ML22004A353
| ML22004A353 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/30/2021 |
| From: | Cunningham J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 86FR62220 00024, NRC-2020-0277 | |
| Download: ML22004A353 (2) | |
Text
1/4/22, 2:34 PM blob:https://www.fdms.gov/88e5a532-6b1f-4498-a98f-7a27b022aa1a SUNI Review Complete Template=ADM-013 As of: 1/4/22 2:34 PM E-RIDS=ADM-03 Received: December 30, 2021 PUBLIC SUBMISSION ADD: Phyllis Clark, Stacey Imboden, Mary Status: Pending_Post Tracking No. kxt-qw2y-qnmy Neely Comment (24) Comments Due: January 03, 2022 Publication Date: Submission Type: Web 11/9/2021 Citation: 86 FR 62220 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-2020-0277-0194 NextEra Energy Point Beach, LLC; Point Beach Nuclear Plant, Units 1 and 2 Document: NRC-2020-0277-DRAFT-0220 Comment on FR Doc # 2021-24407 Submitter Information Name: James Cunningham Address:
Powell, OH, 43065 Email: jimc.guitarz@gmail.com Phone: 6143260730 General Comment These comments are made regarding the NUREG-1437 Supplement 23 Second Renewal EIS document pertaining to the renewal of license to operate the Point Beach Nuclear Plant Units 1 and 2 well beyond the established duration limits of safe operation as laid out in the initial design parameters.
The proposed action fails to establish a viable purpose.
The purpose and need for the proposed action (i.e., issuance of subsequent renewed facility operating licenses for Point Beach) is to provide an option that allows for power generation capability beyond the term of the current nuclear power plant renewed operating licenses to meet future system generating needs.
This initial statement ignores the fact that the units are already operating beyond their designed limits of safe operation. In making this statement, the NRC is abrogating the regulatory aspect of the agency itself, rendering this EIS an exercise in pro-corporate profit sophistry rather than an examination of scientific facts regarding safe operation to benefit the public. It is my understanding that the whole point of having an NRC is to protect the public from the greed-based motives of for-profit businesses in any form, in this instance relating to those involved in the operation of these units. It also summarily ignores a wide range of viable alternatives in favor of propping up energy company profits.
Regarding the alternatives section, there are not only blatant falsehoods, but also a complete failure to truly address all alternatives.
The NRC staff evaluated each potentially feasible and commercially viable replacement power blob:https://www.fdms.gov/88e5a532-6b1f-4498-a98f-7a27b022aa1a 1/2
1/4/22, 2:34 PM blob:https://www.fdms.gov/88e5a532-6b1f-4498-a98f-7a27b022aa1a alternative and the no-action alternative using the same resource areas that it used in evaluating impacts from license renewal. The NRC staff also evaluated any new and significant information that could alter the conclusions of the SAMA analysis that was performed previously in connection with the initial license renewal of Point Beach in 2005.
It is apparent to me that the same resource areas used for evaluating impacts from this license renewal are woefully inadequate and most likely seriously outdated. After disregarding recent data available for a range of clean energy alternatives, the NRC is discarding multiple viable alternatives and focusing on just three, two of which rely on technology that does not even exist - Small Modular Reactors have not even been designed let alone tested, proven or manufactured. Reliance on non-existent technology is fantasy and has no place in a serious appraisal of public safety. There is no composite 100% renewable energy alternative considered. Furthermore, if the license at PBNP is not renewed, the alternatives considered do not include the use of wind power, either onshore or offshore, or simple energy conservation.
The NRC staffs preliminary recommendation is that the adverse environmental impacts of subsequent license renewal for Point Beach are not so great that preserving the option of subsequent license renewal for energy-planning decision makers would be unreasonable.
This recommendation statement egregiously ignores the fundamental nature of nuclear energy in that it requires great danger to acquire and process the fuel, no human being has even a remote idea of what to do with the massively toxic and essentially eternal waste, or the very real possibility of catastrophic failure which would contaminate the drinking water for millions of American citizens for decades, if not centuries - not to mention the potential loss of life for anyone nearby or the many decades of radiation poisoning that would inevitably follow. I cannot agree that the profits generated or the power delivered are worth the potential for widespread death, disease, and destruction.
As it stands, this section of the EIS is not simply completely inadequate, it is downright dangerous.
This document is full of statements which rely on outdated information.
The section on climate change needs to be completely rewritten so that it is based on the most current data from the Intergovernmental Panel on Climate Change - the IPCC 2021 report. AR6 Climate Change 2021: The Physical Science Basis, was published August 2021, but is not referenced in this document.
The immediate and imminent impacts of climate change on operations at PBNP are new categories of consideration for an EIS, and much of the science and observed changes are recent phenomenon, which underscores why the most current data must be used and why this topic should receive an updated, current appraisal of conditions. With more than 1,000 metric tons of eternally toxic nuclear waste stored on site, and the continued operation of reactors which are operating well beyond their designed duration limits, the use of fourteen-year-old data is not acceptable as a basis for evaluating the multiple risks to public safety.
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