ML24212A155
| ML24212A155 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/2024 |
| From: | Lombardi J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2024-0076, 89FR53659 00088 | |
| Download: ML24212A155 (1) | |
Text
PUBLIC SUBMISSION As of: 7/30/24, 9:36 AM Received: July 29, 2024 Status: Pending_Post Tracking No. lz7-p29k-rux2 Comments Due: July 29, 2024 Submission Type: API 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-0088 Comment on FR Doc # 2024-14112 Submitter Information Name: Joan Lombardi Address:
Covert, MI, 49043 Email:jwellslombardi@gmail.com General Comment
Dear National Regulatory Commission:
I am writing to you because of serious concerns about the proposed restarting of the Palisades Nuclear Power Plant in Covert, Michigan. I would strongly urge you to closely scrutinize Holtecs application to restart this defunct plant and that it, at least, be subject to a particularly exacting and stringent environmental impact review. Even currently operating nuclear power plants must successfully pass an EIS. It would seem imperative that Palisades meet, at minimum, this standard and hopefully a higher bar, given the advanced age of the facility.
We own a family home, in Palisades Park, on the shores of Lake Michigan and have since the mid-1940s.
It has been a pivotal center for five generations of our family, remains so now and, hopefully will for years to come. We watched Palisades being planned and built and are well aware of the many problems and safety violations it has encountered over the years. We are very concerned about the idea of reopening this plant, which is very old, and built on the shores of the largest fresh water system in the world. This is not the location for a mistake.
As you well know, restarting a defunct nuclear power plant after it has been permanently shut down has never been done in the U.S. There are very good reasons for this. Palisades hardly seems like a wise choice for this experimental first-time restart.
Also, while Holtec is experienced in shutting down nuclear power plants and maintaining them in a shut-down state, they have no experience in restarting or running a nuclear power plant and they do have a history of safety violations. Holtec seems like a very unwise choice of company to take this on and Palisades a plant with way too many inherent problems.
Given that nuclear fission is the most dangerous form of power generation, particular care is essential in its handling. Restarting a very old facility by a company with no experience doing so and a history of violations seems like a perfect recipe for very serious problems.
7/30/24, 9:37 AM blob:https://www.fdms.gov/ab0d0fb7-e794-4908-9fb9-7f6851e14e75 blob:https://www.fdms.gov/ab0d0fb7-e794-4908-9fb9-7f6851e14e75 1/2 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Laura Willingham, Mary Richmond, Antoinette Walker-Smith, Marlayna Doell, Mary Neely Comment (88)
Publication Date:6/27/2024 Citation: 89 FR 53659
Please ensure that this review of environmental impact includes wide ranging criteria and receives the most stringent evaluation. We trust in your experience and thorough evaluation and look forward to learning your recommendations and requirements for the Palisades Power Plant.
Respectfully, Joan Lombardi 27895 Shorewood Walk Covert, Michigan 49043 Attachments Palisades Park Board Covert MI 7/30/24, 9:37 AM blob:https://www.fdms.gov/ab0d0fb7-e794-4908-9fb9-7f6851e14e75 blob:https://www.fdms.gov/ab0d0fb7-e794-4908-9fb9-7f6851e14e75 2/2
Comment on Behalf of Palisades Park on Scope of Environmental Review of Holtecs Request to Restart Palisades Nuclear Plant Docket ID NRC-2024-0076 July 23, 2024 This comment is submitted on behalf of Palisades Park, the residential community abutting 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 we are familiar with the realities of having this nuclear power plant as our neighbor. After 50 years of operations, the plant was in financial distress, maintenance was deferred, and its owner shut it down - permanently. Or so we, the public and the NRC were told.
Now, the new owner of the plant seeks to do what has never been done before - take a nuclear facility back on line 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 rulemaking 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 present environmental risks and unknowns greater than an operating plant that seeks an extension of an existing license. For years, PNPs operator ran the plant knowing it was on a schedule to shut down permanently. PNPs operator deferred maintenance and investment based on this timeline. Simply stated, it operated the plant as a short-timer, not as if it would need to be on line 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, aging infrastructure, deferred maintenance, and 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, Palisades Park Board of Directors