ML24198A174
| ML24198A174 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/11/2024 |
| From: | Stanger K - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2024-0076, 89FR53659 00009 | |
| Download: ML24198A174 (1) | |
Text
PUBLIC SUBMISSION As of: 7/16/24, 1:09 PM Received: July 11, 2024 Status: Pending_Post Tracking No. lyh-jsfh-mgeg Comments Due: July 29, 2024 Submission Type: Web Docket: NRC-2024-0076 Notice of Intent to Conduct Scoping Process and Prepare an Environmental Assessment Holtec Decommissioning International, LLC and Holtec Palisades, LLC; Palisades Nuclear Plant, Unit 1 Comment On: NRC-2024-0076-0001 Holtec Decommissioning International, LLC, and Holtec Palisades, LLC; Palisades Nuclear Plant; Notice of Intent To Conduct Scoping Process and Prepare an Environmental Assessment Document: NRC-2024-0076-DRAFT-0009 Comment on FR Doc # 2024-14112 Submitter Information Name: Karen Stanger Address:
Covert, MI, 49043 Email:stangwmn@aol.com Phone:5184410125 General Comment I write to you out of an abundance of concern regarding the proposed restarting of Palisades Nuclear.
Over its 53 year history, this plant has been amongst the worst power plants with regards to safety violations, breakdowns and releases of radiation and other toxins. I have summered in Palisades Park for nearly 62 years, and now reside here permanently. In late 2003 I was diagnosed with thyroid cancer, which as you know is not genetic and can be caused by excess exposure to radiation; my mother and sister were also diagnosed in early 2004. Nationally, the incidence of Tyroid Cancer/Disease is between 2-5 women/100,000 in the US, so it is alarming given that all 3 of us came down with thyroid cancer at the same time when we all lived in different states. The only thing we had in common was Palisades. About 10 years ago Jack Giessner came to our community to talk to us about issues/concerns related to the power plant. At that time my husband discussed my families situation and suggested that the NRC do a health study to determine if there was any need for concern in our community. Jack assured us this would be done, but not one single resident ever received a survey and we were brushed off. As of todays date, I know of at least 30-40 members of our community that have either had their thyroid stop working or had thyroid cancer. This is VERY alarming and needs further follow-up by the NRC before even contemplating reopening of this plant! I submit to you, along with my comment, a study that was done by epidemiologist Joe Mangano detailing the Mortality Trends in VanBuren county from 1968-2003. What he discovered in reviewing CDC data is that between 1968-1978 VanBuren County had a cancer mortality rate 38.3% below the national rate; between 2003-2020 Van Buren County had a rate that was 49.9%
above the national rate. In the young adult age group (25-34) this rate increased 70.7%, and none of this data from the CDC included any members of the Lake side communities abutting the power plant because they are not primary residences for most individuals. I implore you to incorporate a study of this nature, and make it compulsory for the review of this plant before allowing it to go back on-line. "Clean energy" 7/16/24, 1:10 PM blob:https://www.fdms.gov/13a290ff-e94f-4a68-985d-f1165b224922 blob:https://www.fdms.gov/13a290ff-e94f-4a68-985d-f1165b224922 1/2 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Laura Willingham, Mary Richmond, Antoinette Walker-Smit, Jessica Hammock, Marlayna Doell, Mary Neely Comment (9)
Publication Date:6/27/2024 Citation: 89 FR 53659
is not worth subjecting individuals who live nearby to cancer and/or death. I ask you this so that my daughters and grand daughter do not have to go through what I have had to endure.
Additionally, I am questioning why there have been no weekly tests of the emergency siren since November of 2018? Several times I have heard sirens go off on the grounds of the nuclear plant, but the tower in our community remained silent (this includes the day Entergy was forced to shut down). Most recently Indiana Michigan officials came to our park and disconnected our siren and when questioned we were told they were doing this because Holtec was no longer paying for this service. This seems very counter intuitive considering the fact that you want to re-open this plant. Safety is of the upmost priority and should not be taken lightly!
Attachments Mortality Trends Near Palisades Nuclear 7/16/24, 1:10 PM blob:https://www.fdms.gov/13a290ff-e94f-4a68-985d-f1165b224922 blob:https://www.fdms.gov/13a290ff-e94f-4a68-985d-f1165b224922 2/2
MORTALITY TRENDS NEAR THE PALISADES NUCLEAR REACTOR Joseph Mangano MPH MBA October 4, 2023 Background.
The Palisades nuclear plant in South Haven Michigan (Van Buren County), is in the southwestern part of the state. The plants reactor went critical (began generating radioactivity) on May 24, 1971; and went commercial (began selling power) on December 31, 1971.
Entergy Nuclear operated the reactor until it closed permanently, on May 31, 2022. Entergy sold the plant to Holtec International, which initially intended to decommission the plant. However, Holtec has since applied (unsuccessfully) for funds from the Civil Nuclear Credit to re-start the reactor; and it intends to re-apply.
Of the dozens of U.S. reactors that have closed permanently, none have re-started. Potentially operating a 51-year-old reactor that requires considerable maintenance for its aging and embrittled parts raise the question of health risks to the local populations.
Methodology.
This report will present historical data on mortality for the area closest to Palisades compared with the U.S., a method similar to that used by the National Cancer Institute (NCI) in the 1980s in the only federal study of cancer near U.S. nuclear plants. Because Van Buren County is the site of the reactor, it will be the focus of this study.
The Centers for Disease Control (CDC) web site makes mortality rates for each of the 3100 U.S.
counties for each year from 1968 to 2020. Like the NCI study, this report will analyze cancer mortality for each five-year period starting in 1968. The percent that Van Buren is greater than or less than the U.S. will be given.
Rates will be adjusted for age (standard 2000 U.S. population), a standard method used in epidemiology (and used by the NCI). In addition to all cancers combined, rates for all causes combined will be analyzed, as exposure to radiation can raise risk of diseases other than cancer.
The source for all data presented is the CDC (https://wonder.cdc.gov).
Results - Cancer Mortality.
Table 1 shows mortality rates for all cancers combined for Van Buren County and the U.S., for each five-year period starting in 1968.
Table 1 Age-Adjusted Deaths per 100,000 Population All Cancers Combined Van Buren County MI and the U.S.
By Period, 1968 to 2020 Deaths Rate Rate
% County Period Van Buren Van Buren U.S.
vs. U.S.
Excess Deaths 1968-1973 571 188.81 202.10
- 6.6 1974-1978 527 186.80 205.18
- 9.0 1979-1983 622 199.44 201.31
- 5.2 1984-1988 724 221.82 214.64 3.3 1989-1993 805 235.37 217.44 8.2 1994-1998 773 211.85 209.37 1.2 1999-2003 752 197.26 201.12
- 1.9 2004-2008 871 215.70 186.35 15.7 2009-2013 863 193.27 173.30 11.5 2014-2018 903 186.80 159.50 17.1 2019-2020 349 165.81 149.02 11.3 1968-1978 1098 188.06 203.77
- 7.7 1979-1998 2924 217.53 213.09 2.1 287 1999-2020 3738 194.24 175.05 11.0 699 Total 986 14.8%
Estimated Rate 2021-2023 524 163.85 147.98 10.7 In the earliest five-year periods, the Van Buren County rate fell below the U.S. (-6.6%, -9.0%, and
-5.2%). But in all but one of the periods thereafter, the county rate exceeded the U.S. The largest excesses are in the periods since 2004 (+15.7%, +11.5%, +17.1%, and +11.3%).
If the county rate had remained 7.7% below the U.S., as it was in 1968-1978, the number of cancer deaths since 1978 would have been 986 fewer than that recorded - an excess is 14.8% of all cancer deaths during that time.
Table 2 presents age-specific cancer mortality rates for Van Buren County and the U.S., for the most recent 18 years (2003-2020).
Table 2 Age-Specific Deaths per 100,000 Population All Cancers Combined Van Buren County MI and the U.S.
For Years 2003 to 2020 Deaths Rate Rate
% County Age at Death Van Buren Van Buren U.S.
vs. U.S.
0-24 17 3.77 3.00 25.7 25-34 23 15.23 8.92 70.7 35-44 57 32.94 29.87 10.3 45-54 249 123.23 107.54 14.6 55-64 599 321.10 297.15 8.1 65-74 897 750.16 640.33 17.2 75-84 851 1366.52 1187.53 15.1 85+
435 1839.95 1747.19 5.3 Total 3128 192.72 170.17 13.3 Van Buren County cancer rates exceed the U.S. for each age group. However, the largest increases occurred among children and young adults (age 0-34). Table 3 presents the historical rates for this age group.
Table 3 Trends in Deaths per 100,000 Population All Cancers Combined, Age 0-34 Van Buren County MI and the U.S.
Deaths Rate Rate
% County Period Van Buren Van Buren U.S.
vs. U.S.
1968-1978 20 5.63 9.20
- 38.3 1979-1998 63 8.50 6.74 26.1 2003-2020 40 6.94 4.63 49.9 In the period 1968-1978, the Van Buren death rate was well below (-38.3%) the U.S. But in the next two decades, the rate was 26.1% higher, rising to 49.9% higher in 2003-2020.
Results - All-Cause Mortality.
Table 4 shows mortality rates for all causes combined for Van Buren County and the U.S., for each five-year period starting in 1968.
Table 4 Age-Adjusted Deaths per 100,000 Population All Causes Combined Van Buren County MI and the U.S.
By Period, 1968 to 2020 Deaths Rate Rate
% County Period Van Buren Van Buren U.S.
vs. U.S.
Excess Deaths 1968-1973 3641 1220.57 1235.61
- 1.2 1974-1978 2910 1043.60 1083.56
- 3.7 1979-1983 2967 966.35 1005.94
- 3.9 1984-1988 3272 1027.98 978.54 5.1 1989-1993 3174 933.77 927.92 0.6 1994-1998 3289 910.76 829.50 9.8 1999-2003 3376 897.00 860.33 4.3 2004-2008 3539 902.78 793.69 13.7 2009-2013 3520 829.28 740.33 12.0 2014-2018 3825 822.83 728.31 13.0 2019-2020 1676 856.76 775.79 10.4 1968-1978 6551 1134.52 1163.27
- 2.5 1979-1998 12702 957.56 947.75 1.0 445 1999-2020 15936 858.80 775.31 10.8 2119 Total 2564 9.0%
Estimated Rate 2021-2023 2672 906.73 809.37 12.0 Source: Centers for Disease Control and Prevention (https://wonder.cdc.gov)
In the earliest five-year periods, the Van Buren County rate fell below the U.S. (-1.2%, -3.7%, and
-3.9%). But in all but one of the periods thereafter, the county rate exceeded the U.S. The largest excesses are in the periods since 2004 (+13.7%, +12.0%, +13.0%, and +10.4%).
If the county rate had remained 2.5% below the U.S., as it was in 1968-1978, the number of all-cause deaths since 1978 would have been 2564 fewer than that recorded - an excess of 9.0%
during that time.
Discussion.
The data presented in this report include mortality rates for all cancers combined, comparing Van Buren County and the U.S. Results show that the cancer death rate among Van Buren County residents was 7.7% below national rates in the years 1968 to 1978.
In subsequent periods, the county rate has consistently exceeded the U.S. rate, and the most recent period (2004 to 2020) shows the greatest excess. If the county rate had remained 7.7% below the U.S. after 1978, 986 fewer cancer deaths would have occurred in the next 42 years. This excess represents 14.8% of all Van Buren cancer deaths during this time.
In the most recent period (2003-2020), Van Buren County cancer mortality exceeded the U.S. for each age group. Excesses were highest (+49.9%) among children and young adults age 0-34, based on 40 deaths during this time.
In addition, the report illustrates trends in county vs. national mortality for all causes combined.
Van Buren Countys all-cause mortality rate was 2.5% below the U.S. from 1968-1978. Soon after, county rates exceeded the nation, peaking in the years after 2003. If the county rate had remained 7.7% below the U.S. after 1978, 2564 fewer deaths would have occurred in the next 42 years, or 9.0% of all Van Buren deaths.
The consistent pattern of low death rates, for cancers and other causes, occurred during the period just before and just after the startup of Palisades. The shift from a low-mortality to a high-mortality county, with steadily widening gap between the county and nation over time, is observed for both all cancers and all causes.
Radioactive emissions from Palisades have occurred since its startup in 1971. This array of over 100 chemicals not existent in nature, are produced only by atomic bomb explosions and nuclear reactor operations. These radionuclides enter the environment and human bodies through breathing and the food chain. They can kill or damage cells, increasing risk of cancer and other diseases, and are most harmful to the very young.
The shift in Van Buren County from a low-mortality to a high-mortality area raises the issue of which factors contributed to this change. While multiple causes of mortality can be assessed, one of these is the introduction of toxic, cancer-causing radioactivity from Palisades. The fact that excess deaths occurred for all causes, especially for cancer, and especially for cancers in young persons, suggest that radioactivity contributed to these trends.
More study of health trends in the Palisades area are in order, and results shared with the public and public officials. Based on the report, no action to re-start the reactor should be taken until the impact Palisades has had on local health is understood.
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