ML24212A135
| ML24212A135 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/2024 |
| From: | Lloveras L Breakthrough Institute |
| To: | Office of Administration |
| References | |
| Download: ML24212A135 (1) | |
Text
PUBLIC SUBMISSION As of: 7/30/24, 8:17 AM Received: July 29, 2024 Status: Pending_Post Tracking No. lz7-fp79-jfk5 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-0075 Comment on FR Doc # 2024-14112 Submitter Information Email:leighanne@thebreakthrough.org Organization:The Breakthrough Institute General Comment See attached file(s)
Attachments Palisades env. review.docx 7/30/24, 8:17 AM blob:https://www.fdms.gov/9fc3cd20-3df9-404e-ba87-f3aaf955a8d3 blob:https://www.fdms.gov/9fc3cd20-3df9-404e-ba87-f3aaf955a8d3 1/1 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Laura Willingham, Mary Richmond, Antoinette Walker-Smith, Marlayna Doell, Mary Neely Comment (75)
Publication Date:6/27/2024 Citation: 89 FR 53659
July 29, 2024
Subject:
Comment on Holtec Decommissioning International, LLC, and Holtec Palisades, LLC; Palisades Nuclear Plant; Notice of Intent To Conduct Scoping Process and Prepare an Environmental Assessment. [Docket ID: NRC-2024-0076].
The Breakthrough Institute (BTI) appreciates this opportunity to comment on the scope of the environmental assessment (EA) for the restart of Palisades Nuclear Plant. BTI is an independent 501(c)(3) global research center that advocates for appropriate regulation and oversight of nuclear reactors to enable the new and continued use of safe and clean nuclear energy. BTI acts in the public interest and does not receive funding from industry.
Palisades ceased operations in May 2022, but Holtec is looking to bring it back online. Doing so would save 600 good-paying, high-skill jobs and provide clean, reliable power for 800,000 homes.1 Palisades is essential for meeting the regions electricity demands while ensuring grid stability. Additionally, the electricity Palisades produces is carbon-free, contributing to a decrease in greenhouse gas emissions and supporting decarbonization goals.
Palisades still has a valid operating license that does not expire until 2031.2 A full Environmental Impact Statement (EIS) that considers commercial operation was performed prior to the issuance of this license. Therefore, the scope of this EA should only consider any impacts that could reasonably have changed since the plant ceased operations and are significantly different from the prior EIS. Analyzing only those new impacts would improve the efficiency of the review.
The No-Action Alternative The Fiscal Responsibility Act of 2023 (FRA)3 includes amendments to the National Environmental Policy Act (NEPA). One amendment mandates consideration of the negative impacts of the no-action alternative:
...a reasonable range of alternatives to the proposed agency action, including an analysis of any negative environmental impacts of not implementing the proposed agency action in the case of a 3 Public Law No: 118-5, https://www.congress.gov/bill/118th-congress/house-bill/3746.
2 https://www.nrc.gov/info-finder/reactors/pali.html 1 Department of Energy, Biden-Harris Administration Announces $1.5 Billion Conditional Commitment to Holtec Palisades to Support Recommission of Michigan Nuclear Power Plant, March 27, 2024, https://www.energy.gov/articles/biden-harris-administration-announces-15-billion-conditional-commitment-holtec-palisades.
no action alternative, that are technically and economically feasible, and meet the purpose and need of the proposal.
Instead of only considering the positive impacts of not restarting Palisades (e.g. cooling water will not be withdrawn from Lake Michigan), the Nuclear Regulatory Commission (NRC) must now also consider the negative impacts. Such impacts could include the emissions from the alternative energy sources that will need to be used (likely fossil fuels) and the corresponding public health consequences.
In addition to its responsibilities under NEPA, the NRC also needs to consider the full breadth of impacts of the no-action alternative in order to meet the mandate in the Atomic Energy Act of enabling nuclear energy to make the maximum contribution to the general welfare.4 This recognition of the benefits of nuclear energy was emphasized in the recently passed ADVANCE Act, which stated that licensing and regulation of the civilian use of radioactive materials and nuclear energy be conducted in a manner that is efficient and does not unnecessarily limit the benefits of civilian use of radioactive materials and nuclear energy technology to society.5 BTI appreciates the opportunity to express our support for the re-opening of Palisades and to comment on the scope of the environmental review for the project.
Sincerely, Leigh Anne Lloveras Nuclear Energy Analyst The Breakthrough Institute 5 Public Law No: 118-67, Sec. 501, https://www.congress.gov/bill/118th-congress/senate-bill/870.
4 42 USC 2011(a).