ML24212A157
| ML24212A157 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/29/2024 |
| From: | Bogen D - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2024-0076, 89FR53659 00090 | |
| Download: ML24212A157 (1) | |
Text
PUBLIC SUBMISSION As of: 7/30/24, 9:44 AM Received: July 29, 2024 Status: Pending_Post Tracking No. lz7-rh6c-sk27 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-0090 Comment on FR Doc # 2024-14112 Submitter Information Name: Doug Bogen Address:
Barrington, NH, 03825-5815 Email:dbogen@metrocast.net Phone:6036642696 General Comment
Dear NRC,
I would like to comment on the the Palisades reactor restart (Docket ID NRC-2024-0076). This proposal is unprecedented, extremely high-risk, unreasonably expensive for taxpayers and ratepayers, and unneeded. NRCs Environmental Assessment is unacceptable - a full-blown Environmental Impact Statement is called for regarding this major federal action. Because the Palisades closed reactor restart precedent is now being applied elsewher a Generic or Programmatic EIS is necessary.
The No Action Alternative is the only acceptable one, as the Palisades reactor should remain closed for good. Renewables like wind and solar power, efficiency, and storage are much more preferable alternatives. They can readily replace Palisades 800 Megawatts-electric (MWe), and do so much more cost-effectively, cleanly, safety, securely, promptly, and reliably than the reactor restart as well as with Holtecs inextricably connected SMR-300 new builds scheme at Palisades.
A reactor core meltdown at the Palisades zombie reactor would have extremely LARGE negative environmental impacts. Palisades has long had multiple high-risk pathways to meltdown, especially including the single worst neutron-embrittled reactor pressure vessel in the country, at risk of through-wall fracture. As with many other reactors that never made it through their original licensing periods, Palisades' steam generators and a reactor vessel closure head are degraded and are way overdue for expensive replacement. Fire protection and containment coating/sump strainer upgrades have likewise been largely to entirely neglected. As you must know, all these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by 7/30/24, 9:44 AM blob:https://www.fdms.gov/53acb2d0-468c-461b-bc5f-ad2f87b35e21 blob:https://www.fdms.gov/53acb2d0-468c-461b-bc5f-ad2f87b35e21 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 (90)
Publication Date:6/27/2024 Citation: 89 FR 53659
Palisades initial owner, Consumers Energy, to the Michigan Public Service Commission, in spring 2006.
Yet Entergy never fixed any of this, during its ownership tenure from 2007 to 2022, simply because you did not require it. Given the history throughout the industry, this record is very disconcerting and should disqualify Palisades from restart without extensive retrofits.
Additionaly, Palisades has also had the worst operating experience of any reactor in the U.S., regarding Control Rod Drive Mechanism seal leakage. The first leaks were in 1972, in the first year of full power operations. They have continued since. In fact, Entergys decision to close Palisades for good on May 20, 2022 was 11 days earlier than scheduled, because of the most recent CRDM seal leak. Palisades owners, now Holtec, have never determined the root cause, nor taken comprehensive corrective action, to solve this problem, instead relying on mere, short-lasting fixes. Given their location very near the reactor core, replacement of CRDM seals exposes workers to significant doses of hazardous radiation, putting their health at risk. CRDM seal leaks involve reactor core primary coolant water, so represent yet another pathway to meltdown.
Because of these and many other unaddress deficiencies, I urge you to take No Action on the reckless and unnecessary Palisades restart proposal. Thank you for consideration of these concerns.
Respectfully, Doug Bogen Barrington, NH 7/30/24, 9:44 AM blob:https://www.fdms.gov/53acb2d0-468c-461b-bc5f-ad2f87b35e21 blob:https://www.fdms.gov/53acb2d0-468c-461b-bc5f-ad2f87b35e21 2/2