ML23005A208

Comment (14) of B. Iris Potter on Holtec Decommissioning International, LLC Palisades Nuclear Plant Post-Shutdown Decommissioning Activities Report

ML23005A208
Person / Time
Site:	Palisades
Issue date:	12/29/2022
From:	Potter B Michigan Safe Energy Future, Kalamazoo Chapter
To:	Stacy Schumann NRC/OGC, Office of Administration
References
NRC-2022-0158, 87FR52598 00014
Download: ML23005A208 (1)

Text

SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03

ADD: Marlayna Doell, Sarah Achten, Pam Buzdygon-Menefee, Mary Neely Comment (14)

Publication Date: 8/26/2022 Citation: 87 FR 52598

From: B. Iris Potter <b.irispotter@gmail.com >

Sent: Thursday, December 29, 2022 5:43 AM To: Stacy Schumann <Stacy.Schumann@nrc.gov>

Cc: b.irispotter <b.irispotter@gmail.com>

Subject:

[External_Sender] NRC Docket 2022-O158 Iris Potter-Public Comments-NRC

Good Morn. I was having computer issues and so submit this a.m. Please submit. Thank you.

(My formal comments submitted from the South Haven meeting re: PSDAR)

NRC staff, citizens and PCAP members. My name is Iris Potter, Coordinator for Michigan Safe Energy Future -Kalamazoo Chapter within the 40-mile radiation zone.

The PSDAR or plan is important but Holtec International has applied for a grant from DOE to run an operating plant and has other options with SMR development in the works. This comes when Palisades is Not operating Nor does HDI, LLC, have an operating license according to NRC documents but I am sure that can be changed. We want the NRC, HDI and other parties to know we strongly oppose re-opening Palisades which has serious problems worth millions in repairs which we have said for years nor any new reactors there. For 5 years we were told it would shut and it is. How does this PSDAR play into the potential of re-opening Palisades? Would some parts be decommed and others not to make room for an SMR? Or, does the plan become fully moot and time wasted.

We know that the NRC and HDI have agreed to this plan so no changes will be made unless our voices are finally heard? We hope so. Our Coalition filed a legal intervention after the PSDAR came out and we were denied a chance to be heard then.

The cost estimates are almost 2 years old. According to NRC regulations, th ere must be "financial assurance" that a full decom can be done with funds available but not in this case. NRC's website states $612 million as the highest cost for decom and this PSDAR is already above that. We know that with cost overruns, etc., it could be a billion. Where is the decom money to come from if the NDT funds are gone and going more quickly due to HDI can use them for spent fuel and site restoration with their exemptions. I believe that HDI said they would raise funds during dormancy and wait for the NDT to increase interest -wise. The funds are the public ratepayers' with no reporting to us with $166 million already drawn down. A legal concern we raised along with our State Attorney General, is there is no 3rd party oversight on the NDT funds and it can be drawn without public reporting. How will HDI be held financially accountable to the people? If finances become too heavy, who is to say we couldn't get into a bail situation with taxpayers left with it. And, is the parent company or HDI, LLC liable? Also, we are unaware of any contingency funds for unforseen costs such as a fire or radiological accident. The use of sub-contractors will also allow for even less NRC oversight. It appears there will be a lack of real time information and only infrequent reports to the PCAP now that the fuel rods are in the pool.

So, We continue to strongly oppose:

- barging across the Lake which is in Holtec's promo info;

- dumping of any materials into the Lake;

- only a 3 feet deep dig for a full radiological clean-up because how would Tritium and other toxins be found;

We strongly request:

- a full new Environmental Impact Statement and clean -up as needed and not use the 14 year -old EIS. HDI is not "bounded" by it as stated in the plan.

- adequate inspectors onsite;

- that Holtec work with the local municipalities to review the emergency plan although Holtec is not bound to do it and we hope that there is adequate security onsite even though it has been reduced.

The public is forced to solely rely on HDI and the NRC to protect us. This is the Public's Lake Michigan and Great Lakes-the drinking water for millions, our land forever, our recreation area and our tourism revenue--

not a place for Russian Roulette. We are watching and involved. I love Lake Michigan so much which is why I always speak to protect it. Thank you.

Other:

-If, and when, the radioactive parts are to be removed, barging highly radioactive fuel and parts across the Lake is not an option which we also expressed at a prior meeting and it is referenced in Holtecs promo materials.

Also, we oppose dumping which could be hard to trace at first. This is our Great Lake and we have a legally-protected Public Trust for this treasured resource.

-What about tritium and any other toxic leaks into groundwater underneath the plant?

-A new full EIS or Supplemental is not in the plan to evaluate all the current environmental impacts and then remediate so that our land and waters are protected. Instead, HDI plans to use the almost 14 year-old one saying that they are "bounded" by this which they are not. Three feet deep is all that will be required for a complete radiological clean-up which will likely not find any deeper groundwater issues such as Tritium and other toxic chemical leakeages. How will we ever know all of the current radioactive and toxic hazards there from decades of use of this degraded, old reactor and site? -We also wonder about the amount of real NRC oversight including inspectors monitoring on site now and as the plant goes into decom. We strongly urge the NRC to require a full, detailed new SEIS and to require a deeper clean-up.

-For years, we have spoken about the embrittled reactor pressure vessel -one of the Country's top worst, the CRDM seals are so bad that Entergy shut the plant early, the reactor lid, degraded steam generators and reactor lid which are potential pathways to meltdown.

Entergy never fixed the major problems after buying it from Consumers because the repairs to this 51 year-old plus plant would cost millions.

Iris Potter, Michigan Safe Energy Future Kalamazoo, MI