ML24212A128
| ML24212A128 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/2024 |
| From: | Cordell J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2024-0076, 89FR53659 00068 | |
| Download: ML24212A128 (1) | |
Text
7/30/24, 7:16 AM blob:https://www.fdms.gov/8c180d6c-fd0b-4d9f-84cc-f74b8ff6d0ad
SUNSI Review Complete As of: 7/30/24, 7:16 AM Template=ADM-013 E-RIDS=ADM-03 Received: July 29, 2024 ADD: Laura Willingham, Mary Status: Pending_Post PUBLIC SUBMISSIONRichmond, Antoinette Walker- Tracking No. lz7-andc-bass Smith, Marlayna Doell, Mary Neely Comments Due: July 29, 2024
Comment (68) Submission Type: Web Publication Date:6/27/2024 Docket: NRC-2024-0076 Citation: 89 FR 53659 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-0068 Comment on FR Doc # 2024-14112
Submitter Information
Name: John Cordell Address:
Covert, MI, 49043 Email: cordellj@gmail.com Phone: 8472262496
General Comment
See attached file(s)
Attachments
Comment to NRC on Palisades Nuclear Plant Environmental Review 7-29-2024
blob:https://www.fdms.gov/8c180d6c-fd0b-4d9f-84cc-f74b8ff6d0ad 1/1 Comment from adjacent homeowner to immediate south on Scope of Environmental Review of Holtecs Request to Restart Palisades Nuclear Plant in Covert, Michigan
Docket ID NRC-2024-0076
July 29, 2024
I am a second-generation property owner in Palisades Park, the residential community that directly abuts Palisades Nuclear Plant (PNP) to the south. Palisades Park was founded in 1905 and currently has over 200 homes. The great majority of these homes existed at the time PNP began operations in 1971 so many of us are very familiar with the realities of having this nuclear power plant as our neighbor. My home which was constructed in the late 1960s in Palisades Park is only 2,000 feet from the existing PNP twin cooling towers; depending on the wind direction, we can even hear their operation.
After 50 years of operations, the plant was in financial distress, maintenance was deferred, and in 2022, Entergy, its previous owner shut it down - permanently. PNP was sold to Holtec who would take on the process of decommissioning PNP and a detailed timetable was developed and approved by the regulators. Or so we, the public and the NRC were told! Now, Holtec, the new owner of the plant, seeks to do what has never been done before - take a nuclear facility back online that is no longer licensed to be operated or have fuel emplaced into the reactor vessel.
Our community appeals to the NRC to employ its Congressionally mandated oversight authority over PNP to conduct a thorough and rigorous environmental review of Holtecs request. The NRC and DOE should require an environmental review that is at least as comprehensive as what the NRC requires for an operating plant applying to renew its license, known as subsequent license renewal (SLR). The NRCs recent rule making on the scope of the review required for SLR confirms that Section 102(2) of the National Environmental Policy Act, implemented through 10 CFR Part 51, requires the preparation of an Environmental Impact Statement (EIS). The environmental review of Holtecs application must do at least that - and even more - because of the unique risks arising from restarting PNP. Holtecs requested restart license presents environmental risks and unknowns greater than an operating plant that seeks an extension of an existing license. For years, PNPs operators ran the plant knowing it was on a schedule to shut down permanently. PNPs operators deferred maintenance and investment based on this timeline. It has been well documented for many years how the pipe work at PNP connected to the reactor core has become extremely brittle and weakened; experts have testified and written that due to a high risk of failure from continued operations that these components must be replaced yet a complex and dangerous project like this has never before been attempted.
PNP has been operated as a short timer, not as if it would need to be online through 2031, the expiration date of its then-existing license. The NRC granted waivers for safety upgrades that otherwise would have been required but for the imminent shut down. An additional risk here is the requested issuance of a new license to an entity that has never operated a nuclear power plant! If the EPA mandates a rigorous EIS when determining whether an operating plant with an experienced licensee and ongoing investment and NRC oversight should be allowed to continue operating beyond its license term, shouldnt the EPA - and the NRC and DOE - require at least an EIS when a plant that has been shut down and not subject to the same level of review as an operating plant seeks to restart?
Holtecs request presents to the NRC and DOE an important and novel environmental impact question: can this plant, with its history of financial distress, extremely aging infrastructure, years of deferred maintenance, and now degradation from being out of operation, be restarted and operated safely without causing unacceptable risk to the immediate community, environment and the cherished resources of the Great Lakes? Answering this question requires the highest level of environmental review - an EIS that is directed to the unique circumstances of this plant and the unprecedented request before the NRC to restart a permanently shut down nuclear facility.
Respectfully submitted,
John Cordell Palisades Park Covert, MI 49043