Impact Statement (EIS) that analyzes the issues referenced below and to ultimately reject this proposal to extend the license for operations at Point Beach.
It is horrifying that we have to fight our own government to save the environment.
-- Ansel Adams WASTE & STORAGE The EIS needs to explain to the lay person (as well as for the decision-makers) how nuclear fuel is used during the fuel cycle and NextEras process for removing spent fuel and storing this waste material on site.
The EIS needs to address the reasonably foreseeable and perpetual impacts from storage of nuclear waste materials including spent reactor rods.
How will the EIS address existing storage capabilities on site and the additional waste material that will be created over an extra 20 years if the license renewal is granted?
What are the energy requirements (electricity) to safely maintain cooling of spent nuclear fuels? What is the plan to maintain this requirement beyond the time frame that generators are now scheduled to work (5 days)?
How will fluctuating lake levels impact (through erosion, flooding) the integrity a) of the concrete pads that support dry cask fuel storage units as well as b) the air-cooled fuel casks?
How will NextEra safely manage the risks to the Great Lakes watershed if spent fuel eventually is transported to a federally designated nuclear fuel storage site by barges to the port of Milwaukee?
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ACCIDENT/RELEASES
- I request that the EIS address the consequences of a nuclear reactor accident (on the continuum from excess radiation leaks to meltdowns) for each Point Beach Unit and as well as an accident that effects both units for the surrounding communities within a 50-mile radius and for Lake Michigan and Great Lakes watershed.
The Wisconsin Division of Health Services (WI DHS) https://www.dhs.wisconsin.gov/library/P-00442.htm needs to make radiation monitoring available to the public for the past 3 years (2018-2020). Currently there is only monitoring data available up to 2017.
NextEra in conjunction with the WDHHS should include monitoring of air, soil and water during refueling cycles for Point Beachs 2 units (this occurs every 18 months for each unit) as this is the time that excess radiation releases occur and this would be particularly important to vulnerable populations (such as pregnant women, infants and small children), particularly those living and working within the 5 mile radius of Point Beach Nuclear Power Plant.
Updated Evacuation plans from NextEra (now out of date from 2018 on the Manitowoc County website and link broken for Kewaunee County) need to be both provided to those who live, work and go to school/daycare within the 50 mile radius of Point Beach Nuclear Power Plant.
Have families and workers (who could be exposed during an accident) been given information about safe use of Potassium Iodide and will it be provided?
Is there a plan for evacuation of specific events in the 50 mile radius, such as an accident during a Packer game (81,441 people) at Lambeau Field in Green Bay?
How will campers and swimmers utilizing recreation at Point Beach State Forest Beach and Campground be notified and evacuated if there is excess release of radiation or an accident? Should these people (staff, swimmers, and visitors) also be notified when fuel rods are exchanged and there may be excess radiation release into air and water?
Is there a plan to track, monitor and treat anyone who has been exposed to excess radiation during an accident? This would also include information on who will bear responsibility for the cost of this monitoring and treatment over the exposed populations lifespan.
The analysis of a reactor meltdown effect on the human environment is expected in the EIS. This credible scientific evidence relative to assessing the impact of this catastrophic scenario is within the rule of reason and now reasonably available given the incidents at Chernobyl and Fukushima Daiichi nuclear facility. The National Environmental Policy Act (NEPA) requires this analysis per 40 CFR 1502.22 and the agency's evaluation of such impacts based upon theoretical approaches or research methods generally accepted in the scientific community. For the purposes of this section, reasonably foreseeable includes impacts which have catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of reason.
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WATER The EIS needs to address the effects of the release of water into Lake Michigan, the temperature at which the water is released and how that water effects the natural ecosystem in the surrounding lake area. At present, Green Bay and Lake Michigan are experiencing increased episodes of harmful algae and bacteria (cyanobacteria) blooms that affect both the aquatic environment and recreation.
o Are there zooplankton affected that represent a food source to higher order species?
o Has the level of phytoplankton changed since original baseline limnological conditions and will extended licensure perpetuate and/or worsen those impacts?
o Are there threatened or endangered aquatic species at risk from this release?
o Are there aquatic species that we depend upon for our food supply at risk?
o How is the discharge monitored?
o Point Beach Nuclear Power Plant does not have Cooling Towers as part of the normal fuel cycle. Is there a cooling process for the water used during the fuel cycle at present prior to discharge? If so, I would like more information on this process. If not, what needs to be in place?
o In addition to increased temperature, the EIS needs to address both normal/acceptable low level discharge and accidental radiation releases into Lake Michigan and into groundwater vital for communities and farms surrounding Point Beach Nuclear Power Plant.
I request the EIS cover the impact to the soil, shoreline, and lake bottom from the discharge of water. Will there be any erosion and if so, how does that effect the operations at Point Beach and the surrounding aquatic environment?
I request that the EIS covers the threat of water level fluctuations on Lake Michigan.
o Will climate change models and the reasonably foreseeable impacts to water levels and climate conditions (including higher frequency of significant disasters like the Derecho that impacted the Palo, Iowa nuclear plant) be considered?
o What measures would need to be in place to ensure high water levels do not affect the reactors or storage units?
How will the EIS address the transportation of nuclear fuel and waste by barges on Lake Michigan as well as across land and the following risks to the environment?
The EIS must address the current accident rate of all shipping vessels on Lake Michigan.
SOCIO-ECONOMIC I am very concerned about the socio-economic impacts to the community if an accident occurs.
o What would happen to peoples livelihoods, particularly farmers whose land and livestock will be contaminated?
o What would happen to property values?
o What would happen to the fishing and agricultural industry?
o What about businesses that rely on recreational use of Lake Michigan during summer and winter?
o What would the economic consequences be for the county and please specify the indirect socioeconomic consequences on property tax revenues and the State of Wisconsin as a whole?
o Would NextEra compensate the county and people into perpetuity?
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The EIS must address the full impacts to the socioeconomic environment from the no-action alternative. So, if licensure is denied, what is the impact to the wholesale power grid at the end of existing licensure and how does the reduced power to the grid impact reliability to off-takers and subsequent consumers of that electricity.
Does the no-action alternative have significant socioeconomic impacts? Will retraining of nuclear industry workers into jobs in renewable energy be the responsibility of the state or NextEra?
ENSURING ACCESS TO PUBLIC AND OTHER AGENCIES The draft EIS needs to be provided in other languages for the public.
Due to the challenges of internet access in rural areas as well as COVID-19 related precautions, scoping comment cards as well as comment cards for the draft EIS should be mailed to every resident and business within 25 miles of the reactors.
The NRC website encourages the public to submit comments online and does provide a mailing address. However, due to concerns over internet access and postal mail delays in this country, will comments be accepted if they were postmarked on March 3rd?
Information about radiation releases by Point Beach Nuclear Power Plant into soil, water and air by Wisconsin Department of Health Services is not available on their website for the 3 years after 2017. See https://www.dhs.wisconsin.gov/library/P-00442.htm I request an extension of the EIS scoping comment period due to the challenges presented by COVID-19 and lack of internet access for both rural and aging populations.
The results of early coordination and the scoping process, which includes the definition of project scope (actions, alternatives, and impacts), decisions on appropriate assessment methodologies, the extent or depth of analysis necessary, the timing of agency reviews, the project schedule, as well as other agreements and expectations, must be communicated to all involved agencies and the public as early as possible. This information should be included in the environmental document and administrative record. As lead Federal agency, NRC should take special efforts to ensure, before indirect and cumulative impact studies are conducted, that cooperating agencies and key review agencies not object to the scope of review, including the specific methodology to be employed.
ALTERNATIVE ANALYSIS The purpose and need for the proposed action will obviously be based on electric demand on the wholesale power grid and the ability to meet that demand reliably and cost-effectively. For required National Environmental Policy Act (NEPA) proposed action alternative analysis, the EIS should adequately address meeting the purpose and need with alternatives that include alternative energy production scenarios such as photovoltaic plus storage and use of natural gas power plants to help control intermittency of non-hydroelectric renewable electric generation?
When Point Beach was built, alternative energy was not as common and not as economical, therefore this EIS needs to take a hard look at the alternative options of differing energy sources in comparison to the proposed action of extending the license of the reactors. The analysis should include comparative analysis of the Page 4 of 5
proposed action to alternatives with respect to jobs and tax base include indirect effects of alternative energy scenarios in the burgeoning clean energy economy.
The EIS must provide analysis of potential significant positive impacts on the human environment from the proposed action AND alternatives.
The EIS must full address impacts from the no action alternative. If the no action alternative is denial or relicensing both reactor units, this alternative must fully address the impacts of decommissioning the plant and returning the property and land use to its former state. The EIS must provide data to the public that shows adequate funding has been set aside or escrowed for decommissioning and maintaining the spent fuel storage facilities into perpetuity under the no-action alternative.
The EIS needs to address reasonable and prudent alternatives to re-licensing the reactors. This needs to be sufficiently analyzed. This alternative analysis should not only be limited to equivalent power production methods but also power demand reduction measure including broad-based energy efficiency and distributed generation incentives and measures by those power companies purchasing the existing and proposed nuclear-derived power.
Could one of the alternatives to the proposed action be that only one of the two reactors is re-licensed?
o If so, what are the following effects?
o What are the impacts to grid reliability and the resultant indirect socioeconomic impacts (e.g., see impacts from California utility-imposed blackouts during wildfire season)?
o How does the impact of licensure of only one unit impact the cost of power from the nuclear plant as compared to the cost of power from other sources (i.e., does the financial operational efficiency of the plant decrease with only one unit available resulting in a higher cost per kWh or mWh to the wholesale power grid)?
OTHER The EIS needs to address the baseline scientific studies used or the lack of baseline studies to adequately monitor the effects on the environment from the proposed action.
A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise.
-- Aldo Leopold Again, I strongly urge the NRC to produce a comprehensive Environmental Impact Statement that analyzes the issues referenced above and to ultimately reject this proposal to extend the license for operations at Point Beach.
Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.
Sincerely, Christopher Lish San Rafael, CA Page 5 of 5