ML25027A133

Environmental Assessment Scooping Process Summary Report

ML25027A133
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Site:	Palisades
Issue date:	01/28/2025
From:	Richmond M NRC/NMSS/DREFS/EPMB3
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ML25027A101	List: ML25027A133 ML25027A136
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ML2527A133 Environmental Assessment Scoping Process Summary Report Palisades Nuclear Plant Potential Reauthorization of Power Operations Covert, Michigan January 2025 U.S. Nuclear Regulatory Commission Rockville, Maryland A. Objective The purpose of this report is to provide a concise summary of the determination of the scope of the environmental review associated with the regulatory and licensing requests to support reauthorization of power operations at the Palisades Nuclear Plant (Palisades or PNP). These requests were submitted by Holtec Decommissioning International, LLC (HDI, current licensed operator for decommissioning); Holtec Palisades, LLC (Holtec Palisades, licensed owner); and Palisades Energy, LLC (OPCO, proposed licensed operator for reactor operation) (collectively, Holtec) to the U.S. Nuclear Regulatory Commission (NRC).

In addition to the set of licensing and regulatory requests submitted to the NRC related to the potential reauthorization of power operations at Palisades, the U.S. Department of Energy (DOE) Loan Program Offices (LPO) Federal action is a decision on providing Federal financial assistance for refueling and resumption of power generation activities at Palisades pursuant to Holtecs loan guarantee agreement with DOE that was issued pursuant to the Energy Policy Act (EPAct) of 2005. The NRC is the lead Federal agency under the National Environmental Policy Act of 1969, as amended (NEPA), and DOE LPO is the cooperating agency. This report will briefly summarize the issues identified by the scoping process and how the issues will be considered in the NRC and DOE LPO staffs environmental review of the Holtec requests to support reauthorizing power operations.

For environmental impact statements (EISs), the NRCs regulations at Title 10 of the Code of Federal Regulations (CFR) 51.28 and 51.29 require a scoping process and issuance of a concise summary of the NRCs determinations and conclusions for scoping. Scoping is not required for environmental assessments (EAs). While the NRC is preparing an EA as part of the environmental review of the Holtec requests, the NRC has conducted scoping and is issuing this scoping summary report to further transparency and openness to stakeholders given the uniqueness of these licensing and regulatory requests and heightened stakeholder interest.

This report briefly summarizes the issues, or topics, identified by the environmental scoping process and is structured as follows:

A. Objective B. Introduction/Background C. Scoping Process D. Summary of Comments Provided E. Determinations and Conclusions Appendix A to this report contains a list of commenters who provided comments on the scope of the NRC and DOE LPO staffs environmental review. Appendix B to this report contains a summary of the comments for each scoping topic identified from the comments received during the scoping period. Appendix C contains the categorized comments and appendix D contains a copy of the U.S. Environmental Protection Agencys (EPA) letter to the NRC.

Throughout this scoping summary report, the NRC's Agencywide Documents Access and Management System (ADAMS) Accession Numbers which begin with ML are provided so the public can review the document. Publicly available documents can be found online in the ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select Begin Web-based ADAMS Search. For problems with ADAMS, please contact the NRC's Public Document Room (PDR) reference staff at 1-800-397-4209, or 301-415-4737, or by email to PDR.Resource@nrc.gov.

B. Introduction/Background Palisades consists of a single unit pressurized-water nuclear reactor located near Covert, Michigan. The U.S. Atomic Energy Commission (the predecessor of the NRC) originally granted Palisades Interim Provisional License No. DPR-20 on March 24, 1971, (ML18052A832). The NRC subsequently issued Facility Operating License No. DPR-20 on February 21, 1991, (ML020810482), which superseded the provisional license in its entirety. The NRC issued Renewed Facility Operating License (RFOL) No. DPR-20 for Palisades on January 17, 2007, (ML070100476), with the RFOL term expiring on March 24, 2031.

On June 13, 2022, the licensee at the time, Entergy Nuclear Operations, Inc. (Entergy),

submitted certifications to the NRC that operation had permanently ceased, and that fuel had been permanently removed from the reactor (ML22164A067). The docketing of these certifications means that the license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. As part of this transition from an operating reactor to a reactor in decommissioning, the NRC issued amendments changing the operating license (OL) to reflect the authorities and requirements for a reactor in decommissioning (ML22039A198). However, even after these amendments became effective during the decommissioning period, the license is still referred to as a Palisades RFOL in the license itself, and it continues to be a 10 CFR Part 50 OL.

During the transition to decommissioning, the NRC approved Entergys requested transfer of the ownership and operations from Entergy to Holtec International subsidiaries (ML20358A075). As a result of the transfer (ML22173A179), the current license holders for Palisades are HDI (licensed operator) and Holtec Palisades (licensed owner).

After the cessation of power operations and the commencement of decommissioning at Palisades, HDI began to pursue a path to resume power operations. On February 1, 2023, (updated on March 13, 2023), HDI (on behalf of Holtec Palisades) submitted a letter to the NRC outlining a proposed regulatory path for the reauthorization of power operations at Palisades (ML23032A399; ML23072A404). Throughout 2023 and 2024, Holtec engaged with the NRC and submitted a set of requests for NRC approval to support the reauthorization of power operations at Palisades (see https://www.nrc.gov/info-finder/reactors/pali.html for information related to these interactions and other information on the Palisades reauthorization of power operations activities).

The proposed NRC actions are the regulatory and licensing requests under consideration by the NRC staff (summarized in bullet form and listed individually in the table below), including any revisions or supplements thereto or other regulatory or licensing requests submitted to the NRC that are necessary to reauthorize power operations of Palisades:

The September 28, 2023, request for an exemption from the 10 CFR 50.82(a)(2) restriction that prohibits reactor power operations and retention of fuel in the reactor vessel by allowing for a one-time rescission of the docketed 10 CFR 50.82(a)(1) certifications.

The December 6, 2023, license transfer request for Palisades, which seeks NRC consent to, and a conforming amendment for, a transfer of operating authority from HDI to OPCO under the Palisades RFOL No. DPR-20 and the general license for the Palisades Independent Spent Fuel Storage Installation.

A series of license amendment requests (LARs) needed to restart power operations at Palisades.

Document Description ADAMS Accession No.

Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated September 28, 2023.

ML23271A140 Application for Order Consenting to Transfer of Control of License and Conforming License Amendments, dated December 6, 2023.

ML23340A161 Request to Revise Operating License and Technical Specifications to Support Resumption of Power Operations, dated December 14, 2023.

ML23348A148 Request to Revise the Administrative Technical Specifications to Support Resumption of Power Operations, dated February 9, 2024.

ML24040A089 Request to Reinstate the Palisades Emergency Plan to Support Resumption of Power Operations, dated May 1, 2024.

ML24122C666 Request to Update the Main Steam Line Break Analysis Methodology, dated May 24, 2024.

ML24145A145 As previously discussed, DOE LPO is a cooperating agency for the environmental review and its proposed action is a decision on providing Federal financial assistance for refueling and resumption of power generation activities at Palisades pursuant to Holtecs loan guarantee agreement with DOE that was issued pursuant to the EPAct of 2005.

C. Scoping process The NRC and DOE LPO staff conducted a scoping process to gather information to assist in the preparation of an EA to evaluate the environmental impacts of the potential reauthorization of Palisades.

On June 27, 2024, the NRC, as the lead Federal agency, published a Federal Register (FR) notice of intent (NOI) (89 FR 53659) to conduct a scoping process and prepare a draft EA for the potential reauthorization of power operations at Palisades given the uniqueness of the request and high level of interest from the public and other stakeholders. The NOI informed the public and other stakeholders about the NRC and DOE LPO staffs intent to prepare an EA and initiated a 30-day scoping comment period, which closed on July 29, 2024. The scoping comment period provided the public and other stakeholders with an opportunity to participate in the environmental scoping process. The NRC staff requested input from members of the public on the scope of the environmental review and what environmental issues should be considered. On July 11, 2024, the NRC and DOE LPO staff held a hybrid (in-person and virtual) public scoping meeting in Benton Harbor, Michigan. All comments received, both written and oral, throughout the scoping period were considered in the scoping process.

This scoping summary report provides a concise summary of the determinations and conclusions reached as a result of the scoping process. The objectives of the scoping process were to:

1) Define the proposed action, which is to be the subject of the EA.

2) Determine the scope of the EA and identify the significant issues to be analyzed in depth.

3) Identify and eliminate from detailed study those issues that are peripheral or are not significant or were covered by prior environmental review.

4) Identify any other EAs and EISs that are being or will be prepared that are related to, but are not part of, the scope of the EA.

5) Identify other environmental review and consultation requirements related to the proposed action.

6) Identify parties consulting with the NRC and DOE under the National Historic Preservation Act of 1966, as amended (NHPA), as set forth in 36 CFR 800.8(c)(1)(i).

7) Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the EA and, if applicable, finding of no significant impact (FONSI), between the NRC and any cooperating agencies.

8) Describe how the EA will be prepared, including any contractor assistance to be used.

The NRC and DOE LPO staffs determinations and conclusions regarding the above objectives are provided in section E below.

D. Summary of Comments Provided Table A-1 in appendix A of this scoping summary report provides a list of commenters who provided comment submissions (i.e., non-form letter submissions) identified by name, affiliation (if stated), the correspondence identification (ID) number, the comment source, and the ADAMS Accession Number of the comment submission. The staff reviewed each comment submission, including the public scoping meeting transcripts, to identify individual comments. Each comment was marked with a unique identifier consisting of the correspondence ID (specified in table A-1) and a comment number. For example, Comment 3-1 refers to the first comment within the document provided by correspondence ID 3. This unique identifier allows each comment to be traced back to the source where the comment was identified. Table A-2 of appendix A lists the commenters who submitted all or part of form letter content. Table A-3 of appendix A identifies the distribution of comments received by resource area or topic.

The staff reviewed all comments received and first categorized each as either related to a resource area that is applicable to the environmental review (summarized in appendix B.1) or related to topics that are beyond the scope of the environmental review (summarized in appendix B.2). The comments were then consolidated according to a specific resource area or topic. Appendix B contains a summary of the scoping comments received during the scoping period, categorized and consolidated by topic or resource area. Appendix C contains the comments associated with each comment summary for reference to the reader. Appendix D contains the letter received from the EPA to assist the reader of this scoping summary report due to the unique formatting of the letter.

In the course of its review, the staff will consider all scoping comments related to environmental resource areas covered by the EA (i.e., in appendix B.1), as appropriate. While these comments will be considered, the NRC staff may determine that some of these comments include suggestions that go beyond the requirements of NEPA. In addition, the specific content or suggestions provided in the comments on how to address the identified topics will be considered but may not ultimately be discussed or implemented in the EA.

The distribution of comments by resource area or topic in appendix B are as follows:

Appendix B (Section)

Resource Area or Topic B.1 Comments on Resource Areas Considered in the EA B.1.1 Comments Concerning Accidents B.1.2 Comments Concerning Alternatives-No-Action B.1.3 Comments Concerning Alternatives-Other B.1.4 Comments Concerning Cumulative Impacts B.1.5 Comments Concerning Ecology-Aquatic Resources B.1.6 Comments Concerning Ecology-Terrestrial Resources B.1.7 Comments Concerning Environmental Justice B.1.8 Comments Concerning General Environmental Concerns B.1.9 Comments Concerning Greenhouse Gas Emissions and Climate Change B.1.10 Comments Concerning Human Health-Nonradiological B.1.11 Comments Concerning Human Health-Radiological B.1.12 Comments Concerning Hydrology-Groundwater Resources B.1.13 Comments Concerning Hydrology-Surface Water Resources B.1.14 Comments Concerning Land Use and Visual Resources B.1.15 Comments Concerning Meteorology and Air Quality B.1.16 Comments Concerning Need for Project/Purpose and Need B.1.17 Comments Concerning Noise B.1.18 Comments Concerning Socioeconomics B.1.19 Comments Concerning the Uranium Fuel Cycle B.1.20 Comments Concerning Waste Management-Radioactive Waste B.2 Non-Technical and Comments Outside the Scope of the Environmental Review B.2.1 General Comments in Support of the Licensing Action B.2.2 General Comments in Opposition to the Licensing Action B.2.3 Comments Concerning Cooperating Agency Appendix B (Section)

Resource Area or Topic B.2.4 Comments Concerning Process-Licensing Action B.2.5 Comments Concerning Process-NEPA B.2.6 Comments Concerning Outside Scope - Aging Management B.2.7 Comments Concerning Outside Scope - Emergency Preparedness B.2.8 Comments Concerning Outside Scope - Energy Costs B.2.9 Comments Outside Scope - Miscellaneous B.2.10 Comments Outside Scope - Other Non-Restart Actions B.2.11 Comments Outside Scope - Safety B.2.12 Comments Outside Scope - Security and Terrorism E. Determinations and Conclusions (1) Define the Proposed Action The NRCs proposed action is a decision on whether to issue a set of LARs, a license transfer request, and an exemption request to support reauthorizing power generation operations at Palisades, including any revisions or supplements thereto or other regulatory or licensing requests submitted to the NRC that are necessary to reauthorize power operations of Palisades.

DOE LPOs proposed action is to provide Federal financial support (a loan guarantee) to HDI for the reauthorization of power operations at Palisades, specifically the fuel loading and power restart activities.

(2) Determine the scope of the EA and identify the significant issues to be analyzed in depth For the proposed Federal actions, the EA will identify the purpose and need for the proposed actions, examine alternatives to them (including the no-action alternative), and evaluate the proposed actions environmental consequences. In assessing the environmental consequences of the proposed actions, the EA will reflect consideration of impacts associated with preparation activities needed to resume power operations of Palisades and the continuation of power operation for the remainder of the RFOL (March 2031), as well as cumulative effects. The staff intend to consider environmental consequences associated with the following categories:

Land Use and Visual Resources Meteorology and Air Quality Water Resources and Geologic Environment Ecological Resources Historic and Cultural Resources Socioeconomics Environmental Justice (EJ)

Human Health - Radiological Impacts Human Health - Nonradiological Impacts Waste Management Impacts of Postulated Accidents (Design Basis Accidents and Severe Accidents)

Impacts Associated with the Uranium Fuel Cycle Decommissioning Impact Evaluation Climate Change and Greenhouse Gas (GHG) Evaluation Finally, the NRC staff will consider the impacts of reasonable alternatives to the proposed actions and compare them with the impacts of the proposed actions.

The NRC staff will also identify in section 3 of the EA those topics to be analyzed in depth. For example, the EA will discuss the ecological habitats and historic and cultural resources present within the Palisades site boundary in depth. The EA will also discuss water quality and use, EJ, GHG emissions and air quality, and socioeconomic impacts in depth. Climate change will also be considered in the EA in an appendix. Several commenters raised concerns regarding local resident cancer rates, and this will also be considered in an appendix to the EA.

The staff will consider all scoping comments related to environmental resource areas covered by the EA, as appropriate. While these comments will be considered, the NRC staff may determine that some of these comments include suggestions that go beyond the requirements of NEPA. In addition, the specific content or suggestions provided in the comments on how to address the identified topics may not ultimately be discussed or implemented in the EA.

(3) Identify and eliminate from detailed study those issues that are peripheral or are not significant or were covered by prior environmental review.

The EA will summarize the applicable impact determination analysis for resource areas that have been identified during scoping to have negligible impact or that were covered by prior environmental review(s), narrowing the discussion of these issues to a brief presentation. The assessment of the impacts of these issues was primarily covered by previous or generic environmental reviews. Section 3 of the EA will briefly discuss the following issues, including the relevance of previous environmental evaluations: land use and visual impacts; human health (both radiological and non-radiological); waste management; uranium fuel cycle; and postulated accidents.

Additionally, the staff received a number of comments that were either general in nature or otherwise beyond the scope of the environmental review (appendix B.2). These included comments from organizations and individuals in opposition to or in support of the reauthorization of power operations at Palisades. Comments related to the environmental review process expressed concerns regarding the type of environmental review document to be produced, with some commenters indicating that an EIS was appropriate rather than an EA. Commenters also expressed concern with the timeline of review, with some commenters requesting more time for comment. Additionally, safety concerns were raised by several commenters, but safety concerns are outside the scope of the environmental review. Lastly, commenters also provided feedback on the lack of an established regulatory pathway for restarting a reactor in decommissioning and indicated that rulemaking was necessary to establish an NRC regulatory pathway. The staff will not consider or evaluate any issues in the EA which do not pertain to the staffs environmental evaluation, or which are beyond the scope of the proposed actions associated with the environmental review.

(4) Identify any other EAs and EISs that are being or will be prepared that are related to, but are not part of, the scope of the EA.

The scoping process did not identify any other EAs or EISs that are being or will be prepared that are related to the scope of the EA.

(5) Identify other environmental review and consultation requirements related to the proposed action.

Concurrent with its NEPA review, the NRC, as the lead Federal agency, is consulting with the U.S. Fish and Wildlife Service under section 7 of the Endangered Species Act (ESA) to evaluate the potential impacts of the reauthorization of power operations on endangered and threatened species and their critical habitat.

Additionally, consistent with 36 CFR 800.8(c), the NRC, as the lead Federal agency is also consulting with affected Federally recognized Indian Tribes and the Michigan State Historic Preservation Office to fulfill its Section 106 obligations under the NHPA.

DOE LPO is jointly consulting with NRC for both NHPA and ESA consultation activities.

The NRC did not identify any additional environmental review requirements and consultation requirements through the scoping process that were not already considered.

(6) Identify parties consulting with the NRC under the NHPA, as set forth in 36 CFR 800.8(c)(1)(i).

See (5) above.

(7) Identify any cooperating agencies and, as appropriate, allocate assignments for preparation and schedules for completing the EA and, if applicable, FONSI, between the NRC and any cooperating agencies.

DOE was identified by the NRC staff as a cooperating agency prior to initiating the scoping process, and the agencies allocated assignments for preparation and schedule for completing the EA.

(8) Describe how the EA will be prepared, including any contractor assistance to be used.

Upon completion of the scoping process, a site audit, and the NRCs and DOE LPOs independent evaluations, the staff will compile its findings into a draft EA and, if warranted, draft FONSI. The NRC staff plans to issue a draft EA and (if applicable) draft FONSI for public comment in January 2025. The draft EA comment period will offer an opportunity for participants, such as the licensee; interested Federal, State, and local government agencies; Tribal governments; local organizations; and members of the public to provide further input to the agencys environmental review process. The EA will identify the information considered and the evaluations that the staff performed, and they will provide the basis for the NRCs and DOE LPOs environmental decision on Holtecs applications to support reauthorizing power operations (NRC) and request for Federal financial support (a loan guarantee) (DOE) to support restart of power operations at Palisades.

Based on the information gathered during the public comment period, the NRC staff will amend the draft EA findings, as necessary, and then will publish the final EA and, if warranted, a final FONSI. The NRC staff is currently scheduled to finalize the final EA in June 2025. The current schedule for the issuance of the draft EA may be found on the project website at https://www.nrc.gov/info-finder/reactors/pali.html.

In parallel with this environmental review, the NRC staff in the Office of Nuclear Reactor Regulation are conducting a detailed safety evaluation of the exemption, transfer, and amendment requests.

Appendix A List of Commenters The NRC received comment submissions from 298 individuals. Table A-1 provides a list of commenters who provided comment submissions (i.e., non-form letter submissions) identified by name, affiliation (if stated), the correspondence identification (ID) number, the comment source, and the ADAMS Accession Number of the source. The staff also reviewed the scoping meeting transcript, and all written material received to identify individual commenters. Table A-2 provides a list of commenters who provided submissions that consisted of a form-letter in part or in full and lists the commentor, the ADAMS Accession Number for the comment submittal, and the form letter used in the comment. Each form letter used in the submittal is numbered and their source provided at the bottom of table A-2. The original form letter is referenced as a single comment in table A-1. A total of 538 individual comments were received during the scoping period. Comments were consolidated and categorized according to a resource area or topic.

Table A-3 identifies the distribution of comments received by resource area or topic.

Table A-1. Individuals Providing Comments During the Scoping Comment Period Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Andrews, Joey Michigan State Representative 143-7 Meeting Transcript ML24219A265 Anonymous 14 Email ML24200A119 Anonymous 4

Regs.gov ML24198A179 Anonymous Palisades Park 68 Regs.gov ML24205A169 Anonymous 59 Regs.gov ML24201A002 Anonymous 112 Regs.gov ML24211A150 Anonymous 114 Regs.gov ML24211A159 Anonymous, Gregg 30 Email ML24201A036 Babin, Barbara 136 Email ML24215A399 Balasko, Deborah 47 Email Barnes, Kathryn Don't Waste Michigan, Sherwood Chapter 143-16 Meeting Transcript ML24219A265 Bibee, Bruce 135 Email ML24215A398 Bilenko, Stephanie 143-22 Meeting Transcript ML24219A265 Bilenko, Stephanie 117 Regs.gov ML24212A142 Birdsall, Sheila 33 Email ML24201A041 Birney, Robert 52 Email ML24210A002 Blind, Alan 143-14 Meeting Transcript ML24219A265 Blind, Alan 141 Regs.gov ML24198A168 Blind, Alan 118 Regs.gov ML24219A389 Bogen, Doug 123 Regs.gov ML24212A157 Boris, Donna 45 Email ML24209A003 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Bosold, Patrick 36 Regs.gov ML24187A128 Boudart, Jan Nuclear Energy Information Service 143-38 Meeting Transcript ML24219A265 Brand, Charles 12 Regs.gov ML24198A172 Brennaman, John 143-36 Meeting Transcript ML24219A265 Brenneman, John 56 Email ML24210A006 Brown, Robert 7

Regs.gov ML24198A183 Cabala, Tanya 143-40 Meeting Transcript ML24219A265 Campbell, Bruce 143-41 Meeting Transcript ML24219A265 Chappell, Mike County Commissioner for Van Buren County 143-17 Meeting Transcript ML24219A265 Cole, Margaret 122 Regs.gov ML24212A156 Connor, Bill 41 Email ML24207A027 Connors, Shawn 143-19 Meeting Transcript ML24219A265 Cook, Daywi Covert Township 143-31 Meeting Transcript ML24219A265 Cordell, Cyndy 143-18 Meeting Transcript ML24219A265 Cordell, Cyndy 87 Regs.gov ML24208A010 Cordell, John 131 Regs.gov ML24212A128 Cornelius, Ellen Flynn 97 Regs.gov ML24211A153 Cullen, Noreen 38 Regs.gov ML24187A129 Cunningham, James 9

Regs.gov ML24198A166 Currant, Jonathan IBEW Local 131 143-33 Meeting Transcript ML24219A265 Dalke, Lillian 16 Email ML24200A131 Davis, Bruce 70 Email ML24212A005 Davis, Bruce 143-2 Meeting Transcript ML24219A265 Davis, Bruce 143-26 Meeting Transcript ML24219A265 Davis, Bruce 10 Regs.gov ML24198A169 Dembs, Barb 91 Regs.gov ML24208A009 Dermody, Laurie 51 Email ML24209A015 Detering, Dietmar 31 Email ML24201A037 Diklich, Dolores 121 Regs.gov ML24212A154 Dinnin, Susan 82 Regs.gov ML24207A056 Doenmez, Sarah 1

Regs.gov ML24198A176 Donahue, James 49 Email ML24209A012 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Donovin, Paul 143-3 Meeting Transcript ML24219A265 Drechsler, Jacqueline 143-29 Meeting Transcript ML24219A265 Drechsler, Jacqueline 143-43 Meeting Transcript ML24219A265 Dunlevy, Andrea 81 Regs.gov ML24207A054 Duran, Brandon 17 Email ML24200A290 Ebert, Robert 93 Regs.gov ML24211A140 Eldredge Stark, Martha 106 Regs.gov ML24212A134 Eldredge, Tamesin 119 Regs.gov ML24212A152 Ferry, Carolyn 109 Regs.gov ML24208A006 Fetzer, Bruce 143-12 Meeting Transcript ML24219A265 Fetzer, Darby 143-10 Meeting Transcript ML24219A265 Flynn, Jody 143-11 Meeting Transcript ML24219A265 Flynn, Jody 67 Regs.gov ML24205A075 Flynn, Jody 142 Regs.gov ML24198A170 Flynn, John 126 Regs.gov ML24207A053 Flynn, Kevin 96 Regs.gov ML24211A152 Flynn, Lawrence 128 Regs.gov ML24211A142 Flynn, Olivia 99 Regs.gov ML24211A160 Flynn, Thomas 102 Regs.gov ML24212A126 Flynn, Tom 143-20 Meeting Transcript ML24219A265 Foresee, Peter 129 Regs.gov ML24211A149 Forsee, Jenny 79 Regs.gov ML24206A226 Francis, Darin 132 Email ML24215A380 Freeman, James 95 Regs.gov ML24211A145 Gibson, Robert 57 Email ML24211A001 Gillespie, Emily 88 Regs.gov ML24206A009 Goetzinger, Laurel Eldredge 133 Regs.gov ML24212A147 Gold, Colin 37 Regs.gov ML24200A016 Gordon, John 20 Email ML24201A010 Grabowski, Mary Ann 85 Regs.gov ML24207A187 Grigoa, Salvatore 64 Regs.gov ML24205A071 Grigola, Barbara 120 Regs.gov ML24212A153 Grivins, Jennifer 29 Email ML24201A035 Haan, Megan 32 Email ML24201A040 Hagen, James 23 Email ML24201A014 Hanson, Art 71 Email ML24212A007 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Hanson, Art 6

Regs.gov ML24198A182 Hartsough, Denise 21 Email ML24201A011 Hayes, Rose 18 Email ML24201A008 Hickmott, Carl 28 Email ML24201A019 Hohman, Kevin 105 Regs.gov ML24212A132 Holst, Jacqueline 143-13 Meeting Transcript ML24219A265 Holt, Philip Generation Atomic 143-39 Meeting Transcript ML24219A265 Hosier, Kate City of South Haven 143-32 Meeting Transcript ML24219A265 Hoskin, John 72 Email ML24212A015 Huffman, Mary 111 Regs.gov ML24211A148 Ippel, Trudi 50 Email ML24209A013 Jacobs, Kristen 103 Regs.gov ML24212A130 Jones, Virginia 44 Email ML24209A002 Kamps, Kevin Beyond Nuclear 76 Email ML24212A021 Kamps, Kevin Beyond Nuclear 143-35 Meeting Transcript ML24219A265 Kamps, Kevin Beyond Nuclear 143-42 Meeting Transcript ML24219A265 Keegan, Michael Don't Waste Michigan 143-37 Meeting Transcript ML24219A265 Keegan, Michael J.

Don't Waste Michigan 125 Regs.gov ML24212A159 Kelly, Katie 94 Regs.gov ML24211A144 Kleb, John 90 Regs.gov ML24207A067 Kraft, Dave Director of Nuclear Energy Information Service 143-30 Meeting Transcript ML24219A265 Lawlor, Edward 55 Email ML24210A005 Lee, Michel Council on Intelligent Energy &

Conservation Policy and Promoting Health and Sustainable Energy 77 Email ML24212A022 Lewis, Raymond J 89 Regs.gov ML24206A107 Lloveras, Leigh Anne The Breakthrough Institute 107 Regs.gov ML24212A135 Loar, Steve 43 Email ML24209A001 Lodge, Terry J Beyond Nuclear and Dont Waste Michigan 75 Email ML24212A020 Lombardi, Joan 134 Regs.gov ML24212A155 Lowy, Rebecca Environmental Law

& Policy Center 73 Email ML24212A017 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Mcardle, Edward 58 Email ML24211A002 McClain, Krystle Z.

US Environmental Protection Agency 63 Agency Letter ML24212A019 McCleary, Deidra 62 Regs.gov ML24204A137 McCleary, Dennis 65 Regs.gov ML24205A072 McLean, Michael 143-1 Meeting Transcript ML24219A265 McLean, Michael 143-15 Meeting Transcript ML24219A265 McLeod, Ben 143-6 Meeting Transcript ML24219A265 Metz, Ei 116 Regs.gov ML24212A140 Miller, Sherry 69 Email ML24211A313 Miller, Tom 69 Email ML24211A313 Moevs, Christian Forest Dunes Association 8

Regs.gov ML24198A184 Morris, Zach Market One 143-27 Meeting Transcript ML24219A265 Muhich, Mark 5

Regs.gov ML24198A180 Munski, Donald 48 Email ML24209A011 O'Brien, Kevin 74 Email ML24212A018 O'Brien, Kevin 140 Email ML24212A275 O'Brien, Thomas 98 Regs.gov ML24211A156 O'Byrne, Paul 61 Regs.gov ML24204A136 O'Connor, Gerry 86 Regs.gov ML24207A189 OBrien, Terry 124 Regs.gov ML24212A158 OConnor, Patricia 83 Regs.gov ML24207A183 Park, Abby 139 Email ML24212A262

Paulison, Christeen 138 Email ML24212A257 Paver, John 26 Email ML24201A017 Pierce, Kathleen 84 Regs.gov ML24207A184 Pierman, Bette Michigan Safe Energy Future 143-23 Meeting Transcript ML24219A265 Pilarski, Diane 3

Regs.gov ML24198A178 Progacki, Josh Office of State Senator Aric Nesbitt 143-8 Meeting Transcript ML24219A265 Quinn, Francis 108 Regs.gov ML24212A139 Quinn, Mary 104 Regs.gov ML24212A131 Ratcliff, Philip 60 Regs.gov ML24204A135 Reed, Dillon 66 Regs.gov ML24205A073 Reed, Dillon 11 Regs.gov ML24198A171 Reid-LeZotte, Nora 24 Email ML24201A015 Relias, George 130 Regs.gov ML24211A157 Richards, Terry 25 Email ML24201A016 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Ridley, Gavin 40 Email ML24206A262 Rivet, Ed Michigan Conservative Energy Forum 143-24 Meeting Transcript ML24219A265 Robertson, Ed 19 Email ML24201A009 Rogers, Julie 127 Regs.gov ML24208A007 Rogers, Larkin 39 Email ML24202A002 Rogers, Rosie 137 Email ML24212A273 Rushlow, Jake Office of State Representative Pauline Wendzel 143-9 Meeting Transcript ML24219A265 Sahagian, Linda G.

42 Email ML24207A029 Sawasky, Joseph 27 Email ML24201A018 Schalk, Tracy 46 Email ML24209A004 Schultz, Kraig 53 Email ML24210A003 Schultz, Kraig Michigan Safe Energy Future 143-21 Meeting Transcript ML24219A265 Scott, Ann 110 Regs.gov ML24208A005 Scott, Robert James 80 Regs.gov ML24207A052 Sears, Kathy 78 Regs.gov ML24206A185 Shariff, Nayyirah 143-4 Meeting Transcript ML24219A265 Sheridan, Paul 15 Email ML24195A000 Sleeper, George South Haven City Council 143-28 Meeting Transcript ML24219A265 Sloan, Jamie 92 Regs.gov ML24208A050 Somes, Claudia 113 Regs.gov ML24211A155 Stein, Ross South Haven Charter Township 143-34 Meeting Transcript ML24219A265 Stewart, Douglas A.

42 Email ML24207A029 Stranger, Karen 13 Regs.gov ML24198A174 Strehlow, Laura 35 Email ML24201A043 Taylor, Wally Beyond Nuclear and Don't Waste Michigan 143-25 Meeting Transcript ML24219A265

Thompson, Kathryn 101 Regs.gov ML24212A125 Tom McCullough, Tom 2

Regs.gov ML24198A177 Way, Ineke 143-5 Meeting Transcript ML24219A265 Weykamp, Greg 22 Email ML24201A012 Williams, Bonnie 54 Email ML24210A004 Commenter Affiliation Correspondence ID Comment Source ADAMS Accession Number Williams, Bonnie 100 Regs.gov ML24212A124 Williams, Donald 34 Email ML24201A042

Woodward, William 115 Regs.gov ML24212A136 Table A-2. Individuals Submitting All or Part of Form Letter Content Commenter ADAMS Accession Number Associated Form Accettulli, Samantha ML24200A128 Form 1 Alsterda, Terese ML24211A147 Form 8 Anderson, Kristen ML24211A294 Form 3 B, Maraia ML24211A334 Form 3 Bear, Charlotte ML24200A129 Form 1 Beatty, Lorne ML24212A002 Form 3 Beld, Cara ML24212A008 Form 3 Bell, Alyssa ML24202A005 Form 2 Bell, Christinia ML24200A151 Form 2 Benner, DeNell ML24211A308 Form 3 Blesing, Jessica ML24209A005 Form 3 Bobilin, Dris ML24200A278 Form 1 Boris, Donna ML24211A310 Form 3 Borton, Hannah ML24211A315 Form 3 Bouck, Jake ML24212A006 Form 3 Bridgwater, Elizabeth ML24200A135 Form 1 Brigham-Kardos, Marjorie ML24212A001 Form 3 Broses, Cathy ML24213A003 Form 3 Budde, Julie ML24200A299 Form 1 Burgess, John ML24200A298 Form 1 Chadwick, Lisa ML24211A312 Form 3 Clawson, Janet ML24211A296 Form 3 Coleman, Elayne ML24209A010 Form 3 Considine, John ML24212A004 Form 3 Craven, Jessica ML24200A133 Form 2 Dalhoff, Kathleen ML24212A265 Form 10 Daly, Anna ML24200A301 Form 2 De Jonge, Hope ML24211A314 Form 3 Denny, Frances ML24211A332 Form 3 Doster Marcusse, Jill ML24211A322 Form 3 Draper, Janet ML24209A008 Form 3 Draper, Janet ML24211A329 Form 3 Durivage, Mary Jo ML24211A323 Form 3 Commenter ADAMS Accession Number Associated Form Ellmann, Doug ML24211A318 Form 3 Ennis, Ryan ML24211A333 Form 3 Feltner, Pauline ML24209A016 Form 3 Fifelski, Karen ML24211A292 Form 3 Fisher, Marla ML24211A316 Form 3 Ford, Laura ML24200A274 Form 2 Gabriele, Jill Eldredge ML24212A151 Form 9 Garlit, Donald ML24211A337 Form 3 Gilpin, Thomas ML24211A339 Form 3 Goodman, Pamela ML24211A303 Form 3 Gregorski, MaryLynn ML24211A336 Form 3 Hankins, Lilly ML24200A155 Form 1 Hernandez, Amanda ML24211A327 Form 3 Hoag, Andrea ML24200A294 Form 2 Hoekema, Susan ML24211A338 Form 3 Horne, Tamara ML24209A006 Form 3 Jones, Connie M ML24200A130 Form 2 Kardos, Ron ML24212A000 Form 3 Kimball, Jess ML24200A292 Form 2 Kneeskern, Jill Davis ML24200A153 Form 1 Kowaleski, Tatyana ML24211A302 Form 3 Larsen, Keira ML24202A004 Form 1 Lin, LL ML24200A300 Form 2 Little, Debra ML24211A331 Form 3 Loos, Elisabeth ML24211A317 Form 3 Loyde, Patricia ML24200A287 Form 1 M, Areli ML24200A291 Form 1 Mantyk, Nancy ML24212A012 Form 3 Matey, Sam ML24200A302 Form 2 McEvoy, Michael ML24211A320 Form 3 McNeely, Allison ML24215A381 Form 3 Merz, Evan ML24200A116 Form 1 Miller, Richard ML24200A134 Form 2 Minotas, Tim ML24212A010 Form 3 Morgan, Karen ML24211A326 Form 3 Morgenthaler, Jeffery ML24211A298 Form 3 Morrison, Barbara J ML24211A328 Form 3 Moyer, Herbert ML24212A016 Form 4 Munski, Donald ML24211A299 Form 3 O'Brien, Matthew ML24212A271 Form 10 O'Neill, Nancy ML24211A297 Form 3 P, M ML24211A300 Form 3 Commenter ADAMS Accession Number Associated Form Park, Lucy ML24212A279 Form 10 Park, Lucy ML24212A146 Form 10 Parker, Elizabeth ML24210A001 Form 1 Paton, Patricia ML24200A132 Form 2 Pellegrini, Deb ML24211A335 Form 3 Pikaart, Marilyn and Phil ML24211A307 Form 3 Prostko, Linda ML24211A330 Form 3 Quinn, Barney ML24212A145 Form 5 Quinn, Charlotte ML24212A133 Form 7 Renkoski, Tami ML24211A321 Form 3 Rennie, Alice ML24200A288 Form 2 Ruth, Julie ML24212A267 Form 10 Salvat, Susan ML24211A290 Form 3 Sayre, Cathy ML24213A002 Form 3 Schaus, Carol ML24211A309 Form 3 Scheidler, Colleen O'Brien ML24212A255 Form 10 schlacht, walter ML24211A305 Form 3 Shillito, Jan ML24211A293 Form 3 Skelton, Julie ML24211A291 Form 3 Skelton, Julie ML24211A311 Form 3 SMALLFIELD, Margie ML24211A295 Form 3 Smith, Amy ML24211A304 Form 3 Solano, Daniel ML24211A319 Form 3 Spring, Kimberly ML24212A013 Form 3 St. Peter, Michele ML24209A007 Form 3 Stewart, Lane ML24211A301 Form 3 Stillman, Allison ML24202A003 Form 1 Viglietta, Martha and Tony ML24200A120 Form 1 Wiederhold, Joe ML24200A156 Form 1 Wightman, Jill ML24208A008 Form 6 Williams, David ML24209A014 Form 3 Woodland, Marcia ML24200A277 Form 2 Yankee, Everyl ML24212A003 Form 3 Zahn, Janet ML24212A009 Form 3 Zubrys, Paul ML24211A325 Form 3 Zubrys, Regenia ML24211A324 Form 3 ADAMS accession numbers for listed forms:

Form 1 = ML24200A119, Form 2 = ML24200A131, Form 3 = ML24209A004, Form 4 = ML24212A021, Form 5 = ML24212A139, Form 6 = ML24208A050, Form 7 = ML24208A006, Form 8 = ML24205A169, Form 9 = ML24212A147, Form 10 = ML24212A273 Table A-3. Distribution of Comments by Resource Area or Topic Subject Comments Accidents 3

Alternatives-No-Action 6

Alternatives-Other 18 Cooperating Agency 1

Cumulative Impacts 8

Ecology-Aquatic Resources 2

Ecology-Terrestrial Resources 1

Environmental Justice 5

General Environmental Concerns 21 Greenhouse Gas Emissions and Climate Change 3

Human Health-Nonradiological 2

Human Health-Radiological 24 Hydrology-Groundwater Resources 6

Hydrology-Surface Water Resources 9

Land Use and Visual Resources 1

Meteorology and Air Quality 3

Need for Project/Purpose and Need 3

Noise 1

Opposition-Licensing Action 95 Outside Scope-Aging Management 16 Outside Scope-Emergency Preparedness 6

Outside Scope-Energy Costs 21 Outside Scope-Miscellaneous 14 Outside Scope-Other Non-Restart Actions 35 Outside Scope-Safety 70 Outside Scope-Security and Terrorism 3

Process-Licensing Action 76 Process-NEPA 17 Socioeconomics 4

Support-Licensing Action 42 Uranium Fuel Cycle 1

Waste Management-Radioactive Waste 23 Appendix B Summary of Comments Received During the Scoping Period The NRC and DOE LPO staff reviewed all comments received and first categorized each as either related to a resource area that is applicable to the environmental review (summarized in section B.1) or related to a topic that is beyond the scope of the environmental review (summarized in section B.2). The comments were then consolidated according to a resource area or topic. This appendix contains a summary of the scoping comments received during the scoping period, categorized and consolidated by topic or resource area. The text of each categorized comment is shown in appendix C. Each comment submittal was uniquely identified.

When a submittal addressed multiple issues, the submittal was further divided into separate comments with tracking identifiers.

In the course of its review, the staff will consider all scoping comments related to environmental resource areas covered by the EA (i.e., those comments summarized in section B.1 and listed in complete form in section C.1), as appropriate. While these comments will be considered, the staff may determine that some of these comments include suggestions that go beyond the requirements of NEPA. In addition, the specific content or suggestions provided in the comments on how to address the identified topics will be considered but may not ultimately be discussed or implemented in the EA.

B.1 Comments Related to Resource Areas Considered in the Environmental Review B.1.1 Comments Concerning Accidents Comment Summary: Commenters requested that the accident analysis for the Palisades Nuclear Plant (Palisades) include the worst-case scenario.

Comments: (77-1-12) (143-41-4) (143-41-10)

B.1.2 Comments Concerning Alternatives - No-Action Comment Summary: Several commenters expressed preference for the No Action Alternative for Palisades based on the age of the plant and supposed unaddressed deficiencies and expressed a preference for alternative energy sources such as wind and solar. One commenter requested consideration of the negative impacts of not restarting Palisades, such as the need to use fossil fuels to meet energy needs. One commenter stated that a no-action alternative is required for the environmental assessment and that there has been adequate power in the region since cessation of operations at Palisades. This commenter stated that effects on the grid arrangements caused by restoration of Palisades should be included.

Comments: (75-6) (76-1-5) (107-3) (123-3) (123-6) (143-42-4)

B.1.3 Comments Concerning Alternatives-Other Comment Summary: Commenters requested a discussion of the impacts from alternate sources of power. Multiple commenters recommended or expressed their preference for the use of renewable energy (e.g., wind, solar, hydropower) as an alternative option to the restart of Palisades. Commenters stated that renewable energy is more cost-efficient, safe, sustainable and reliable, compared to the energy produced by Palisades. One commenter stated that there is renewable power waiting to be connected to the power grid and would be looking to the NRC to facilitate connection of renewable energy to the grid. Two commenters stated that solar power would require many acres of land, which would be on Michigan farmland. One commenter asked about consideration of the reuse of spent fuel as an alternative. One commenter expressed concern that the alternative of not restarting Palisades would result in extending reliance on fossil generation. A commenter discussed the impacts of nuclear energy compared to other alternative sources of energy. One commenter stated that the purpose and need for the action should be used to define the range of alternatives to be evaluated.

Comments: (19-2) (36-1) (46-3) (57-5) (63-1-4) (63-1-6) (63-1-7) (73-4) (73-6) (76-1-6) (77-2-5)

(108-3) (143-3-1) (143-3-2) (143-12-2) (143-24-2) (143-30-2) (143-42-5)

B.1.4 Comments Concerning Cumulative Impacts Comment Summary: Commenters expressed concerns over cumulative impacts at Palisades, including the potential future license extension and proposed new small modular reactors proposed by Holtec at Palisades. Cumulative concerns related to these potential future actions include additional risk from the extended lifespan, ecosystem degradation, potential cultural resource concerns, and additional releases of hazardous radioactivity and toxic chemicals. One commenter asked if the license extension at Palisades has already been granted, due to the funding to be provided to Palisades. One commenter stated that the nearby New Covert Generating plant, a natural gas facility, emits harmful emissions and plumes that, with certain wind conditions, can block sunlight when Palisades is in an operating status.

Comments: (1-2) (53-5) (55-6) (55-7) (76-1-12) (76-1-15) (77-1-3) (112-3)

B.1.5 Comments Concerning Ecology-Aquatic Resources Comment Summary: One commenter expressed concern about the effect of the intake entrapping fish, fish eggs, mollusks and other lifeforms and the impact that would have on the health and biota of Lake Michigan. Another commenter expressed concerns about the potential effects of higher surface water temperatures from the discharge on aquatic organisms.

Comments: (58-2) (63-1-15)

B.1.6 Comments Concerning Ecology-Terrestrial Resources Comment Summary: One commenter addressed regulated wetlands that may be located within the footprint of Palisades. If there will be potential impacts to wetlands during construction activities, this commenter recommended providing a wetland delineation and coordination with the Michigan Department of Environment, Great Lakes and Energy (EGLE).

Comment: (63-1-18)

B.1.7 Comments Concerning Environmental Justice Comment Summary: Commenters expressed concern over the environmental and human health impacts on communities with environmental justice concerns. The U.S. Environmental Protection Agency (EPA) provided recommendations regarding environmental justice issues, including worksite proximity to children, public participation, a potential change to the community composition since plant construction, and direct, indirect, and cumulative effects. The EPA also recommended that environmental justice terminology reflect recently revised CEQ regulations, EO 14096, and EO 13045.

Comments: (63-2-1) (63-2-2) (63-2-9) (76-1-16) (77-2-6)

B.1.8 Comments Concerning General Environmental Concerns Comment Summary: Commenters expressed general concerns about the environmental impacts from the reauthorization of operation at Palisades and requested that the NRC consider public comments and protect human health, safety, and the environment. Comments included concerns on the fresh water supply and Lake Michigan, tritium, the risk burden of the public, human health, groundwater, and greenhouse gases. One commenter requested environmental statistics for the surrounding area since the beginning of Palisades.

Comments: (33-2) (35-2) (37-2) (50-1) (71-1) (76-1-1) (76-2-5) (77-1-8) (113-4) (119-2) (124-3)

(134-2) (139-1) (139-2) (139-3) (140-2) (143-13-1) (143-13-4) (143-25-2) (143-30-1) (143-40-2)

B.1.9 Comments Concerning Greenhouse Gas Emissions and Climate Change Comment Summary: The three comments related to climate change at Palisades are from a single piece of correspondence: EPA Comments Notice of Intent to Conduct Scoping and Prepare Environmental AssessmentPalisades Nuclear Plant Reauthorization, Covert Township, Van Buren County, MichiganDocket Number 05000255. The comments provide recommendations for how to consider potential climate effects, mitigation, and adaption issues in the EA. The core recommendations are to consider (1) the potential effects of a proposed action on climate change, including the assessment of both GHG emissions and reductions from the proposed action; and (2) the effects of climate change on the proposed action and its environmental effects.

Comments: (63-1-19) (63-1-20) (63-1-21)

B.1.10 Comments Concerning Human Health-Nonradiological Comment Summary: The U.S. Environmental Protection Agency provided a list of protective measures related to occupational health to be considered in the draft EA. Protective measures included use of HEPA filters and respirators to minimize worker exposure to diesel fumes and reducing exposure through training and routine inspections. One commenter expressed concern about the release of water vapors from the cooling towers, stating that this increases the humidity in the environment and promotes growth of bacteria that cause diseases such as Legionellosis and meningitis.

Comments: (63-2-8) (75-4)

B.1.11 Comments Concerning Human Health-Radiological B.1.11.1 Human Health-Radiological Comment Summary 1 Comment Summary: Multiple commenters requested a thorough review of the cumulative impact to human health of Palisades, including from radiation. One commenter indicated that independent experts should be consulted as part of this review.

Comments: (62-1) (77-1-19) (143-4-1)

B.1.11.2 Human Health-Radiological Comment Summary 2 Comment Summary: Multiple commenters expressed concerns over environmental emissions produced by operations at Palisades and their potential release into the environment.

Commenters identified tritium and carbon-14 as emissions of concern with regards to human health. Commenters stated that impacts of planned and unplanned emissions must be considered during the licensing process.

Comments: (75-11) (77-1-20) (77-1-21)

B.1.11.3 Human Health-Radiological Comment Summary 3 Comment Summary: Multiple commenters expressed concerns about local health issues in the community surrounding Palisades. Commenters indicated that local health issues could be related to operation of Palisades. Commenters requested additional review of radiological human health specific to offsite members of the public.

Comments: (13-1) (55-4) (55-8) (58-4) (70-1) (110-2) (112-9) (113-3) (140-1) (143-2-1) (143 1) (143-13-3) (143-16-5) (143-19-2) (143-26-2) (143-31-2) (143-37-2) (143-37-4)

B.1.12 Comments Concerning Hydrology-Groundwater Resources Comment Summary: Comments related to groundwater address radiological releases (namely tritium) to groundwater from Palisades operations. Commenters are concerned with the potential risk of tritium-impacted groundwater migrating from the site to off-site drinking water sources and human receptors. Commenters are also concerned about the robustness of the sampling and monitoring procedures implemented at the site now and in the future (e.g., if the license is renewed beyond the current operating license).

Comments: (55-5) (63-1-17) (75-10) (75-12) (143-16-1) (143-26-4)

B.1.13 Comments Concerning Hydrology-Surface Water Resources Comment Summary: Commenters expressed concerns over surface water resources, specifically releases of radioactive, heated wastewater from Palisades into Lake Michigan and the effect on drinking water, littoral drift, and biomagnification within the food chain. One commenter requested information related to the past use of Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonate (PFOS) at Palisades, as the State of Michigan and the U.S.

Environmental Protection Agency have or are developing groundwater standards for these compounds. The U.S. Environmental Protection Agency requested inclusion of a water balance analysis and recommended providing information regarding coordination with EGLE on Coastal Zone Management Act actions.

Comments: (2-1) (7-2) (58-3) (63-1-9) (63-1-16) (75-15) (76-1-14) (102-2) (143-29-2)

B.1.14 Comments Concerning Land Use and Visual Resources Comment Summary: Commenter requested an examination of beach erosion that started in the early 1970s to determine if Palisades is responsible. This commenter stated that the beach erosion has made surrounding areas a High Risk Erosion Area.

Comment: (8-2)

B.1.15 Comments Concerning Meteorology and Air Quality Comment Summary: The U.S. Environmental Protection Agency provided the recommendation that the applicant commit to voluntary measures to reduce construction-related emissions. The commenter submitted an enclosure titled Construction Emission Control Checklist, which includes mobile and stationary source diesel controls and fugitive dust source controls.

Comments: (63-1-14) (63-2-6) (63-2-7)

B.1.16 Comments Concerning Need for Project/Purpose and Need Comment Summary: A commenter stated that a purpose and need statement is required by NEPA but is missing from the environmental report Holtec submitted to the NRC. The commenter suggests that the purpose and need consider the description of Palisades history, including previous plant maintenance, the rationale for decommissioning, and the current license. Another commenter stated that as energy demands from artificial intelligence and data centers increase, more energy will be required, which will necessitate increased baseload generation and other power sources, such as renewable energy.

Comments: (63-1-3) (63-1-5) (143-27-2)

B.1.17 Comments Concerning Noise Comment Summary: Commenter states that operational activities can be heard at their home, depending on the wind direction.

Comment: (131-1)

B.1.18 Comments Concerning Socioeconomics Comment Summary: A commenter expressed concern about negative economic effects of the reauthorization of operation at Palisades. Several commenters stated that Palisades would provide positive impacts for the local areas tax base and employment. One commenter requested that the long-term tax and economic effect of adding nuclear waste in Michigan be addressed.

Comments: (77-2-1) (143-7-2) (143-27-1) (143-32-2)

B.1.19 Comments Concerning the Uranium Fuel Cycle Comment Summary: A commenter expressed concern about the origin of new fuel for Palisades. The commenter requested that the impacts of the reauthorization of operation at Palisades on the uranium fuel cycle in the United States be analyzed.

Comment: (58-5)

B.1.20 Comments Concerning Waste Management-Radioactive Waste B.1.20.1 Waste Management-Radioactive Waste Comment Summary 1 Comment Summary: Multiple commenters expressed concern about the potential impacts of radioactive waste on the local environment. Several commenters expressed concerns about potential impacts of storing radioactive waste from Palisades next to Lake Michigan.

Commenters expressed concerns about the impact of radioactive waste to local environmental features and fresh water.

Comments: (42-3) (51-1) (66-3) (91-1)

B.1.20.2 Waste Management-Radioactive Waste Comment Summary 2 Comment Summary: Multiple commenters expressed concern about long term storage of radioactive waste at Palisades. Several commenters expressed concerns over the lack of a permanent disposal solution. Several commenters expressed concerns over the storage of fuel in spent fuel pools and subsequently into dry cask storage.

Comments: (1-3) (18-1) (48-3) (63-1-10) (76-1-18) (76-1-20) (76-2-2) (77-2-3) (86-2) (93-2)

(143-19-3) (143-23-2) (143-37-1)

B.1.20.3 Waste Management-Radioactive Waste Comment Summary 3 Comment Summary: Two commenters expressed concerns over the potential cumulative impacts of spent fuel storage from additional small modular reactors. One of the commenters stated that impacts of high-level radioactive waste generated by any small modular reactors built at Palisades would need to be assessed in the NEPA process.

Comments: (75-14) (76-2-3)

B.1.20.4 Waste Management-Radioactive Waste Comment Summary 4 Comment Summary: Multiple commenters expressed concern over the transportation impacts of fresh and spent fuel to and from Palisades, including the potential use of barges on Lake Michigan to transport spent nuclear fuel. One commenter requested an analysis of radioactive wastes that would be generated by the reauthorization of operations at Palisades.

Comments: (33-5) (63-1-12) (143-23-4) (143-40-1)

B.2 Non-Technical and Comments Outside the Scope of the Environmental Review B.2.1 General Comments in Support of the Licensing Action Comment Summary: Commenters expressed support for nuclear power or for reauthorization of operation at Palisades Nuclear Plant (Palisades). Commenters cite the clean energy provided by nuclear power, the safe operation of nuclear power and of Palisades historically, the need for baseload power, and positive impacts on the community and economy.

Comments: (14-1) (16-1) (16-2) (17-1) (22-1) (23-1) (29-1) (31-3) (32-1) (34-1) (37-1) (37-3) (39-

1) (40-1) (42-5) (52-1) (57-1) (57-3) (107-1) (107-4) (134-5) (143-6-1) (143-7-1) (143-7-3) (143-8-1) (143-9-1) (143-10-2) (143-12-1) (143-15-1) (143-17-1) (143-19-1) (143-19-4) (143-24-1)

(143-28-1) (143-31-1) (143-31-4) (143-32-1) (143-32-3) (143-33-1) (143-33-5) (143-34-1) (143-39-1)

B.2.2 General Comments in Opposition to the Licensing Action Comment Summary: Commenters expressed opposition to nuclear power or the reauthorization of operation at Palisades. Reasons for opposition included various environmental and safety concerns, cost, and the fact that a nuclear power plant that has entered decommissioning has never resumed power operations.

Comments: (3-1) (4-1) (5-1) (5-6) (6-1) (7-1) (7-4) (9-1) (12-1) (15-1) (19-1) (20-1) (21-1) (24-1)

(25-1) (27-1) (28-1) (30-1) (33-9) (36-2) (38-1) (41-1) (43-1) (44-1) (45-1) (46-4) (47-1) (48-1)

(48-4) (51-2) (54-4) (55-2) (56-1) (59-1) (60-1) (61-1) (66-4) (67-1) (69-1) (72-1) (72-4) (74-1)

(76-1-2) (77-1-10) (78-1) (79-1) (80-1) (80-3) (82-1) (83-1) (84-1) (86-1) (88-1) (93-1) (94-1) (95-

1) (97-1) (101-1) (105-1) (108-1) (108-7) (109-1) (109-2) (110-5) (111-4) (112-11) (113-1) (114-

2) (115-1) (116-1) (117-1) (122-1) (123-1) (124-1) (124-4) (124-5) (126-1) (127-1) (128-1) (130-

1) (132-1) (134-3) (136-1) (137-1) (140-3) (143-14-1) (143-16-4) (143-16-7) (143-29-4) (143 6) (143-36-1) (143-37-3) (143-40-5) (143-41-5) (143-41-8)

B.2.3 Comments Concerning Cooperating Agency Comment Summary: One commenter requested the Holtec Conditional Commitment Loan term sheet be made available for public view.

Comment: (141-10)

B.2.4 Comments Concerning Process-Licensing Action B.2.4.1 Process - Licensing Action Comment Summary 1 Comment Summary: Commenters expressed concern that Holtec is attempting to sidestep NRC regulatory requirements by requesting an exemption, license transfer, and license amendments in connection with the reauthorization of operations at Palisades and requested that the NRC not grant the requests. One commenter also stated that the NRC must not rely on outdated reports or cite regulations as an evidentiary basis for any finding. Another commenter stated that Holtec is exploiting a loophole from an NRC denial letter concerning the exemption rule, which the commenter states is the basis for all licensing actions for Palisades. This commenter stated that exemptions are not for reversing a major licensing event. One commenter asked whether the passing of the ADVANCE Act changes the process for Palisades. One commenter demanded that no exemptions be granted to Holtec on safety and environmental testing, in the event Palisades is reopened. Two commenters noted the importance of the NRC's task and requested the NRC to get it right.

Comments: (75-16) (75-17) (77-1-4) (77-2-8) (138-1) (141-1) (141-3) (141-5) (143-1-1) (143 2) (143-18-2) (143-26-3)

B.2.4.2 Process - Licensing Action Comment Summary 2 Comment Summary: Commenters provided comments regarding public involvement during the scoping comment period. Two commenters expressed interest in reviewing the transcripts from the public scoping meeting on July 13th, 2024, and noted that the transcripts had not yet been released to the public. Commenters expressed concern that the 30-day public comment period is insufficient and requested that the comment period be extended to 180 days. One commenter expressed thanks for the opportunity to be involved in the NEPA process. One commenter conveyed appreciation for the NRC staffs communications concerning the environmental analysis and Covert Township. One commenter stated that they expect the NRC to consider all public comments. The U.S. Environmental Protection Agency recommended the NRC and DOE address their comment before releasing the EA.

Comments: (55-1) (63-1-1) (63-1-2) (76-1-4) (125-2) (143-13-5) (143-31-3) (143-33-3) (143 1) (143-41-2)

B.2.4.3 Process - Licensing Action Comment Summary 3 Comment Summary: Multiple commenters requested the NRC develop a site-specific environmental impact statement or a programmatic or generic environmental impact statement for Palisades. Reasons provided for this request include the following:

(1) restarting a nuclear plant from a decommissioning state is a first of a kind event; (2) restarting a nuclear plant from a decommissioning state should be as stringent or more stringent than commissioning a new plant or license renewal; (3) Holtec is a new, inexperienced operator; (4) NRC cannot assume that there will be a FONSI; (5) if there is controversy over the degree of environmental impacts, an EIS is required; (6) the Palisades Plant entered decommissioning because it was no longer financially feasible to run due to disrepair and required safety upgrades, which may impact the human environment; (7) NRC compared the restart of Palisades 'to the license renewal process and NRC's regulations require an EIS for license renewals; (8) NRC and DOE cannot rely on outdated, stale documents, including the 2006 Palisades EIS or the 2013 Generic EIS for License Renewal; (9) reauthorization of Palisades requires an alternative analysis; and (10) potential environmental effects, including the impact of climate change conditions and hazards of nuclear.

One commenter stated that as Palisades has a valid operating license until 2031 and that a full EIS was previously completed, only new impacts that could reasonably have changed since the plant ceased operations and that are significantly different from the prior EIS should be considered in an EA. Another commenter advocated for an expedited environmental review as Palisades has remained unchanged since its shutdown.

Comments: (5-2) (31-1) (31-2) (31-4) (35-1) (42-2) (53-1) (54-1) (54-3) (55-3) (58-6) (68-1) (68-

4) (73-1) (73-2) (73-3) (73-7) (73-8) (74-3) (75-1) (75-2) (76-1-3) (77-1-1) (77-1-5) (77-1-11) (81-

1) (85-1) (89-1) (89-2) (92-2) (96-1) (98-2) (100-1) (102-1) (103-2) (104-1) (105-3) (106-1) (107-

2) (116-2) (123-2) (125-3) (130-2) (133-1) (133-4) (134-1) (143-21-3) (143-25-1) (143-25-3)

(143-29-5) (143-35-2) (143-41-1) (143-41-9) (143-42-2)

B.2.5 Comments Concerning Process-NEPA B.2.5.1 Process - NEPA Comment Summary 1 Comment Summary: The U.S. Environmental Protection Agency provided several recommendations for inclusion in the Palisades draft environmental assessment. These recommendations include:

(1) providing copies of interagency coordination; (2) providing a list of all required permits; (3) using the updated NEPA regulations for evaluations; (4) creating an appendix for all scoping comments; (5) writing the draft environmental assessment in plain language; and (6) considering use of databases for resource areas, including environmental justice, water, and air quality.

Comments: (63-1-8) (63-2-3) (63-2-4) (63-2-5) (75-5)

B.2.5.2 Process - NEPA Comment Summary 2 Comment Summary: Multiple commenters requested that the NRC expand the current rules or develop new regulations, guidelines, or protocols that would provide direction on restarting Palisades and potential future nuclear plants that are in decommissioning. Commenters stated that these new regulations should be in place prior to reauthorizing Palisades. Several commenters stated that a petition for rulemaking related to returning a decommissioning plant to operating status has already been submitted and requested that the NRC grant the petition. The NRC is reviewing this petition for rulemaking outside of this environmental review.

Comments: (10-1) (90-1) (118-2) (120-2) (121-1) (129-1) (141-2) (141-4) (141-6) (143-14-3)

(143-18-3) (143-26-1)

B.2.6 Comments Concerning Outside Scope - Aging Management Comment Summary: Several commenters expressed concern about aging components at Palisades or the ability to effectively manage aging for preparation of reauthorization activities and future operations. Commenters cited reactor vessel embrittlement, age-degraded steam generators, and deferred maintenance due to planned plant decommissioning, among other concerns.

Comments: (8-1) (26-1) (66-1) (75-7) (76-1-8) (77-1-2) (77-1-17) (112-1) (112-4) (120-1) (124-2)

(131-2) (133-2) (143-16-2) (143-23-1) (143-40-3)

B.2.7 Comments Concerning Outside Scope - Emergency Preparedness Comment Summary: The NRC received comments addressing emergency preparedness concerns at Palisades, including the disconnection of local emergency sirens and emergency response planning. Two commenters requested that a non-revocable fund be established by Holtec for current and future issues related to human life and the environment. One commenter asked who would be responsible for the financial impacts of a possible accident and stated that local residents needed assurances that compensation would be provided.

Comments: (13-2) (72-3) (74-4) (77-1-15) (112-8) (140-4)

B.2.8 Comments Concerning Outside Scope - Energy Costs Comment Summary: Commenters expressed concerns related to the high cost of electricity and restart and operation of Palisades. Commenters also made statements regarding the overall cost advantages of renewable energy sources. Commenters noted that there are additional costs related to accidents, transportation of waste, emergency planning, and security.

One commenter stated that these additional costs should be quantified and included in an EIS.

One commenter expressed concern over the lack of liability of nuclear plant operators. Other commenters noted the low operating cost of nuclear energy.

Comments: (5-5) (33-7) (33-8) (46-2) (48-2) (57-4) (73-5) (77-1-9) (77-1-16) (77-2-2) (77-2-4)

(108-5) (110-4) (111-1) (112-2) (118-3) (143-15-2) (143-38-3) (143-41-3) (143-42-1) (143-42-3)

B.2.9 Comments Concerning Outside Scope - Miscellaneous Comment Summary: The U.S. Environmental Protection Agency recommended methods for reducing operational costs and protecting the environment during construction at Palisades through the use of energy-efficient and/or sustainable building materials, considering green stormwater practices, and replacing carbon-intensive cement. One commenter requested assurance from the NRC that monitoring of wells will occur in the local areas around Palisades.

Two commenters provided recommendations for how their state should prioritize energy options. One commenter provided information regarding zero-carbon-dioxide power for naval bases. Other comments addressed project labor and maintenance agreements at Palisades, choosing between human health and business, and pricing out the cost of things that can't be calculated (e.g., safety of workers, cancer of children, and not listening to the ideas of indigenous peoples).

Comments: (63-1-13) (86-3) (108-6) (109-4) (135-1) (135-2) (143-13-2) (143-13-6) (143-33-4)

(143-38-1) (143-38-2) (143-38-4) (143-38-5) (143-38-6)

B.2.10 Comments Concerning Outside Scope - Other Non-Restart Actions B.2.10.1 Outside Scope - Other Non-Restart Actions Comment Summary 1 Comment Summary: Numerous commenters expressed concern over Holtecs business practices, stating that Holtec is inexperienced and has demonstrated negative past practices and performance, resulting in a lack of confidence and trust in Holtec's ability to operate a nuclear reactor.

Comments: (5-4) (8-3) (11-1) (33-3) (41-2) (42-4) (53-3) (66-2) (68-3) (72-2) (76-1-10) (76-1-17)

(91-2) (93-3) (108-2) (109-3) (111-3) (112-5) (112-10) (113-2) (119-1) (133-3) (134-4) (143 3) (143-29-1) (143-40-4) (143-41-7) (143-43-1)

B.2.10.2 Outside Scope - Other Non-Restart Actions Comment Summary 2 Comment Summary: Commenters provided comments concerning Holtec's proposed addition of small modular reactors (SMRs) at Palisades. Commenters stated that SMRs have never been deployed in the U.S., are not small, would generate more radioactive waste, and are risky to install next to a large freshwater source. One commenter asked if the SMRs could be used to black start the rector during a regional grid blackout.

Comments: (1-1) (1-4) (57-2) (76-1-13) (112-6) (143-33-2) (143-41-6)

B.2.11 Comments Concerning Outside Scope - Safety Comment Summary: Commenters expressed concern about the safety at Palisades and requested the NRC take various safety issues under consideration. Comments included concerns over deferred maintenance of equipment, structures, and components, the need for Palisades to be brought up to safety standards, storage of waste, the quality assurance plan, and a track record of safety problems and violations at Palisades. Commenters stated that safety issues could result in reactor meltdown or a nuclear accident similar to Chernobyl. Other commenters expressed concerns about the impacts of external events and natural hazards, primarily from climate change, on Palisades. Commenters noted that climate change would increase the frequency and intensity of storms and requested an assessment of how these changes could impact the project. One commenter requested that the NRC inspection plan of restart activities and a list of resort issues from the NRC Inspection Manual be made available to the public.

Comments: (5-3) (7-3) (10-2) (33-1) (33-4) (42-1) (46-1) (49-1) (53-2) (53-4) (54-2) (58-1) (61-2)

(63-1-11) (64-1) (65-1) (68-2) (74-2) (75-3) (75-8) (75-9) (75-13) (76-1-7) (76-1-9) (76-1-11) (76-1-19) (76-2-1) (76-2-4) (77-1-6) (77-1-14) (77-1-18) (77-2-7) (80-2) (87-1) (87-2) (92-1) (93-4)

(98-1) (99-1) (103-1) (104-2) (105-2) (108-4) (109-5) (110-1) (110-3) (111-2) (112-7) (114-1)

(118-1) (123-4) (123-5) (125-1) (141-7) (141-8) (141-9) (142-1) (143-10-1) (143-11-1) (143 6) (143-18-1) (143-20-1) (143-21-1) (143-21-2) (143-21-4) (143-23-3) (143-26-5) (143-29-3)

(143-35-3) (143-35-4)

B.2.12 Comments Concerning Outside Scope - Security and Terrorism Comment Summary: Two commenters expressed concern about potential terrorist attacks at Palisades, including cyberattacks and attacks on the regional electric grid, and the potential effects of such attacks on major Midwestern cities.

Comments: (33-6) (77-1-7) (77-1-13)

Appendix C Comments Received During the Scoping Period C.1 Comments Related to Resource Areas Considered in the Environmental Review C.1.1 Comments Concerning Accidents Comment: Severe accidents must not be discounted simply because NRC and licensee assumptions deem them unlikely. Plausible worst case scenarios mandate evaluation and transparent disclosure to the public. (77-1-12 [Lee, Michel])

Comment: One question got a response that reactor accident consequences will be assessed in the EA, or preferably in the EIS.

Please make sure that various intensities of nuclear accidents are considered in this assessment.

Sandia Labs came out with a reactor accident consequences study late in 1982; however, the worst-case reactor accident consequences information was suppressed until Ed Markey still in, now in the Senate, raised hell and finally got them to release the worst case reactor accident data they had.

So, don't suppress that worst case data in that assessment. (143-41-4 [Campbell, Bruce])

Comment: don't suppress worst case reactor accident consequences (143-41-10 [Campbell, Bruce])

C.1.2 Comments Concerning Alternatives - No-Action Comment: Presentation and Discussion of Alternatives is Missing But Required There is no presentation of alternatives, even a no-action alternative, in the Holtec ER. Under NEPA, Holtecs environmental review must rigorously explore and objectively evaluate all reasonable alternatives. 40C.F.R. § 1502.14(a). NEPA requires a searching inquiry into alternatives. Simmons v. U.S. Army Corps of Eng'rs, 120 F.3d 664, 666 (7th Cir.1997).

Identification and discussion of alternatives to the project must appear in an Environmental Assessment for an NRC license. 10 CFR § 51.30(a)(1) (ii and iii).

NEPA regulations also require a discussion of a no-action alternative. 40C.F.R. § 1502.14(d).

The purpose of the no-action alternative is to compare the potential impacts of the proposed major federal action to the known impacts of maintaining the status quo. Custer Cnty. Action Ass'n v. Garvey, 256 F.3d 1024, 1040 (10th Cir. 2001).

NEPA expects a substantial treatment of each alternative to be considered in an EIS. 40 C.F.R. § 1502.14(b); see also, Southeast Alaska Conservation Council v. FHWA, 649 F.3d 1050 (9th Cir. 2011).

Notably, the no-action alternative is the de facto circumstance presently in the Palisades power distribution region. Regional grid administrators had timely prepared for the permanent cessation of operations and for more than two years there has been adequate power for all purposes in that portion of the regional electrical grid which formerly received power from Palisades. Effects on present and planned power grid arrangements caused by restoration of Palisades to operation must be encompassed within the scope of the NEPA document here. (75-6 [Lodge, Terry J])

Comment: The No Action Alternative is preferred. The nearly 60-year-old (ground was broken in 1967) Palisades atomic reactor should remain closed for good, as it has been since May 20, 2022. (76-1-5 [Kamps, Kevin])

Comment: 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 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 3 Public Law No: 118-5, https://www.congress.gov/bill/118th-congress/house-bill/3746.

4 42 USC 2011(a).

5 Public Law No: 118-67, Sec. 501, https://www.congress.gov/bill/118th-congress/senate-bill/870.

(107-3 [Lloveras, Leigh Anne])

Comment: 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 newbuilds scheme at Palisades. (123-3 [Bogen, Doug])

Comment: Because of these and many other unaddress[ed] deficiencies, I urge you to take No Action on the reckless and unnecessary Palisades restart proposal. (123-6 [Bogen, Doug])

Comment: So of course, our preferred alternative, no restart. So, the no action alternative. (143-42-4 [Kamps, Kevin])

C.1.3 Comments Concerning Alternatives-Other Comment: Alternatives like wind and solar power are preferable and can replace Palisades 800 Megawatts-electric output more cost-effectively, cleanly, safely, securely, promptly, and reliably. (19-2 [Robertson, Ed])

Comment: I have some expertise in renewable energy technologies such as wind energy and solar energy, in particular distributed solar power projects. You have never heard of a wind turbine spill, leak or core meltdown; or a solar array spill, leak or core meltdown, and you never will. These technologies are far safer than nuclear electric power generation, particularly in the case of Holtec Corp.'s proposed re-start of the shuttered Palisades Nuclear Power Plant and Holtec's proposed new Small Modular Reactors at the same site. All of the electric power that would be generated by these nuclear facilities can be generated by solar and wind electric power facilities, at far lower cost, with less cost per Kwh [kilowatt hour] to ratepayers, and with none of the public health and environmental hazards that come with Holtec Corp.'s proposed projects. (36-1 [Bosold, Patrick])

Comment: We have a unique opportunity to pivot towards a sustainable and cost-effective energy future. By investing in large-scale solar and wind energy, combined with energy efficiency, storage, demand response, and distributed generation, we can meet our energy needs without the burden of nuclear energy. This approach not only promises a cleaner environment but also ensures that we do not saddle our ratepayers with unnecessary and exorbitant costs. (46-3 [Schalk, Tracy])

Comment: Environmental Land Impact of Energy Because the energy density of nuclear energy is the highest of all energy sources, land impact of nuclear energy is very low and maybe the lowest of any human made energy source.

Carbon Intensity of the Energy System in 2050 The state of Minnesota has propose an electrical grid whose carbon intensity may be 83 grams of CO2(eq) per kWh [my calculation] and has 76% of its electrical generation coming from solar energy and wind energy and with some battery backup. The Center of the American Experiment has proposed an electrical grid whose carbon intensity may be 12 grams of CO2(eq) per kWh [my calculation] and has 86% of its electrical generation coming from nuclear energy and a very small amount of battery backup.

How can a renewable energy grid have more carbon intensity than a nuclear energy grid? If too little natural gas or nuclear energy is not allowed to back up a grid, which depends primarily on renewable energy, you must add many more solar energy and wind energy units to the energy system than what was originally planned to compensate for the low-capacity factors and the intermittency of the energy sources. How the overall electrical grid is designed makes a huge difference in the carbon intensity of an electrical grid. (57-5 [Gibson, Robert])

Comment: The purpose and need for the action should be used to define the range of alternatives to be evaluated. (63-1-4 [McClain, Krystle Z.])

Comment: Include alternatives that discuss alternate sources of power for proposed users. (63-1-6 [McClain, Krystle Z.])

Comment: Demonstrate how the Preferred Alternative will address identified problems or deficiencies. (63-1-7 [McClain, Krystle Z.])

Comment: NRC and DOE must consider a robust combination of renewables and energy efficiency alternatives both in terms of costs and environmental impacts.

NRC and DOE must evaluate reasonable alternatives to restarting Palisades.

These alternatives should include other energy alternatives, such as renewables, and in particular consider renewables in combination with each other. The 2006 EIS assessed renewable alternatives such as solar, wind, and hydropower in isolation. However, the landscape for renewables has changed dramatically since 2006. Advanced technology, current economics, ongoing energy transition, and other factors now support combination of renewable energy resources as critical to a reliable grid and better than an isolated source approach.

Therefore, a combination of renewables is well within the reasonable range of alternatives that an agency should consider in its alternatives analysis.23 23 40 C.F.R. § 1502.14(a).

(73-4 [Lowy, Rebecca])

Comment: Additionally, though NEPA and NRC regulations allow for evaluation of alternatives in a later stage analysis when there is a two-phase process, there does not appear to be any such second-stage planning for the proposed restart of Palisades.26 This is the only opportunity to evaluate alternatives.

26 See Simmons v. U.S. Army Corps of Engineers, 120 F.3d 664 (7th Cir. 1997); c.f. Environmental Law &

Policy Center v. U.S. Nuclear Regulatory Commission (ELPC), 470 F.3d 676 (7th Cir. 2006) (holding that alternatives could be evaluated in the second stage of the licensing process). (73-6 [Lowy, Rebecca])

Comment: 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, safely, securely, promptly, and reliably than the zombie reactor restart scheme, and Holtec's inextricably connected SMR-300 (so-called "Small Modular Reactors" of 300 MWe each) new builds scheme at Palisades, as well as at its sibling closed and decommissioned (although still radioactively contaminated, and still storying high-level radioactive waste on-site) Lake Michigan shoreline reactor site, Big Rock Point near Charlevoix. (76-1-6 [Kamps, Kevin])

Comment: Exploration of all reasonable energy alternatives, especially the renewable clean forms of energy that are widely viewed as the energy technologies of the future as well as efficiency technologies, demand-side options, grid upgrades, and battery/storage.

In contrast to nuclear power, all of these energy solutions are less costly, more sustainable, and do not present anywhere near the level of national and global security risks inherent in nuclear. (77-2-5 [Lee, Michel])

Comment: Nuclear energy is inherently risky, slow, and expensive. Instead of investing in this outdated technology, our state should focus on cleaner, safer, and more cost-effective energy solutions. Renewable energy sources such as solar and wind, combined with energy efficiency programs, offer a more sustainable path forward. These alternatives not only provide reliable power but also create jobs and stimulate economic growth. (108-3 [Quinn, Francis])

Comment: You're supposed to also look at what I understand is alternatives to nuclear. So, people talk about solar. For 900 megawatts, that would take about, oh, 1200 or so acres, and in Michigan that's prime farmland. So, in terms of human health, there's people that depend on that farmland to produce food that we eat.

And to me, the Michigan fruits and vegetables are unique in this part of the world. And you probably want to, before you leave to go back to Washington, sample them for your own information. (143-3-1 [Donovin, Paul])

Comment: Item 2 is, are you considering spent fuel reuse. And the Canadians have proposed a variation of the CANDU reactor that uses blended-down spent fuel. So, would that be considered as an alternative? (143-3-2 [Donovin, Paul])

Comment: I trust the NRC experts also and thank you for the proceeding with the review and the restart of this. And from your presentation tonight, I understand that your review includes social and economic considerations as well.

So, my request in your scoping project is to consider the impact of not including reliable baseload power to the tune of 800 megawatts. (143-12-2 [Fetzer, Bruce])

Comment: But I can tell you that, if you have to consider the impacts of alternatives -- and someone mentioned earlier the impact of having solar and the volume to equal Palisades' 800 megawatts, and they, unfortunately, pretty vastly underestimated it. It would be almost 10,000 acres of farmland to produce the same amount of energy with solar that Palisades would. Now, we're all good with solar, even 10,000 acres worth, but you do have to understand that alternatives, which I heard you earlier say is part of your assessment, that alternatives include thousands and thousands of acres for solar. And we do like that. We're fine with that.

Another alternative to not restarting Palisades, though, means that we will be extending our reliance on fossil generations for many years longer than necessary, and that is a high opportunity cost we need not pay. We should not leave these environmental benefits on the table in producing energy without direct carbon emissions to the atmosphere. (143-24-2 [Rivet, Ed])

Comment: I wanted to get this comment out verbally because a lot of the misinformation I've heard, and mixed mischaracterization about renewal energies availability, and reliability.

But also, I will write this out specifically as a task for the NRC examiners, in terms of doing a time and cost comparison since you're required to evaluate alternatives to the Palisades reopening.

I wanted to point out that last year, the Federal Energy Regulatory Commission, FERC, announced that in the cue waiting to be connected to the power grid, roughly 2,600 gigawatts of power.

About 80-85 percent of that is solely renewables, which means there's roughly 1,900 gigawatts of power in various stages of development from renewables, solar, wind, and battery storage, things like that, that are not connected to the grid but could be.

We need to do a time and cost comparison as to whether it is much more efficient, improve the reliability and the power availability of power in Michigan, to actually go ahead and get some of those renewables connected to the grid.

Now, the 1,800 megawatts nationwide, is roughly 20 times the entire output of every operating nuclear plant in the country today.

I don't know what Michigan's percentage of that is, but it certainly would be something that has to be examined by the NRC, if it's going to make an appropriate economic evaluation of the opening of Palisades.

I would also point out for those Michiganders who have been misinformed about renewable energy, that in the first third of this year, the energy information agency of the government announced that solar and wind alone, the power output exceeds the entire output of all of the operating nuclear reactors in the United States.

So if you're talking about reliability and availability of power, the information you have had and I've heard tonight, is incredibly out of date if not deliberately misleading.

So, to summarize specifically, I will be looking for the NRC's comments on the facilitating the connection of renewable energy, energy storage, and transmission improvements to the grid as an alternative to Palisades.

And that is another aspect is transmission. It doesn't matter if you have a million wind turbines or a million nuclear reactors. If you don't have a viable transmission system to conduct it, it's all useless.

And there are technologies are available such as reconductoring, grid resiliency solutions, which could double the entire capacity of the existing grid we have, without having to put any new lines up.

So from a standpoint of jobs, from a standpoint of reliability, from a standpoint of power availability, there are many alternatives that Michigan should be looking into instead of lavishing tens, if not hundreds of millions of dollars, on a speculative reopening of a nuclear reactor.

I'll put some of this in writing to make it a little more clear, but I will expect that to be in the final analysis. (143-30-2 [Kraft, Dave])

Comment: And in terms of alternative sources of electrical generation, that would be renewables like wind and solar combined with efficiency and storage.

That is our preferred alternative. (143-42-5 [Kamps, Kevin])

C.1.4 Comments Concerning Cumulative Impacts Comment: As Holtec CEO Krishna Singh himself has pointed out, the two SMR-300s at Palisades would nearly double the nuclear mega-wattage on the 432-acre site (800 MWe + 600 MWe). This would represent a very concentrated amount of nuclear risk and radioactive environmental impact on the tiny site. [T]he environmental impacts at the nearly 60-year old zombie reactor cannot legally be segmented from the environmental impacts at the SMR-300 new builds. These are not only radiological but also physical. For example, the construction of two 300-MWe reactors on the tiny, 432-acre Palisades site would wreak further havoc with the fragile, endangered forested dunes ecosystem there. It would also threaten Indigenous cultural properties very likely located there, including sacred ancestral burial sites. (1-2 [Doenmez, Sarah])

Comment: Holtec has said they intend to pursue a license past 2031, and they would like to build SMRs there as well. If we intend to operate this plant for decades longer (something that has never been done before), we need to double down and increase our scrutiny to make sure we don't have a nuclear disaster here or anywhere in the world." (53-5 [Schultz, Kraig])

Comment: A complicating factor in an environmental and safety assessment is the proximity of the New Covert Generating Plant, a 1.17MW natural gas facility (for reference only 1.1 miles from our house), that is also producing significant emissions with known health risks. While natural gas generating plants have a reputation for being clean relative to coal, they still produce significant NOx, CO, and other harmful emissions. Depending on wind conditions, the combination of plumes from the Palisades plant (when operating) and the New Covert Generating Plant can be extraordinary, blocking the sunlight. (55-6 [Lawlor, Edward])

Comment: While the NRC can take the position that emissions from an adjacent natural gas plant is "not our problem, from the perspective of residents it is the cumulative risk to health that is the relevant question, especially as Holtec and the NRC contemplate adding additional nuclear plants. (55-7 [Lawlor, Edward])

Comment: Risks at the zombie reactor, and their impacts on the environment, will be exacerbated by reactor risks at the SMR-300s Holtec also proposes building on the tiny, 432-acre Palisades site. In addition to having no experience operating atomic reactors, Holtec also lacks any experience building atomic reactors. The nearly 60-year old reactor will have worsening age-related degradation, breakdown phase risks, from August 2025 to 2051 (Holtec has announced application for a 2031 to 2051 license extension, amounting to 80 years of operations, twice the initial 40 years). (76-1-12 [Kamps, Kevin])

Comment: The environmental impacts at the nearly 60-year old zombie reactor cannot legally be segmented from the environmental impacts at the SMR-300 new builds. These are not only radiological but also physical. For example, the construction of two 300-MWe reactors on the tiny, 432-acre Palisades site would wreak further havoc with the fragile, endangered forested dunes ecosystem there. It would also threaten Indigenous cultural properties very likely located there, including sacred ancestral burial sites.

---The Palisades zombie reactor restart will involve cumulative effects, on top of the 1971-2022 operational impacts on the environment thus far. This will include not only "routine releases" of hazardous radioactivity and toxic chemicals (planned/permitted, as well as unplanned/unpermitted leaks, spills, etc.) from 2025 to 2051 at the restarted zombie reactor (likely worse than in the past, given the nuclear power plant's severe age-related degradation),

but also "routine releases" from the SMR-300 new builds. The environmental impacts are not only cumulative, but also synergistic. As Rachel Carson warned in her iconic book Silent Spring in 1962, credited with helping launch the environmental protection movement, hazardous ionizing radioactivity and toxic chemicals have synergistic negative impacts on the environment

-- the harm from the synergistic hazardous exposures is greater than the sum of their individual parts. (76-1-15 [Kamps, Kevin])

Comment: Building small modular reactors (SMRs) at or near the site would exacerbate the hazard inestimably. Restarting an aged reactor years after it has been mothballed is unpreceded in the US, and for good reason. Adding novel reactors of a design and operation which has never been tested would obviously also be unprecedented. (77-1-3 [Lee, Michel])

Comment: Is the NRC silently granting this extension now? Why would the state ($150 Million) and the feds ($1.5 Billion) pour billions of dollars into a facility for five years, from 2026 to 2031 when the license is due to expire? Is this already a done deal? This is one reason the NRC does not bode confidence in the community; we feel our concerns and best interests have been ignored. (112-3 [Anonymous, Anonymous])

C.1.5 Comments Concerning Ecology-Aquatic Resources Comment: The effect of restart on the health and biota of Lake Michigan should be studied.

Both the intake of millions of gallons of lake water which entraps fish, fish eggs, and mollusks, and damage to various other lifeforms need to be considered. (58-2 [Mcardle, Edward])

Comment: 6. WATER RESOURCES A. Restarting plant operations would include withdrawal and return of water to Lake Michigan (Lake). Water released from power plants can have a higher temperature than the receiving water body resulting in impacts on aquatic organisms from heated water discharged back into the Lake.

Recommendations for the Draft EA:

1. Discuss potential effects of higher surface water temperatures on aquatic organisms.

(63-1-15 [McClain, Krystle Z.])

C.1.6 Comments Concerning Ecology-Terrestrial Resources Comment: Regulated wetlands or Waters of the United States may be located within the Project footprint or staging area. Fill into wetlands or streams may trigger the need for a Clean Water Act (CWA) Section 404 permit, CWA Section 401 Water Quality Certification, or isolated wetlands permit from EGLE.5 Based on the map provided in the Scoping Document, it appears that wetlands within the Project area and to the southeast of the Project boundary will not be impacted by the construction of the daycare, visitor center, parking garage, or training facility.

Recommendations for the Draft EA:

1. If Project plans change and result in potential impacts to wetlands, provide a wetland delineation, and discuss measures to avoid, minimize, and mitigate impacts. The delineation should be submitted to and coordinated with EGLE for review and any necessary permit requirements. EPA strongly recommends that the delineation, if applicable, be completed before and included as an appendix to the Draft EA, along with a copy of the jurisdictional determination.

5Michigan, EGLE, administers the CWA Section 404 Permit Program, approved by EPA.

(63-1-18 [McClain, Krystle Z.])

C.1.7 Comments Concerning Environmental Justice Comment: 8. ENVIRONMENTAL JUSTICE A. Outreach and meaningful engagement are underlying pillars of environmental justice (EJ). It is imperative that NRC determines if there-authorization of power operations, construction, and maintenance of the proposed Project will affect communities with EJ concerns. CEQ requires Lead agencies to analyze the disproportionate and adverse human health and environmental effects of a proposed action in communities with EJ concerns.14 If significant human health and environmental effects disproportionately and adversely affect communities with EJ concerns, CEQ regulations direct Lead agencies to consider incorporating mitigation measures that address or reduce those effects.15 Executive Order (EO) 14096: Revitalizing Our Nations Commitment to Environmental Justice for All supplements EO 12898: Federal Actions to Address Environmental Justice in Minority and Low-Income. EO 14096directs Federal agencies, as appropriate and consistent with applicable law, to identify, analyze, and address disproportionate and adverse human health and environmental effects (including risks) and hazards of Federal activities, including those related to climate change and cumulative effects of environmental and other burdens on communities with EJ concerns.

Section 3(b)(i) of EO 14096 also directs EPA to assess whether each agency analyzes and avoids or mitigates disproportionate human health and environmental effects on communities with environmental justice concerns when carrying out responsibilities under Section 309 of the Clean Air Act, 42 U.S.C. 7609. EPAs recommendations below suggest opportunities to further analyze, disclose, and reduce effects to communities with EJconcerns.16 Recommendations for the Draft EA:

1. Pages 67-68 of the Applicants Environmental New and Significant Review stated, The scope of review in the 2006 Palisades SEIS includes identification of impacts on minority and low-income populations, and whether these impacts are likely to be disproportionately high and adverse...the NRC staff did not identify any location dependent disproportionately high and adverse impacts affecting these minority and low-income populations. Under CEQs NEPA Implementing Regulations17 and EO 14096, environmental justice is now evaluated based simply on disproportionate and adverse effects. The FactSheet18 accompanying EO 14096 states, The Executive Order [EO 14096] uses the term disproportionate and adverse as a simpler, modernized version of the phrase disproportionately high and adverse used in Executive Order 12898.Those phrases have the same meaning but removing the word high eliminates potential misunderstanding that agencies should be only considering large disproportionate effects. EPA recommends NRC modify references to use disproportionate and adverse as outlined in CEQ regulations and EO 14096.

2. PNP has been decommissioning for two years. Resumption of power operations at PNP may constitute a new and direct effect in the Project area. The community composition may have changed from the time when the original plant was designed in 1971 to the current request for reauthorization. EJScreen identified the potential presence of communities with EJ concerns located in or near the Project area. EJScreen also identified Covert Township and the surrounding area as disadvantaged.19 14 40 CFR § 1502.16(a)(13) 15 40 CFR § 1505.3(b) 16 For purposes of NEPA review, EPA considers a project to be in an area of potential EJ concern when the area shows one or more of the thirteen EJ indices at or above 80th percentile in the nation/state on EJScreen. However, scores under the 80th percentile should not be interpreted to mean there are definitively no EJ concerns present.

17 40 CFR § 1502.16(a)(13) 18 FACT SHEET: President Biden Signs Executive Order to Revitalize Our Nations Commitment to Environmental Justice for All. Seehttps://www.whitehouse.gov/briefing-room/statements-releases/2023/04/21/fact-sheet-president-biden-signs-executive-order-torevitalize-our-nations-commitment-to-environmental-justice-for-all/

19 EJScreen includes a layer on the Justice40 Climate and Economic Justice Screening tool to identify disadvantaged communities based on certain criteria. See https://screeningtool.geoplatform.gov/en/methodology.

(63-2-1 [McClain, Krystle Z.])

EPA recommends that NRC consider the following, consistent with CEQs NEPA Implementing Regulations and EO 14096:

a. Direct, Indirect, and Cumulative Effects Analysis:

1. Identify the presence of communities with EJ concerns in and near the Project area that could experience environmental effects from the Proposed project. Disclose demographic information.

2. Describe past and future plans to engage both Tribes and communities with EJ concerns during the environmental review and planning phase, and, if the Project commences, during construction and operation. Evaluate the effects of the Proposed project on communities with EJ concerns and sensitive receptors (e.g., children, people with asthma).

3. Summarize input from community members during the public meeting held on July 11, 2024.

4. Include an analysis and conclusion regarding whether the proposed Project or any action alternatives, including the No Action Alternative, may have disproportionate and adverse effects on the communities with EJ concerns, as specified in CEQs Environmental Justice Guidance.20 Identify what those effects may be and include measures that will be taken to avoid, minimize, or mitigate effects.

5. Consider any disproportionate non-Project-related pollution exposures that communities of EJ concern may already be experiencing, as well as any disproportionate non-pollution stressors that may make the communities more susceptible to pollution, such as health conditions, other social health determinants, and disproportionate vulnerability to climate change.

6. Consider cumulative environmental effects on communities with EJ concerns and Indigenous peoples in the Project area in the EJ analysis and disclose conclusions on those effects.

3. EJScreen can inform environmental justice and community outreach to identify potential meeting locations and any language barriers by providing information on linguistic isolation, languages spoken, and places of community cohesion (e.g., schools, places of worship).

EJScreen identified two census block groups in or near the Project area that are Limited English-speaking communities (LEP) in the 98th percentile as compared to the state of Michigan. EPA recommends NRC consider the following:

a. Meaningful Engagement and Public Participation:

1. Discuss the meaningful involvement and targeted outreach undertaken by NRC in plain language and languages other than English spoken by residents in and/or near the Project area.21

2. Utilize resources such as the Promising Practices for EJ Methodologies in NEPA Reviews Practices22 report and the Community Guide to EJ and NEPA Methods23 to conduct an EJ analysis that appropriately engages in meaningful, targeted community outreach, analyzes effects, and advances environmental justice principles through NEPA implementation.

20 CEQs Environmental Justice Guidance Under the National Environmental Policy Act. See Section III, Part C-4. https://www.epa.gov/sites/default/files/2015-02/documents/ej_guidance_nepa_ceq1297.pdf 21 July 11, 2024, public meeting materials: https://www.nrc.gov/pmns/mtg?do=details&Code=20240883 22 https://www.epa.gov/sites/default/files/2016-08/documents/nepa_promising_practices_document_2016.pdf 23 https://www.energy.gov/sites/prod/files/2019/05/f63/NEPA%20Community%20Guide%202019.pdf (63-2-2 [McClain, Krystle Z.])

Comment: NEPA Documentation

• Per Executive Order 13045 on Childrens Health,6 EPA recommends the lead agency and project proponent pay particular attention to worksite proximity to places where children live, learn, and play, such as homes, schools, and playgrounds. Construction emission reduction measures should be strictly implemented near these locations to be protective of childrens health.

• Specify how impacts to sensitive receptors, such as children, elderly, and the infirm will be minimized. For example, locate construction equipment and staging zones away from sensitive receptors and fresh air intakes to buildings and air conditioners.

6 Children may be more highly exposed to contaminants because they generally eat more food, drink more water, and have higher inhalation rates relative to their size. Also, childrens normal activities, such as putting their hands in their mouths or playing on the ground, can result in higher exposures to contaminants as compared with adults. Children may be more vulnerable to the toxic effects of contaminants because their bodies and systems are not fully developed, and their growing organs are more easily harmed. EPA views childhood as a sequence of life stages, from conception through fetal development, infancy, and adolescence. (63-2-9 [McClain, Krystle Z.])

Comment: Palisades' location, in Covert Township, Michigan, raises serious Environmental Justice concerns. The Palisades Park Country Club resort community, nearly 120-years old, is located immediately south of the nuclear power plant, sharing property lines. There are reportedly elevated rates of cancer and thyroid pathology in that 200-cottage community. Covert Township itself has a large African American population, and also a high rate of low-income households. Covert Twp. has a rich African American cultural history. The area is also Anishinaabe aki, specifically Pokagon Potawatomi traditional land. The Palisades zombie reactor restart, as well as the SMR new builds, put this all at risk, including from extremely LARGE environmental impacts. (76-1-16 [Kamps, Kevin])

Comment: Environmental justice, especially the environmental and health impacts on indigenous, lower income and communities of color.

Such impacts are well understood to be disproportionate regardless of whether the issue is chronic low-level toxic exposure or disasters of virtually any scale. (77-2-6 [Lee, Michel])

C.1.8 Comments Concerning General Environmental Concerns Comment: Now to today. Ive seen no actual comparison, but I wonder is 20% of the worlds freshwater loss comparable to the puny lack of foresight for energy needs of one state of USA (even less than 5% of the states energy needs at that)? Can we actually say we have a restoration plan when the fragile nature of the plant reveals itself some 50 yrs in? (33-2 [Birdsall, Sheila])

Comment: My home is in Van Buren County about 30 miles east-northeast of the Nuclear Plant. Just as important, we own a cottage in Palisades Park Country Club (PPCC) adjacent on the south side of the plant. Years ago nuclear plant staff visited PPCC to discuss safety issues following a tritium leak. The spokesperson actually said, the solution to pollution is dilution. I will never forget that statement and the distrust it instilled in me.

Please protect Lake Michigan, the citizens of Van Buren County and SW Michigan. (35-2 [Strehlow, Laura])

Comment: I ask the NRC to be mindful not only of the environmental effects of recommissioning the plant, but also comparatively with the environmental effects of other electrical generation that will be needed in place of it. (37-2 [Gold, Colin])

Comment: This issue really matters to me because we live near beautiful Lake Michigan, and this nuclear power plants poses a risk for potential damage to the safety of the people, the animals, and our water. (50-1 [Ippel, Trudi])

Comment: However, you MUST do MUCH MORE. We MUST keep ALL Climate-Changing fossil fuels IN THE GROUND! We MUST achieve 100% Clean, Renewable Energy like Solar and Wind in electrical generation and transportation by 2030. (71-1 [Hanson, Art])

Comment: Please find below my environmental scoping public comments, submitted on behalf of Beyond Nuclears members and supporters in the Great Lakes State, throughout the Great Lakes Basin, and beyond, downwind, downstream, up the food chain, and down the generations from Holtec's zombie reactor restart and so-called "Small Modular Reactor" new build schemes, at the supposedly "permanently closed for good" Palisades nuclear power plant in Covert Township, Van Buren County, Michigan. (76-1-1 [Kamps, Kevin])

Comment: For more environmental review topics that NRC should address, see our environmental coalition's extensive and comprehensive public comments to NRC in opposition to Palisades' 2011-2031 (60 years of operations) license extension:

May 18, 2006: Group comments, submitted by a coalition of organizations including NIRS and numerous grassroots groups in Michigan and other U.S. states and Canadian provinces around the Great Lakes Basin, regarding NRCs draft Environmental Impact Statement on the Palisades 20-year licensee extension (http://archives.nirs.us/reactorwatch/licensing/cntsnureg1437supplement27.pdf). This coalition represents well over 200,000 residents of Michigan alone, in opposition to the dangerous extension of operations and waste generation at Palisades from 2011 to 2031.

May 18, 2006: Executive summary of coalition comments to NRC regarding its draft Environmental Impact Statement for the Palisades 20-year license extension.

(http://archives.nirs.us/reactorwatch/licensing/executivesummary051806.pdf)

Although from 18 long years ago, most of our points have never been adequately addressed, if addressed at all! In fact, our concerns have grown deeper. Thus, they are still very relevant.

---For yet more environmental review topics relevant to the Palisades zombie reactor restart scheme, and the SMR new build schemes, see the following posts:

https://beyondnuclear.org/background-info-on-holtecs-zombie-reactor-restart-and-small-modular-reactor-new-build-schemes-on-the-lake-michigan-shore/

https://beyondnuclear.org/newest-nuke-nightmares-at-palisades-2022-present/

https://podcast.rogerrapoport.com/episodes On March 27, 2024, Beyond Nuclear published three new backgrounders: A Peoples History of the Palisades Atomic Reactor (https://beyondnuclear.org/wp-content/uploads/2024/03/3-3 A-Peoples-History-of-Palisades-Atomic-Reactor-1.pdf) (13 pages); Nuclear Nightmares:

Palisades Zombie Reactor Restart and SMR New Build Schemes (https://beyondnuclear.org/wp-content/uploads/2024/03/2-28-24-Holtec-restart-and-smr-schemes-at-palisades-3-pager.pdf) (3 pages); Holtec: Criminality, Corruption, Incompetence, and Inexperience (https://beyondnuclear.org/wp-content/uploads/2024/03/2-29-24-Holtec-two-pager.pdf) (2 pages).

Beyond Nuclear has also published: a breakdown of the $15.7 billion, and counting, in bailouts at Palisades and Big Rock Point (https://beyondnuclear.org/breakdown-of-bailouts-at-holtecs-palisades/); and a major exposé based on Freedom of Information Act revelations regarding Holtecs nuclear white elephant secret plans to build SMRs at all its decommissioning sites, as well as to re-nuclearize Palisades, using many billions of dollars of federal and state taxpayer, as well as ratepayer, bailouts (https://beyondnuclear.org/5775-2/).

https://www.sierraclub.org/michigan/blog/2024/05/reopening-palisades-nuclear-power-plant-creates-many-risks https://www.sierraclub.org/michigan/blog/2024/02/should-palisades-nuclear-plant-be-brought-back-life http://archives.nirs.us/reactorwatch/licensing/palisades.htm Please take a hard look at my comments, as NEPA requires. (76-2-5 [Kamps, Kevin])

Comment: Paramount in the array of issues requiring consideration in the scoping of an EIS for Palisades is the fact that a considerable share of the overall risk burden will fall upon the public, both at the state and national level. (77-1-8 [Lee, Michel])

Comment: Nuclear energy doesn't feel very "clean" to those impacted by the presence of a troubled reactor which has the potential to irrevocably destroy one of our most precious resources-the clean waters of Lake Michigan. (113-4 [Somes, Claudia])

Comment: I worry for our cottage. I worry for our health. And as a resident of the Great Lakes states, I worry about the safety of one of the most important assets our state and our country have -- the Great Lakes. There is much to gain from nuclear power, but so much to lose from this untested endeavor. Too much. (119-2 [Eldredge, Tamesin])

Comment: Because of its proximity to one of the largest fresh water sources in the world, the environmental impact is substantial. (124-3 [OBrien, Terry])

Comment: 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 freshwater system in the world. This is not the location for a mistake. (134-2 [Lombardi, Joan])

Comment: I am writing to you today to express my concern over the reopening of the Palisades Nuclear Powerplant in Covert, MI. (139-1 [Park, Abby])

Comment: Please understand that Ive lived with the power plant for every summer of my life, with many of those living with an active powerplant. However, being an active, highly regulated power plant that undergoes rigorous tests and standards is very different than what Holtec is trying to do now. (139-2 [Park, Abby])

Comment: I ask you to thoughtfully consider, and I thank you for doing so. Im hopeful youll take to heart the sentiment our family expresses and maintain the mission of the NRC to protect public health, safety, and the environment. (139-3 [Park, Abby])

Comment: Additionally, we are requesting environmental statistics (positive & negative) since the beginning of PNPP for the immediate area. (140-2 [O'Brien, Kevin])

Comment: I'm just curious how we're going to look at a restart that's never been done before and consider that impact to the environment, when it's something that's never happened before.

I also have some concerns that we're doing a lot of new things at one time. Holtec, for example, has never operating a nuclear power plant; the SMRs that we're talking about -- there's just some concerns about a lot of new things.

And we haven't even talked about infrastructure. A tree falls down because the wind blows and nobody has power. So, it's not just making power; it's getting the infrastructure to deliver that power. (143-13-1 [Holst, Jacqueline])

Comment: Like at what point are we going to say that, hey, there's too many health issues; there's too many groundwater issues; this isn't going to work here because of the previous damage done? (143-13-4 [Holst, Jacqueline])

Comment: These include, among others, embrittlement of the reactor core and problems with the steam generators that have been there for years; the thermal pollution and greenhouse gas effects of the water vapor from the cooling tower; the need to seriously consider alternative sources, mainly, renewable energy; the effects of earthquakes --it's my understanding this area may be in an earthquake fault -- and the serious problem of generating even more nuclear waste that we don't know what to do with. (143-25-2 [Taylor, Wally])

Comment: We, of course, are very concerned about the Palisades proposed relicensing, because we share a drinking water supply, and because you guys provide us with terrific blueberries, which we really appreciate. (143-30-1 [Kraft, Dave])

Comment: My community, the White Lake area, and northern Muskegon County has learned well the sad promise of jobs, jobs, jobs, but accompanied by pollution. I have worked much of my adult life helping our community to heal, our lake to heal, starting when I had young children, and ending when I had grandchildren. Even so, the groundwater pollution at one site will remain hazardous for thousands of years.

So, I would encourage people to think long and hard and look past the short-term promise of jobs. Palisades might provide short-term employment, but they have to be weighed against the long-term risks and costs. The benefits are temporary, I can promise you that. All of the companies that provided jobs are now closed, but we live with the legacy. So, the dangers associated with nuclear waste endure indefinitely. (143-40-2 [Cabala, Tanya])

C.1.9 Comments Concerning Greenhouse Gas Emissions and Climate Change Comment: 7. CLIMATE CHANGE AND GREENHOUSE GASES A. Executive Order (EO) 14008: Tackling the Climate Crisis at Home and Abroad states, The United States and the world face a profound climate crisis. We have a narrow moment to pursue actionto avoid the most catastrophic impacts of that crisis and to seize the opportunity that tackling climate change presents. The U.S. Global Change Research Programs National Climate Assessment provides data and scenarios that may be helpful in assessing trends in temperature, precipitation, and frequency and severity of stormevents.6 Federal courts have consistently upheld that NEPA requires agencies to disclose and consider climate effects in their reviews, including effects from greenhouse gas (GHG) emissions. On January 9, 2023, CEQs National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change7 was published in the Federal Register. CEQ issued this interim guidance to assist Federal agencies in assessing and disclosing climate effects during environmental reviews. The guidance responds to EO 13990: Protecting Public Health and the Environment, and Restoring Science to Tackle the Climate Crisis, which directed CEQ to review, revise, and update CEQs 2016 emissions guidance. The 2023 emissions guidance is effective immediately and should be used to inform the reviews of new proposed actions.

It is important for NRC to fully quantify and adequately disclose the effects of GHG emissions from the No Action Alternative and the action alternative and discuss the implications of those emissions considering the science-based policies established to avoid the worsening effects of climate change. It is recommended NRC review EPAs final technical document, Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances,8 which explains the methodology underlying the most recent set of SC-GHG estimates. To better assist lead Federal agencies with the utilization of these updated estimates, EPA released a Microsoft Excel Workbook for Applying SC-GHG Estimates v.1.0.1 spreadsheet9 designed by EPAs National Center for Environmental Economics to help analysts calculate the monetized net social costs of increases in GHG emissions using the estimates of the SC-GHGs.

Recommendations for the Draft EA:

1. NRC should apply the interim CEQ guidance as appropriate, to ensure robust consideration of potential climate effects, mitigation, and adaptation issues. As discussed in CEQs interim guidance, Federal agencies should consider the following when conducting a climate change analysis for NEPA reviews: (1) the potential effects of a proposed action on climate change, including the assessment of both GHG emissions and reductions from the proposed action; and (2) the effects of climate change on the proposed action and its environmental effects.

6 Information changing climate conditions is available through the National Climate Assessment at https://nca2023.globalchange.gov/

7 https://www.federalregister.gov/d/2023-00158 8 https://www.epa.gov/system/files/documents/2023-12/epa_scghg_2023_report_final.pdf 9 https://www.epa.gov/environmental-economics/scghg (63-1-19 [McClain, Krystle Z.])

Comment: Additional recommendations are as follows:

a. Emissions and SC-GHG Disclosure & Analysis

1. Quantify estimates of all reasonably-foreseeable direct (e.g., construction) and indirect (e.g., off-site material hauling and disposal) GHG emissions from the proposed Project over its anticipated lifetime for all alternatives, including the No Action Alternative, broken out by GHG type. Include and analyze potential upstream and downstream GHG emissions, if applicable.

2. Use SC-GHG estimates to consider the climate damages from net changes in direct and indirect emissions of CO2 and other GHGs from the proposed Project. To do so, EPA recommends a breakdown of estimated net GHG emission changes by individual gas, rather than relying on CO2-equivalent(CO2e) estimates, and then monetize the climate effects associated with each GHG using the corresponding social cost estimate (i.e., monetize CH4 emissions changes expected to occur with the social of methane (SC-CH4) estimate for emissions).10

3. When applying SC-GHG estimates, just as with tools to quantify emissions, NRC should disclose the assumptions (e.g., discount rates) and uncertainties associated with such analysis and the need for updates overtime to reflect evolving science and economics of climate effects. Use comparisons of GHG emissions and SC-GHG across alternatives to inform Project decision-making.

4. Avoid expressing the overall Project-level GHG emissions as a percentage of the state or national GHG emissions. The U.S. must reduce GHG emissions from a multitude of sources, each making relatively small individual contributions to overall GHG emissions, to meet national climate targets.

10 Transforming gases into CO2e using Global Warming Potential (GWP) metrics, and then multiplying the CO2e tons by the SC-CO2, is not as accurate as a direct calculation of the social costs of non-CO2 GHGs. This is because GHGs differ not just in their potential to absorb infrared radiation over a given time frame, but also in the temporal pathway of their impact on radiative forcing and in their impacts on physical endpoints other than temperature change, both of which are relevant for estimating their social cost but not reflected in the GWP. See the Interagency Working Group on Social Cost of Greenhouse Gases February 2021 Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive Order13990 for more discussion and the range of annual SC-CO2, SC-CH4, and SC-N2O estimates currently used in Federal benefit-costs analyses. (63-1-20 [McClain, Krystle Z.])

Comment: b. Consistency with Climate Policy

1. Provide an analysis of GHG emissions in the context of state GHG reduction targets and policies, which includes Michigans GHG emission reduction goals. 11 This should inform NRCs consideration of GHG mitigation measures.

2. Include a detailed discussion of the Projects GHG emissions in the context of national and international GHG emissions reduction goals, including the U.S. 2030 Paris GHG reduction target and 2050 net-zero policy.

3. Include a complete discussion of the extent to which the estimated GHG emissions from the proposed Project and alternatives may be inconsistent with the need to take actions necessary to achieve science-based GHG reduction targets.12 In addition to the Inflation Reduction Act13 (IRA),there are proposed EPA climate change regulatory actions and initiatives that address greenhouse emissions from transportation, oil and gas, and power sectors.

c. Resilience and Adoption

1. Describe changing climate conditions (i.e., temperatures and frequency and severity of storm events) and assess how such changes could impact the proposed Project and the environmental effects of the proposed Project and all alternatives.

2. Incorporate robust climate resilience and adaption considerations into (1) Project design and engineering; (2) construction oversight; (3) commitments for protective measures related to stormwater and erosion; and (4) routine monitoring during operations. NEPA documentation should describe how NRC has addressed such considerations and provide a rationale for any reasonable alternatives to enhance resilience that were not adopted or discussed in detail.

3. Discuss how climate change could worsen long term effects/risks from the Project to communities with Environmental Justice (EJ) concerns. For any such impacts, consider mitigation and adaptation measures.

d. GHG Reductions and Mitigation

1. Identify practices to reduce and mitigate the expected GHG emissions from the Project (e.g., delivery of fuel rods and construction of the daycare, visitor center, parking garage, and training facility). Mitigation measures should be identified and evaluated; include commitments to do so in the Draft EA and NEPA decision document. EPA recommends the Applicant commit to practices in the enclosed Construction Emission Control Checklist.

11 Including, but not limited, to, the MI Healthy Climate Plan. See:

https://www.michigan.gov/egle/-/media/Project/Websites/egle/Documents/Offices/OCE/MI-Healthy-ClimatePlan.pdf?rev=d13f4adc2b1d45909bd708cafccbfffa 12 See, e.g., Executive Order 14008; U.S. Nationally Determined Contribution to the Paris Agreement (April 20, 2021).

13 The IRA is expected to reduce dependence on fossil fuels while increasing availability for renewable energy sources.

(63-1-21 [McClain, Krystle Z.])

C.1.10 Comments Concerning Human Health-Nonradiological Comment: Occupational Health

• Reduce exposure through work practices and training, such as maintaining filtration devices and training diesel-equipment operators to perform routine inspections.

• Position the exhaust pipe so that diesel fumes are directed away from the operator and nearby workers, reducing the fume concentration to which personnel are exposed.

• Use enclosed, climate-controlled cabs pressurized and equipped with high-efficiency particulate air (HEPA)filters to reduce the operators exposure to diesel fumes. Pressurization ensures that air moves from inside to outside. HEPA filters ensure that any incoming air is filtered first.

• Use respirators, which are only an interim measure to control exposure to diesel emissions. In most cases, an N95 respirator is adequate. Workers must be trained and fit-tested before they wear respirators. Depending on the type of work being conducted, and if oil is present, concentrations of particulates present will determine the efficiency and type of mask and respirator. Personnel familiar with the selection, care, and use of respirators must perform the fit testing. Respirators must bear a National Institute for Occupational Safety and Health approval number. (63-2-8 [McClain, Krystle Z.])

Comment: Efficacy of Cooling Tower Array Adequacy of the cooling tower array to mitigate thermal pollution and the greenhouse effects of water vapor from the cooling tower array at Palisades must be investigated and analyzed. The two cooling tower arrays were replaced in 2012 and 2017. They draw prodigious amounts of water from Lake Michigan and simultaneously dump huge volumes back into the Lake. During normal operations, approximately 98,000 gpm are pumped from the Lake,86,000 gpm are returned, and 12,000 gpm are lost to evaporation from the coolingtowers.7 As the ambient air becomes more humid, the performance of wet cooling towers tends to fall.8 The constant humidity from cooling towers can expand the volume of microbes capable of causing dangerous illnesses like legionnairesdisease9 and amoebic meningitis.10 Holtec admits that there must be vigilance regarding legionnaires disease:

The human health microbiological occupational health issue was considered applicable to PNP.

The operation of the mechanical draft cooling towers could potentially expose PNP workers to Legionella spp. Plant personnel most likely to come into contact with Legionella aerosols would be those who dislodge biofilms, where Legionella are often concentrated, such as during the cleaning of condenser tubes and cooling towers (NRC 2013a).11 These facts suggest significant environmental effects that must be considered in light of anthropocene climate change. Water vapor amounts to roughly 50% of the earths greenhouse gas emissions at any given moment. There has never been NEPA analysis of Palisades water vapor output and its contribution to climate chaos resulting from the 2012 and 2017 newer cooling towers. Given the nonstop rises in ambient temperature, the potential for Palisades to increase its contribution to the greenhouse effect as the atmosphere warms must be investigated.

The long-term warming of the temperatures of Lake Michigan also must be considered as creating an expanding growth medium for disease microbes such as Legionella and amoebic meningitis.

The trend toward warmer water in the Great Lakes from anthropocene climate change is undeniable, and future operations of Palisades may expand the growth medium of Lake Michigan for Legionella and amoebic meningitis. The prospect of two new reactors, which will have voluminous water needs and return large amounts to the Lake while emitting vapor, will compound the local conditions and underscores the need for NEPA analysis.

7 Holtec letter to NRC, 9/28/2923, p. 27/121 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23271A140.

8 https://deltacooling.com/resources/news/understanding-wet-bulb-temperatures-and-how-it-affects-cooling-tower-performance 9 https://www.getchemready.com/water-facts/what-are-the-risks-of-legionella-in-cooling-tower-water/

10 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8619718/

11 Holtec letter, fn. 7 infra, p. 110/121.

(75-4 [Lodge, Terry J])

C.1.11 Comments Concerning Human Health-Radiological C.1.11.1 Comments Related to Human Health-Radiological Comment Summary 1 Comment: I have huge concerns about the reopening of the power plant near Palisades Park.

This park has a long history and was there before the nuclear power plant opened. This community, where I have family that I love dearly is right next to the plant. I have concerns about reopening and its impact on the health of the community, my family and one-day children.

The radioactive waste that comes with reopening will pollute the water and be harmful. Not only can this nuclear waste impact the people of this park, but also the air, water, and the animals including my dog Swayze. I beg you to reconsider reopening and think about the real-life people that will be impacted by this. (62-1 [McCleary, Deidra])

Comment: The cumulative environmental and health consequences of additional decades of radionuclide emissions into the environment. This must include consideration of the current science, not just reference to outdated studies and regulations.

Impact analysis must incorporate the reality that the impacts of radioactive emissions are cumulative and affirm that impacts from additional releases from Palisades will be additive to all those released previously.

The NRC must consult with medical experts independent of the nuclear industry and acknowledge and incorporate the science pointing to the risks posed to those most susceptible to radiation and harmful chemicals, including women, adolescents, children, babies, breast-fed infants, the embryo/fetus, and persons exposed to radiation and chemicals from other sources such as medical diagnostic and treatment procedures.

A central principle of environmental protection must be to protect those most at risk, but that principle is disregarded with respect to emissions, effluents, and waste products from the nuclear fuel cycle.

The EIS should explicitly state that the US radiological protection regime does not consider noncancer illnesses, early failed pregnancies, or developmental disorders. (77 19 [Lee, Michel])

Comment: The comment, I'm getting that out of the way. I am very much hoping that the cumulative impact assessment is going to include something on public health. (143-4-1 [Shariff, Nayyirah])

C.1.11.2 Comments Related to Human Health-Radiological Comment Summary 2 Comment: Tritium Is an Understated Health Threat The lightest of all radionuclides, tritium, or H3, has largely escaped public and scientific scrutiny.

This is surprising given that tritium is usually the single largest radioactive substance emitted as a part of normal nuclear power plant operations.40 Contrary to some popular notions that tritium is a relatively benign radiation source, the vast majority of published studies indicate that exposures, especially those related to internal exposures, can have significant biological consequences including damage to DNA, impaired physiology and development, reduced fertility and longevity, and can lead to elevated risks of diseases including cancer.41 Tritium is a very underrated environmental toxin that deserves much greater scrutiny.

In his book, Exploring Tritium Dangers, Dr. Arjun Makhijani states that tritium crosses the placenta with facility, and that by ionizing water in the cytoplasm, it set[s] in motion processes that can profoundly disrupt mitochondrial DNA and hence the system that converts food to usable form, ATP, that the body uses for all functions.42 By affecting ova during the time of their formation in utero and during the time of the maturation during pregnancy, he continues, tritium can exemplify the ways in which other internal emitters can have non-cancer impacts, including during the early period of pregnancy, when internal radiation can result in miscarriages andmalformations.43 Dr. Makhijani, who is president of the longtime Institute for Energy and Environmental Research in Takoma Park, Maryland and holds a Ph.D. from Berkeley in nuclear fusion, further asserts that tritium is about150,000 times as radioactive, in terms of disintegrations per unit time, asplutonium-239. One teaspoon of tritiated water would contaminate about 100billion gallons of water to the U.S. drinking water limit, enough to supply about 1 million homes with water for a year.44 It becomes easier to imagine contamination of a large share of the Great Lakes from just one poorly managed chronic leaking nuclear plant in light of this.

The presence of tritium as a byproduct of generating electricity at nuclear power plants is growing as those plants age. In 2014, the NRC admitted that [T]ritium levels as high as 3.2 million pCi/L have been reported to the NRC in the ground water at some nuclear power plants.

40 Mousseau, Timothy and Todd, Sarah A., Biological Consequences of Exposure to Radioactive Hydrogen (Tritium): A Comprehensive Survey of the Literature (April 11, 2023), Abstract. Available at SSRN: https://ssrn.com/abstract=4416674 or http://dx.doi.org/10.2139/ssrn.4416674 41 Id.

42 Makhijani, Arjun, Exploring Tritium Dangers, p. 5 (Opus Self-Publishing Services 2022),

https://ieer.org/wp/wp-content/uploads/2023/02/Exploring-Tritum-Dangers.pdf 43 Id. at p. 5.

44 Id. at p. 5.

45 https://www.federalregister.gov/documents/2014/02/04/2014-02307/environmental-radiation-protection-standards-for-nuclear-power-operations (75-11 [Lodge, Terry J])

Comment: Given the history of unplanned leaks, given that many have gone on for years before discovery, and given the fact acknowledged by the NRC that corrosion of buried pipes is likely to lead to more radioactive leaks in the future, any assessment must acknowledge and address these additional exposure risks to the public. Tritium leaks and tritium emitted into the air (for example through venting) must be given serious attention as newly emerging evidence indicates the isotope to be a far more pernicious pollutant than previously believed. (77 20 [Lee, Michel])

Comment: Additional radioactive exposures to beta, alpha, and gamma rays from a variety of types of additionally generated radioactive waste will also be incurred by members of the public through transportation activities. EIS should note that such exposures may be significant at an individual and population level, especially to those residing or working along road and rail routes. Evaluation of the impacts of decades more of radioactive emissions must also include acknowledgement that nuclear power is neither a zero-emission nor a carbon-free industrial activity. Indeed, even during power generation, nuclear produces carbon-14, a radioactive form of carbon which will persist for some 5,700 years. Tritium is now recognized to be far more harmful than previously understood. (77-1-21 [Lee, Michel])

C.1.11.3 Comments Related to Human Health-Radiological Comment Summary 3 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 familys 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" is not worth subjecting individuals who live nearby to cancer and/or death. I ask you this so that my daughters and granddaughter do not have to go through what I have had to endure. (13-1 [Stranger, Karen])

Comment: as well as cluster analyses of cancers north and south of the plant. Analyses of health and safety should include collaboration with the Michigan State Department of Health and Human Services and the CDC if appropriate, to rule out potentially high rates of cancers associated with the proximity of the Palisades discharges. Like the Palisades Park residents (south of the plant) who spoke at the NRC meeting, neighbors along the Ruggles Road corridor (north of the plant) have been speculating that recent cancer deaths in the neighborhood are related to the Palisades plant. (55-4 [Lawlor, Edward])

Comment: While I fully understand the complexities of attributing any health impacts, including cancers to a particular source, this does not negate the responsibility of the NRC to thoroughly investigate these health risks. This is especially true in light of a future scenario that includes a precedent-setting plant restart and plans for future small nuclear reactors also on the site. As one of the NRC officials explained in the public meeting, the NRC EA process includes consideration of past, present, and future impacts.

If the restart process for Palisades continues, the NRC should conduct a comprehensive environmental, health, and safety impact assessment in collaboration with other key public health agencies. The analysis should rigorously study concerns about clusters of cancers that have been raised by local residents. We specifically expect groundwater and drinking water sampling at or near our location. I also believe a comprehensive analysis of the combined impact of power generation discharges (nuclear and natural gas) on local residents and users of Van Buren State Park is necessary. (55-8 [Lawlor, Edward])

Comment: Also, the effect of numerous and bio-accumulative radioactive batch releases on human health and the ecosystem. A German study detailed massive radioactive isotope releases during refueling. The study correlated the releases to spikes in childhood leukemia within a 5-mile radius. (58-4 [Mcardle, Edward])

Comment: Additionally, I want to inform you of all of the individuals in Palisades Park who over the course of the last 50 years had Thyriod Cancer. We know of at least 40-50 individuals now and will publish our study once we have all the results. DO NO HARM should be the first principle you obey, and that has been violated! PLEASE do not let history repeat itself! (70-1 [Davis, Bruce])

Comment: Over the years, our community has suffered serious health issues including cancers that have occurred at a rate significantly higher than the general population - that has escaped attention due to homeowners having second addresses spread across the country - we are funding the research and will soon have documentation of the extraordinarily high level of cancers typically connected with poisoning from nuclear wastes. (110-2 [Scott, Ann])

Comment: Our family has lived next door to the plant for 50 years. We have endured mistakes by more qualified operators, like steam generator leaks and the release of radioactive gases. As a result, we have abnormal amounts of cancer in our community, especially thyroid cancer.

Radiation exposure is a known risk for thyroid cancer. (112-9 [Anonymous, Anonymous])

Comment: Cancer rates have increased in VanBuren county sine the plant opened and it is reprehensible that no public health studies regarding the health of nearby residents have been conducted in the last forty years. As a physician, reopening this reactor seems extremely dangerous. (113-3 [Somes, Claudia])

Comment: We are owners of Property within a community (PPCC) adjacent to Palisade's Nuclear Power Plant (PNPP), located in Covert Michigan. We have experienced the positives &

negatives of PNPP since its inception, and through its closing/shutdown.

We have heard of the terrible records & statistics of PNPP operation, errors, omissions, and damage caused to the area, including our adjacent community, Van Buren State Park, and other local areas including Lake Michigan.

We are requesting further studies & investigation to warrant & guarantee a safe environment for adjacent communities (property & people) before proceeding with reopening/ restarting PNPP via Holtec.

We are requesting you publish & provide again the human health statistics of the immediate area since the beginning of PNPP, including human cancers, birth deformities, other health issues, etc. (140-1 [O'Brien, Kevin])

Comment: I live in Palisades Park, which i[s] right adjacent to the nuclear power plant.

And when I'm talking about health and safety, I want to know what you guys are going to do to ensure the health and safety of the residents that live next door.

And I say this because we met with Jack -- I think his name is Giessner -- the regional guy about 10 years ago. And I gave him evidence that we were having a real problem in Park with thyroid disease and thyroid cancer. We have over 40 people in our community of 200 homes that have thyroid issues. Statistically, that is significant, which means that there's something that's been going on.

We have great concern that, with aged infrastructure and trying to reopen this plant at warp speed, that safety issues -- you've got to get it right. You've got to get it right the first time.

I'm disappointed that Jack didn't follow up on his word 10 years ago and do a study for us.

We're in the middle of doing our own study right now. We hired an epidemiologist, and we want this on the public record. And I want to know that you guys have our backs, because we're the neighbors. (143-2-1 [Davis, Bruce])

Comment: there was a question earlier about the high rate of thyroid cancer in Palisades Park. And the answer was that that information would be used in the baseline. My question about that is: recognizing that the hypothesis is that these thyroid cancers were related to past Palisades operation and nuclear power, how will using that as a baseline also attend to how the cancers were related to previous atomic energy production at Palisades? (143-5-1 [Way, Ineke])

Comment: Also, talking about the environmental baseline, if you've got folks in that area with health problems, I would expect you're using, like, the local health departments and getting data from them, but I didn't hear anything about limits. (143-13-3 [Holst, Jacqueline])

Comment: You talk about jobs. Do you really want to have somebody have a job where they're going to get cancer or where they're going to have birth defective kids, where they're going to lose their lives, where they're going to die young?

One of my relatives is a young guy. He's an electrician. And he went in to work in a nuclear power plant and he only could work for a couple of hours because he dosed out the dose meter.

They have a high turnover rate because these guys are getting dosed with radiation. They say, "Don't go in that corner, that wet stuff over there. That's a mess. Stay away from that." (143 5 [Barnes, Kathryn])

Comment: I feel really bad for the people that are fighting with thyroid cancer. I hope you look into every possible cause that could be causing that thyroid cancer in your park. But I doubt very much it's Palisades Nuclear Plant.

Tritium is a radioactive substance. It's created in the atmosphere above us. When a proton from the sun hits a nitrogen molecule, you create tritium.

Tritium coming out of a nuclear reactor is in such low doses, that the tritium they put in the water in Japan, after it was all treated and all they had left in the water was tritium, because you can't get it out, I would have drank that water if they had let me rather than pour it in the ocean.

Nuclear energy is the safest possible source of power we can have and it is clean. Sure, we create a little CO2 when we mine for uranium and we move things around. (143-19-2 [Connors, Shawn])

Comment: Secondly, I'd like to say, as Tom said, our development there has been there as a nature sanctuary since 1905. We didn't choose Palisades Nuclear Plant as a neighbor; they took our land by eminent domain. So, we had no choice in the matter, except to sell properties that have been in the families for years and move out of there, if we didn't want to be subjugated to the problems than can be associated.

There has been, as I've previously stated, a big problem with cancer in the community, and that needs to be addressed. And it's largely because of the poor maintenance, the poor build in the first place. (143-26-2 [Davis, Bruce])

Comment: I hope that other community members can find answers to some of the thyroid cancer cases that have been brought up tonight. (143-31-2 [Cook, Daywi])

Comment: I've been asked to read a brief statement from Joseph J. Mangano, Masters of Public Health, Masters of Business Administration, epidemiologist and Executive Director of Radiation and Public Health Project. These are his comments.

Comments for public hearing on proposed restart of Palisades Nuclear Reactor, July 11, 2024.

Discussion on the proposed restart of the Palisades reactor has focused largely on needed maintenance of its old and corroded mechanical parts, an enormous cost of this upkeep.

Ignored is the most important issue, whether bringing Palisades back to life presents a health hazard to people living nearby.

Historical data from the Centers for Disease Control and Prevention, provide the answer. In Van Buren County, the rate of cancer deaths was 8 percent below the U.S. in a period just before the reactor started up.

But in the past two decades, the county rate was 14 percent above the U.S. Thus, in the Palisades era, Van Buren has shifted from a low cancer to a high cancer county.

If the county rate had remained 8 percent below the U.S., about 1,000 fewer Van Buren residents would have died of cancer since the late 1970s.

Among children, teenagers, and young adults, the county's cancer death rate shifted from 38 percent below, to 50 percent above the U.S.

The dose of radiation is known to be the most damaging to young humans.

Each of these cancer victims had been exposed to radioactive chemicals, routinely released from Palisades into local air and water.

Cancer is a terrible menace for our society. Almost half of all Americans will be diagnosed sometime in their lives.

Every case is a tragedy. An agonizing ordeal for the persons, and their friends, and their family, regardless of whether it is successfully treated or not.

(143-37-2 [Keegan, Michael])

Comment: And just hearing of the thyroid cancers and illnesses at Palisades Park.

What I am asking for is a baseline study, community study, that is funded and independent to look at the cancers around Palisades.

Also, independent monitoring of rad alert systems so that the community can have early warnings and know what's going on there. (143-37-4 [Keegan, Michael])

C.1.12 Comments Concerning Hydrology-Groundwater Resources Comment: Unfortunately, we do not have confidence in the commitment of the NRC to monitor the groundwater in our location. We have attended meetings and made requests, but they were passed off at the time to Entergy, who was completely unresponsive. After our efforts, there was no subsequent testing of groundwater samples near our location or other follow-up from the company or the NRC (See NRC, Palisades Nuclear Plant, and Big Rock Point, 2022 Annual Radioactive Effluent Release and Waste Disposal Reports, especially Table 1-12, REMP Program Locations, and Holtec's 2022 Palisades Nuclear Plant Annual Radiological Environmental Operating Report). The Report shows no groundwater monitoring in our area and no drinking water sampling. The Palisades Park sampling occurs only during summer months. It was illustrative that one of the Palisades Park residents who presented at the NRC Community Meeting indicated that he is paying for his own water testing out of concern for the lack of monitoring. This is unacceptable. (55-5 [Lawlor, Edward])

Comment: Monitoring wells at PNP detected tritium above the regulatory threshold from 2019-2022. The Applicant did not own or operate PNP during the times of threshold exceedances, however, the Applicant identified the sources of tritium leaks and plans to cap underground piping and install aboveground piping to prevent future contamination.4 Recommendations for the Draft EA:

1. Discuss how water that might be contaminated with tritium would not be used for drinking water consumption, livestock, or irrigation if levels are above regulatory thresholds.

4 Pages 25-26, 82-83 of Environmental New and Significant Review. (63-1-17 [McClain, Krystle Z.])

Comment: Palisades Tritium Problem Tritium leakage and migration through groundwater beneath and surrounding Palisades is becoming a major problem. Tritium is radioactive Hydrogen and thus radioactive water travels easily and is often a harbinger of other leaking radioisotopes from a nuclear plant. It can go anywhere in the human anatomy, right down to the DNA molecule. It poses from 123 to 246 years of hazard. Cesium-137 (a muscle-seeker) causes around 300 to 600 years of hazard.

Strontium-90 (a bone-seeker), around 300 to 600 years of hazard;Carbon-14 (which can also go anywhere in the human body, right down to the DNA molecule), 55,000 to 110,000 years of hazard; Plutonium-239, 240,000 to 480,000years of hazard; Iodine-129, 157 to 314 million years of hazard; to name but a small number of the more than 200 hazardous artificial radioactive isotopes contained in irradiated nuclear fuel.

A. Tritium Problems at Palisades Date at Least to 2007 In 2007, groundwater monitoring equipment at Palisades detected a leak from a tank onsite that contained tritium water. That water made its way into the groundwater and from there into Lake Michigan.30 The tank was repaired, but additional sections of piping have had leaks in the years since and needed to be fixed.

Since 2009, the only target radionuclide detected above its minimum detectable activity (MDA) has been tritium.31 Until 2021, tritium was detected at fluctuating levels in onsite wells north of storage tanks. Concentrations were below the U.S. Environmental Protection Agency (EPA) drinking water maximum contaminant level (MCL) of 20,000 picoCuries per liter (pCi/L).

Between 2013 and 2018, tritium was detected in two monitoring wells, MW-2 and MW-1 1, and in six temporary monitoring wells at concentrations that fluctuated over time but remained below its MCL. Underground piping leaks were identified and repaired; tritium concentrations subsequently decreased, remaining below the EPA MCL.

In 2019 through 2022, GPI monitoring was conducted in the 23monitoring wells and 16 of the 18 temporary monitoring wells. In 2019, tritium was detected above its MCL in wells within an area approximately 200 feet wide (north to south) and 120 feet long (east to west) near the plant.32 Tritium was detected in 2020 above its MCL in three monitoring wells (MW-2, MW-3, and MW-

11) and several temporary monitoring wells with a maximum detection of 63, 153pCi/L in TW-

10. These wells had been contaminated with previously discharged radiological effluents. High lake levels and consequently high mixing basin levels is believed to have caused some of the effluent to migrate to a storm drain that normally discharges into the mixing basin. The extent of this leakage polluted an area 270 feet wide by 90 feet long. These tritium detections were determined to be the result of recapture of previously accounted-for effluents.33 Between October 2019 and January 2020, an increasing trend in tritium concentrations was observed in five temporary monitoring wells and two permanent groundwater monitoring wells.

No gamma isotopes were detected, however.34 The heating boiler rooms' sump and the underground piping that discharges to it were determined to be a potential source of tritium impacts to groundwater; therefore, cured-in-place liners were installed in the underground piping in 2020, and a chemical coating and seal were applied to the sump cavity. During installation of the underground pipe liner, it was difficult to install the line through two of the elbows; therefore, the elbows were excavated and replaced in 2021.

In 2022, tritium was detected above its MCL in two wells with a maximum detection of 32,254 pCi/L in MW-2. Wells in which tritium was detected above the MDA in 2022 are within an area of approximately 280 feet wide by 40 feet long. (Entergy 2022b; HDI 2023b). Data collected in 2023 showed that tritium was not detected above MDAs in the monitoring wells.35 In May 2022, tritium in the IC switchgear sump located within the protected area reached a concentration of as high as 645,255 pCi/Lbut at least no plant-related gamma isotopes were detected.36 Investigation showed that the tritium leaked either the tank T-91 recirculation line or the transfer line between tanks T-87and T-91. The tanks and associated underground piping were flushed with domestic water, and tank T-91 was removed from recirculation after it was flushed and drained. Tritium detections in the sump steadily decreased to typical levels pCi/L).37 Remediation and repairs are planned as part of the resumption of power operations efforts. Holtec plans to cap the underground piping, install aboveground piping, and reroute radwaste through the aboveground pipes.38 Holtec currently believes that any tritium impacts are limited to the upper 10 to 15 feet of the dune sand aquifer (Entergy 2019; Entergy2020; Entergy 2021b; Entergy 2022b; I-IDI 2023b).39 30 https://www.mlive.com/news/kalamazoo/2013/05/leak_at_palisades_nuclear_plan.html 31 Palisades ER p. 25.

32 Id.

33 Id.

34 Id. at p. 26.

35 Id.

36 Id.

37 Id.

38 Id.

39 Id.

(75-10 [Lodge, Terry J])

Comment: Tritium at Palisades Isnt Trivial Nuclear power plants may have a mile or more of water and drainage pipes built into their foundations and laying immediately beneath them. At Palisades, the leakage is so pervasive and voluminous that Holtec is resorting to constructing new pipe connections to bring them to the surface and to build bypasses over and around buried and inaccessible pipes. One of the reasons that the undersigned commenters are insisting that a new license, and not merely an amended license to operate based on a suspect exemption be required is the entrenched, difficult to mitigate or reverse tritium leakage that is a given from Palisades nearly 60-year-old plant structures. In the decades since the plant opened, there is considerably more population in the neighborhood of Palisades, and also, in the communities up and down the Lake Michigan shore, many of which draw drinking water from the Lake but also use it for recreation such as skiing, boating, fishing and swimming, all of which mean contact with the waters of Lake Michigan. Given that Holtec is signaling interest in reopening Palisades for perhaps 26 years of operation, the tritium leakage is probably going to worsen and may do so exponentially given the age of pipes and concrete, not to mention shifts in the soil in which the plant reposes.

Monitoring and especially remediation will become larger obligations of the plant owner.

Requiring an entirely new license and for Palisades to meet contemporary construction and operating standards is legally required. Remediation and mitigation is a hit-or-miss proposition at best and cannot provide an overall solution. This must be addressed at length in the NEPA document associated with the pending license change request. (75-12 [Lodge, Terry J])

Comment: I've got two major concerns: tritium underneath the plant. (143-16-1 [Barnes, Kathryn])

Comment: We sit on 20 percent of the world's freshwater -- 20 percent. That gives more than 40 million here and in Canada drinking water every day. I have to test my well at my expense for tritium to make sure that I am [not] drinking this stuff.

And I just saw the report the other day. There's two wells, 117 and 118, I believe, that are putting out a hell of a lot of tritium, and that's getting into the groundwater.

And per one of the other respondent's requests -- I think it was the woman over here -- that needs to be solved before this plant goes back online. You can't be spilling stuff. And if this guy back here wants to drink tritium water, take him to the well. I don't want to drink that stuff. (143-26-4 [Davis, Bruce])

C.1.13 Comments Concerning Hydrology-Surface Water Resources Comment: Has the Palisades Nuclear Power Plant ever used any products that contain Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS)? Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are part of a large group of lab-made chemicals known as perfluoroalkyl and polyfluoroalkyl substances (PFAS). Some of these chemicals have been in commercial use since the 1940s. These chemicals may be a component of products used by the Palisades Nuclear Power Plant such as AFFF Fire suppression Foam or Corrosion Inhibitors. The state of Michigan and the United States EPA have or are setting both NPDES discharge standards and groundwater cleanup standards for these compounds. (2-1 [Tom McCullough, Tom])

Comment: In addition, as minor as it may seem, Lake Michigan is unethically used as a free heat sink landfill. (7-2 [Brown, Robert])

Comment: Likewise, the discharge of superheated wastewater to an already warming Lake Michigan. (58-3 [Mcardle, Edward])

Comment: 3. COASTAL ZONE MANAGEMENT ACT A. The proposed Project is located within the boundary of Michigans Lake Michigan Coastal Program and will require a Federal Consistency Determination under the Coastal Zone Management Act (16 USC § 1451.307).

Recommendations for the Draft EA:

1. Provide information regarding the status of coordination with EGLE regarding the request for a Federal Consistency Determination. (63-1-9 [McClain, Krystle Z.])

Comment: 6. WATER RESOURCES Recommendations for the Draft EA:

2. Include a water balance analysis for the facility and provide additional information from past studies, if any. (63-1-16 [McClain, Krystle Z.])

Comment: Cumulative Effects of Routine Releases of Radioactivity Palisades so-called routine releases of hazardous radioactivity since 1971 have been significant. These include planned and permitted radiation releases,52 but also unplanned or unpermitted leaks and spills.53 Palisades routine releases of radioactive and toxic chemical wastewater into Lake Michigan including seasonal batch releases are harmful to Lake Michigan, its fisheries and ecology. Lake Michigan serves as the drinking water supply for a very large number of shoreline communities, from South Haven, to Chicago, and beyond.

Some 16 million people drink Lake Michigan water, not only in Michigan, but also Indiana, Illinois, and Wisconsin. Such discharges of artificial radioactive substances from Palisades into Lake Michigan do not dilute they increase the concentration of such artificial radioactive hazards in the Lake, and in fact the radioactivity bio-accumulates, bio-concentrates, and bio-magnifies up the ecosystem and food chain, as via fisheries, harming animals at the top of the ecosystem/food chain, from predators to people.

As the U.S. National Academies of Science have repeatedly confirmed for decades, citing the long-established Linear, No Threshold theory54 which forms the very foundation of the Biological Effects of Ionizing Radioactivity reports, any exposure to ionizing radiation, no matter how small, still carries a health risk, such as cancer causation; and such risks accumulate over a lifetime. Such risks are not limited to cancer, but also include radiogenic birth defects, genetic damage, and a very long list of other health risks, maladies, and morbidities. Given that Lake Michigan water is also used for agricultural irrigation, hazardous radioactive contamination of the food supply can also occur via this exposure pathway.

The Palisades zombie reactor restart will involve cumulative effects, on top of the 1971-2022 operational impacts on the environment thus far. This will include not only routine releases of hazardous radioactivity and toxic chemicals (planned/permitted, as well as unplanned/unpermitted leaks, spills, etc.) from 2025 to 2051 at the restarted zombie reactor (likely worse than in the past, given the nuclear power plants severe age-related degradation),

but also routine releases from the SMR-300 new builds. The environmental impacts are not only cumulative, but also synergistic. As Rachel Carson warned in her iconic book Silent Spring in 1962, credited with helping launch the environmental protection movement, hazardous ionizing radioactivity and toxic chemicals have synergistic negative impacts on the environment the harm from the synergistic hazardous exposures is greater than the sum of their parts.

A NEPA document must examine a proposals direct, indirect and cumulative effects.55 42 U.S.C. § 4332(C)(iii); 40 CFR. §§ 1502.16, 1508.7, 1508.8.56 The Council on Environmental Quality (CEQ) mandates that environmental impact assessments and statements include impacts, which may be cumulative within their scope. 40 CFR § 1508.25(c).

An EA, like an EIS, must take a hard look at the environmental consequences of the proposed action, Kleppe v. Sierra Club, 427U.S. 390, 410 n.21 (1976), including its direct, indirect, and cumulative effects, see EarthReports, Inc. v. FERC, 828 F.3d 949, 953 (D.C. Cir. 2016); 40 CFR. §§ 1508.9, 1508.25(c). NEPA requires an agency to evaluate cumulative impacts along with the direct and indirect impacts of a proposed action. TOMAC, Taxpayers of Michigan Against Casinos v. Norton, 433 F.3d 852, 864 (D.C.Cir. 2006) (citing Grand Canyon Tr. v. FAA, 290 F.3d 339, 345 (D.C. Cir.2002)). A cumulative impact is the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. 40 CFR § 1508.7. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. Id. § 1508.7.

A NEPA cumulative impact analysis must include discussion of other actionspast, present, and proposed, and reasonably foreseeablethat have had or are expected to have impacts in the same area, the impacts or expected impacts from these other actions, and the overall impact that can be expected if the individual impacts are allowed to accumulate. Grand Canyon Tr., 290 F.3d at 345.

52 http://static1.1.sqspcdn.com/static/f/356082/26605366/1444852853757/BN_RoutineRadioactiveReleas es_Oct2015.pdf?token=zwsUExAyfOttAa88dOgh7qJ3NkE%3D 53 https://archive.beyondnuclear.org/reports 54 http://archives.nirs.us/press/06-30-2005/1 55 Effects and impacts are synonymous as they are used in NEPAs implementing regulations. 40 C.F.R § 1508.8.

56 Direct environmental effects are caused by the [agencys] action and occur at the same time and place. 40 CFR § 1508.8. Indirect environmental effects are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Id. Cumulative environmental effects account for the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Id. § 1508.7.

(75-15 [Lodge, Terry J])

Comment: But it doesn't take an accident. Palisades' so-called "routine releases" of hazardous radioactivity since 1971 have been significant. These include planned and permitted radiation releases, but also unplanned/unpermitted leaks and spills (https://static1.1.sqspcdn.com/static/f/356082/26605366/1444852853757/BN_RoutineRadioacti veReleases_Oct2015.pdf?token=zwsUExAyfOttAa88dOgh7qJ3NkE%3D). Palisades' "routine" releases of radioactive and toxic chemical wastewater into Lake Michigan -- including seasonal "batch releases" -- are harmful to Lake Michigan, its fisheries and ecology. Lake Michigan serves as the drinking water supply for a very large number of shoreline communities, from South Haven to Michigan City, IN, Chicago, IL, Milwaukee, WI, and beyond. Some 16 million people drink Lake Michigan water, not only in Michigan, but also Indiana, Illinois, and Wisconsin. Such discharges of artificial radioactive substances from Palisades into Lake Michigan do not dilute -- they increase the concentration of such artificial radioactive hazards in the Lake, and in fact the radioactivity bio-accumulates, bio-concentrates, and bio-magnifies up the ecosystem and food chain, as via fisheries, harming animals at the top of the ecosystem/food chain, from predators to people. As the U.S. National Academies of Science have repeatedly confirmed for decades, citing the long-established "Linear, No Threshold" theory which forms the very foundation of the Biological Effects of Ionizing Radioactivity reports (http://archives.nirs.us/press/06-30-2005/1), any exposure to ionizing radiation, no matter how small, still carries a health risk, such as cancer causation; and such risks accumulate over a lifetime. Truth be told, such risks are not limited to cancer, but also include radiogenic birth defects, genetic damage, and a very long list of other health risks, maladies, and morbidities. Given that Lake Michigan water is also used for agricultural irrigation, hazardous radioactive contamination of the food supply can also occur via this exposure pathway. (76-1-14 [Kamps, Kevin])

Comment: Also Palisades disbursement of waters from the cooling towers is having an adverse impact on the littoral drift of sand in Lake Michigan and severely impacting its closest neighbors.

This needs to be studied by competent hydrologist (102-2 [Flynn, Thomas])

Comment: The real risk of radioactive releases into the Great Lakes must be taken into serious deliberation. Radioactive waste, including from tritium and strontium-90, among other radionuclides, have consequences to the health and safety of the waters, the environment, and to the people.

The Great Lakes comprise 20 percent of the world's fresh drinking water -- with 16 million people alone in Michigan, Indiana, Illinois, and Wisconsin drinking and using this water every day and with 40 million people all together using it.

The effects of radiation are known to cause thyroid cancer and other cancers and illnesses. And these waters contaminate fish that people eat. And these waters are also used for irrigation for farming for foods that people eat. (143-29-2 [Drechsler, Jacqueline])

C.1.14 Comments Concerning Land Use and Visual Resources Comment: Please examine whether the Palisades Plant is responsible for the severe beach erosion that started south of it exactly when it was put in, in the early 1970s. That has made Palisades Park, Linden Hills, and Fire Lanes 1-8 a High Risk Erosion Area. There are letters in the Forest Dunes files from the 1970s, when the erosion started, making the connection to the plant. (8-2 [Moevs, Christian])

C.1.15 Comments Concerning Meteorology and Air Quality Comment:

B. EPA acknowledges that an NRC license cannot include mitigation measures that are unrelated to nuclear safety and security, including, but not limited to, construction diesel emission reduction measures. However, it is reasonable to assume that a 53-year-old plant will undergo refurbishment or other facility improvements, and EPA finds that mitigation measures taken to reduce construction diesel emissions are value-added. As referenced in Comment 5.A, the Applicant proposed the construction of a new daycare, visitor center, parking garage, and training facility.

Recommendations for the Draft EA:

1. EPA encourages the Applicant to commit to incorporating applicable mitigation measures from the enclosed Construction Emission Control Checklist, wherever possible.

2. Establish material hauling routes away from places where children live, learn, and play, to the fullest extent feasible. Consider the location of homes, schools, daycares, and playgrounds. In addition to air quality benefits, careful routing may protect children from vehicle-pedestrian accidents. Identify potential hauling material routes in the Draft EA. (63-1-14 [McClain, Krystle Z.])

Comment: U.S. Environmental Protection Agency Construction Emission Control Checklist Diesel emissions and fugitive dust from project construction may pose environmental and human health risks and should be minimized. In 2002, EPA classified diesel emissions as a likely human carcinogen, and in 2012 the International Agency for Research on Cancer concluded that diesel exhaust is carcinogenic to humans. Acute exposures can lead to other health problems, such as eye and nose irritation, headaches, nausea, asthma, and other respiratory system issues. Longer term exposure may worsen heart and lung disease.1 EPA recommends the Applicant consider the following protective measures and commit to applicable measures in the draft EA.

Mobile and Stationary Source Diesel Controls Purchase or solicit bids that require the use of vehicles that are equipped with zero-emission technologies or the most advanced emission control systems available. Commit to the best available emissions control technologies for project equipment to meet the following standards.

On-Highway Vehicles: On-highway vehicles should meet, or exceed, the EPA exhaust emissions standards for model year 2010 and newer heavy-duty, on-highway compression-ignition engines (e.g., long-haul trucks, refuse haulers, shuttle buses, etc.).2 Non-road Vehicles and Equipment: Non-road vehicles and equipment should meet, or exceed, the EPA Tier 4 exhaust emissions standards for heavy-duty, non-road compression-ignition engines (e.g., construction equipment, non-road trucks, etc.).3 Locomotives: Locomotives servicing infrastructure sites should meet, or exceed, the EPA Tier 4 exhaust emissions standards for line-haul and switch locomotive engines where possible.4 Marine Vessels: Marine vessels hauling materials for infrastructure projects should meet, or exceed, the latest EPA exhaust emissions standards for marine compression-ignition engines (e.g., Tier 4 for Category 1 & 2 vessels, and Tier 3 for Category 3 vessels).5 Low Emission Equipment Exemptions: The equipment specifications outlined above should be met unless: 1) a piece of specialized equipment is not available for purchase or lease within the United States; or 2) the relevant project contractor has been awarded funds to retrofit existing equipment, or purchase/lease new equipment, but the funds are not yet available.

Consider requiring the following best practices through the construction contracting or oversight process:

Establish and enforce a clear anti-idling policy for the construction site.

Use onsite renewable electricity generation and/or grid-based electricity rather than diesel-powered generators or other equipment.

Use electric starting aids such as block heaters with older vehicles to warm the engine.

Regularly maintain diesel engines to keep exhaust emissions low. Follow the manufacturers recommended maintenance schedule and procedures. Smoke color can signal the need for maintenance (e.g., blue/black smoke indicates that an engine requires servicing or tuning).

Where possible, retrofit older-tier or Tier 0 nonroad engines with an exhaust filtration device before it enters the construction site to capture diesel particulate matter.

Replace the engines of older vehicles and/or equipment with diesel-or alternatively fueled engines certified to meet newer, more stringent emissions standards (e.g., plug-in hybrid-electric vehicles, battery-electric vehicles, fuel cell electric vehicles, advanced technology locomotives, etc.), or with zero emissions electric systems. Retire older vehicles, given the significant contribution of vehicle emissions to the poor air quality conditions. Implement programs to encourage the voluntary removal from use and the marketplace of pre-2010 model year on-highway vehicles (e.g., scrappage rebates) and replace them with newer vehicles that meet or exceed the latest EPA exhaust emissions standards, or with zero emissions electric vehicles and/or equipment.

1 Benbrahim-Tallaa, L, Baan, RA, Grosse, Y, Lauby-Secretan,B, El Ghissassi, F, Bouvard, V, Guha, N, Loomis, D, Straif, K &International Agency for Research on Cancer Monograph Working Group (2012).Carcinogenicity of diesel-engine and gasoline-engine exhausts and some nitroarenes. The Lancet.

Oncology, vol. 13, no. 7, pp. 663-4. Accessed online from:

https://kclpure.kcl.ac.uk/portal/files/6492297/coverBenbrahim_Tallaa_2012_Lancet_Oncology.pdf 2 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-heavy-duty-highway-engines-and-vehicles 3 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-nonroad-engines-and-vehicles 4 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-nonroad-engines-and-vehicles 5 https://www.epa.gov/emission-standards-reference-guide/epa-emission-standards-nonroad-engines-and-vehicles (63-2-6 [McClain, Krystle Z.])

Comment: Fugitive Dust Source Controls Stabilize open storage piles and disturbed areas by covering and/or applying water or chemical/organic dust palliative, where appropriate. This applies to both inactive and active sites, during workdays, weekends, holidays, and windy conditions.

Install wind fencing and phase grading operations where appropriate and operate water trucks for stabilization of surfaces under windy conditions.

When hauling material and operating non-earthmoving equipment, prevent spillage and limit speeds to 15miles per hour (mph). Limit speed of earth-moving equipment to 10 mph. (63-2-7 [McClain, Krystle Z.])

C.1.16 Commenters Concerning Need for Project/Purpose and Need Comment: 1. PURPOSE AND NEED / PROJECT ALTERNATIVES A. The Scoping Document does not provide detailed information about PNP, including its structural integrity, refurbishment history, how often maintenance is required, why it was decommissioned, and the reasons for restarting operations.

Recommendations for the Draft EA:

1. Describe the history and context of the existing plant. Provide background information on PNPs function within Covert Township and, more broadly, within Michigan. Describe previous plant maintenance and any retrofits that would be needed to resume power operations.

2. Discuss the rational for decommissioning PNP.

3. Discuss how the current license that allows operation through 2031 will affect restarting PNP. (63-1-3 [McClain, Krystle Z.])

Comment: Clearly describe the purpose and need for the Project. (63-1-5 [McClain, Krystle Z.])

Comment: But what I want to talk about, baseload generation. From an economic developer's standpoint, I'm getting on a regular basis inundated with requests for hundreds of megawatts for data centers. And if you think this is going to go away anytime soon, take a look at your phone and think about the last time megapixels actually went down, not up, with the latest generation of your phone. And then, we have AI coming online.

So, data centers are only getting bigger. They're asking for more energy all the time. We need baseload generation, especially with the numbers we're talking about with coal. We're bringing coal off. Those are gigawatts and we're adding gigawatts back on. Those numbers just don't add up in a positive direction for our grid. And if we're going to have reliability, which is the hallmark of America, then we need to make sure that we are doing the responsible thing, bringing baseload generation on, along with these other sources of generation, such as solar and wind. (143-27-2 [Morris, Zach])

C.1.17 Comments Concerning Noise Comment: 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. (131-1 [Cordell, John])

C.1.18 Comments Concerning Socioeconomics Comment: The cost and risks attendant to decades more of high-level and low-level nuclear waste.

The long-term tax and economic effects of adding to what is, in effect, a high-level nuclear waste dump in Michigan for an indefinite, and potentially centuries-long, duration must be addressed. (77-2-1 [Lee, Michel])

Comment: And as you're considering the environmental impact, I also encourage you to consider the human impact here. Right now, you sit in Benton Township in the greater community of Benton Harbor with an unemployment rate of north of 18 percent -- one of the most impoverished communities in the State. There were jobs lost in this community in Covert, another economically hard-hit community, when the plant shut down. The restoration of these jobs is meaningful to families here in this community -- in the communities of Covert, Benton Harbor, and Van Buren County, a county not ripe with large economic assets.

What this means to our community and the people who live here goes, I think, beyond the scope of just simple assessments, and the future of our region, the industries that have begun reaching out and looking at our region; the employers that have begun reaching out because we'll have this consistent, reliable electricity and a clean source to power their industries.

And to echo what was just said, the jobs, hundreds of six-figure jobs, hundreds of good-paying jobs, union jobs. These are family-sustaining careers for people here, that they can go on and retire from. (143-7-2 [Andrews, Joey])

Comment: This, from an economic development standpoint, is enormously impactful. We know the numbers, $10 million in tax base for the County, $75 million in payroll, and $300 million in economic regional impact. Those are big numbers and make a big difference for the people who live here. (143-27-1 [Morris, Zach])

Comment: The economic impacts include the wages of a skilled and talented workforce, and the tax base that supports schools and public services.

Importantly, these plant employees are real people in our community. They've raised their kids in South Haven. They've volunteered and donated to local non-profits, churches, and service organizations. They've shopped in small businesses while they've called South Haven home.

Additionally, the previous owners of the plant have been active partners in the community, and we expect the same from Holtec. (143-32-2 [Hosier, Kate])

C.1.19 Comments Concerning the Uranium Fuel Cycle Comment: What effect would the use of highly enriched fuel have on operations and storage?

Would Holtec purchase "high burnup" enriched fuel from Russia or Russian allies until the U.S.

can supply itself? What effect would restart have on the nuclear supply chain? (58-5 [Mcardle, Edward])

C.1.20 Comments Concerning Waste Management-Radioactive Waste C.1.20.1 Comments Related to Waste Management-Radioactive Waste Comment Summary 1 Comment: We were incredibly surprised to hear that the casks on site - presumably in a fenced area - were deteriorating. This plant sits on a bluff adjacent to Lake Michigan, a fresh water source for millions of people. If the casks are compromised, the impact would be catastrophic. (42-3 [Sahagian, Linda G.] [Stewart, Douglas A.])

Comment: As I live a 5-minute walk from Lake Michigan I am especially concerned about the possible pollution and NUCLEAR trash waste from Palisades. (51-1 [Dermody, Laurie])

Comment: How can the U S Department of Energy & the NRC endanger the quality of the nearby adjoining Lake Michigan water source by storing highly toxic, radioactive spent uranium fuel rods on the critical dunes shoreline for decades? (66-3 [Reed, Dillon])

Comment: I attended the NRC presentation on July 11, 2024, at Lake Michigan College in Benton Harbor, MI and I was confused how Holtec can claim that the Palisades Nuclear Plant provides clean energy. This plant when it operates produces radioactivity and nuclear waste which is considered hazardous and deadly when not properly managed.

Currently this site has casts that are storing this toxic waste in shifting dunes bordering Lake Michigan since the early 1970's which is a dangerous threat to the drinking water of 40 million people. Restarting this plant would add to this problem. How is this deadly waste that is NEVER going to go away be clean for our environment and our fresh water? (91-1 [Dembs, Barb])

C.1.20.2 Comments Related to Waste Management-Radioactive Waste Comment Summary 2 Comment: The closure-for-good of Palisades by Entergy on May 20, 2022, meant that no more radioactive waste would be generated there. But the proposed restart would mean that the highly radioactive waste inventory stored on-site at Palisades would grow by around 15 metric tons per year, from 2025 to 2051. Thus, the associated LARGE impacts on the environment would also grow. (1-3 [Doenmez, Sarah])

Comment: How much nuclear waste will be produced over the lifetime of the renewed lease and how will it be disposed of since there is no plan for a national repository? (18-1 [Hayes, Rose])

Comment: We still don't have a long-term storage solution for the nuclear plant waste. (48-3 [Munski, Donald])

Comment: 4. NUCLEAR WASTE STORAGE A. Liquid, gaseous, and solid radioactive waste management systems can collect and create radioactive byproducts from spent nuclear fuel if required for continued on-site storage. Due to the uncertainty regarding the future availability of a geologic repository or other away-from-reactor storage facility, on-site storage may be required for many decades, until a permanent repository is established.

Recommendations for the Draft EA:

2.

Indicate if there will be any changes in the generation of waste including low-level radioactive waste, mixed low-level radioactive waste, transuranic waste, and hazardous and Toxic Substance Control Act wastes over the life of the program.

3.

Describe plans to transport spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options outside the facility. (63-1-10 [McClain, Krystle Z.])

Comment: The actual past and potential present and future environmental impacts resulting from the ongoing (1971 to the present and counting) radioactive waste crisis at Palisades are also LARGE. More than 800 metric tons of highly radioactive irradiated nuclear fuel have accumulated on-site at Palisades. Around two-thirds is still stored in the wet indoor storage pool; one-third is stored in a growing number of outdoor dry casks, very near the Lake Michigan shore. (76-1-18 [Kamps, Kevin])

Comment: Dry cask storage at Palisades has been controversial and risky from the start in 1993. The fourth cask to be loaded, in summer 1994, was quickly announced by then-owner Consumers Energy to be defective. Consumers Energy had assured the public that any problems with casks would be easily resolved by simply returning the highly radioactive waste to the indoor wet storage pool. NRC backed this up, including under oath in a federal court room in Grand Rapids, MI, when State "Eternal General" (Attorney General -- he served 37 years, still a national record) Frank Kelley legally challenged the loading of the casks in the first place. (By 1997, Dr. Mary Sinclair of Don't Waste Michigan pointed out that perjury had likely been committed.) (http://archives.nirs.us/reactorwatch/licensing/sinclairltr020697.pdf) Although Consumers Energy initially assured the public it would live up to its previous promise, and promptly at that, 30 years have now passed, and the defective cask still sits fully loaded, 150 yards or less from the shoreline of Lake Michigan. Complications previously identified and warned about by environmental watch-dogs proved accurate. Grinding through welds on the lid, and removing pressure fit shims, would contribute to missing the 40-hour deadline for transferring the fuel from the defective dry cask back into the pool -- convection air current cooling would be disrupted -- violating Technical Specifications related to fuel-and cask-overheating. Even then, lowering the thermally hot (up to 750-degree Fahrenheit) containerized fuel into the 100-degree F pool water would cause a thermal shock to fuel and container, exacerbating degradation. It would also cause a radioactive steam flash, most hazardous to nearby workers and local residents or visitors, such as those at Palisades Park Country Club immediately to the south, and/or Van Buren State Park, immediately to the north. (76 20 [Kamps, Kevin])

Comment: The closure-for-good of Palisades by Entergy on May 20, 2022 meant that no more radioactive waste would be generated there. But the proposed restart would mean that the highly radioactive waste inventory stored on-site at Palisades would grow by around 15 metric tons per year, from 2025 to 2051. Thus, the associated LARGE impacts on the environment would also grow (76-2-2 [Kamps, Kevin])

Comment: Whether waste will remain at the site in perpetuity or ultimately be transported to another site in Michigan or elsewhere, all the additional spent fuel will still need to be stored and protected at Palisades for decades to come.

The U.S. began a search for potential geologic repository sites in 1970. More than half-a-century later, we have none and the Nuclear Waste Policy Act (NWPA), passed in 1982, puts the liability for permanent sequestration of high-level nuclear waste on the American taxpayer.

Yucca Mountain was defunded in 2010 and there is no current realistic expectation that the project will be resuscitated.

Consolidated interim storage facilities (CISFs) proposed by Holtec International in New Mexico and Waste Control Specialists in Texas have faced judicial scrutiny and fierce opposition. The governors of both Texas and New Mexico have opposed these facilities, in large part because of the safety and security concerns. These interim nuclear waste storage facilities have also been staunchly opposed by Native American Tribes and Indigenous groups, farmers, ranchers, and the oil and gas industry.

The decades of additional high-level nuclear waste which would be generated by the relicensing of Palisades will only add to the problem of nuclear waste and raise all attendant costs. (77-2-3 [Lee, Michel])

Comment: We still have poorly protected nuclear waste stored on site. (86-2 [O'Connor, Gerry])

Comment: As you know nuclear power production generates highly toxic, radioactive, spent fuel rod waste, that must be stored in thin wall casks at the plant site for an undetermined about of years. Further generation of radionuclides at this site risks destabilizing the adjacent Lake Michigan clean water source for MI, IND, IL, WISC. (93-2 [Ebert, Robert])

Comment: And the waste is safe. It's not waste. I'm glad that we have it set in these casks because there's so much energy left in it, that we're going to use that supposedly waste in advanced reactors, and we'll run our country for hundreds of more years on that nuclear waste.

It's not waste; it's a national treasure.

And it just sits on what amounts to about a half a football field here at Palisades. For 50 years of operation, we have like -- what? -- 22 casks. That's because nuclear power traps all of its waste before it goes into the atmosphere. Every ounce of waste coming out of a nuclear plant is accounted for. (143-19-3 [Connors, Shawn])

Comment: So, I'm going to skip over to the fact that everyone talks about this being a clean energy process, except that nobody's addressing the fact that we are, when it is in operation, producing highly toxic, radioactive waste that has to be stored on the shore, and it's an unstable shore -- a sandy, movable dunes, unstable shore that we are planning on storing this waste. I hope you're considering that. (143-23-2 [Pierman, Bette])

Comment: I'm with Don't Waste Michigan.

Don't Waste Michigan has a long history with Palisades. In 1993-1994, the Attorney General of the State of Michigan joined us in representing Don't Waste Michigan in federal court regarding the loading of the dry casks.

We were promised, they promised the court that they could always unload them. And we were remanded back to the agency. Lo and behold, a year and a half later we learned that no, they can't be unloaded. They've never been unloaded anywhere in the industry.

Cask Number 4 remains faulty with cracks and welding problems and was never unloaded but was supposed to have been. And it's still here, faulty. (143-37-1 [Keegan, Michael])

C.1.20.3 Comments Related to Waste Management-Radioactive Waste Comment Summary 3 Comment: Prospective Radioactive Waste Inventory Would Have Environmental Effects The proposed Palisades restart would mean that the highly radioactive waste inventory stored onsite at Palisades would grow by around 15metric tons per year, from 2025 to 2051. Thus, the associated large impacts on the environment would grow. Holtecs proposed SMR-300 new builds at Palisades (and also at Big Rock Point), absent economies of scale in the generation of electric power, would each generate more highly radioactive waste per unit of electricity generated than Palisades. Drs. Allison Macfarlane, and Rodney Ewing, President Obamas NRC chair and U.S. Nuclear Waste Technical Review Board chair, respectively, reported recently that, depending on their specific design, SMRs will generate 2 to 30 times the radioactive waste, as compared to current reactors, per unit of electricity generated.51 Holtecs SMR new build schemes would exacerbate the Palisades reactor restart scheme to manage high-level radioactive waste at the site, situations which must be documented and analyzed under NEPA. (75-14 [Lodge, Terry J])

Comment: Holtec's proposed SMR-300 new builds at Palisades (and also at Big Rock Point),

due to loss of economy of scale, would each generate more highly radioactive waste, per unit of electricity generated, than the zombie reactor. Drs. Allison Macfarlane, and Rodnew Ewing, President Obama's NRC chair and U.S. Nuclear Waste Technical Review Board chair, respectively, reported recently that, depending on their specific design, SMRs will generate 2 to 30 times the radioactive waste, as compared to current reactors, per unit of electricity generated. But similar things can be said regarding thermal wastewater discharges, cost per unit of electricity generated, etc. Thus, Holtec's SMR new build schemes would exacerbate the already LARGE impacts on the environment and socioeconomics of its zombie reactor restart scheme. (76-2-3 [Kamps, Kevin])

C.1.20.4 Comments Related to Waste Management-Radioactive Waste Comment Summary 4 Comment: None of this is safe, now or in the future. You have no safe transportation, storage or transfer methods for used fuel. NONE! That means its not safe. Even if the great Cheyenne Mountain plan ever came into existence, youd have to transfer/transport it by truck or train. We see those things fail a lot and thats one large failure for the people of the US to eat up because WMich wants nuclear fuel (less than 5% of whats required remember? Traded for 20% of all the fresh water on the PLANET!) (33-5 [Birdsall, Sheila])

Comment: 2. Indicate if there will be any changes in the generation of waste including low-level radioactive waste, mixed low-level radioactive waste, transuranic waste, and hazardous and Toxic Substance Control Act wastes over the life of the program.

3. Describe plans to transport spent nuclear fuel and spent fuel debris offsite for storage pending long-term disposal options outside the facility. (63-1-12 [McClain, Krystle Z.])

Comment: But the other issue that nobody is talking about is moving that highly toxic, radioactive waste. Right now, they don't have a storage place that's available for it, but they have talked about moving, when they do, moving this waste through rails, through barges, and using barges on Lake Michigan to move that waste.

And I want you to consider, please consider, if we have highly toxic, radioactive nuclear waste being transported on barges on Lake Michigan in high seas, when we have had so many shipwrecks in the Great Lakes, what impact that's going to have on this freshwater system if we dump a barge loaded with highly toxic, radioactive waste. (143-23-4 [Pierman, Bette])

Comment: I live in White Hall, in northern Muskegon County. I wish to express my profound concern regarding the proposed restart of the Palisades Nuclear Power Plant.

Particularly in the light of an absence of a solution to the waste the plant will create. The plants that all our country's nuclear plants create.

This issue is of paramount importance as it directly impacts public safety, environmental health, and the long-term sustainability of our community, and state.

The lack of a permanent national repository for high-level radioactive waste presents a significant and seeming insurmountable challenge.

It was 73 years ago that commercial nuclear power plant began to operate. And a repository was promised for these dangerous waste beginning to be created. Today, there is still no answers to the waste.

Unbelievably, we continue to allow the creation of a waste that we don't know what to do with except for we stockpile them onsite.

Or later down the road we plan transporting them through communities by rail, by water, I even heard by barge to Muskegon's harbor, to a repository forced on a sacrificial state.

Currently, Palisades houses approximately 630 tons of spent fuel waste in the country, and 30, excuse me, in 21 concrete casks. And a restart will only increase this dangerous inventory.

The waste remain[s] hazardous for thousands of years, far exceeding the life span of any containment measures we can currently guarantee.

This is irresponsible and poses a continual risk to future, current and future generations.

Here we are using energy again and not dealing with the results. (143-40-1 [Cabala, Tanya])

C.2 Non-Technical and Comments Outside the Scope of the Environmental Review C.2.1 General Comments in Support of the Licensing Action Comment: I'm writing to urge the U.S. Nuclear Regulatory Commission to approve the plan to restart the Palisades Nuclear Power Plant in Michigan, backed by the Biden Administration and Governor Whitmer.

Palisades was closed in 2022 for financial reasons and reopening it would mark the first successful restart of a nuclear power plant in American history, providing clean electricity precisely when it's most needed.

As a climate activist, I strongly support I strongly support reopening the Palisades Nuclear Power Plant.

Here's why:

1. Nuclear power is significantly cleaner and safer than fossil fuels. Nuclear and renewables are the only major energy sources with less than 10 tonnes of greenhouse gas emissions per gigawatt-hour and less than 0.1 human deaths per terawatt-hour of electricity production.

2. Nuclear power isn't necessary replaced with renewable energy. Germanys closure of its nuclear plants in 2023 led to a short-term increase in coal use. This has hindered decarbonization efforts, creating a "treadmill" effect where new wind and solar power additions replace offline nuclear capacity, but do not reduce reliance on fossil fuels.

3. Reactivating Palisades will bolster the local economy and deliver clean energy to residents.

Governor Whitmer emphasizes that reopening the plant would protect 600 union jobs, support 1,100 community jobs, and provide reliable power for 800,000 homes.

We need all the clean energy sources available to transition away from fossil fuels effectively.

Nuclear is a clean, safe, and zero-carbon-emissions technology that we should support where feasible.

I'm calling on you to accelerate the transition away from fossil fuels and approve the reopening of the Palisades Nuclear Power Plant! (14-1 [Unknown, Unknown])

Comment: I'm writing to urge the U.S. Nuclear Regulatory Commission to approve the plan to restart the Palisades Nuclear Power Plant in Michigan, as supported by the Biden Administration and Governor Whitmer.

Nuclear power is much cleaner and safer than fossil fuels, and America needs all the clean electrons we can get right now. Let's make this happen! (16-1 [Dalke, Lillian])

Comment: As a climate activist, I strongly support the plan to reopen the Palisades nuclear power plant. Heres why.

Reopening Palisades would be a good thing for climate action, as nuclear power is much cleaner and safer than fossil fuels. Nuclear and renewables are the only major energy sources with less than 10 tonnes of greenhouse gas emissions per gigawatt-hour and less than 0.1 human death per terawatt-hour of electricity production.

Worst-case scenario nuclear accidents kill fewer people than fossil fuel plants working normally.

A 2021 study from Harvard calculated that fossil fuel-caused air pollution killed over 8 million people in 2018, making fossil fuels responsible for one-fifth of all human deaths worldwide. And thats just direct fossil fuel deaths, from soot and particulate matter in the air getting in peoples lungs. Indirect fossil fuel deaths, from the wildfires, storms, heatwaves droughts, floods, and famines exacerbated by climate change, are harder to calculate but are also considerable.

Shutting down nuclear power might seem safer, but often ends up killing people. A 2020 study found that Germanys phase-out of nuclear power after the 2011 Fukushima disaster directly caused over 1,100 additional deaths from air pollution each year!

The [German nuclear] phase-out resulted in more than 1,100 additional deaths per year from increased concentrations of SO2, NOx, and PM (particulate matter). The increase in production from hard coal plants is the key driver here, making up roughly 80% of the increase in mortality impacts.

-Jarvis, Deschenes, and Jha, 2019.

Furthermore, nuclear power is a zero-carbon emissions energy source. Shutting down nuclear power generally means making climate change worse. Germanys unnecessary closing of its last nuclear power plants in 2023 has been widely criticized for causing a short-term increase in coal burning. This has slowed decarbonization, with a treadmill effect where the new wind and solar power coming online is replacing nuclear power going offline, swapping one clean energy source for another without decreasing the use of fossil fuels. To be fair, Germany has also committed to ending coal burning by 2030 and replacing it with even more renewables, so this isnt a permanent issue-but its already caused years of unnecessarily high emissions during a climate crisis! Not okay!

On April 16, the day after the final nuclear plants shut down in Germany, the country recorded a carbon intensity of 476 grams of CO2 equivalent for every kilowatt-hour of electricity produced. About half the nations electricity came from renewable sources, but coal made up about 30% of the supply. Meanwhile, in France, only 30% of electricity came from renewables.

Add in nuclear, though, and low-carbon power sources made up 93% of the electricity supply.

So Frances emissions for every unit of electricity were lower than Germanys by a factor of nearly 10, at 51 grams CO2-eq/kWh, largely because of its heavy reliance on nuclear power.

-MIT Technology Review It's true that nuclear power has been overtaken, so to speak, by equally clean and safe technologies that are also cheaper and faster to build (not to mention less controversial). Both solar and wind power got incredibly cheap, incredibly fast in the 2010s due to rapid advances in technology and a surge in investment: from 2020 onwards, solar has been the cheapest source of electricity in history. During this same period, nuclear power got more expensive.

Unsurprisingly, this has led to the building of lots more wind and solar and very little new nuclear

-thats why new solar and battery storage projects are set to account for over 80% of newly built U.S. grid capacity in 2024 while new nuclear will supply 2%.

Still, we need all the clean electrons on the grid we can get -nuclear is a clean, safe, and zero-carbon-emissions technology that we should support where feasible. Where we have shut down perfectly good nuclear power plants, as with the Palisades case in Michigan, we should reactivate them to help achieve cleaner air and lower emissions.

I'm calling on you to help speed up the transition away from fossil fuels, the dirtiest energy source, and approve the reopening of the Palisades Nuclear Power Plant! (16-2 [Dalke, Lillian])

Comment: We as Americans have a general aversion to nuclear power, due to a few high-profile incidents/disasters in our history. However, time has come where we as a nation need to embrace nuclear energy, alongside wind, solar, and other renewables, as a reliable source of energy as we seek to transition away from fossil fuels into a green economy. Restarting the Palisades Plant would provide a new influx of union jobs, as well as extra resilience to the Michigan power grid. It would be a great success if this could be achieved, and I hope that Governor Whitmer's vision is borne out. (17-1 [Duran, Brandon])

Comment: I support the effort to restart Palisades Nuclear Power Plant.

We need more carbon free energy sources like wind, solar, and nuclear. (22-1 [Weykamp, Greg])

Comment: Please continue with the restart review process. Nuclear energy is critical for providing a base load to the grid and decarbonization of power. (23-1 [Hagen, James])

Comment: Michigan needs nuclear power as part of our energy profile. Updated nuclear regulations and equipment will make the energy cleaner and safer. We need this power plant in Michigan. (29-1 [Grivins, Jennifer])

Comment: The environmental conditions at the Palisades site remain the same as when the plant was operational. This stability underscores the importance of a prompt environmental review. The ecosystems along Lake Michigans coast are thriving, and repowering Palisades will ensure we continue to protect this ecological balance. Nuclear energy, as a clean and reliable source of power, is vital for reducing Michigans carbon footprint and preserving our natural environment.

While no human activity is risk free, delaying (or even preventing) the restart of the Palisades Plant will result in significant harm to climate, the environment, grid stability, and electricity consumers, as discussed in the July 11 hearing. Bipartisan support and substantial financing are in place to facilitate the plants restart. This support is driven by the need to lower CO2 emissions and prevent potential energy shortages in Michigan. The NRCs consideration of the plants status at its closure should guide the review process, avoiding unnecessary delays advocated by antinuclear groups.

Failing to repower Palisades would exacerbate the impact of closing 6 GWe of coal production by 2033 and reducing natural gas power production. Michigans energy demand is rising, and without Palisades firming power, the state faces scheduled blackouts, increased electricity costs, and potential deindustrialization, similar to challenges seen in Germany and California. (31-3 [Detering, Dietmar])

Comment: Today I would like to emphasize the critical importance of reopening and maintaining the operational status of the Palisades nuclear power plant to ensure that Michigan continues to enjoy stable, reliable, and affordable energy. This is not just a matter of convenience; it is a crucial element in supporting the economic well-being of our state, safeguarding against blackouts, and promoting a balanced approach to energy sources.

As a resident and business owner, my husband, Scott, understands firsthand the impact of energy costs on the construction industry. His business, as well as countless others, relies heavily on guaranteed stable and affordable energy to operate efficiently and remain competitive.

The stability of our energy grid is paramount to preventing blackouts and ensuring uninterrupted productivity. Palisades has played a crucial role in maintaining this stability, and its reopening is essential to avoid potential disruptions that could negatively impact businesses, homes, and overall quality of life for Michigan residents.

Moreover, we recognize the need for a diverse energy portfolio that balances sustainability with affordability. While solar and wind farms have their place in our energy mix, an over reliance on these intermittent sources can lead to challenges in maintaining a consistent and reliable power supply. By reopening Palisades, we can achieve a more balanced and resilient energy infrastructure that incorporates nuclear power as a clean, efficient, and constant energy source.

We understand the desire for affordable and reliable energy at home without resorting to extensive use of solar panels and wind turbines. Palisades offers a solution that allows us to meet our energy needs without compromising the aesthetics of our neighborhoods or burdening homeowners with the costs and maintenance associated with alternative energy sources.

In conclusion, reopening Palisades is not just a prudent decision; it is a strategic move to safeguard Michigan's economic interests, ensure energy reliability, and promote a well-rounded energy strategy. I urge all stakeholders, policymakers, and the community at large to support the reopening of Palisades for the benefit of our state's businesses, residents, and future generations. (32-1 [Haan, Megan])

Comment: I write to provide context. I hope that the "scope" of the NRC-required review includes the range of facts that I present here.

The important word "environment" calls me to consider context, namely, is there a better alternative to nuclear power? Every method that is currently used to generate electricity has a downside here are a few:

• Coal ash is toxic and radioactive,

• Gas can burn explosively and always contributes to global warming,

• Windmills fall in tornadoes, kill birds, their reflections produce seizures for some people and their blades do not recycle well.

• Solar panels have limited lifetimes, include toxic substances and are inefficient,

• Dams are not very effective during a drought.

The list for each example could go on and on. That is why no thoughtful person seeks a single source of electrical power.

I believe that good ecology calls for diversity and nuclear power belongs in the mix. Its radioactive waste seems to bother some folks the most. It is dangerous but, comparatively, very, very small in volume. Furthermore, other countries are making giant strides in isolating it, Finland for example.

In particular, the Palisades Power Plant is not located in a seismically active zone nor is it likely to experience a hurricane or tsunami. It has an inherently safer design than that of old Russian reactors and it has more experienced operators that those at Three Mile Island (where, by the way, no one was physically injured).

Yes, nuclear power plants call for a well-educated and trained staff. That and careful regulation explain why American reactors have accumulated millions of worker hours of safe operation.

The service record of the Palisades Plant indicates a steady progression of improved performance. It has not harmed its immediate environment over the 40+ years of its existence, yet kept our lights lit. (34-1 [Williams, Donald])

Comment: As a young adult who will live to see the effects of climate change through the latter half of this century, I enthusiastically support the efforts of Holtec and Gov. Whitmer to restart Palisades. Nuclear energy is a requirement for the clean energy transition to successfully occur, as solar and wind power lack the capacity and availability factor necessary for fully powering the grid. By restarting this plant, clean, carbon-free energy will be generated that would otherwise be taken up by polluting fossil fuel base load generation. (37-1 [Gold, Colin])

Comment: I ask that members of the public who are afraid of the effects of radiation and risks from nuclear operation take it upon themselves to learn the facts regarding nuclear energy and its excellent track record with regards to safety. (37-3 [Gold, Colin])

Comment: I just wanted to drop a note I've seen in LinkedIn some comments about the great work being done to reopen the Palisades power plant. I feel very strongly that nuclear is the way forward and that wind and solar, so very cool, are unable to meet our future needs. I'm very happy that this plant is being turned on and hope that many, many more are built. I'm very tired of constantly having to turn down my air conditioner and not certain things in the day because too many people are using power because we have too much renewable energy that is not producing when we need it. (39-1 [Rogers, Larkin])

Comment: The following is my statement in support of the project. The Palisades Nuclear Plant, with its proven track record of safe and reliable energy production, stands as a critical asset in our pursuit of a cleaner, more sustainable energy future. Restarting the plant will not only provide a significant boost to our energy grid's stability but also reduce our carbon footprint by supplying emission-free electricity. Furthermore, the plant's reopening will create jobs, stimulate the local economy, and contribute to energy security. Given the urgent need to address climate change and the growing demand for clean energy, reviving the Palisades Nuclear Plant is a pragmatic and forward-thinking decision. (40-1 [Ridley, Gavin])

Comment: With all this said we at Palisades Park appreciate the steps the Nuclear Regulatory Commission is taking to ensure safety and the environmental impact of any action taken. No shortcuts. (42-5 [Sahagian, Linda G.] [Stewart, Douglas A.])

Comment: Simple and sweet - I SUPPORT THE RESTART OF THE PALISADES FACILITY.

As electrical demands grow, both naturally and due to political mandates, and generating facilities are being taken offline, the need for additional generation using nuclear power is obviously necessary. This facility exists, thus will not take decades of permitting and supply issues, thus it is a natural extension of adding to our generating facilities in a comparatively short time.

RESTART IT ASAP! (52-1 [Birney, Robert])

Comment: I am in favor of restarting the Palisades nuclear energy plant in Michigan. I have made some comments in the attached PDF document. (57-1 [Gibson, Robert])

Comment: Reliability of Nuclear Energy How can we measure reliability of electricity with some numbers? I would use a metric called capacity factor. Back in 1975, nuclear energy had a capacity factor of 56%, and in 2007, the capacity factor rose gradually to over 90%. Since 2007, nuclear energy has had a capacity factor of over 90%, except for 2011 and 2012. Nuclear energy is the world's most reliable energy source. (57-3 [Gibson, Robert])

Comment: 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.

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-harrisadministration-announces-15-billion-conditional-commitment-holtec-palisades. (107-1 [Lloveras, Leigh Anne])

Comment: 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. (107-4 [Lloveras, Leigh Anne])

Comment: 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. (134-5 [Lombardi, Joan])

Comment: Congressman Huizenga has been a consistent supporter of repowering Palisades.

As the Republican Co-Chair of the Great Lakes Task Force and a member of the Conservative Climate Caucus, Congressman Huizenga is knowledgeable in both environmental and energy policy, which is why he readily recognizes the benefits of restoring 800 megawatts of reliable, safe, carbon-free energy generation and bringing back hundreds of highly skilled jobs right here to Michigan's north district.

With southwest Michigan's fast-growing energy needs, it is also important to note that this historic project lays the groundwork for small modular reactors, a key piece of America's energy security future.

As this process moves forward, Congressman Huizenga and our office will remain engaged with stakeholders and decisionmakers from the community level to the federal level to see that we safely reauthorize this key plant for the benefit of southwest Michigan and our Nation. (143 1 [McLeod, Ben])

Comment: I represent Covert Township, where Palisades sits. And it was a great effort of mine this year to secure some of the State funding, the $300 million, to get this plant restarted. I've been a strong proponent of getting the plant back on the grid and the clean energy that it represents.

We passed a climate package in Michigan last year that cannot be met without nuclear power; cannot be met without resources like Palisades coming back on the grid. I believe that we stand no chance of meeting our climate goals as a planet without Palisades, without nuclear energy being brought back online. (143-7-1 [Andrews, Joey])

Comment: So, I encourage you, you know, this project is a huge deal. I know you know that. It's the center of a lot of attention. It's bringing a lot to our communities. But I cannot overstate how critical this is, both to meet our climate goals and for the sustainability of our communities here in southwest Michigan. (143-7-3 [Andrews, Joey])

Comment: I want to thank the NRC for hosting today's meeting on this issue of importance to Michigan's energy future. Palisades has long been a provider of reliable, carbon-free energy for southwest Michigan for decades.

Though its early shutdown was announced years ahead of time due to business decisions, it was, nonetheless, a devastating blow to this region as a reliable provider of vital energy, jobs, and economic activity.

Palisades has a long and proven history of safe operations, ranked in the NRC's highest safety category. Under Holtec, they've remained good community partners and keep the health of the public and environment paramount.

The folks who work there are experienced and well-qualified, moreover, and as evidenced by some of the commenters we've heard at past meetings -- a lot of community leaders and a lot of folks from around southwest Michigan coming out -- they are our friends and neighbors.

Michigan families need dependable power sources like Palisades to help alleviate high energy prices and provide electricity when the sun doesn't shine or the wind doesn't blow. The last thing Michigan wants is to be in a situation like California, where prices are high and energy insecurity leading to the rapid reopening of shuttered plants is the norm.

Restarting Palisades is not just a matter of our energy supply. It's a matter of ensuring our future. The environmental benefits, combined with the plant's proven safety record, make it a critical asset we cannot afford to lose.

Senator Nesbitt urges the NRC to recognize and support the indispensable role of Palisades and its restart here in southwest Michigan. (143-8-1 [Progacki, Josh])

Comment: First, I want to thank the NRC for hosting today's meeting and for your regulatory oversight that you provide for our country's nuclear industry.

Palisades has a proven history of providing clean, carbon-free energy to our region for decades.

Its long operational history highlights its crucial role in delivering reliable power to our State.

Nuclear energy is vital to ensuring Michigan has an adequate power supply to meet the needs of our residents. Recently enacted clean energy mandates are unattainable without Palisades in the mix, and frankly, not without more nuclear energy.

Moreover, Palisades provides a reliable baseload power supply. Unlike intermittent and unreliable renewable sources, nuclear power offers a consistent and stable energy output, ensuring that our grid remains robust and reliable. The stability and reliability is vital as our energy portfolio continues to change.

The environmental impact of Palisades is well-understood, thanks to its long history of safe operations. The plant has consistently met stringent safety standards set by the NRC, operating within the Commission's highest safety category. This track record of safety, public transparency, and stewardship provides confidence that the plant can continue to operate without adverse impacts on our community.

Lastly, Palisades is an important part of our community. The plant supports hundreds of high-quality jobs and contributes significantly to the local economy. Its operations generate tax revenues that fund essential public services, further enhancing the quality of life in southwest Michigan.

Restarting Palisades is vital for maintaining our supply of clean, carbon-free, and reliable energy. The environmental benefits, coupled with the plant's proven safety record, make it a crucial asset for our community and our energy future.

Rep. Wendzel respectfully urges the NRC to support the restart of the Palisades Nuclear Plant.

(143-9-1 [Rushlow, Jake])

Comment: That said, I'm a huge fan of nuclear energy. Changes in the climate, whether we want to admit it or not, are becoming a reality. A little factoid: temperatures have been recorded around the globe since 1880. The last 10 years are the highest temperatures on record. Global sea levels have risen at least 8 inches since 1880.

You can't turn on the Weather Channel without seeing broad areas of extreme heat, flooding, and deadly tornado and hurricane systems. We're even seeing weather changes in our more protected region of southwest Michigan. In Kalamazoo County, in the last few months, we've seen two major storm systems tear roofs off of houses and businesses and rip old-growth trees out of the ground.

The data clearly points to increased CO2 levels as causal for the changes in climate. I'm a fan of nuclear energy because it's the only reliable source of energy currently available with little to no CO2 emissions.

Today, I look around my neighborhood and I see a majority of neighbors now riding around in electric golf carts, on electric bikes, and electric scooters. With electric cars and trucks coming off the line, the pull on our grid will be more significant than ever.

I personally don't want coal and natural gas power companies spewing more CO2 into the atmosphere to provide the power we want and need to fuel our lives.

With the NRC doing all they can to make operations safe, it is time to embrace the clean option:

nuclear energy and the reopening of Palisades. (143-10-2 [Fetzer, Darby])

Comment: I operate a business that actually helps the health of thousands of people. My business actually relies on reliable power.

And I strongly support the reopening of Palisades Nuclear Plant for multiple reasons.

First of all, Palisades would provide reliable, clean baseload power. The restart of Palisades is crucial in the face of impending coal plant shutdowns. The demand for power is rapidly increasing, not just in Michigan, but nationwide. Wind and solar can't fill that widening gap because reliable electric storage doesn't exist to provide electricity when wind and solar are offline. (143-12-1 [Fetzer, Bruce])

Comment: I also want to say thank you to the state representatives and federal elected officials that are in attendance as well. I've been watching this over from where I sit here in Chicago, Illinois, and it's awesome to see the cooperation, bipartisan cooperation, that made this happen.

And I want to give a comment just urging the NRC to account for the benefits of nuclear energy, while it's also going to be addressing the risks of it as well. I live in Chicago, where our grid right now is powered by 73 percent nuclear energy. We have 10 reactors that feed my grid. (143 1 [McLean, Michael])

Comment: With our growing rate of dependence on electricity, it is more important than ever to support Holtec in their efforts to reopen Palisades for the safe, reliable, carbon-free power that it will be able to provide to all of us.

This nuclear power would enhance our energy security by diversifying the energy mix and by reducing our dependence on imported energy sources. This would also decrease or eliminate power supply disruptions and help mitigate climate change.

In addition to the safe, clean energy, Palisades has always been a great corporate citizen. They provide our region with hundreds of high-paying jobs and tax revenues that are vital to our communities and public services.

The Van Buren County Board of Commissioners voted to support this historic effort by Holtec.

And I just wanted to thank the NRC for your time and transparency and for putting these meetings together. (143-17-1 [Chappell, Mike])

Comment: I advocate for nuclear energy. I didn't start off that way. Palisades started operations when I was a freshman in high school in Kalamazoo. And I have some friends that worked for many years to try to get the plant shut down. And I still like my friends. I just disagree with them about this plant.

One of the reasons I like nuclear energy is I owned publishing business where we would go in and do communications inside of other businesses. And one of my clients was Sandia Laboratories. And I was having lunch with some of those guys. And if you've ever seen the Far Side cartoons -- are you familiar with those? -- they actually looked like that at Sandia Labs when I was there in the '90s. And I was telling them I was nervous about Palisades and they started to reassure me a little bit about nuclear energy.

And I didn't buy into it immediately. I just started reading and ramping up a little more and getting more involved. And by the time I sold my business in 2016, I decided I wanted to spend my retirement advocating for nuclear energy.

And before that, I was somewhat agnostic. But what really turned me towards it was 70 years, for 70 years in this country, we now have experience with fission. The worst accidents we have had in the United States was at Three Mile Island. And it was an accident. It was and it was serious, but no one was killed. No one was injured.

All the safety support worked just like it did, or it was supposed to. The radiation was contained within the containment vessel. If you got any radiation, you had to be on the fenceline when they let some of the hydrogen loose. You would have got as much as a dental x-ray. And that's the worst accident we've had in the United States.

There are going to be accidents with every source of power. If you do not want nuclear power, you have to think very carefully about what power you do want.

Michigan is going to shut down 6 gigawatts of coal power by 2033. Ladies and gentlemen, this State is going to start having blackouts. (143-19-1 [Connors, Shawn])

Comment: So, for these reasons, I advocate for nuclear energy. You're never going to make all these anti-nuclear people happy. They'll want more details. They'll want more time. They'll want another foot of cement. It's never going to end.

We're at the point we need energy now. It's a bipartisan issue. And the reason this plant is going to be reopened is because this is what the people want to happen. (143-19-4 [Connors, Shawn])

Comment: And for over a decade, MICEF has advocated for policies that will facilitate an advanced clean energy system that will provide grid, economic, and national security while reducing pollution as much as possible. We promote a diversified energy portfolio, of which nuclear energy can and should be an important part.

MICEF also played an important role in the formation last year of the bipartisan, bicameral Nuclear Legislative Caucus in the State Legislature, and we did advocate in Lansing for the

$300 million in State funds dedicated to bringing Palisades back online.

As proponents of electrifying vehicles and our buildings and foreseeing the evolving energy demands that are coming from data centers that utilize artificial intelligence technology, we know that demand for electricity is going to steadily increase over time.

Michigan needs more energy, and it should be from sources without carbon emissions to the greatest extent possible. We do have targets for clean energy production in our State laws and they will be impossible to meet without nuclear energy.

And with this hearing being focused on potential environmental impact, I would like to discuss what are the environmental benefits, the beneficial impacts of carbon-reduced energy generation that would come from Palisades.

Everything we can do to supply energy without direct carbon emissions to the atmosphere helps us combat the cumulative impact of greenhouse gas emissions. If we have Palisades' clean energy powering EVs, like the one that I drove here, it takes emissions out of both generation and transportation. That is a double environmental benefit.

And even more promising as an environmental benefit for this energy would be to couple the energy from Palisades with storage, so that its full capacity during low-demand periods could be leveraged during the peak demand periods. That is another double benefit. Shaving peak load and avoiding the deployment of fossil peaker plants will be a very valuable environmental win.

The importance of the cumulative benefits of every megawatt of carbon-reduced energy cannot be overstated. And MICEF is also a leading facilitator of siting large-scale wind and solar projects across this State. I have solar panels at my house. (143-24-1 [Rivet, Ed])

Comment: I'm here representing the South Haven City Council, which is voicing our support for the restart of Palisades. The City Council approved a resolution supporting the restart of Palisades, and I have confidence that the NRC, the DOE, and Holtec will do everything they need to, to ensure acceptable environmental impact associated with the restart. (143 1 [Sleeper, George])

Comment: Covert Township unanimously passed a resolution in support of the re-powering of Palisades. My family has been in Covert Township since 1924.

So, we have multiple generations of my family who has grown up with the nuclear power plant in our backyard. And I can tell you my personal experience has been nothing but positive.

So, I don't recall growing up with the fear of having this power generation in our community. I raised my kids here. We're 5 miles away from the nuclear power plant.

So that's my own personal experience. That does not negate anybody else's experience in the community. (143-31-1 [Cook, Daywi])

Comment: I can also tell you that I have been throughout the community, and the greater region, and run into multiple families who are so happy that they have family members, sons, daughters, fathers, who have reliable jobs and are hopeful for the future. (143-31-4 [Cook, Daywi])

Comment: I serve as the City Manager for the City of South Haven. The South Haven city council unanimously adopted a resolution of support for the reopening of the Palisades Nuclear Power Plant.

That resolution was adopted for a number of reasons. The council recognized the need for clean, base load energy generation, and noted the significant economic impacts the power plant has had in our community. (143-32-1 [Hosier, Kate])

Comment: And finally, as a fellow public employee, I know that there will be a committed, there will be committed public servants from the NRC and DOE going through a rigorous, practical process for the reopening of the plant in a safe and effective way.

Thank you for the NRC team and the DOE for being here and spending the appropriate time, energy and effort on this important project for our community. (143-32-3 [Hosier, Kate])

Comment: I grew up in Watervliet, and I also represent Electrical Workers Local 131.

Our members work in Palisades Nuclear Plant, and they go to work there every day expecting a safe working environment. And they get that safe working environment.

They know first-hand that nuclear power is highly regulated, and it's highly regulated for good reason, and they feel safe there. (143-33-1 [Currant, Jonathan])

Comment: I will say that if there is one thing that we know about nuclear power, it's that it has been safe throughout its existence in the United States There is a great deal that we expect in the nuclear industry, and we have always helped to maintain that.

And so, I really do think that this project going forward is going to be essential. It's going to be a bellwether for how we solve this climate crisis, how we solve green energy, and understanding that we are not going to be able to build battery plants.

We are not going to be able to build chip factories. We're not going to be able to have data centers and have these, and electric vehicles without reliable energy.

And, reliable energy is going to need a diverse set of power sources, and nuclear energy should be a key part of that.

And so going into the future, that's what we should aspire to. To aspire to do things and to do it the right way, through professionalism.

And I believe that all of you up there are going to do that. I have faith in you just like I have faith in our electricians, and the engineers that are going to design this plant.

We're going to do it right. We're going to look at all the facets. We're going to clean up all of the things that people are concerned about, and we're going to do it right. And, we're going to move forward. (143-33-5 [Currant, Jonathan])

Comment: We're the municipality just north of Covert.

Passed a resolution in support of the Palisades Plant opening. I won't bore you with the same details that all the other governmental leaders have already given you, but we're excited to hopefully have this plant open again for all the reasons that they stated.

We have confidence that Nuclear Regulatory will do their job and get the safe opening of the plant.

And thank you for being here, and I personally come from a fifth generation fruit farmer that lives in the area.

So, I've spent my whole life here. I've been here longer than the Palisades Plant, so I'm confident that you will do what's necessary and keep it going. (143-34-1 [Stein, Ross])

Comment: My name is Philip Holt, I work with Generation Atomic, we're a non-profit volunteer group that have a case for the use of nuclear power to address this century's challenges of climate change, and carbon emissions.

And, I just want to thank the NRC, the DOE, all the stakeholders that are here, and everyone who has shared their comments with the group, and for the consideration in this environmental assessment.

I call in both as part Gen A and also as a property owner in Michigan, whose family has enjoyed lakefront cabin summers there for many, many years.

So, I know there's been a lot of talk about the potential risks and theoretical cancers, and the possibility of accidents that may be associated with nuclear power.

What I do know, and where I encourage the NRC in its evaluation of its environmental assessment to consider, is the known facts.

And those known facts are that when the Palisades Nuclear Power Plant shut down, global carbon emissions increased in relation to the plant shutting down, as those sources were immediately replaced by carbon-based fuels.

And when the Palisades Plant comes back online, the global carbon emissions will go down proportionally.

I think it's important when we look at environmental assessments and environmental impact statements, it's all too common to look at the negatives and the challenges of what will this project do bad for the environment.

And, we have a situation here where almost unexpectedly, the reactivation of the Palisades Nuclear Power Plant can in fact, and will in fact, have a positive net benefit on the environment.

And, I strongly urge the NRC to consider that often neglected but in this case real possibility, that restarting the Palisades Nuclear Power Plant will in fact, be an increase and benefit to the environment. (143-39-1 [Holt, Philip])

C.2.2 General Comments in Opposition to the Licensing Action Comment: As a resident who lives within 17 miles of the site in question, I do not support the reopening. I am aware of the checkered past of this facility. I fear that this first of its kind attempt to reopen such an aging facility could go horribly wrong and impact the health and safety of my community. Please reconsider this plan and continue the decommissioning of Palisades. (3-1 [Pilarski, Diane])

Comment: Adams Farms is 7 miles as the crow flies. I am not opposed to nuclear power, but I am opposed to opening a plant this old. Build a new one (4-1 [Unknown, Unknown])

Comment: The Nuclear Regulatory Commission should REJECT HOLTEC International's permit application to "restart" the decommissioned Palisades Nuclear Plant in Covert MI. (5-1 [Muhich, Mark])

Comment: I urge NRC to require of the applicant, HOLTEC, the most rigorous assessment of the safety and functionality of Palisades NP, as if it were an entirely new applicant. And then the REJECT HOLTEC's application to operate Palisades NP (5-6 [Muhich, Mark])

Comment: I strongly Oppose nuclear power because the short-run and the long-run dangers are far too great. (6-1 [Hanson, Art])

Comment: It can be done, but is it a wise choice to use 1.5 billion (and likely more) taxpayer dollars? I believe that, in the long run, the environmental costs and risks will outweigh the benefits, whereas the same tax dollar investment in recyclable decentralized wind and solar energy generation would be a wiser and more sustainable choice. Palisades has already generated legacy waste responsibilities that are forced upon future generations. (7-1 [Brown, Robert])

Comment: As with many political expenditure projects in this country, the reopening of Palisades would be putting a short-sighted corporate control and profits of energy generation in the hands of few, rather than for the control by the multitude of citizens that that kind of investment could benefit. It would be a long-term poor investment decision, regardless of the legacy waste generation and potential catastrophic environmental radiation hazards that are unique to nuclear power. Corporations excel at making well-meaning promises for the upfront public money to go into their pockets, and I see this as another unwise, long term, public investment. (7-4 [Brown, Robert])

Comment: Under no circumstances should any nuclear reactor be authorized to operate beyond the safety parameters for longevity. Doing so puts the American public at risk as a nuclear accident becomes increasingly likely. Continuing to run the Palisades reactor is egregiously irresponsible as that puts all property in the area, as well as a major source of fresh water, at risk for permanent contamination.

I find myself wondering if greed is such a powerful motivator that it makes people unable to learn from Three Mile Island, Chernobyl, or Fukishima.

There is no such thing as a safe nuclear facility. Not anywhere or at any time. There is no known method for safely dealing with the waste. So why are we still operating the dirtiest, most dangerous, most permanently toxic power source ever invented? (9-1 [Cunningham, James])

Comment: Due to safety and environmental concerns, I oppose the restart of the Palisades Nuclear power plant. The idea of restarting a 50-year-old nuclear power plant that has been sitting idle, with a long history of serious problems is very disconcerting. Our family home of over 75 years is less than one mile south of the plant in a community established in 1905. Any attempt to restart the plant in any respect will be an experiment with tremendous risk to our health and property. We have a unique and rare natural environment on the shores of one of the most important bodies of fresh water in the world. The best decision for current and future generations is to dismantle the plant and restore property to its natural state as was the plan when Holtec took control in 2022. (12-1 [Brand, Charles])

Comment: I am opposed to the Palisades reactor restarton behalf my friends and relatives living in the area! (15-1 [Sheridan, Paul])

Comment: The Palisades atomic reactor should remain closed for good. (19-1 [Robertson, Ed])

Comment: Restarts are simply a mistake. What we need is phase outs. (20-1 [Gordon, John])

Comment: I strongly oppose restarting this nuclear power plant. It amazes and puzzles me that nuclear power is referred to as green energy or clean energy.

From my perspective, nuclear power plants are an ominous threat to the health and wellbeing of myself and my family--I'm looking forward to having grandchildren come along in the next few years and want them to grow up without having to be dosed against radiation poisoning.

It is bad enough that the casks of nuclear waste from the operation of the Palisades plant are sitting very close to me and close to the shores of Lake Michigan. I have opposed this storage method from its inception in 1993.

My drinking water comes from aquifers, but many Michigan residents rely on Lake Michigan for drinking water. Those casks pose a threat to the lake's quality--which affects aquatic life, the fishing industry, tourism and the health of residents on or near the lake.

So, the waste from Palisades' operation is already a threat. We do not need or want more waste to be generated.

Nuclear energy is incredibly expensive, as well as dangerous. Please do not spend my tax dollars to restart an ancient nuclear plant to be run by an inexperienced company (Holtec) to produce energy that we can better produce by genuinely green methods such as wind and solar. Michigan is making great strides with genuinely green energy.

Restarting Palisades would be a huge, negative, dangerous step backwards.

Please know that one nearby resident in Michigan OPPOSES the restart of the Palisades nuclear power plant. (21-1 [Hartsough, Denise])

Comment: I am opposed to the restart of the Palisades Nuclear Power Plant.

I have lived in Michigan my whole life. I am 72 years old; a Medical Professional and I remember all the drama surrounding the age and faults in the reaction chamber. The extreme expense to repair or replace the reaction chamber and the discussion around the catastrophic disaster should the reactor fail.

Not only the local communities will be affected, the Downwind communities will be affected (that is NEVER talked about) but the contamination of Lake Michigan.

I am not against Nuclear Power as an option to provide electricity to Michigan, although, I do not consider Nuclear Power as Clean Energy nor Renewable Energy.

I am against the attempt to restart this Plant. Only positive information is being made available to the public.

No information on the possibility of catastrophic failure is being made available to the public.

The storage of Nuclear Waste on the Lake Michigan shoreline is ridiculous for many obvious reasons.

I understand that many people will be reemployed, and that the community will benefit from the revenue this Project will bring, but at what cost?

I do not Trust that "Big Business" will divulge all the potential risks of this endeavor.

There are many other Renewal Energy Options available to the Citizens of Michigan than an attempt to restart a 60+ year old Nuclear Power Plant. (24-1 [Reid-LeZotte, Nora])

Comment: In 1973, I was truly hoping that the Three Mile Island meltdown would be the end of Nuclear Power. At that time, the power being generated by nuclear was way more expensive than generating by other means (remember the promise of "electrical power too cheap to meter"), we still didn't know where the radioactive waste was going to be stored, and at the age of 15, I was hand cutting a wind generator blade from a piece of wood, knowing I could power two lights and a 12 volt car radio (FM no less!) in my father's garage, where I was learning to work on cars.

In 1989, I was truly hoping that the Chernobyl Nuclear Power Plant meltdown would be the end of Nuclear Power. People in Germany were using Giger-counters to check for radiation before picking plants out of gardens. Home-sized wind generators were now available for some of us on the very outer fringes (if you had the room and the local zoning ordinances would allow for such things), and solar panels were down to $8 a watt.

In 2017 I was truly hoping that the Fukushima Nuclear Power accident would be the end of Nuclear Power. Solar panels are now down to $0.60 a watt, and wind farms are producing 6%

of the nation's energy. Commercial wind turbines are up and running in the US at the Block Island offshore wind farm supplying power to Rhode Island (but way behind power generation of offshore wind farms in the EU).

In 2022, I was truly hoping that the Palisades Nuclear Power plant shutdown would be the end of Nuclear Power on the west side of the state of Michigan. By now, I'm driving an electric car and an electric motorcycle. US wind capacity is at roughly 122 gigawatts, and US solar capacity is at 23.6 gigawatts. After starting up in 1973, Palisades had one of the worst safety records (remember the 5 unplanned shutdowns in 2011, then 3 more shutdowns for water leaks after that) before turning itself around and doing fairly well for the remainder of its career. By this time, 24 percent of the US electrical energy production in 2022 is from renewable sources.

So now, it's 2024. The power being generated by nuclear is still way more expensive than generating by other means, and we still don't have a permanent place to store the nuclear waste. 42 gigawatts of renewable electrical energy generation is added in the US, 7.2 gigawatts of electrical battery storage is here in the US and operational. Wind and solar energy in the US exceed 20% of the nation's electrical power, approaching 30% if you include all forms of renewable energy. California has had days of producing more than 100% of its power with renewable sources this year. 6 GW of battery storage has been added to just California.

And here in Michigan, Holtec wants to restart a 50-year-old nuclear reactor, with a reactor vessel embrittlement issue that was reported back as far as 2014, using 50-year-old nuclear technology (pressurized water reactor) similar to what was used at Three Mile Island. This is Holtec, who never ran a nuclear plant and was just sited by the NRC for using language in their severance agreements to Indian Point employees to discourage them from testifying as a witness in a proceeding that could damage Holtec.

Restarting the Palisades Nuclear Plant is a really bad idea. I know Holtec is trying their best with their PR about bringing back former employees and what a happy family they were but that doesn't make this project any safer does it? And now they want to build two SMR-300 units on the site, except that those units don't exist yet, and they're talking about maybe operational by mid-2030. By the time that's running, battery storage and solar could easily replace the.8 gigawatts that the plant used to make.

Restart Palisades? Don't...just don't. Use Palisades for a battery energy storage site and use the existing grid wiring? Absolutely. (25-1 [Richards, Terry])

Comment: Michigan is taking a huge risk to our Great Lakes, experimenting with a never-attempted-before restart of a 1960s-era nuke plant. Holtec corp has never operated a nuke plant before, and they want to transfer ownership to a new *limited liability corporation*. Even they don't seem confident.

Don't experiment on our Great Lakes. Don't restart Palisades. Failure is literally forever. (27-1 [Sawasky, Joseph])

Comment: There is a reason for the decommission of the Palisades Nuclear power plant. There is strict governmental guidelines, protocol and checks and balances to protect communities and our environment. (28-1 [Hickmott, Carl])

Comment: No please. (30-1 [Unknown, Gregg])

Comment: People in the area are scared to death. Its an ugly death to die by slow or fast exposure to a nuclear problem. People living in sight of the plant are visually distressingly concerned about bodily harm. You never get ok with that. They cant move because that danger is to everyone living on the great lakes and nobody, and I mean NOBODY wants to be living in the shadow of that plant. Property values take a huge hit and fear grows. It shouldnt frighten the wits out of people to have electricity. Stop the lying, absconding with funds and general mayhem of this dog and pony show. Many better answers exist, long term, safer, greater employment with less or at least same expenses with more benefits. We are in an area suitable for geotherm power plants and its time we did get on to a future plan for energy supplies that dont carry the harms you want us to be satisfied paying billions, even trillions for. We neither desire it nor find it acceptable. (33-9 [Birdsall, Sheila])

Comment: I urge you to deny any new approvals or permits for these nuclear facilities. The taxpayer dollars that would be spent on these dangerous and unnecessary projects will deliver far better and more effective results if dedicated to supporting distributed solar and wind generation and increasing the capacity of the area power grid as needed. (36-2 [Bosold, Patrick])

Comment: No one should contemplate restarting this old reactor. It is a prescription for radiation releases above the usual on a daily basis and have the potential for a disaster. It should not be risked, and our precious Lake should not have more radiation poured into it as the old and brittle core will need extraordinary cooling to stay intact.

This is a very risky and bad idea. (38-1 [Cullen, Noreen])

Comment: Without merit! Complete recklessness, utter insanity -it is simply unfathomable that the NRC is entertaining the concept of reopening Palisades. Political pressures aside, this concept is not sustainable and if examined in the slightest it falls flat. No good can come out of the unsafe and outmoded plant. (41-1 [Connor, Bill])

Comment: There are sustainable natural forces available that will not poison our planet. USE them. (43-1 [Loar, Steve])

Comment: Do Not re-open Palisades-we do not need their energy and their impact on the environment is awful! (44-1 [Jones, Virginia])

Comment: We must protect our precious environment and lake!!! It is foolhardy to restart a nuclear facility that was shut down because it was the worst in the country. We cannot trash our beautiful environmental assets. (45-1 [Boris, Donna])

Comment: Before we venture further down this path, I urge you to reconsider the restart of Palisades Nuclear Plant. Let us not perpetuate a cycle of risk and financial strain. Instead, let us decommission the plant properly and responsibly, and embrace a future powered by true and affordable renewable energy. Our community, our economy, and our planet deserve nothing less.

Thank you for your attention to this critical matter. I look forward to your commitment to a safer, cleaner, and more sustainable energy future for all of us. (46-4 [Schalk, Tracy])

Comment: I don't feel safe with nuclear power and a disaster would greatly hurt the Great Lakes. (47-1 [Balasko, Deborah])

Comment: Restarting a nuclear power plant should not be an option. (48-1 [Munski, Donald])

Comment: Stop the nonsense and build clean electric production with solar and wind. (48-4 [Munski, Donald])

Comment: Do not open the plant, do not ignore the potential of terrorism, do not forget that this is a terrible mistake and waste of money. (51-2 [Dermody, Laurie])

Comment: This plant is not safe, and there is no reason to believe it will be safe, especially without conducting an EIS. If this plant were to open and have an accident, heaven forbid the destruction it could cause.

It is nothing short of reckless to re-open a plant with such glaring and avoidable dangers for the community and for Lake Michigan - which is the source of water for millions of people and wildlife. Please do the right thing for the people, the environment, and the future, and conduct an EIS. (54-4 [Williams, Bonnie])

Comment: I am writing as the owner of one of the closest residences to the plant, 1.2 miles away to the North. Like respondents from Palisades Park, we also draw our drinking water from a well. From the information that has been released publicly, I oppose the reopening of the plant based on risks and benefits of an "experiment" with an already-decommissioned 53-year old plant. The incremental gain to the grid does not justify the safety and health risks of restarting such aged infrastructure with an inexperienced operator and a plant-lifetime of operational, safety, and environmental problems. The troubled history of the plant as well as the inexperience and performance problems of the proposed operator should warrant extra caution and due-diligence by the NRC. While I realize the huge financial and political momentum to get this plant (and additional small reactors) done as soon as possible, my understanding of the NRC's mission and this process is to protect local residents such as ourselves. (55-2 [Lawlor, Edward])

Comment: Ok, I was at the July 11th environmental meeting in Michigan, I don't do public comments very well, but I did protest the restart of Palisades nuclear power plant.

A while back a very wise man named Arney Gundersen said that nuclear power for electricity is a result of bipartisan stupidity.

Everybody representing the government already had made up their minds that they were going to restart the Palisades nuclear power plant.

You guys know how dangerous this plant is and yet you are moving ahead for political reasons.

I don't believe that you are representing the American people that you are a captured agency and that you have sold us out by deciding to reopen this time bomb.

Yes, it's possible that somehow, we don't have a meltdown between now and 2051 when you are going to be done with this relicensing, But the fact that you will take a chance with the water table and the lake Michigan watershed is astounding to me.

There are other ways to make electricity. There are other technologies that are not dangerous that will eventually be carbon-free and it's just around the corner.

Every time we run a nuclear power plant we are creating more fuel that has to be stored we only skim a little bit off the top and then put it off into dry cast storage, And we are condemning the unborn to spend billions of dollars to somehow repackage it for the rest of human history, I think that leaving what will end up being over a 100000 tons of nuclear waste for future generations is a much bigger threat than the so-called climate change.

My concern is if you're willing to open a zombie nuclear power plant that most likely will blow up before you're done that you will also keep open other nuclear power plants that should be shut down.

You people have sold out for political reasons, and you are crazy.

You have already made up your mind and I believe with the restart of Palisades nuclear power plant that you will have blood on your hands. This shift in policy away from safety and for political benefit will cost the country its greatest natural resource which is the fresh waters of the Great Lakes. (56-1 [Brenneman, John])

Comment: I write because of the substantial and deeply disturbing risks and negative environmental impacts inherent in this proposal. Among them are: (59-1 [Anonymous, Anonymous])

Comment: The Holtec recommissioning business has spawned interest in bringing to life old, dead, reactors. One of them is at Three Mile Island. Constellation Energy, subsumed by Exelon Generation and spun off in charge of its nuclear power operations, has jumped on the bandwagon for federal funds to look at "recommissioning" the decommissioning Three Mile Island Unit 1 nuclear power station in Middletown, PA. TMI, along with the radioactive wreck of Unit 2, was certified to the Nuclear Regulatory Commission as permanently closed, defueled and slated for decontamination, dismantlement and radioactive site cleanup. There are 14 "permanently" closed US reactors awaiting decommissioning. These are old reactors, embrittled by radiation. Extending their operations another 20 or so years is a very bad idea. Another old "zombie" reactor is at Diablo Canyon. The Biden administration said it has approved conditional funding of up to $1.1 billion to prevent the closure of the Diablo Canyon nuclear power plant in California, as part of its effort to fight climate change. (60-1 [Ratcliff, Philip])

Comment: Holtec's attempt to restart the closed Palisades atomic reactor is unprecedented, misguided and extremely high risk for the health and safety of the citizens of the area as well as all communities that fish, swim or receive their drinking water source from Lake Michigan. (61-1 [O'Byrne, Paul])

Comment: How can any U S Government agency completely disregard the safety of life &

continuing good health of its citizens in the plant's surrounding communities? (66-4 [Reed, Dillon])

Comment: Faith that the NRC is protecting our environment and health has eroded dramatically.

This is clear. If we had faith that the NRC was giving top priority to the people and not breaking its back to help the energy companies, life would sure be a lot less stressful.

But that is not the case.

When you are taking on reviving a 53-year-old plant, that was clearly a problematic plant, the NRC should be extremely rigorous and demanding that this be perfect. You are setting a stage that is quite dangerous.

But instead, its exception after exception.

When Holtec asked you for a blanket exception, they were making fun of you!

They know they can get away with anything. Your organization has very little credibility.

If you can actually muster up a tiny bit of care for the people who rely on Lake Michigan for water, or for the dunes that are holding all this nuclear waste, with plans to increase that waste many times, you would start building back some of. that faith. The GAO report on nuclear industry preparedness for climate change should give you pause. But instead....no reaction......ignore everything.

I always say, nuclear power never completed the circle. No place to put the waste, but they just moved on creating more and more of it. Complete the Circle before you move on!!!!

I keep thinking that just one person will speak up. One person will care. (67-1 [Flynn, Jody])

Comment: What are you thinking? We know the area. It's a mess to begin with. And lots of homes. Stop this sort of thinking. We move forward. We won't go back! (69-1 [Miller, Sherry]

[Miller, Tom])

Comment: As a longtime resident near the Palisades plant I was relieved when it was shut down. The issues with the safe operation of the plant made us concerned about our health and safety. (72-1 [Hoskin, John])

Comment: We hope you will decide not to allow the restart and relieve all of us of this worry. (72-4 [Hoskin, John])

Comment: We are against Holtec's request for License Exemption for Palisades Nuclear Plant. (74-1 [O'Brien, Kevin])

Comment: The Palisades zombie reactor restart is unprecedented, entirely unneeded, extremely high-risk, insanely expensive for taxpayers and ratepayers (https://beyondnuclear.org/breakdown-of-bailouts-at-holtecs-palisades/) (76 2 [Kamps, Kevin])

Comment: We submit that the events which have already transpired in the first decades of our current century illustrates why low-probability, high consequence events must be taken into consideration in assessments, especially where the high consequence may be truly catastrophic. In the case of nuclear, to an unparalleled degree, cumulative effects, safety risks, and security risks are inextricably connected to environmental impacts.

The very conditions of climate change are risk multipliers for reactor operation and nuclear waste management and sequestration.

Palisades was designed for a world which no longer exists. (77-1-10 [Lee, Michel])

Comment: If the state of Michigan is serious about using Nuclear Power should we not be looking at building a state of the art plant as opposed to trying to restart one of the oldest nuclear power plants in the country? The problems of restarting an antiquated system simply do not add up to success. (78-1 [Sears, Kathy])

Comment: I am devastated at the thought of this extremely unsafe nuclear power plant to be reinstated. There a so many reasons why it concerns me - listed below are just a few:

Palisades since its opening in 1971 has been plagued with serious problems and violations. In fact, in 2012 it was classified as the worst performing reactor in the nation. After 50 years it finally was shuttered in May of 2022, a week and a half earlier than planned due to control rod failure which is essential for safe operation Even you, the Nuclear Regulatory Commission had declared Palisades one of the four worst-performing plants in the country.

Propping up a damaged nuclear power plant that has leaked in the past and has already been shut down is a foolish way to use state funds - when private companies decided this facility should be shut down and proceeded with doing that, spending taxpayer dollars to resuscitate an outdated and dangerous nuclear power plant is fiscally irresponsible. (79-1 [Forsee, Jenny])

Comment: The State of Michigan, the US Department of Energy and the Biden administration are poised to provide $1.5 billion in funding to reopen the outdated and unsafe Palisades Nuclear Power Plant in Covert, MI.

As a reminder, this is what we know about the Palisades Plant.

• The plant was built in 1967, over 50 years ago, and began producing power in 1971 under a 40-year license set to expire in 2011.

• The plant experienced problems just over a year after opening in 1971, including radioactive leaks. Safety problems have continued over the life of the plant causing the plant to be shutdown many times.

• The Palisades plant, complete with its very poor safety and operating record, is on Lake Michigan, one of the largest fresh water sources in the world.

• After being operated by Entergy since 2007, Entergy decided in 2018 to close the plant. After lengthy delays, the plant was closed in 2022.

• Shortly after being closed, the plant was sold to Holtec International, a company that would decommission and dismantle the plant. Holtec has never operated a nuclear plant.

• In September of 2022, Holtec, under the encouragement of State and Federal agencies, applied for funds to reopen the plant. The State of Michigan brokered a deal to have the Wolverine Power Cooperative reach a power agreement with Holtec once the plant is reopened.

• Recent community studies suggest above average health problems for longtime residents of our adjacent community, including high incidences of thyroid and other cancers.

Lets summarize.

Under the guise of saving jobs and a federal green energy play, billions of taxpayer dollars are going to Holtec, a company with no experience operating a nuclear plant, to reopen an aged plant with one of the worst safety records in the world. Its kind of like selling your 40-year-old car to a local junk/parts dealer and then giving that dealer lots of money to open a car manufacturing plant. I doubt those cars would be very safe. (80-1 [Scott, Robert James])

Comment: We can do better. Oppose the reopening of Palisades. (80-3 [Scott, Robert James])

Comment: I stand opposed to the reopening of the Palisades Nuclear Plant. It poses many threats to people and the environment. These threats include health risks and environmental damage from uranium mining, as well as transport. I stand staunchly opposed to the discharge of hot water being released by this nuclear plant into our beautiful Lake Michigan where I spent every summer as a child. This has a negative impact on the ecosystem! This Nuclear Plant must not be allowed to re-open! (82-1 [Dinnin, Susan])

Comment: Its hard to understand why reopening the Palisades nuclear plant is even on the table. When it was in operation it was classified as one of the worst performing reactors in the nation. Bringing a nuclear power plant back online has NEVER been done before and yet the plan is to allow a company with a bad track record to attempt this. We need to invest in clean and alternative energy. Keep the Palisades nuclear plant closed. Lets ensure the shores of Lake Michigan and the surrounding dunes remain clean and pristine for many generations to come. (83-1 [OConnor, Patricia])

Comment: I am vehemently opposed to the reopening of the Nuclear Power Plant in Coert, Michigan. I have known too many people who live in close distance to have died of cancer....and many doctors have attributed that to the plant polluting the air and water.

It would be an irresponsible move to reopen. (84-1 [Pierce, Kathleen])

Comment: I am really surprised that this plant would be allowed to re0open and again produce nuclear power, when this particular plant has one of the worst track records of all nuclear plants in the US. (86-1 [O'Connor, Gerry])

Comment: I'm concerned about the re-opening of the nuclear plant -- doing so would have a tremendously negative effect on the nearby park, its residents and the animals that call the area home.

When it was open, this plant was one of the worst performing in the country.

The plant has leaked in the past, and reopening a plant that has already been shut down is a foolish way to use state funds.

Nuclear energy is risky, dirty, dangerous, slow, and expensive.

I urge you to not move forward with allowing this plant to reopen. (88-1 [Gillespie, Emily])

Comment: Im writing to you in opposition to the reopening of the Palisades Nuclear Power Plant for the following reasons. (93-1 [Ebert, Robert])

Comment: Due to safety and environmental concerns, I oppose the restart of the Palisades Nuclear power plant. The idea of restarting a 50-year-old nuclear power plant that has been sitting idle, with a long history of serious problems is very disconcerting.

Our family home of over 50 years is less than one mile south of the plant in a community that was established in 1905. Any attempt to restart the plant in any respect will be an experiment with tremendous risk to our health and property. This first of its kind restart on such an aged and neglected facility should not be permitted due to the very high risk it presents to the community and the entirety of Lake Michigan itself and her residents.

We have a unique and rare natural environment on the shores of one of the most important bodies of fresh water in the world. The best decision for current and future generations is to dismantle the plant and restore the property to its natural state as was the plan when Holtec took control in 2022. (94-1 [Kelly, Katie])

Comment: As per the US GAO report on Nuclear Waste Disposal, we struggle to dispose of the huge volumes of low-level radioactive waste and have yet to achieve authorization for long-term safe storage of high-level radioactive waste. Nuclear power plants have been generating these wastes for decades. Reviving the Palisades Nuclear Plant is not a reliable energy source for reducing carbon emissions. This money would be better spent on other sources such as wind and solar, that have fewer risks while still producing electricity in a way that can help reduce global warming. (95-1 [Freeman, James])

Comment: As a member of Palisades Park Country Club, just south of the power plant, I feel you are acting very Unresponsively by reopening the power plant. As one of the oldest power plants in the country there is no way to evaluate how well it will hold up. You are putting both the citizens and environment in the area at risk. I urge you to keep Palisades Park Nuclear plant shut down for good. (97-1 [Cornelius, Ellen Flynn])

Comment: Nuclear energy can be great if you start with the latest technology and EQUIPMENT!

With the Huge amount of money that the state is getting in both federal and state funding I would hope to see a new plant built.

Putting Lake Michigan and the surrounding populations in jeopardy seems risky.

If Governor Whittmer needs to show how GREEN and progressive she is, build a new plant in Glen or somewhere. Dont experiment on us by being the FIRST to restart an antiquated plant! (101-1 [Thompson, Kathryn])

Comment: While I, like most residents, would have rather the Power Plant stayed closed, I realize that ship has sailed. (105-1 [Hohman, Kevin])

Comment: I am writing to express my opposition to the proposed restart of the Palisades Nuclear Power Plant. The plants history of significant issues and safety violations is deeply concerning. Since its opening in 1971, Palisades has faced numerous problems, culminating in its classification as the worst-performing reactor in the nation in 2012. The plant was permanently shut down in May 2022, earlier than planned, due to a critical control rod failure.

The NRC itself has previously identified Palisades as one of the four worst-performing plants in the country. Given this track record, it is alarming to consider using state funds to revive a facility that has already been deemed unsafe and outdated by private companies. (108-1 [Quinn, Francis])

Comment: I urge the NRC to reconsider the decision to restart the Palisades Nuclear Power Plant and instead support a transition to cleaner, safer, and more sustainable energy sources. (108-7 [Quinn, Francis])

Comment: PLEASE DO NOT CONSIDER REOPENING PALISADES!

-Palisades since its opening in 1971 has been plagued with serious problems and violations. In fact, in 2012 it was classified as the worst performing reactor in the nation.

After 50 years it finally was shuttered in May of 2022, a week and a half earlier than planned due to control rod failure which is essential for safe operation.

-Even you, the Nuclear Regulatory Commission had declared Palisades one of the four worst-performing plants in the country. (109-1 [Ferry, Carolyn])

Comment: Propping up a damaged nuclear power plant that has leaked in the past and has already been shut down is a foolish way to use state funds - when private companies decided this facility should be shut down and proceeded with doing that, spending taxpayer dollars to resuscitate an outdated and dangerous nuclear power plant is fiscally irresponsible (109-2 [Ferry, Carolyn])

Comment: And now the NRC has a decision to make. Either bend established NRC safety requirements and allow for the first time ever a nuclear power plant to be reopened after being closed for 3 years. Or do the right thing and close the plant as was the plan when sold to Holtec three years ago. (110-5 [Scott, Ann])

Comment: In conclusion, if Palisades were allowed to start back up, our beautiful state of Michigan would be LESS SAFE, with the risk of a fall-out plume that would travel 150 miles across the state. Holtec is asking for hundreds of millions of dollars from the state of Michigan for this endeavor that would put us all at SERIOUS RISK.

Please do not allow this to happen. Please do your research, and you will come to the same conclusion as Arnie Gundersen: this would be a disaster in the making. (111-4 [Huffman, Mary])

Comment: Secretary Granholm, said, "this loan was given with a focus on safety, professionalism and community support." Palisades communities do not feel safe, safety assurances have NOT been communicated to residents. Holtec and the NRC have avoided attempts at transparency. The only community support comes from a few shop owners and previous power plant staff. Talk to the people that live near the plant, the people of Palisades Park, Linden Hills, Blue Star, Red Arrow and Coloma residents. They are the ones who drink the water and breathe the air. They and many thousands more are the ones who need an emergency plan in the event the plant reopens.

(112-11 [Anonymous, Anonymous])

Comment: I wish to register opposition to the commissioning of the Palisades nuclear reactor.

Not only has a closed plant been reactivated, Palisades has a troubled history having had near misses and poor ratings in the past. (113-1 [Somes, Claudia])

Comment: Decommission process has to be expeditiously and safely completed, resulting in permanently removing any traces of nuclear material from the shores of Lake Michigan, the source of drinking water for 40 million people. (114-2 [Anonymous, Anonymous])

Comment: I am a longtime board member of a nuclear watchdog group descended from the Clamshell Alliance that tried unsuccessfully to stop the Seabrook reactor in New Hampshire.

Our name is Seacoast Antipollution League and our goal, having failed to stop the premature relicensing of our aging nuclear plant, is to persuade the State of NH to replace nuclear with renewables, especially offshore wind power. We heartily oppose the efforts of Holtec International to "re-nuclearize" or rehabilitate the decommissioned plant at Palisades on Lake Michigan. This approval has already generated copycat efforts from other decommissioned nuclear sites! This is a scam. Just read this indictment of a Holtec board member in NJ (https://beyondnuclear.org/long-serving-holtec-board-member-indicted-on-racketeering-in-new-jersey/) or the $5 million fine against Holtec in January 2024:

https://www.njspotlightnews.org/2024/0)1/holtec-camden-will-pay-5-million-fine-false-documents-nj-tax-breaks-controversial-nuclear-projects/.

What were the problems of the Palisades reactor. "As a result of erosion near the plant, structures have fallen into Lake Michigan. In addition, with no permanent disposal site for Palisades' nuclear waste, the plant's radioactive waste is stored in concrete casks near Lake Michigan. May 17, 2024." Pressurizer problems showed up in the control panels. Metal components had become brittle. These documented reasons, along with financial problems, led to its decommissioning in 2022. Recommissioning a structure what dates back to 1967 is absurd. We live in a new era of wind and solar which do not have the harmful effects of storing radioactive waste forever, and the susceptibility to climate change effects. Nuclear power is NOT green and NOT efficient; it depends on government handouts. We in NH are still pay ingrates reflecting the problems of nuclear power. It is time to transition out of nuclear. (115-1 [Woodward, William])

Comment: I am a resident near the Palisades Nuclear Power Plant, and voicing concern over the rushed decision to re-open this plant. It was decommissioned several years ago. Because of this, any maintenance was neglected. This power plant had constant problems when it was open, so we all know repairs are needed. We were all glad to see it shut down. It doesn't belong here. IT IS ADJACENT TO A STATE PARK, FEEDS INTO ONE OF MICHIGAN'S GREATEST RESOURCES (LAKE MICHIGAN), AND IS SURROUNDED BY MANY HISTORICAL HOMES THAT ARE EITHER ON THE HISTORICAL REGISTRY OR IN THE PROCESS OF BEING APPROVED. These are all reasons for denial, or at the very least an investigation (EIS). (116-1 [Metz, Ei])

Comment: On January 27, 2021, President Biden issued Executive Order 14008 titled Tackling the Climate Crisis at Home and Abroad. The White House Environmental Justice Advisory Council (WHEJAC) was established to advise and to increase the Federal Government's efforts to address environmental injustice. WHEJAC's efforts will include a broad range of strategic, scientific, technological, regulatory, community engagement, and economic issues related to environmental justice.

On May 13, 2021, WHEJAC listed Examples of the types of projects that would not benefit a community.

Number 4 and 5 were:

-THE PROCUREMENT OF NUCLEAR POWER

-AND ITS RESEARCH AND DEVELOPMENT.

WHEJAC recommended in September of 2023 that the federal Government stop supporting nuclear power through loan guarantees and other financial incentives and create plans to decommission all nuclear power plants at the end of their current license terms.

And in order to better understand that nuclear is not carbon free energy, WHEJAC recommends that a thirty-five-thousand-year life-cycle carbon assessment be completed for all nuclear power plants including micronuclear. The study will aim to evaluate their true carbon emissions resulting from

- the building and maintenance of the plants

- mining of uranium

- long term storage and management of spent nuclear fuel.

The Inflation Reduction Act (IRA) designated 6 billion in subsidies and 3.5 billion for research/development for Nuclear Energy. The Build Back Better (BBB) was in for 35 billion in subsidies. Seems there is no shortage of snake oil in America. The Nuclear Industry has bamboozled the government to decree that nuclear is the elixir of life. (117-1 [Bilenko, Stephanie])

Comment: Please disband the powerplant. This is unsafe for our community Palisades Park and those surrounding.

Our babies play in this water (122-1 [Cole, Margaret])

Comment: 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. (123-1 [Bogen, Doug])

Comment: Although we support job creation, we're opposed to restarting the decommissioned Palisades Nuclear Plant, and vehemently oppose the exemption requests made by Holtec. (124-1 [OBrien, Terry])

Comment: There is no room for error, and for Holtec, a company with no experience operating a nuclear power plant, to request exceptions for bringing a shuttered plant with a history of safety and maintenance violations is counterintuitive. (124-4 [OBrien, Terry])

Comment: Please invest the available funds in another project that has both promise and the support of the community. Restarting the Palisades Plant is not that project. Please continue the decommissioning and disassembly of this 50+ year old plant that began several years ago after much study, deliberation, and community input. (124-5 [OBrien, Terry])

Comment: I am a property owner in Palisades Park Covert Township, Van Buren County, Michigan. We have owned our property since 1967, which sits lakefront less than a half mile from the decommissioned nuclear power plant that Holtec is petitioning to restart at the same site. We have lived there for several months a year since the plant was originally built in 1971 and are very concerned about the state of this facility and exposure to the environment and our health. My family and I vigorously oppose the proposed plan that Holtec has submitted. We agree with the facts as stated below which support a reassessment by the NCR. (126-1 [Flynn, John])

Comment: I'm fully against reopening the power plant for so many reasons, especially those listed below. (127-1 [Rogers, Julie])

Comment: If you choose to go ahead with this plan, you certainly will be on the wrong side of history -- and the greed and power play that is leading the charge here will be shamed for decades to come. Don't allow this. Why? (128-1 [Flynn, Lawrence])

Comment: I am opposed to the reopening of the Palisades Nuclear Power Plant due to the inherent risks associated with nuclear energy to the neighboring community. (130-1 [Relias, George])

Comment: Don't experiment on our Great Lakes. Don't restart Palisades. Failure is literally forever. (132-1 [Francis, Darin])

Comment: 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. (134-3 [Lombardi, Joan])

Comment: It is unsafe & irresponsible. (136-1 [Babin, Barbara])

Comment: My parents bought a cottage in Palisades Park back in 1978 so that our family could gather together and create memories. Our family is 192 strong. I tell you this because it matters.

There are 192 people behind this email asking you to NOT let Holtec reopen the Palisade's Nuclear Power Plant.

My mom is 94 and is so excited to go up to Palisades in August. Our family has spent the last 46 summers gathering together from several different states and the most popular weeks are the weeks when "everyone" is there. We could choose weeks where there are less people, but we CHOOSE to be together to create lasting memories.

Palisades is a very special place to us. I live in NC, and it is still my daughter's (22 years old) favorite place in the world. We drive 13-14 hours to get there. The beaches in NC are beautiful and wide and close! Yet we choose to go to Michigan, to Palisades, to create memories and continue the family bonds that my mom and dad started years ago.

Please understand that we've lived with the power plant for many summers, as it was active during several of our summers there.

However, being an active, highly regulated power plant that undergoes rigorous tests and standards is very different than what Holtec is trying to do now. (137-1 [Rogers, Rosie])

Comment: We believe Holtec is taking advantage of the Energy Infrastructure reinvestment under Title 17 Clean Energy Financing Section 1706. This would be the 1st time in American history to restart a nuclear power plant. We have tremendous concerns about this, being adjacent landowners. We are against restarting the Palisades Nuclear Power Plant located in Covert, Michigan by Holtec Palisades/ Holtec International. (140-3 [O'Brien, Kevin])

Comment: I'm speaking today on behalf of the residents of Palisades Park in Covert, Michigan, some of whom you've heard from already.

Governor Whitmer supported continuing operations at Palisades. Yet, Entergy shut down the plant, surrendered its operating license, and sold the plant as junk suitable only for decommissioning. These actions should not be easily reversible. (143-14-1 [Blind, Alan])

Comment: And also, people talking about nuclear energy as if it's clean and green, give me a break. They mine that stuff. They use fossil fuels to mine it. It's a hot process. People die. And they transport it. That's fossil fuels. They refine it. That's fossil fuels.

All along the whole cycle of nuclear power is death. The ultimate end is nuclear war, when you get the plutonium which is too hot to handle.

They don't know how to safely store nuclear waste. It shouldn't be transported. They have problems with the casks. They've had explosions. They have contaminations. They have stillbirths. Child mortality rates go up when those things operate and cancer rates. They're not safe. (143-16-4 [Barnes, Kathryn])

Comment: Nuclear is hot. When you make a nuclear reactor, it heats up so much, they have to dump it down in the water to make steam, back and forth. It's hot. If you've ever seen radioactive waste, it has heat rising up out of it. The whole thing is hot.

Native Americans say, "Leave it in the ground," and I think that's what you should do. Leave the radioactivity in the ground and the uranium rocks and do something better. That's the worst thing you can do for everybody. (143-16-7 [Barnes, Kathryn])

Comment: I and others are very upset, furious, to know that Holtec's intention is to buy every site they can, restart if they can; if not, repopulate sites with SMRs -- all done with ratepayer and taxpayer money, and the taxpayer gifted to Holtec -- (143-29-4 [Drechsler, Jacqueline])

Comment: Bruce Davis said, "We have to do this right." Well, I say, why do it at all? Shut it down. (143-29-6 [Drechsler, Jacqueline])

Comment: The last meeting I was at, it seemed like the NRC had already made the decision. It seemed like they're going to start the Palisades Nuclear Power Plant.

And this meeting is just seems like you're checking a box, one last thing before we start it.

And, I would like to protest. I think you people know everything I know about the degraded reactor vessel.

You know everything I know about the lid and the pumps, and all that. And it feels to me like money and politics is making this decision, and I protest. (143-36-1 [Brennaman, John])

Comment: Our leaders must ensure that any and all steps be taken to prevent cancer. Closing Palisades was one such action that would result in fewer people suffering from cancer in the future.

Safe sources of electricity such as solar and wind, are now growing rapidly. Palisades is not needed and should remain permanently closed. (143-37-3 [Keegan, Michael])

Comment: So in conclusion, the restart of this plant poses significant and long-lasting risks that far outweigh the short-term benefits.

I urge the NRC to prioritize the safety and well-being of the public and the environment, by reconsidering the restart of this aging facility. (143-40-5 [Cabala, Tanya])

Comment: There are a lot of bait and switches related to the nuclear industry. They promise thick transportable casks, but we got thin canisters instead once the industry moved into high burn up fuel in the year 2000.

Look at the shiny object of nuclear fusion they're dazzling people with these days, while they're just, they're dazzling people with fusion while they're getting their rubberstamp together to rubberstamp getting those creaky old giant nuclear reactors going again.

And getting that new generation of nuclear reactors going. Those, the small modular reactors, I understand there's been one model approved and now that one admittedly doesn't work.

The Idaho town that was going to host one has backed out.

Bill Gates was given $2 billion by the government; I think he could afford it himself if he wanted if he thought his Wyoming nuclear project was so good.

And also, we don't have time. These old creekers aren't trustworthy. (143-41-5 [Campbell, Bruce])

Comment: And this recent craze push for nuclear is due to big tech pressuring to power their AI, as well as a frenzy among confused investors.

And also, speaking of carbon footprints, the main part of the nuclear industry carbon footprint is in uranium enrichment.

Or some good things in bringing some industry home. However, bringing the nuclear industry home will poison indigenous people.

And the Center for Uranium Enrichment will be that one commercial uranium enrichment facility in southeast New Mexico, to my knowledge.

Also where Whip is, and where Holtec wants their so-called consolidated interim dump, which will likely become permanent.

And then, I saw this map in the San Onofre film someone mentioned, a documentary. I saw this, the map of the Ogallala Aquifer.

And the southeastern end of that not only goes through the Permian Basin, which is sure dumb, but then it goes into the place where the two companies want their so-called consolidated interim dump sites, and about to where the Whip is. (143-41-8 [Campbell, Bruce])

C.2.3 Comments Concerning Cooperating Agency Comment: The term sheet specific to the Holtec Conditional Commitment Loan needs to be made available for public view. (141-10 [Blind, Alan])

C.2.4 Comments Concerning Process-Licensing Action C.2.4.1 Comments Related to Process-Licensing Action Comment Summary 1 Comment: The Exemption Request Is Legally Insufficient and Should Be Denied Holtec seeks an exemption from the requirements of 10 C.F.R.§ 50.82, pursuant to10 C.F.R. § 50.12. The proposed exemption would remove the10 C.F.R. § 50.82(a)(2) restriction that prohibits reactor power operations and retention of fuel in the reactor vessel when the reactor is in the process of decommissioning. Holtecs proposed exemption does not comply with the requirements for an exemption set forth in 10 C.F.R. § 50.12. Therefore, the NRC must not allow Holtec to use this exemption.

An exemption pursuant to 10 C.F.R. § 50.12 may be invoked only in extraordinary circumstances. Section 50.12 is available only in the presence of exigent circumstances, such as emergency situations in which time is of the essence and relief from the Licensing Board is impossible or highly unlikely. Washington Public Power Supply System, 5 NRC 719, 723 (1977). There are no exigent circumstances presented by Holtec.

10 C.F.R. § 50.12(a)(1) first requires that the exemption be authorized by law. In its Request for Exemption, Holtec does not cite any law that authorizes the exemption. It just says that the Atomic Energy Act does not prohibit it.

A request for a § 50.12 exemption must also show that the exemption will not present an undue risk to the public health and safety and common defense and security. In an attempt to satisfy this requirement, Holtec simply states that Palisades will be returned to the condition it was in prior to decommissioning. But there were significant safety problems with the plant that militate against such a conclusion. In fact, risks to the public health and safety prompted Palisades to be shut down earlier than anticipated. The Palisades nuclear reactor was operating with poorly maintained parts, woefully inadequate safety equipment, and outdated and outmoded components when Entergy sold it to Holtec less than 2-years ago. (75-16 [Lodge, Terry J])

Comment: Section 50.12(a)(2) lists several special circumstances, at least one of which must be present:

(i) Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission. Holtecs Request for Exemption does not cite a §50.12(a)(2)(i) special circumstance conflict, because there is none.

(ii) Application of the regulation in the particular circumstance would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

This requirement means that application of § 50.82 in this case would not serve the purpose of

§ 50.82. The purpose of § 50.82 is to ensure that the reactor is certified to be in decommissioning status in order to facilitate decommissioning. Holtec claims that application of

§ 50.82 in this case would not serve its purpose because that would prevent Holtec from reopening Palisades. But it is not the purpose of § 50.82 to allow a reactor in decommissioning status to restart. On the contrary, the purpose of the rule is to facilitate decommissioning.

Holtec maintains that the purpose of § 50.82 is merely to notify the NRC of Entergys intent to place Palisades into decommissioning status. But Holtec may not simply rescind the certification that the plant is in decommissioning status. If the rules purpose, as Holtec alleges, is just to notify the NRC of the intent to decommission, that purpose is accomplished without an exemption. The invocation of § 50.82 commences the formal undertaking of the decommissioning process and that application of the rule is clearly served by continuing the decommissioning process, not by attempting to restart Palisades.

(iii) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated.

Holtecs assertion regarding this consideration is farcical. There is no reactor similarly situated.

This is an unprecedented attempt to restart a shutdown nuclear reactor. Since Holtec is financing the restart 100% with taxpayer and ratepayer charges, Holtec will not have been subjected to undue hardship if the requested exemption is not granted. Holtec merely finds itself in a difficult situation of its own making. Holtec knew Palisades was going to be in decommissioning status when it bought the plant. This is certainly not an exigent circumstance or undue hardship. Holtecs argument brings to mind the quip about the boy who kills his parents and then begs for mercy because he is an orphan.

(iv) The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption.

Restarting Palisades would actually harm public health and safety. The NRC has repeatedly weakened pressurized thermal shock (PTS)regulations, over decades, in order to accommodate ever more risky continued operations at the worst neutron-embrittled reactor pressure vessel in the country, namely Palisades. For State of Michigan officials to incuriously accept NRC's flippant assurances of safety is inviting disaster.57 (v) The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation.

Holtec is not asking for temporary relief, nor has it made a good faith attempt to comply with § 50.82. Rather, Holtec is asking for a license amendment - i.e., permanent relief. And, instead of making a good faith effort to comply with § 50.82, Holtec is asking to rescind the § 50.82certifications. Again, Holtec is not even arguing this factor in support of its request for an exemption.

(vi) There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption.

The public interest criterion for granting an exemption under 10 C.F.R. § 50.12(b) is a stringent one: exemptions of this sort are to be granted sparingly and only in extraordinary circumstances. Washington Public Power Supply System (WPPSS Nuclear Power Projects Nos. 3 & 5), CLI-77-11, 5NRC 719 (1977).

Here, Holtec contends that NRC regulations for decommissioning, including § 50.82, were adopted for reactors intended to be permanently shut down, not reactors that are proposed to be restarted. But that does not mean that NRC did not consider the possibility of restarting a reactor in decommissioning status when it promulgated the decommissioning rules. On the other hand, if the NRC had considered the possibility of restarting a decommissioning reactor, it would have provided for that possibility in the rules. Holtec falls well short of showing that the restart of Palisades is in the public interest.

Exemption is an improper procedural vehicle for Holtec to invoke to restart Palisades.

57 Declaration of Kevin Kamps, Appendix 12, p.4.

(75-17 [Lodge, Terry J])

Comment: Entergy Operations, Inc. (Entergy), the prior licensee, permanently ceased operation of Palisades reactor on May 20, 2022 and submitted the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1) on June 13, 2022. No NRC license issued by the NRC to Holtec International or any of its sundry subsidiaries (herein generally referred to as Holtec) authorizes restart of the reactor. In fact, 10 CFR 50.82(a)(1) specifically states: Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. The Renewed Facility Operating License (RFOL) the NRC issued to Holtec is a possession only license, not a license to run the reactor, refuel the reactor, add new spent fuel to the pool, or expand the Independent Spent Fuel Storage Installation (ISFSI).

Holtec seeks to sidestep NRC requirements by requesting: (1) an exemption from the requirement in 10 CFR 50.82(a)(2) that prohibits operation of the Palisades reactor, or emplacement or retention of fuel into the reactor vessel; (2) a license transfer from Holtecs Holtec Decommissioning International subsidiary to a Palisades Energy, LLC (a new Holtec subsidiary created to operate the reactor); and (3) four license amendment requests.

The NRC must not capitulate to Holtecs effort here to turn the NRC into a rank rubberstamping operation. (77-1-4 [Lee, Michel])

Comment: NRC must use up-to-date knowledge and not rely on outdated reports, studies and regulations - as all of which are based on climate, safety and security conditions which have changed and may be reasonably anticipated to change further over the ensuing decades.

Finally, we aver that the NRC may not reasonably cite regulations (either its own or those promulgated by other bodies) as an evidentiary basis for any assertion or finding.

Regulations are merely regulatory tools and operational guides subject to deficiencies and implementation failures.

The NRC owes a duty to the public to look at the conditions and dangers of the real world and assess and describe them with candor. (77-2-8 [Lee, Michel])

Comment: In the likelihood it is decided by you to reopen, we DEMAND you dont give Holtec any exemptions they are requesting on safety, environmental testing, and reopening standards. Our lives depend on it. (138-1 [Paulison, Christeen])

Comment: Federal Register, Docket ID NRC-2024-0076 in part, says:

"...The NRC is announcing that it will hold a hybrid public scoping meeting for the PNP exemption request, license transfer, and license amendment request submittals..."

Based on this wide scope of topics for which the NRC is requesting public comments,

".....in this instance, the NRC considered the unique nature of the requests and the demonstrated high public interest...."

Because of the above Federal Register statements, I am submitting questions on the following:

Holtec and NRC Use of Exceptions for Relicensing Palisades Quality Assurance Program, Restart Activities Planned NRC Inspections Transition to Operational Status Issues List DOE Conditional Loan Term Sheet Attached is a pdf of the text of each question, including supporting. (141-1 [Blind, Alan])

Comment: The Federal Register announcing this public meeting said the purpose was to hear public comments:

The scope is, no significant impacts is reached, related to the exemption request, license transfer request, and license amendment requests Public Interest, in this instance the NRC considered the unique nature of the requests and the demonstrated high public interest.

In view of this meetings purpose, I would like to comment on Exception Requests. I bring up Exception Requests first, because if General Counsel has not approved the current application, then all other Holtec submittals do not stand.

For full disclosure, I am also a co-petitioner on a Petition for Rule Making, in which Exception Requests is one element.

Holtec and NRC staff reference a single sentence from a 2020 Petition for Rulemaking denial as a legal basis for using the exception rule to process Holtec submittals for the purpose to return Palisades to operation from a decommissioned status, essentially a relicensing process. Both Holtec and NRC staff omit other parts contained in the same petition denial letter that do not support their position. The 2020 denial of the request for rulemaking must be read in its entirety, not just selectively, and must include all text from sentences that are used. NRC General Counsel should rule if Holtecs and NRCs application of one sentence, for the purpose if relicensing Palisades, is allowable. The General Councils ruling on Holtecs usage of the 2020 exception denial wording should be made public. Rather than use the exception rule, I urge the NRC to make new rules for this very complicated process of relicensing Palisades for which no current NRC processes exist.

The single sentence, with some text removed by Holtec and NRC is:

The NRC is denying PRM-50-117 because the existing regulatory framework may be used removed >> on a case-by-case basis<< removed Note: The words on a case-by-case basis were removed by Holtec and the NRC, although they appear in the formal denial letter to Mr. George Berka.

In effect, Holtec and the NRC are using a single sentenceat best, a loopholetaken out of context, to deny public involvement in the relicensing of Palisades. The actual licensing rule is much more complex and includes many steps, including opportunities for public input. (141-3 [Blind, Alan])

Comment: According to 10CFR50.3, Interpretations":

"No interpretation of the regulations in this part by any officer or employee of the Commission, other than a written interpretation by the General Counsel specifically authorized by the Commission in writing, shall be considered binding upon the Commission.

The NRC staff must demonstrate that the General Counsel approved the entirety of the 2020 petition denial text, as referenced in Reference 5 of the Holtec StartUp Plan, which appears to also be utilized by NRC staff to progress the matters contained in these proceedings. If the General Counsel did not authorize the 2020 petition denial, then the staff is prohibited from utilizing the text in accordance with the "Interpretations" rule. Conversely, if the General Counsel did approve the complete text, then their approval should be required once more for the current staffs interpretation, which selectively uses portions of the full text to advance the relicensing of Palisades.

For exception requests to be considered by the NRC, the following must be met, in part: There is present any other material circumstance not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. If NRC staff continues to use the 2020 petition for rulemaking denial as the basis for accepting Holtecs use of the existing regulatory framework to address the issue raised in the petition, we request that the NRC General Counsel review this sentences use, including the intentional omission of all other factors, such as the complexity of the issue paragraph and omitted text from the sentence used, from the same 2020 denial letter.

In conclusion, the use of a single sentence from a 2020 petition for rulemaking denial, with the text on a case-by-case basis removed, should not serve as a simple gateway for relicensing Palisades. Without this gateway, the Holtec path for restart does not stand and must be evaluated against new rulemaking. (141-5 [Blind, Alan])

Comment: Yesterday, the ADVANCE Act passed. So, I am curious if that changes this process at all. (143-1-1 [McLean, Michael])

Comment: Holtec has proposed exploiting a loophole from an NRC denial letter concerning a 2019 petition for rulemaking that proposed a fast and easy way to allow it to reload fuel and operate Palisades. And I might add that that earlier petition was denied, but yet, it seems to have standing in these proceedings.

If allowed, this will permit Holtec and NRC to evaluate today's proceedings with very little public involvement under a fast and simple process. Now, I know we heard earlier that there's going to be a chance for public hearings, but this issue of the exemption rule is everything stands on that. If the exemption rule does not stand, then all this other work falls. It's a house of cards.

This process has already been used to allow the NRC to agree with Holtec's motion for a Secretary order denying public hearings. And the public hearings were on the use of the exemption rule. And again, if that falls, which we're not allowed to provide comments on, then none of this stands.

The Petitioner appealed the Holtec proposal, and I'll give Kevin recognition that he was the initiator of that petition. The petition appealed the Holtec proposal order to not allow public hearings. And in that response, it captures what I want to say today from that motion.

The device of an exemption here today is being invoked to camouflage the actual nature of the request, which is a license amendment. The exemption being sought would relieve Holtec from adhering to the core regulations that the Atomic Energy Act imposes to ensure safe regulation of commercial nuclear power plants and in the interest of the health and safety of the public, as well as environmental protection.

Exemptions are for short-duration bypasses of NRC regulations. They are not for reversing a major licensing event, as Holtec is now using. This request for permission to restart is a major change that requires full-blown licensing proceedings.

Now, back to my comment today -- and I'm almost done. The residents of Palisades Park and I request that the NRC General Counsel approve the current NRC staff's interpretation of the Holtec/NRC's use of the selected words, in part and not in whole, taken out of context of the denial of proposed rulemaking 50-117, dated February 19th, 2019. (143-14-2 [Blind, Alan])

Comment: So, please keep your perspective in your scoping to look at this is unprecedented.

And I do encourage you to get it right. Because I agree that we do need alternative sources for energy, and this is the first plant that's been shut down, and then, going to go back up. (143 2 [Cordell, Cyndy])

- 100 -

Comment: And so, you guys have this big job in front of you. This is going to be the first plant in the world to potentially come back online. And there's a big onus on you guys to do it, and do it right, and give a model to everyone else that tries to do it. (143-26-3 [Davis, Bruce])

C.2.4.2 Comments Related to Process-Licensing Action Comment Summary 2 Comment: Thank you for the opportunity to provide input into the NRC Environmental Assessment scoping process for the proposed restart of the Palisades Nuclear Plant in Covert Michigan. We have attended NRC Community Meetings on Palisades, including virtually the most recent meeting on environmental scoping on July 13th, 2024. I am disappointed that the transcripts of this meeting have not been released, especially in light of the quick turnaround required for these comments. (55-1 [Lawlor, Edward])

Comment: We appreciate the opportunity to be involved in the NEPA process! (63 1 [McClain, Krystle Z.])

Comment: EPAs enclosed comments focus on purpose and need; project alternatives; interagency coordination; the Coastal Zone Management Act; nuclear waste storage; energy efficiency and environmental best practices; water resources; climate change and greenhouse gases; environmental justice; CEQs NEPA Implementing Regulations Revisions; and plain language. EPA recommends that NRC and DOE LPO address these comments and recommendations before releasing the draft EA. (63-1-2 [McClain, Krystle Z.])

Comment: Along the same lines, a 30-day public comment period is insufficient. NRC should extend the public comment period to 180 days. Holtec's rush to restart Palisades is no excuse for a short public comment period -- in fact, the rush job itself could significantly increase the environmental risks and worsen the impacts. (76-1-4 [Kamps, Kevin])

Comment: On July 11, 2024, the NRC Cognizant Officer at the Scoping Comment Meeting promised the Public that the Transcript from the Scoping Meeting would be placed into the docket before Comment period expired. They were not (125-2 [Keegan, Michael J.])

Comment: I also thought it was interesting that the NRC gets two weeks for typos, but we only get two weeks for public comment on something that I'm not super familiar with. (143 5 [Holst, Jacqueline])

Comment: I can also say that I appreciate the NRC. They came to our office as part of their environmental analysis, and some of their scoping questions were very thoughtful.

We had a really robust conversation about Covert Township, our community, socioeconomic status, accessibility to utilities, public health, you name it. It was a great conversation.

I appreciate the NRC, the DOE, and Holtec opening up those lines of communication, making me feel like I am being heard, and that our answers, that our questions are being answered. (143-31-3 [Cook, Daywi])

Comment: If there's one thing that IBEW electricians know, it's craftsmanship, it's professionalism, it's integrity.

We expect the Commission to act with that same integrity and consider all the public comments. (143-33-3 [Currant, Jonathan])

Comment: We request 180 days for a public comment period. Thirty days is not sufficient. This is unprecedented, very high risk, insanely expensive for the public. And Holtec's rush to restart is no excuse for a short 30-day public comment period. (143-35-1 [Kamps, Kevin])

- 101 -

Comment: we could use 180-day comment period. (143-41-2 [Campbell, Bruce])

C.2.4.3 Comments Related to Process - Licensing Action Comment Summary 3 Comment: NRC has not established scientifically based guidelines for "restarting" any decommissioned nuclear plant. Certainly, the safety criterion for "restarting" a decommissioned nuclear plant must be even more stringent that those criteria governing the commissioning of a new nuclear plant. NRC must regard HOLTEC's permit application as an entirely new and novel application to operate a nuclear power plant, and not a renewal or extension of ENTERGY's withdrawn operation permit for Palisades NP. (5-2 [Muhich, Mark])

Comment: Thank you for the opportunity to voice my support for the timely restart of the Palisades Nuclear Plant. For this, I am advocating for an expedited environmental review process. This facility has strong support from both the local community and the broader public due to its significant role in our energy landscape and environmental stewardship (31-1 [Detering, Dietmar])

Comment: There is currently no established regulatory framework for repowering a nuclear plant that has rendered its operating license. Antinuclear groups argue that the plant should undergo the regulatory process from scratch. However, considering the sites unchanged conditions since its shutdown in May 2022, a streamlined review process is both logical and necessary. (31-2 [Detering, Dietmar])

Comment: In conclusion, a timely environmental review is critical for the swift restart of the Palisades Nuclear Plant. This step is necessary to meet the energy needs and environmental goals of Michigan and the United States. I urge the NRC to expedite this process in response to the clear demand from the public and the local community. (31-4 [Detering, Dietmar])

Comment: A full environmental assessment based on current rules should be required prior to restarting the Palisades Nuclear Power Plant. (35-1 [Strehlow, Laura])

Comment: With the unknowns, we are deeply concerned. The Holtec group is seeking NRC's approval to shortcut the process. There are too many unanswered questions. To the best of our knowledge, your agency's charge is to ensure safe operations. In a ground up sort of way. We are asking that every procedure and precaution that would apply to a new facility be implemented, should you proceed with a restart. (42-2 [Sahagian, Linda G.] [Stewart, Douglas A.])

Comment: "My name is Kraig Schultz, and I am a volunteer with Michigan Safe Energy Future.

I live 50 miles from the Palisades Nuclear Plant with my family in Robinson Township. I would like to thank you for holding this meeting.

Over the last decade, I have attended most of the public meetings conducted by the NRC and Palisades operators. During this time, I've noticed a disturbing trend: the NRC is becoming increasingly lax in the enforcement of regulations and is not fulfilling its mission to provide adequate safety to our communities. An example of the NRC not fulfilling its mission would be cutting corners and not requiring a full Environmental Impact Statement (EIS) as part of its license review for Holtec's proposed plans for producing electricity at Palisades. (53-1 [Schultz, Kraig])

Comment: I am writing to ask that ask that an Environmental Impact Study be conducted before considering allowing the Palisades Nuclear Plant to re-open. (54-1 [Williams, Bonnie])

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Comment: I am writing to ask that NRC to do its proper oversight role by conducting an Environmental Impact Study (EIS) to understand what it involved in restarting and running this plant. (54-3 [Williams, Bonnie])

Comment: At a minimum, with the stakes this high, the NRC needs to undertake a comprehensive evaluation of environmental and health impacts, including a rigorous EIS. (55-3 [Lawlor, Edward])

Comment: All this and more needs to be studied as part of an EIS and not an EA. (58-6 [Mcardle, Edward])

Comment: 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 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 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. (68-1 [Unknown, Unknown])

Comment: 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 and 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. (68-4 [Unknown, Unknown])

Comment: NRC and DOE should conduct a full Environmental Impact Statement (EIS) in place of the proposed EA.

Restarting a nuclear power plant has significant environmental impacts as a matter of applicable National Environmental Policy Act (NEPA) regulations, involving context and intensity.1 In the NOI, the NRC states that the determination for preparing an EA rather than an EIS was because the NRC does not yet know the significance of potential impacts from

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the proposed action. Although NEPA allows an agency to prepare an EA for a proposed action when the significance of the effects is unknown, the proposed action also must be not likely to have significant effects.2 In our view, restarting an aging nuclear plant that has already entered the decommissioning phase with an inexperienced operator is more than likely to have significant effects, and thus mandates preparation of an EIS. NRC itself describes this proposed action a First of a Kind Effort to Restart a Shuttered Plant.3 As NRC noted, Palisades permanently ceased operations on May 20, 2022, after more than 40 years of commercial operation.4 And while Holtec may be a leader in decommissioning of nuclear reactors in the United States, to our knowledge it does not have experience operating a nuclear plant apart from through a decommissioning process. Indeed, Holtec originally acquired rights to Palisades in order to tear it down, not to rebuild and operate it. Holtec only changed course when the possibility of substantial DOE funding became available. Given these highly unusual -

in fact, first of a kind - circumstances, NRC and DOE should conduct a full EIS.

Even if NRC believes that specific effects are not yet known, that does not exempt NRC from conducting a thorough EIS. The purpose of an EIS is to identify what those effects may be, and whether there are any alternatives that would mitigate such impacts.

Furthermore, representatives from the NRC stated multiple times during a public meeting on July 11th that they expect to make a finding of no significant impact (FONSI), and this was further emphasized on slides shared during the meeting.5 However, agencies may not assume that there will be a FONSI ahead of the analysis, and courts have held that agencies cannot avoid preparing an EIS by such conclusory assertions.6 Additionally, a FONSI will be evaluated against the current scheme of NEPA requirements (discussed in further detail below), including cumulative impacts and controversy.7 This makes it likely that the proposed EA and FONSI would be inadequate and require production of an EIS.

NEPA requires a full EIS when actions are likely to have significant effects.8 When determining the appropriate level of NEPA review, a significance determination requires examining both context and intensity.9 The context analysis should include both geographic scope and duration of impacts.10 The intensity analysis should consider eight factors, including whether the action may adversely affect the public health and safety, adverse effects on unique characteristics such as wetlands, parks, or ecologically critical areas; the degree to which the potential effects on the human environment are highly uncertain, and the degree to which the action may adversely affect communities with environmental justice concerns.11 Furthermore, courts have held that even just one factor may be sufficient to require preparation of an EIS in appropriate circumstances.12 Courts have held that where there is controversy over the degree to which there may be effects on the human environment, production of an EIS may be required.13 1 40 C.F.R. 1501.3.

2 40 C.F.R. 1502.5(a).

3 NRC, Palisades Nuclear Plant - Potential Restart, https://www.nrc.gov/info-finder/reactors/pali.html (last visited July 28, 2024).

4 Id.

5 NRC, NRC Presentation on Palisades Nuclear Plant Potential Reauthorization Scoping Meeting, Accession No. ML24193A025, Slide 12 (July 11, 2024).

6 Ocean Advocates v. U.S. Army Corps of Engrs, 402 F.3d 846, 864 (9th Cir. 2005) (The Corps cannot avoid preparing an EIS by making conclusory assertions that an activity will have only an insignificant impact on the environment.).

7 Grand Canyon Trust v. F.A.A., 290 F.3d 339, 347 (D.C. Cir. 2002) (holding that an EA and FONSI were insufficient because the agency failed to consider individually insignificant but cumulatively significant impacts and requiring an EIS because the project was highly controversial).

8 40 C.F.R. § 1501.3(c)(3).

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9 40 C.F.R. 1501.3(d).

10 Id.

11 Id.

12 Ocean Advocates, 402 F.3d at 865; see also National Parks & Conservation Assn v. Babbitt, 241 F.3d 722, 731 (9th Cir. 2001); Nat'l Parks Conservation Ass'n v. Semonite, 916 F.3d 1075, 1082 (D.C. Cir.),

amended on reh'g in part, 925 F.3d 500 (D.C. Cir. 2019) (Implicating any one of the factors may be sufficient to require development of an EIS).

13 Nat'l Parks Conservation Ass'n v. Semonite, 916 F.3d 1075 at 1083.

(73-1 [Lowy, Rebecca])

Comment: In this situation, restarting a plant that has already entered the decommissioning phase is likely to significantly impact the environment. Just because the plant was previously licensed to run through 2031 does not mean that an EA is sufficient. Circumstances changed, by definition, as shown by the decision to shut down the plant nearly a decade early. There are now numerous differences from when the license renewal was issued: the operator has changed; the relevant NEPA requirements have changed; the science and economics on efficiency and availability of alternatives has evolved; the state of the plant itself has dramatically worsened, exposing it to a greater possibility of radioactive contamination to the environment. Entergy, the prior owner and operator, entered decommissioning in part because the plant was no longer financially feasible to run - due to its disrepair and the upgrades required to operate it safely. Although that decision has been characterized as an economic decision, that characterization is misleading to the extent it overlooks the role that disrepair, required upgrades, and safety issues played in creating the financial challenges that led to the decision to shut down. There is significant controversy over the degree to which this may impact the human environment. Additionally, the plant is located directly on the coast of Lake Michigan, which supplies drinking water to over 10 million people, and is sited near fragile dune ecosystems, making it a unique geographic location. All of these factors and changed circumstances support a finding that the proposed restart is likely to have a significant impact and requires an EIS under the intensity and context analysis.

NRCs own regulations support producing an EIS. In order to require an EIS, a licensing action must be a major Federal action significantly affecting the quality of the human environment.14 The NRC regulations further require an EIS - or at least a supplemental EIS - for [i]ssuance or renewal of a full power or design capacity license to operate a nuclear power reactor, testing facility, or fuel reprocessing plant under part 50 of this chapter, or a combined license under part 52 of this chapter.15 NRC staff compared this restart to the license renewal process during both the April 17th and July 11th public meetings. NRCs regulations require an EIS process for license renewals; indeed, the prior license renewal process in 2006 required an EIS, so it would be reasonable to conduct an EIS analysis for the proposed restart if it is otherwise being compared to a renewal process.

Finally, NRC regulations allow the NRC to prepare an EIS for any other action it determines is a major Commission action significantly affecting the quality of the human environment.16 This restart would be unprecedented in U.S. history and will significantly affect the quality of the human environment. NRC has the authority to, and should, evaluate this action at the strongest level of environmental review.

14 10 C.F.R. § 51.20(a)(1).

15 10 C.F.R. § 51.20(b)(2).

16 10 C.F.R. § 51.20(b)(14).

(73-2 [Lowy, Rebecca])

Comment: NRC and DOE cannot and should not rely on the prior EIS published for Palisades in 2006 nor the Generic EIS from 2013, both of which are stale.

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NRC and DOE both represented during the July 11 public meeting that they would be relying on the prior EIS statements for license renewals for the proposed restart at Palisades. However, the last time an EIS was prepared specifically for Palisades was in 2006,17 and the Generic EIS for License Renewal of Nuclear Plants was in 2013.18 NEPA allows agencies to rely on existing programmatic environmental documents for five years - and only if there are no substantial new circumstances or information.19 Agencies may rely on the earlier documents after five years so long as the agency reevaluates the analysis in the programmatic environmental document and any underlying assumption to ensure reliance on the analysis remains valid.20 Both of the prior EISs are well over 5 years old, and neither addresses a restart of a plant that had already begun the decommissioning process. They only address license renewals.

There were certainly no underlying assumptions that the plant would enter the shutdown phase prior to restarting when conducting the earlier EIS analyses, nor that the operator would be a company without prior operating experience. The plant has aged without appropriate upgrades, and the analyses in the earlier EIS documents are significantly outdated, both as to environmental impacts and when it comes to feasibility and financing of alternatives. The analyses in the earlier programmatic environmental documents are no longer valid. Therefore, NRC and DOE should not, and cannot, rely on the analysis in those stale documents.

Furthermore, many other NEPA requirements have changed since the older EIS documents were issued. For instance, NEPA now requires agencies to consider communities with environmental justice concerns and indirect cumulative impacts in their assessments.21 NRC and DOE cannot avoid these requirements by relying on the fact that the plant had previously been approved for renewal. The prior renewal predates by nearly two decades the current scoping process, and did not address these newer requirements. To rely on these older documents and approach the NEPA process as though nothing has changed flies in the face of the entire purpose of NEPA, to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man.22 Requirements and knowledge of what efforts would protect the environment and protect human health have changed significantly since the earlier documents publication. Relying on these documents will put NRC, DOE, and the public in a guessing game as to what the true ramifications of a restart are in the current day and leave everyone without adequate information to make informed decisions. Instead, NRC and DOE should conduct a thorough EIS that adequately analyzes the implications of a restart in modern conditions and provides sufficient knowledge to make informed choices about whether a restart is an environmentally sound decision.

Finally, put simply, there is a fundamental inconsistency between undertaking an unprecedented, first of a kind action and purporting to do so based on decades old environmental analysis. This action requires thorough new analysis and a full EIS.

17 NRC, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Regarding Palisades Nuclear Plant - Final Report (NUREG-1437, Supp. 27) (Oct. 2006),

https://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1437/supplement27/index.html.

18 NRC, Generic Environmental Impact Statement for License Renewal of Nuclear Plants - Final Report (NUREG1437, Rev. 1) (May 2013), https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/r1/index.html.

19 42 U.S.C. § 4336b.

20 Id.; see also 40 C.F.R. § 1502.11(C)(2).

21 See generally 40 C.F.R. § 1508.1(f), (m) (defining communities with environmental justice concerns and environmental justice); § 1508.1(i) (defining effects or impacts to include direct, indirect, and cumulative effects).

22 42 U.S.C. § 4321.

(73-3 [Lowy, Rebecca])

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Comment: The alternatives analysis is the heart of a full EIS,27 which we believe NRC and DOE must conduct. NRC cannot bypass this requirement by using an environmental assessment approach or reliance on outdated EIS documents, particularly in an unprecedented action to restart a shuttered plant. Even if NRC were to only conduct an EA, such analysis still must include a thorough alternatives analysis per NEPA regulations.28 Conclusion A draft environmental assessment that relies heavily on outdated EIS documents 11-18 years old, with an assumption that the EA would result in a finding of no significant impact, would not meet the NRC or DOEs obligations under NEPA or NRCs own regulatory requirements. This also would not give either agency, or the public, the information and analysis needed to make truly informed decisions about the environmental impacts of restarting an aged nuclear plant that has already begun decommissioning. NRC and DOE should prepare an EIS that fully analyzes the safety concerns and impacts of such restart that complies with all the latest NEPA requirements.

27 40 C.F.R. § 1502.14.

28 40 C.F.R. § 1501.5(c)(ii); see also 42 U.S.C. § 4332(H).

(73-7 [Lowy, Rebecca])

Comment: NRC and DOE should not rely on outdated documents. They should consider whether the applicant is able to operate the Palisades Nuclear Power Plant safely in accordance with NEPA rules and regulations. And the agencies should include a robust assessment of alternatives, including renewable energy in combination. (73-8 [Lowy, Rebecca])

Comment: 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. (74-3 [O'Brien, Kevin])

Comment: An Environmental Impact Statement (EIS), Not an Environmental Assessment (EA),

Is Required By 10 CFR § 51.20 The NRC has committed to compilation of an environmental assessment (EA) instead of an environmental impact statement (EIS) or a supplemental environmental impact statement (SEIS). This is legally unsupported.

Presently, pursuant to 10 CFR § 50.82(a)(2), the 10 CFR part 50 renewed facility operating license for Palisades no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. Holtec is still authorized by the NRC to possess, and store irradiated (i.e., spent) nuclear fuel at the site.1 Palisades spent fuel is currently stored in a spent fuel pool there, and in dry cask storage at the independent spent fuel storage installation

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(ISFSI). Holtec seeks the issuance or renewal of a full power or design capacity license to operate Palisades, i.e., an operating license. When Entergy voluntarily ended operations (and with it, the need for the OL), the license devolved into a possession only license. Assuming without conceding that the ad hoc relicensing pathway proposed by Holtec is in any way appropriate, the obligatory NEPA compilation for the Palisades restart is not an EA, but instead, an EIS, pursuant to the mandatory wording of § 51.20(b)(2):

(b) The following types of actions require an environmental impact statement or a supplement to an environmental impact statement:

(2) Issuance or renewal of a full power or design capacity license to operate a nuclear power reactor, testing facility, or fuel reprocessing plant under part 50 of this chapter, or a combined license under part 52 of this chapter.

Even the NRC admits that what is under consideration here is at least a license renewal.

The Federal Register notice of the scoping meeting says that granting Holtec's request would allow Palisades to resume power operations through March 24, 2031, the end of the renewed operating license. (emphasis added). And a license extension requires a SEIS. So, under any view of the situation, an EIS or SEIS must be prepared. An EA does not comply with NEPA or NRC regulations.

The within commenters submit that whether called a new or renewed license, Holtecs objective is to have a full power or design capacity license under 10 CFR § 51.20(b)(2). Holtec must file an application for a new OL, accompanied by an Environmental Impact Statement in order to avoid violating 10 CFR § 51.21:

All licensing and regulatory actions subject to this subpart require an environmental assessment except those identified in § 51.20(b) as requiring an environmental impact statement, those identified in § 51.22(c) as categorical exclusions, and those identified in § 51.22(d) as other actions not requiring environmental review.

10 CFR § 51.21.

NRC regulations at 10 CFR § 51.20(b) list the circumstances where an EIS or SEIS is required.

There is no regulatory pathway to reverse a possession-only license back to an operating license. The essence of Holtecs exemption request at the Palisades is to vault backwards over the shutdown and decommissioning steps in 10 CFR § 50.82(a)(2) that were discharged and completed in May and June 2022. NRC regulations do not contemplate such an unprecedented maneuver. Holtecs only recourse is to submit an application for a new operating license pursuant to 10 CFR Part 50 and for the NEPA document to be an EIS, not an EA.

The Palisades restart, if allowed, would be an unprecedented reversal of the mothballing of a nuclear plant to renewed operation. It is a major federal action under the National Environmental Policy Act. See Scientists' Institute for Public Information, Inc. v. Atomic Energy Commission, 481 F.2d 1079, 1088 (D.C. Cir. 1973), (there is Federal action within the meaning of the statute not only when an agency proposes to build a facility itself, but also whenever an agency makes a decision which permits action by other parties which will affect the quality of the environment). Because restoration of Palisades to operations would again cause negative environmental impacts, and because a federal license is required, the Palisades restart is major and federal.

Holtec has indicated to the NRC its intention to apply for a license extension after what Holtec claims to be the expiration of a current license to operate in 2031. However, a new operating license application must be submitted by Holtec because there can be no mere resumption of the former operating license under the Atomic Energy Act. The within commenters demand that

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a new license application be submitted by Holtec that would implicate a license period appropriate to the actual physical conditions of relevant components of the Palisades reactor, along with supporting infrastructure and plant-specific environmental circumstances.

1 Notice, Holtec Decommissioning International, LLC, and Holtec Palisades, LLC; Palisades Nuclear Plant; Exemption (January 4, 2024), https://www.federalregister.gov/documents/2024/01/04/2023-28951/holtec-decommissioning-international-llc-and-holtec-palisades-llc-palisades-nuclear-plant-exemption (75-1 [Lodge, Terry J])

Comment: A Programmatic Environmental Impact Statement Is Indicated The Palisades licensing pathway from permanent shutdown to operability has never been identified nor implemented before. Earlier in July, NRC Chair Christopher Hanson explained to a Congressional panel that This is something we have never done before and requires some creativity by the staff as well as Holtecs part.

The Atomic Energy Act does not appear to contemplate such a track. The determinations being made by the NRC as to Palisades will likely set legal and oversight precedents for at least two other shutdown reactor reversals being scrutinized at Duane Arnold Energy Center in Iowa and Three Mile Island, Unit 1 in Pennsylvania.2 There are some environmental, aging management, licensing standards and quality assurance considerations in common as to the three reactors.

There may be more reactors returned from mothballs as well. A de facto program to extend or restore last-generation reactors to continued power generation under NRC licensing oversight has sprung up. The NRC has appointed an internal working group to accomplish the relicensing of Palisades. A Programmatic Environmental Impact Statement (PEIS) is warranted to more precisely identify reactors which may be brought back from the dead in order to anticipate and identify environmental concerns and resist dilution of licensing standards to accommodate bad ideas.

The Supreme Court has recognized the need for national programmatic environmental analysis under NEPA where a program is a coherent plan of national scope, and its adoption surely has significant environmental consequences. Kleppe v. Sierra Club, 427 U.S. 390,400 (1976).

Programmatic direction can often help determine the scope of future site-specific proposals.Laub v. U.S. Dept of Interior, 342 F.3d 1080,1089 (9th Cir. 2003). CEQ regulations define this practice as tiering. 40C.F.R. § 1502.20.

So, with the current attempt to restart Palisades, the foreseeable attempt to restart Duane Arnold and Three Mile Island Unit 1, and likely attempts at other closed reactors, there is certainly a coherent plan of national scope, and its adoption surely has significant environmental consequences, requiring a programmatic EIS.

2 https://neutronbytes.com/2024/07/06/long-shot-restart-efforts-for-duane-arnold-and-tmi-1/ ; also, see https://www.phillyvoice.com/three-mile-island-nuclear-restart-pennsylvania-meltdown-constellation-energy/

(75-2 [Lodge, Terry J])

Comment: NRC's Environmental Assessment is nowhere near enough. A full-blown Environmental Impact Statement is called for regarding this major federal action -- a very hard look is required. In fact, because the Palisades closed reactor restart precedent is now being applied elsewhere -- Three Mile Island Unit 1 in Pennsylvania, Duane Arnold in Iowa, and Diablo Canyon in California (where Unit 1 was supposed to close this year, and Unit 2 next year), etc. -- a Generic or Programmatic EIS is necessary. (76-1-3 [Kamps, Kevin])

Comment: On behalf of the Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) it is respectfully submitted that

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consideration of relicensing a nuclear plant to run for 60 or more years warrants a particularly stringent and comprehensive analysis of all factors relating to the environment and public wellbeing. (77-1-1 [Lee, Michel])

Comment: It should go without saying that going forward with the activities and operations being proposed at the Palisades site by Holtec requires one or more new operating licenses.

Resuming power production and all that entails also clearly constitutes a major federal action under the National Environmental Policy Act (NEPA) and requires issuance of an Environmental Impact Statement (EIS), not just an environmental assessment (EA).

Given the potentiality of continued extreme extensions of reactor operating licenses being sought by plant operators at the present time, we submit that the EIS should be a Programmatic Environmental Impact Statement (PEIS). (77-1-5 [Lee, Michel])

Comment: Below we emphasize certain areas which must be comprehensively investigated and candidly explored in an EIS. (77-1-11 [Lee, Michel])

Comment: It is obviously extremely important to do a thorough examination of the environmental impact the reopening of the Palisades Nuclear Plant will have on our environment. As I understand this is a unique situation and a forerunner of future restoration of nuclear power plants that have been shut down and put back into valuable usage. Precious information can be learned and proactively used for future reference. Please make sure everyone does their due diligence as this is extremely valuable to our society and to others. (81-1 [Dunlevy, Andrea])

Comment: It has come to my attention that there is a move afoot to reopen the Palisades Nuclear Plant in Covert, Michigan. This facility was closed after years of deferred maintenance and lack of infrastructure investment. Holtec, the entity that proposes to run the reopened plant, has no previous experience in nuclear plant re-opening and I am very fearful of the result of their attempt.

I respectfully request that an Environmental Impact Statement be prepared to thoroughly review Holtec's plans to re-start Palisades. I have watched with interest what happens at this nuclear plant, as I reside in Illinois, directly across Lake Michigan (same latitude!) from Covert, MI. This proposal has the potential to be disastrous for not only the Palisades area, but all of Lake Michigan. (85-1 [Grabowski, Mary Ann])

Comment: I was relieved when the plans were announced that the Palisades Nuclear Power Plant was going to be permanently decommissioned. After all, the plant was in chronic financial distress, there was significant deferred maintenance, and it had a long history of safety violations.

Now, I am told that the new owner Holtec wants to bring this troubled facility back online -a feat that I understand has never been attempted let alone successfully accomplished. I find this prospect terrifying, particularly in light of the fact unlike a new plant or an existing plant, there are no existing protocols to ensure that an obsolete plant with a history of safety issues can safely be re-commissioned.

It is for reason that the NRC must follow its Congressionally-mandated oversight responsibilities over the Palisades Nuclear Plant and conduct a thorough environmental impact study that is at least as comprehensive as what the NRC requires for an operating plant applying to renew its license or expand its facilities.

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To my knowledge, no one has ever received a license to restart a decommissioned nuclear plant. It seems obvious on its face that attempting to restart a plant that was so functionally obsolete it was deemed better to shut down than repair presents risks and uncertainties far greater than extending the license of an existing compliant nuclear plant. As if this werent risky enough, it is my understanding that Holtec has never operated a nuclear power plant. If the EPA requires an environmental impact study when renewing the license of an operating plant with an experienced operator, why wouldnt the EPA (and the NRC and DOE) require at least as much to recommission an obsolete plant with a checkered operating history? (89-1 [Lewis, Raymond J])

Comment: Ill end on this thought. According to the EPAs website, the great lakes account for 84% of the US surface fresh water. God forbid that something goes horribly wrong as this inexperienced operator executes and untested re-commissioning process and causes contamination to this vital and strategic national resource. The ramifications would likely be apocalyptic for our country. Does anyone at the EPA, NRC or DOE want to sit in front of a congressional committee and attempt to explain why their department failed to perform at least the same level of environmental impact study as they would perform for a basic license renewal? Its a question that answers itself. (89-2 [Lewis, Raymond J])

Comment: The NRC is a trusted organization who citizens of this country rely on as watch dogs for safety. I write both to thank you for being the safety net that you are and to beg of you to require a full Environmental Impact Statement before consideration of approval of any sort to Holtec and the reopening of Palisades Nuclear Plant. (92-2 [Sloan, Jamie])

Comment: The Palisades Nuclear Power Plan has operated outside of the ASHRAE standard for its last 10 years of life. Entergy did not want to invest in costly maintenance and frequently requested exceptions to the standard which were granted by the NRC with a rubber stamp.

I strongly urge the NRC to conduct an environmental impact assessment of Palisades before it is allowed to re-open. This is such an irregular event that has no rules or operational model for re-opening a shuttered plant. We need to establish new ASHRAE standards for this.

I am concerned for the safety of nearby residents and for the protection of our Great Lakes. (96-1 [Flynn, Kevin])

Comment: Specifically, we need to see an environmental impact study. I request that you NOT approve anything until this study is conducted and made available to the public. (98-2 [O'Brien, Thomas])

Comment: I am writing to ask that ask that an Environmental Impact Study be conducted before considering allowing the Palisades Nuclear Plant to re-open.

My family has had a cottage in Palisades Park for five generations, since the park opened early in the last century.

We are well aware of the history of that plant and the reasons it was eventually shut down.

The plant has a history of safety violations and emergency shutdowns; it was not properly maintained and did not have the proper investment or funding. And now, it may be handed over to Holtec, a company with apparently no experience operating a nuclear plant. It is unthinking to go forward without a full and honest assessment of the big picture that demands attention here.

I am writing to ask that NRC to do its proper oversight role by conducting an Environmental Impact Study (EIS) to understand what it involved in restarting and running this plant.

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This plant is not safe, and there is no reason to believe it will be safe, especially without conducting an EIS. If this plant were to open and have an accident, heaven forbid the destruction it could cause.

It is nothing short of reckless to re-open a plant with such glaring and avoidable dangers for the community and for Lake Michigan - which is the source of water for millions of people and wildlife.

Please do the right thing for the people, the environment, and the future, and conduct an EIS. (100-1 [Williams, Bonnie])

Comment: Please require an Environmental Impact statement. So much has occurred with this plant and the climate change conditions. The GAO said so in their recent review of the nuclear power industry (102-1 [Flynn, Thomas])

Comment: Now Holtec is doubling down on the pretense that Palisades is an operating facility by trying to deceive the NRC and DOE to allow a limited environmental impact study. This is disingenuous in the least and criminal to allow! 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 (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 a full Environmental Impact Statement (EIS).

Holtecs application should require the highest level of environmental review - an EIS that is directed to the unprecedented circumstances of this plant and the outlandish request before the NRC to restart a permanently shut down nuclear facility. Please strenuously question the highly risky venture they propose.

Please require the highest level of environmental impact evaluation to arrive at a realistic assessment of a potential Great Lakes disaster should they move forward with pretending a 60-year-old defunct nuclear facility is good as new. Please treat this proposal as if its happening in YOUR back yard! (103-2 [Jacobs, Kristen])

Comment: As a resident of Palisades Park, Covert Mi. I request that the NRC employ its Congressionally-mandated oversight authority over PNP to conduct a thorough and rigorous environmental assessment of Holtec's request. The environmental review should be 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 environmental review of Holtec's application must do at least that - and even more - because of the unique risks arising from restarting PNP that has been shut down. (104-1 [Quinn, Mary])

Comment: I encourage the NRC (No, I urge the NRC) to require an Economic Impact Statement (EIS) - a review that is more comprehensive than the planned Environmental Assessment - that can fully address this first-time situation and its unique, associated risks.

The key factor here is..."First Time Situation". This will end up being a blueprint for how to re-open a Nuclear Power Plant, or the blueprint for how "Not to" re-open a Nuclear Power Plant. I think I speak for ALL of us, when I say that the first option will make everyone happier and healthier in the coming years.

Please, put all of our lives first when making your decision. (105-3 [Hohman, Kevin])

Comment: It is critical that the NRC conducts a full EIS on this property. Due to the plants risky history, I feel strongly that this is NOT the site to experiment with new technologies.

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Our Palisades Park Country Club Boards submission states our concerns and demands clearly.

Please consider the impact on families near the plant. There are other closed sites with which to experiment.

Thank you for your attention and careful action. (106-1 [Eldredge Stark, Martha])

Comment: 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.

2 https://www.nrc.gov/info-finder/reactors/pali.html (107-2 [Lloveras, Leigh Anne])

Comment: I understand the failed infrastructure is there, but it was not safe before and in need of massive improvements and gov't oversite and regulation if re-commissioned. I would like NO exemptions approved for re-opening. A full EIS is required, and any protocol for a NEW license should be followed. Since when do you rightfully "extend" a license that has been revoked?

There is a MASSIVE amount of money involved. Do not freely give out these funds without finding out how this impacts the area! A great part of Michigan's income is from vacationers.

We've based our school year, working crews, and so much more on this. We must protect our beaches and waterways if we want this to continue. The last thing Michigan needs is more bad press from lack of oversite (i.e.: Flint)! (116-2 [Metz, Ei])

Comment: 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 elsewhere a Generic or Programmatic EIS is necessary. (123-2 [Bogen, Doug])

Comment: I am requesting a Full Environmental Impact Statement not an Environmental Assessment. (125-3 [Keegan, Michael J.])

Comment: Should the power plant re-open it should be with the appropriate review and rigorous safety procedures developed for such an unorthodox reopening as outlined below. (130-2 [Relias, George])

Comment: We watched the power plant from proposal, through its many years of operation, repeated difficulties, and its final years of operations when maintenance was deferred, and oversight became less rigorous. I am writing to you today with the strongest possible request that Holtec's application to restart the currently defunct Palisades Power Plant, be subject to stringent, thorough and exacting environmental study - at minimum the EIS required for the license renewal of a currently operating nuclear power plant. (133-1 [Goetzinger, Laurel Eldredge])

Comment: Green" energy sources are surely the future of power generation. Nuclear fission is the one non-fossil fuel that is lethal when not handled with great care, research and wisdom. As you continue to evaluate this situation, we implore you to require the most thorough of Environmental Impact Studies at the very least.

Thank you for your attention to this important matter. We trust in your experience and thorough evaluation and look forward to learning your recommendations and requirements for the Palisades Power Plant. (133-4 [Goetzinger, Laurel Eldredge])

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Comment: 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 Holtec's 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. (134-1 [Lombardi, Joan])

Comment: We should do a very thorough environmental evaluation and really consider the risk versus the reward. (143-21-3 [Schultz, Kraig])

Comment: Restarting a closed nuclear plant that's in decommissioning mode is an unprecedented undertaking. It has never been done before. So, restarting Palisades is a much more significant project than a 20-year license extension, for example. But a license extension requires a supplemental SEIS, not an EA. So, the NRC and Holtec should not be able to get by with just an EA.

In fact, what Holtec must do is apply for an entirely new operating license. It requires a completely new EIS. That's because Entergy, the previous owner of Palisades, ceased using its operating license in 2022 -- partly because of safety and economic concerns. Entergy, then, was given a position only licensed to proceed with decommissioning Palisades. It's the position only licensed that Holtec now has.

There's no procedure in the NRC rules for reinstating the operating license. The only procedure in the rules, once the operating license ceases, is to continue decommissioning and, ultimately, formally terminating the license, pursuant to 10 CFR Section 50.82, Subsection 9.

And even if we assume this is only a license renewal, the NRC's own regulations dictate the preparation of a SEIS at 10 CFR Section 51.20(b), which states, "The following types of actions require an Environmental Impact Statement or a supplement to Environmental Impact Statement." Among those are: the "Issuance or renewal of a full power or design capacity license to operate a nuclear power reactor."

There's no question that Holtec is requesting a license renewal, because in The Federal Register notice for this meeting, the NRC said that granting Holtec's request would allow Palisades to, quote, "resume power operations through March 24 of 2031, the end of the renewed operating license." End of quote. So, the NRC is admitting, in their terms, this is a license renewal, and that would require a SEIS, not an EA.

Aside from the clear dictates of these regulations, a SEIS is, nevertheless, warranted based on the magnitude of the project as an unprecedented restart from shutdown and all other environmental impacts. (143-25-1 [Taylor, Wally])

Comment: And I've heard tonight that the NRC may rely on the 2006 SEIS that was prepared for the license extension for Palisades, but NEPA regulations require that you cannot rely on outdated information, and that's what that would be.

For all those reasons, the NRC should be doing at least an SEIS, but we think even a completely new EIS rather than an EA. (143-25-3 [Taylor, Wally])

Comment: You, the NRC, are now promoted to being promoters of nuclear energy and you still have the mandate to protect health, safety, and the environment. Right now, you are playing with fire and playing with our lives -- all for a company with no transparency, redacted paperwork, and that is known for its grift, graft, and greed.

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The proposed restart requires a thorough EIS to make sure that all stakeholders' voices are heard, reviewing social and economic harms, as well as tribal nations' voices must be heard.

We cannot believe that this restart does not require an EIS, according to the NRC. (143 5 [Drechsler, Jacqueline])

Comment: To piggyback on something that Wally Taylor said earlier, in terms of a Palisades specific SEIS, I think that a programmatic or even generic EIS is called for. (143-35-2 [Kamps, Kevin])

Comment: So, this never done before proposal to restart Palisades plus using the very disreputable company Holtec, requires a full EIS, not just an EA. (143-41-1 [Campbell, Bruce])

Comment: So anyway, let's please go for the full EIS. (143-41-9 [Campbell, Bruce])

Comment: But since tonight is about an environmental assessment, it should be an EIS on the Palisades restart of the old reactor. (143-42-2 [Kamps, Kevin])

C.2.5 Comments Concerning Process-NEPA C.2.5.1 Comments Related to Process-NEPA Comment Summary 1 Comment: 2. INTERAGENCY COORDINATION A. Implementation of NEPA requires interagency coordination with multiple stakeholders, including Federal and state resource agencies, Tribes, local governments, and affected landowners.

Recommendations for the Draft EA:

1. Include copies of all interagency coordination sent to, and received from, landowners, Federal and state resource agencies, Tribes, and local municipalities. This includes, but is not limited to, correspondence regarding historic and cultural resources (State and Tribal Historic Preservation Officers), wetlands and streams (Michigan Department of Environment, Great Lakes, and Energy [EGLE]), and Federal-and state-listed threatened and endangered species (U.S. Fish and Wildlife Service [USFWS] and Michigan Department of Natural Resources [MDNR]).2

2. Include a list of all Federal, state, and local permits that would be required to undertake the Preferred Alternative 2 The USFWS hosts a project planning tool to assist with the environmental review process, known as IPaCInformation for Planning and Conservation. See https://ipac.ecosphere.fws.gov/.

(63-1-8 [McClain, Krystle Z.])

Comment 9. OTHER COMMENTS A. All new projects should reflect the CEQ Final Rule on NEPA Implementing Regulations, effective July 1, 2024.24 Recommendations for Draft EA:

1.

Ensure NRC uses the updated NEPA regulations for Project evaluation. (63 3 [McClain, Krystle Z.])

B. The Scoping Document does not discuss how NRC will consider scoping comments.

1.

Recommendations for the Draft EA:

Create an appendix to include all comments received during the scoping period, including any comments from public meetings and all comment letters received. EPA

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suggests that NRC utilize an organized format to respond to agency and public comments as follows: reproduction of the original comment and corresponding NRC responses to those comments.

2.

Ensure the Draft EA is written in plain language so that it can be understood by a reader unfamiliar with energy projects. (63-2-4 [McClain, Krystle Z.])

C. EPA has assembled several resources to help NRC obtain environmental information when preparing the Draft EA.

Recommendations for the Draft EA:

1.

Consider the following databases:

a. EnviroMapper: https://enviro.epa.gov/envirofacts/enviromapper/search

b. Envirofacts: https://www3.epa.gov/enviro/facts/multisystem.html

c. EJScreen: https://www.epa.gov/EJSCREEN

d. NEPAssist: https://www.epa.gov/nepa/nepassist

e. 303(d) Listed Impaired Waters:

https://www.michigan.gov/egle/about/organization/waterresources/glwarm/integrated-report

f. National Ambient Air Quality Standards (NAAQS) status:

https://www3.epa.gov/airquality/greenbook/anayo_mi.html (63-2-5 [McClain, Krystle Z.])

Comment: A Purpose and Need Statement is Missing But Required There is no purpose and need statement appearing in the document the NRC considers to suffice for Holtecs Environmental Report.12 A purpose and need statement is required for an Environmental Impact Statement, 40 CFR § 1502.13, and also for an Environmental Assessment, 10 CFR §51.30(a)(1)(i).

12 The NRC staff has indicated that it considers Holtecs September 28, 2023, Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 (ADAMS Accession No. ML23271A140), specifically Enclosure 2, Environmental New and Significant Review Proposed Resumption of Power Operations Palisades Nuclear Plant, to suffice as a Holtec Environmental Report.

References in these comments to the Holtec ER are to ADAMS Accession No. ML23271A140.

(75-5 [Lodge, Terry J])

C.2.5.2 Comments Related to Process-NEPA Comment Summary 2 Comment: My wife and I are full-time residents of Palisades Park and live about 1/4 of a mile from The Palisades Nuclear Reactor. I am writing on behalf of myself and 150 homeowners in my community supporting the Petition that Alan Blind and Roger Rapoport submitted requesting that the NRC amend its regulations in Title 10 of the Code of Federal Regulations (per Mr.

Blind's submittal). (10-1 [Davis, Bruce])

Comment: The present owners of the Palisades Nuclear Power Plant are attempting to restart a shuttered plant which is an action that has never been performed in the United States before.

The NRC should exercise its mandated oversight authority and generate a new set of rules to govern the restart of a decommissioned nuclear plant - rules that go beyond the EA that is required of an operating plant who wishes to extend their operating license. An historic restart of a decommissioned plant presents additional risks over the continuation of an operating plant.

The safe restart is of paramount importance and is front and center to the NRC's mandate.

Please draft new or expanded rules to address this unique activity. (90-1 [Kleb, John])

Comment: What are my concerns about a Palisades Restart?

Broadly speaking, I have two concerns; 1) NRC Full Commission Must be Involved, and 2)

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project justification, cost and schedule. This is a matter of public interest given the use of State and Federal subsidies.

I petition the full NRC Commissioners to codify the process used to define the required, minimum design basis for Palisades. NRC staff recognizes there are no codified regulations for restarting, such as Palisades. Holtec is asking to use a modern process, meant for new plants, at the same time requesting a design basis that predated NRC design requirements, be used.

This is unreasonable and the full commission needs to step in and define the startup process for Palisades. (118-2 [Blind, Alan])

Comment: Since no nuclear plant has ever reopened after being shut down in the U. S., it is not known what safety hazards might crop up. We respectfully request that the NRC and the EPA develop an official formal protocol to determine the technical criteria that should be met before any nuclear power plant is restarted after shutdown. We neighbors of the Palisades Nuclear Power Plant do not want to be the unwitting guinea pigs to find out too late there should have been a set of standard regulations in place to protect us from any failures in restarting this 50-year-old plant.

We respectfully request that the NRC, DOE and EPA develop a protocol and thorough review before approving Holtec's restarting of the Palisades Power Plant. (120-2 [Grigola, Barbara])

Comment:

Dear Commission,

I humbly write to you today as a concerned citizen for our beloved Lake Michigan and the area I call home, Palisades Park. We our neighbors with the nuclear power plant by the same name. Our communities commitment to preserving our critical dunes and the natural habitat define us. The nuclear power plant was closed and sold to a decommissioning company Holtec. Holtec, who is not in the nuclear power plant business, now wants to reopen the plant for use. I urge you to stringently establish guidelines for this and all future plants that may want to reopen. To consider the sustainability and stability of our Great Lakes and the inability of Holtec to safely reopen. We are counting on you to regulate the process and consider all the ramifications of an older, neglected and closed nuclear plant. (121-1 [Diklich, Dolores])

Comment: This message is not against nuclear power but a reminder about safety. Palisades Park nuclear plant should not be opened without the NRC developing a standard to ensure the safety of area residents. The NRC or this company needs to develop protocol's to safely re-open the plant. (129-1 [Foresee, Peter])

Comment: Because it is referenced in comment A (use of Exceptions), attached is a pdf file of the Alan Blind / Roger Rapoport Petition for Rule Making, requesting an NRC Commission-approved process for returning a decommissioned plant to operational status. This request for rulemaking has been received by the Regulatory Analysis and Rulemaking Support Branch but has not yet been docketed. I understand this request is being reviewed outside the scope of this public meeting proceeding. Still, there is an intersection of arguments and basis between my comments to this preceding and the request for rulemaking. Evaluators of this public meeting comment should be aware, and reviewers of the petition for rulemaking should know both, including the outpouring of public support for both.

Also, I have attached a PDF file containing the signatures of residents who support my comment and petition. These residents live next to the Palisades Nuclear Power Plant. The number of signatories continues to increase, and the final list will be presented at the July 11 public meeting. (141-2 [Blind, Alan])

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Comment: The NRC should direct sta[ff] to write a new rule for returning a decommissioned plant to operational status and reinstating its operating license. A recent Petition for Rulemaking has been submitted to the NRC with this same request. (141-4 [Blind, Alan])

Comment: NRC General Counsel needs to review, and make public, the current use of the 2020 Petition for Rule Making Denial.

The Alan Blind / Roger Rapoport Petition for Rule making for a NRC Commission-approved process for returning a decommissioned plant to operational status, includes additional arguments and a solution for relicensing to go forward, while maintaining public health and safety with full transparency. (141-6 [Blind, Alan])

Comment: As a better approach, we request the NRC agree with our petition for rulemaking to include an NRC Commission-approved process for returning a decommissioned plant to operating status. This provides us all the same set of rules for Palisades and for future plants that may be making the same request. (143-14-3 [Blind, Alan])

Comment: And I have heard -- and, you know, you can clarify me, if I'm wrong or not -- but the rules, there is no roadmap for this because you've never done it. There's no roadmap for a plant that's been shut down, and now, how are we going to restart on environmental safety evaluations?

So, when you do this roadmap, let's make sure it's at least as critical as if plant was just getting recertified. Because this plant is unprecedented. Shut down. Now, you know, all these safety issues. It is an old plant.

And so, I just hope keeping that scope and that perspective on how you unique this is and how it will impact probably the future when plants have to restart up. (143-18-3 [Cordell, Cyndy])

Comment: First and foremost, before I start, I want to submit the signatures of the homeowners of Palisades Park endorsing Mr. Alan Blind's proposal for rulemaking. (143-26-1 [Davis, Bruce])

C.2.6 Comments Concerning Outside Scope - Aging Management Comment: There are now immense financial / political pressures pushing toward re-starting the plant. Please be constantly aware that many of the worst catastrophes occur when such pressures over-ride intuition, integrity, and the strict application of established norms and regulations. (A recent case is the Boeing Max airplane.) This concern is heightened in the current case, given that strictly speaking there are no established regulations for re-starting a fully de-activated plant, since it has never happened. Palisades is one of the oldest reactors in the country, and already had a number of exemptions when it closed. (8-1 [Moevs, Christian])

Comment: Hello, what is the status of the Palisades investigation into reactor vessel embrittlement? Have vessel coupons been tested since 2019? The vessel likely needs annealing, and this should be addressed prior to restart. Please advise. (26-1 [Paver, John])

Comment: How can the NRC possibly authorize the restart of power generation at the Holtec Nuclear plant after 50+ years of very troubled safety flaws under the operation on Consumers Power & Entergy Corp?

This plant was shut down prematurely due to the failure of its critical Control Rod Drive Mechanism, which has been a recurring very poor safety issue for many years.

Why would the NRC ignore the worn-out condition of the old reactor vessel hood, that has been rated as the most dangerously embrittled in the entire industry?

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Deteriorating plant piping has caused Tritium & radionuclide leaks into the plant property soil that has been documented for years. (66-1 [Reed, Dillon])

Comment: There Are Cumulative Risks and Environmental Impacts from Unreplaced and Un-refurbished Plant and Equipment Which Must Be Identified and Analyzed as Potentially Damaging to the Environment Concerns, usually framed as safety-related, also implicate potentially large negative environmental impacts. A Palisades reactor core meltdown at the Palisades reactor would have large environmental impacts for the Great Lakes region. Palisades has long had multiple high-risk pathways to meltdown, including the single worst neutron-embrittled reactor pressure vessel in the country,13 at risk of through-wall fracture. The plant has steam generators and a reactor vessel closure head, or lid, that have needed replacement for two decades.

Full replacement of the steam generators at Palisades may well be required,14 at a cost of $510 million. In mid-2022, Holtec had paid some lip service to repairing tubes, or even entirely replacing the stream generators (at a cost of $510 million), in a secret bailout application toDOE,15 obtained from the State of Michigan via a Freedom of Information request submitted by Beyond Nuclear. But recently, Holtec spokesman Nick Culp revealed the company no longer plans to repair or replace the dangerously age-degraded steam generators.16 Although Holtec seems to ignore the need to also replace Palisades reactor vessel closure head, previous owner Consumers Energy acknowledged the need to do this as long ago as May 2006.17 Replacement of the reactor vessel closure head also represents another significant construction impact.

Another significant construction impact is the need to address chronic control rod drive mechanism (CRDM) seal failures. A CRDM seal leak forced Entergy to close Palisades 11 days earlier than planned, on May 20,2022. Palisades has suffered CRDM seal leaks since 1972, a uniquely bad operating experience, as documented by David Lochbaum, retired Nuclear Safety Project director at Union of Concerned Scientists.18 As Lochbaum concluded, little more than band-aid fixes have been applied to this chronic problem at Palisades. The root cause and a comprehensive solution - that is, preventative corrective action - has never been achieved at Palisades, not in more than a half-century. 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 - risk that must be quantified and analyzed. Around a decade ago, Entergy chose to entirely replace its CRDM infrastructure. In the course of the work, 192 workers were exposed to high radiation doses during this near-core job, including young women of child-bearing age.19 Despite this complete replacement of CRDM infrastructure, Palisades continued to experience CRDM seal leaks during its last several years of operations.

Additionally, there are additional problems with Palisades physical structure that are extraordinary and reveal that the physical condition of the Palisades Plant deteriorated terribly while Entergy was the owner. There are many examples of this degradation, including but not limited to:

-The steam generators must be manufactured and constructed for the second time.

-The reactor is dangerously embrittled because the wrong welding material was used in 1969 during manufacture.

-The reactor head has needed replacement since at least2009, which may account for continuing Control Rod Drive failures, which Palisades is infamous for.

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-The interior piping has become excessively radioactive and needs to be cleaned with caustic chemicals to reduce radiation exposure. (Item#6, $25 Million

-Physical improvements to the switchyard are also identified (Table 3, Item #2) and require new construction.

-Incredibly, Entergy appears to have sold its inventory of safety-related replacement parts, forcing Holtec to spend at least $18 Million to find NOS (New Old Stock) replacement parts on eBay!

-The Flow Accelerated Corrosion Program, similar to the failed program at the Surry reactor in Virginia that caused the death of four staff members at the Surry reactor when a pipe ruptured, must be recreated (Item# 5b Table 2, $ 4 million).

-The safety-related wires operating the Control Rod Drives and Incore instrumentation have degraded and require construction (Item# 8, $16Million).20 13 NRC letter 4/18/2013, http://pbadupws.nrc.gov/docs/ML1310/ML13108A336.pdf 14 Holtec DOE Application, pp. 4, 7, https://beyondnuclear.org/wp-content/uploads/2023/10/7-5-22 page-Holtec-application-to-DOE-for-CNC-funds-to-restart-Palisades.pdf 15 https://beyondnuclear.org/5775-2/

16 https://beyondnuclear.org/wp-content/uploads/2024/07/ni240405-1.pdf 17 http://archives.nirs.us/reactorwatch/licensing/kampsconsbrifeinf051806.htm 18 Lochbaum, Headaches at Palisades: Broken Seals and Failed Heals, https://www.nrc.gov/docs/ML1035/ML103540571.pdf 19 https://archive.beyondnuclear.org/safety/2014/12/11/nrc-cites-palisades-for-worker-radiological-safety-violation.html; NRC White Finding, https://adamswebsearch2.nrc.gov/webSearch2/view?AccessionNumber=ML15056A072 20 Declaration of Arnold Gundersen, pp. 16-17, https://beyondnuclear.org/wp-content/uploads/2023/12/12-5-23-CURRICULUM-VITAE-Palisades-APPX-10-COMPILED.pdf (75-7 [Lodge, Terry J])

Comment: Now Holtec plans to continue to run Palisades into the ground, with at best inadequate monitoring and minimal repairs. In mid-2022, Holtec had paid some lip service to repairing tubes, or even entirely replacing the stream generators (at a cost of $510 million), in a secret bailout application to DOE (https://beyondnuclear.org/5775-2 /), obtained from the State of Michigan via a Freedom of Information request submitted by Beyond Nuclear. But recently, Holtec spokesman Nick Culp revealed the company no longer plans to repair or replace the dangerously age-degraded steam generators. ("Palisades Restart Still Faces Significant Hurdles," by Jessica Sondgeroth, NUCLEAR INTELLIGENCE WEEKLY, Vol. 18, No. 14, April 5, 2024.) (https://beyondnuclear.org/wp-content/uploads/2024/07/ni240405-1.pdf) (76 8 [Kamps, Kevin])

Comment: Continued operation of an aging nuclear plant well into the century will also most certainly present substantially elevated challenges, especially with respect to changing climate and other conditions over which neither the Nuclear Regulatory Commission (NRC) nor the site licensee will have control.

We submit the many uncertainties and risks emerging even today caution strongly against pushing aging machines past their limits. Moreover, the vast array of issues related to existing nuclear waste - of all classifications - remain unresolved after nearly 80 years.

Facilitating generation of even more radioactive wastes is feckless and irresponsible.

The general challenges, harms and risks attendant to relicensing operational reactors beyond their second 40-year relicensing period are expanded to an untenable degree with

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respect to The Palisades Nuclear Plant (Palisades), which has been shut down for years. (77 2 [Lee, Michel])

Comment: Aging-related deterioration of buried or otherwise inaccessible or difficult-to-inspect piping, electrical cables, concrete and other equipment and structures must be assumed to be present.

Incontrovertibly, there are significant technical knowledge gaps in the engineering and scientific understanding of age-related deterioration mechanisms (e.g., alkali silica reaction, neutron embrittlement, stress corrosion, etc.).

Yet the NRC has failed to mandate the harvesting and independent lab analysis of aging components, equipment, and structures from U.S. nuclear sites. Instead materials are being sold for scrap or sent out for disposition at storage facilities. Perhaps even more troubling, the NRC has acknowledged that it allows the licensees of decommissioning sites to destroy plant operational records. This means that readily available and cheap to maintain aspects of the paper/digital record which could flag developing problems and critically inform the extended operation of reactors are being irretrievably lost. It is most troubling that original records in the possession of Entergy were not retained.

What this boils down to is the fact that computer models used to rationalize continued running of plants beyond their originally planned lifetime have not been validated.

The NRC must not continue to rely on its Maintenance Rule as a means to evade recognition that components, equipment, and systems - including metals, welds, electrical cable, and concrete - age. For one thing, maintenance, as many NRC inspection reports attest, is not always done and is not always done correctly. For another, NRC regulations are not devoid of imperfection. Further, the history of industrial accidents, including nuclear accidents, demonstrates that failure of components, equipment and systems which are not considered technically necessary for safety can initiate or accelerate the severity of an accident. (77-1-17 [Lee, Michel])

Comment: Please carefully consider what is at stake BEFORE moving forward with the reopening process of the Palisades Power Plant.

This is NOT an anti-nuclear response. This is grave concern for starting up an old plant that has been plagued with issues for years. It has NOT been maintained, it has NOT received the necessary regulatory controls or updates that operating plants are required to have. This is about a company being given billions of dollars to do something they have never done before.

Please read the following for context...

1971 Palisades Power Plant, owned by Consumers Power, went online. Its design was approved for 40 years. At its construction, questionable welding material was used to hold the nuclear reactor, which is now 53 years old. Instead of having one facility to build the reactor and deliver it completed to the site, which was the usual procedure at the time, five different companies constructed the plant on site. It has a bad history of shutdowns due to failures of critical equipment, broken fuel rods and fuel-spill incidents.

1973 Plant shuts down Jan.16 after pinhole-size leaks develop in the steam generator tubes.

1973 Plant shuts down again in August for more than a year after another leak develops in steam generating system, in addition to other problems.

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1974 Consumers Power Co. files a $300 million lawsuit against suppliers of various components. Consumers contend the five firms sold it "defective equipment." Suppliers reached a settlement out of court for $14 million.

1982 February, Hydrogen explosion in turbine generator building injures contract employee.

1988 August, plant shuts down because of a steam generator leak. It shuts down again on Dec. 6.

1993 December, The NRC releases a report giving the plant its lowest scores in engineering and plant operations.

1994-1973 The plant is fined over $574,000 for safety violations and shut down over twenty times for malfunctions. Some shutdowns last as long as 19 months.

2001 Nuclear Management Co. takes over management of Palisades from Consumers.

2005 Nuclear Management Co. begins the license-renewal process with the NRC.

2007 The NRC renews Palisades license for 20 years, to run through March 2031. Entergy Corp. purchases Palisades from Consumers Power. In December, Tritium was found in a test well at Palisades, eventually traced to corrosion of underground pipes. The plant's test results find water with a tritium level of 22,000 picocuries per liter, 2,000 picocuries above the reportable level for drinking water, according to the Environmental Protection Agency. As reported and Chronicled using Kalamazoo Gazette Archives 2011 Entergy's application for extension included a plan to moderate the degradation of the plant, but that plan was not followed. NO monitoring has been done, NO chemicals added to water, which should have been done and NO fuel purchased for maintenance. It takes 2 yrs. to build fuel. NRC extended licensed to 2031.

2022 May, Entergy shut down before expiration because of concerns over a faulty control rod drive seal. It was no longer economical to operate the plant. It was now one of the most expensive sources of power in Michigan from one of the oldest plants. Renewable energy was a more economical alternative. Entergy deferred maintenance modifications because they knew it was closing. Consequently, the plant has questionable welding, steam generator and control drive problems.

2022 June, Holtec International purchased from Entergy to decommission, as a DEMO contractor. The NRC makes an EXCEPTION and grants Holtec Entergy's license. Holtec is NOT a nuclear company, they have NEVER built or operated a nuclear power plant. They purchased it so they would be paid to knock it down and sell it for scrap.

2022 September, Holtec applied for funds from Civil Nuclear Credit to reopen the plant. This request was denied. Did Holtec ever have intentions to decommission? They accepted the funds for it.

2024 March 27, US Energy Dept. loans $1.5 Billion to help fund Holtec's bid to reopen the plant.

This is the first time a US plant would be back on the grid after decommissioning.

2026 Holtec's intended start-up date. Holtec must receive an operating license and other approvals from the U.S. Nuclear Regulatory Commission.

2031 Palisades license to expire. Holtec plans to request a license renewal that will allow it to produce power through 2051. (112-1 [Anonymous, Anonymous])

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Comment: Physicist Edwin Lyman, director of nuclear power safety for the Union of Concerned Scientists, said "Holtec has taken on an aging plant, lying fallow now for a couple of years without the maintenance and regulatory controls that operating plants are under. That regime is going to have to be restored, and there will have to be verification that the NRC is going to be able to have assurance that things haven't happened in the meantime, that would further compromise the safety of trying to restart the plant." (112-4 [Anonymous, Anonymous])

Comment: My husband and I have great concerns about the safety of the process being utilized to reopen the Palisades Nuclear Plant. It is our understanding that some maintenance had been deferred as the aging plant approached the end of its anticipated lifespan and the 2031 end of its license. To restart the plant without addressing these issues could put the residents of Covert, South Haven and the nearby towns in jeopardy. (120-1 [Grigola, Barbara])

Comment: Our family grew up in Palisades Park, the cottage community immediately south of the power plant. Over the years, we grew increasingly concerned with the number of safety and maintenance violations at the plant. We were relieved when the decommissioning was announced, as this plant has clearly lived its useful life. When the closure became imminent, necessary maintenance and investment was deferred as being unnecessary. (124-2 [OBrien, Terry])

Comment: 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. (131-2 [Cordell, John])

Comment: Our concerns include:

-The Palisades Power Plant sits on the shores of the largest freshwater system in the world. To jeopardize this in any way would, of course, be unthinkably shortsighted and self-destructive.

-The plant was very old when it was shut down. It had a history of *minor" accidents. Normal maintenance had been neglected in its final years.

-Restarting a defunct nuclear power plant after it has been permanently shut down has, wisely, never been done in the U.S. This plant was shut down for multiple significant problems as well as advanced age. It hardly seems like a wise choice for this type of first-time restart. (133-2 [Goetzinger, Laurel Eldredge])

Comment: The plant is embrittled. It's a ticking time bomb. No matter how many repairs that should have been done before are done to the plant, it's never going to be safe because it's old; it's embrittled. It has little fissures in there from all the nuclear reactions that it's gone through, and you shouldn't ever take a risk that huge to start it up. (143-16-2 [Barnes, Kathryn])

Comment: I have several concerns and a lot of them have to do with the degraded condition of the plant and the lack of repairs that were done. But many people have addressed those issues. (143-23-1 [Pierman, Bette])

Comment: The Palisades facility is over 50 years old, and with age comes an increased risk of catastrophic failure.

Even though the potential for an accident is statistically low generally, the potential at such an aged facility is concerning.

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Regardless, if it happened, we wouldn't be quibbling about the low probability because it would be devastating not only to those in the immediate vicinity, but to the wider region. (143-40-3 [Cabala, Tanya])

C.2.7 Comments Concerning Outside Scope - Emergency Preparedness Comment: 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! (13-2 [Stranger, Karen])

Comment: What kind of measures will be taken to indemnify local residents should there be an accident that compromises our health and makes our property worthless? Who will be responsible for the billions of dollars needed to provide long term health care and compensate property owners? Surely not Holtec as they will declare bankruptcy. We need assurances that such compensation will be provided.

If you authorize Holtec to restart the plant, please make sure we residents are protected. (72-3 [Hoskin, John])

Comment: We also are requesting a non-revocable fund be established by Holtec Palisades, Holtec International, and the State of Michigan for past & future issues affecting adjacent communities of human life, and the adjacent environmental issues caused from this Nuclear Power Plant. The fund would be a minimum of 1% of Government loan or Revenues generated, whichever is greater, for life of operating plant + 25 years.

Thank you for reviewing and I look forward to your approval of fund if this Holtec project is approved. (74-4 [O'Brien, Kevin])

Comment: The impact of the changing climate and the chaos attendant to extreme weather is relevant not only to the risk of initiating (slowly or rapidly) an accident, but to mitigation capability. Mitigation relies upon reliable communication, transportation infrastructure and rapid response capability with strong situational awareness. Nobody who has picked up a newspaper over the past few decades could reasonably assert these conditions are a given.

Looking forward into the century, it is no longer valid to assume that the necessary level of access or emergency response capability will be available. (77-1-15 [Lee, Michel])

Comment: The state says we must be responsible for our own safety if we live within ten miles of a nuclear plant. Please tell me how we do that? The latest information from Holtec said they decided to dismantle the warning sirens that alerted our community. How are we to protect ourselves? I am doing the only responsible thing I can do; I am asking for your assurance that you look at this carefully and reconsider reopening the plant. (112-8 [Anonymous, Anonymous])

Comment: and [we] feel Holtec and the State of Michigan & the United States of America shall establish a non-revocable fund of minimum of 1% of loan &/or revenues generated, whichever is greater, by Holtec Palisades aka Holtec International for current & future issues with Human life & environment adjacent to Holtec Palisades project in Covert, Michigan USA. I look forward to your reply including requested statistics and approval of our requested fund. (140-4 [O'Brien, Kevin])

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C.2.8 Comments Concerning Outside Scope - Energy Costs Comment: Any presumed benefit from generating electricity from nuclear power is exaggerated and overpriced. Solar panels could be installed for more quickly and much more safely than Gerry-rigging the old Palisades NP back into operation. (5-5 [Muhich, Mark])

Comment: Second and third are that the timeline restore/restart will run this plant out to 80-100yo or more. The upkeep and regulatory watch plus investments to maintain, repair and rebuild would be better spent giving that money to people of west Michigan to replace all their HVAC with geothermal units (closed loop only) than to Holtec Company for personal wealth accumulation. The money to geotherm build would go to safe already existing solutions that would create far more jobs for many more people for many, many years, reducing the ever-popular pollution emissions equation and be a real boon to the people and surrounding states.

And that doesnt risk Lake Michigan ever. (33-7 [Birdsall, Sheila])

Comment: Please stop pretending this is a great idea. Its a money-making scheme between the State of MI and Holtec rolled into a political selling point. Its a disaster for the future dumped in our kids laps, AGAIN. Meanwhile that money could be infinitely better invested in clean futures succeeding in 10 years to lower fossil emissions, reduce electric use and open industry here in west Michigan instead of a 20+ yrs rebuild of fragile nuke plants and their frighteningly hideous waste materials. (33-8 [Birdsall, Sheila])

Comment: Consumers Energy's decision to divest from Palisades in 2007 was a clear indicator of the financial and public risk associated with the plant. Subsequent ownership by Entergy and their reluctance to invest further underscores the precarious state of the facility. The high costs associated with nuclear energy, which is the most expensive form of energy, should be a red flag for us all. It is an outdated and inefficient solution to our energy needs, especially when compared to the rapidly advancing technologies in solar and wind energy. (46-2 [Schalk, Tracy])

Comment: We have solar and wind that could be built with the money being spent to restart the nuclear plant. (48-2 [Munski, Donald])

Comment: Cost of Nuclear Energy Since 2007, the capacity factor for nuclear energy has been flat. Even though nuclear energy's capacity factor improvements have been flat, the operating costs of nuclear energy have dropped by 17% since 2012 without considering inflation. If nuclear energy's operating costs were adjusted to real dollars, the effective cost drop would be even more. Nuclear energy operating costs are already low. (57-4 [Gibson, Robert])

Comment: NRCs regulations for draft EISs require analysis that includes consideration of the economic, technical, and other benefits and costs of the proposed action and alternatives.24 NEPA also allows agencies to include reasonable alternatives not within the jurisdiction of the lead agency.25 Because DOE is planning to provide a federal loan of $1.5 billion, and NRC is the lead agency, both agencies should be considering whether such funds would be better invested in building renewable generation or energy efficiency infrastructure -

not just at the site of the Palisades plant, but throughout Michigan and the area where energy that would be generated by Palisades would be utilized. Such analysis should, for example, compare the cost of the restart, long term benefits, and risk of radioactive waste entering Lake Michigan, with the cost, long term benefits, and environmental risks of a mixed-renewables design. (73-5 [Lowy, Rebecca])

Comment: In this regard, it is worth noting that the cost of any catastrophic accident, the cost of the transportation of nuclear waste, and the cost of safeguarding all of what would be Palisades

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additionally generated high-level nuclear waste (not to mention the waste which has already been generated) is born principally by the public.

All of these costs must be quantified by independent impartial actors and transparently revealed and analyzed in an EIS.

As the industry reaps the profits - and Holtec benefits from billions in federal and state subsidies - it is communities and the American public which bear the incalculable risks inherent in running these old nuclear plants long past their originally planned operation and safeguarding their waste products for literally millennia. (77-1-9 [Lee, Michel])

Comment: The placement of accident risk burden upon the public.

The 1957 Price-Anderson Act absolves nuclear plant operators - as well as firms involved in nuclear construction and maintenance - of most of the liability for damages in the event of a major accident. The 1957 act was supposed to be a temporary measure, needed until the private commercial nuclear industry and insurers gained some experience with the new nuclear power technology. Yet the industry has successfully lobbied over past decades for liability caps under the Price-Anderson Act and the insurance industry has shown no interest in underwriting policies for nuclear accidents.

The industry and insurers deem the financial risks of a rare but consequential event too alarming to shoulder. That fact alone necessitates their incorporation into the scoping process and honest disclosure in the EIS. (77-1-16 [Lee, Michel])

Comment: Part of the equation will be the additional costs and complexities of ultimate decommissioning and remediation of the site. (77-2-2 [Lee, Michel])

Comment: Should the EIS postulate the removal of spent fuel from the Palisades site, waste transportation costs must be included in the accounting, with acknowledgement that the level of spent fuel transportation risk is unique to the energy sector, substantial in sum, and will likely be borne by the public. The calculus of costs should include security, first responder and emergency planning, equipping, training, and staging costs. (77-2-4 [Lee, Michel])

Comment: Independent studies, including the World Nuclear Industry Status Report, have shown that nuclear energy does not meet any technical or operational needs that cannot be better addressed by low-carbon competitors. Investing in nuclear energy is a waste of taxpayer money that could be better spent on more innovative and effective solutions. (108-5 [Quinn, Francis])

Comment: The plant cannot produce and sell power without being subsidized by hundreds of millions of dollars of taxpayer dollars, our money. Recognizing both the economic and safety reality, Entergy shut down the plant and sold the plant to Holtec for decommissioning. (110-4 [Scott, Ann])

Comment: We live very near the former Palisades Nuclear Power plant that Entergy closed in 2022 even though there was a license extension in effect until 2031. Entergy did so because the cost to bring the plant up to safety standards well exceeded any revenue that could be earned.

Simply put: IT BECAME UNECONOMICAL. (111-1 [Huffman, Mary])

Comment: None of this adds up. Billions of tax dollars at stake for six hundred jobs? The state could build, staff and power renewable energy for much less. (112-2 [Anonymous, Anonymous])

Comment: Basic project management requirements include firm scope definition. Given the large number of unknowns stemming from the lack of information of equipment condition, especially the steam generators, and unknown number of safety upgrades, and lack of an

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agreed upon design standard and NRC inspection program, it is impossible for any company to plan out, schedule and cost estimate a large project such a Holtec is proposing. Given even the current cost and schedule estimates, the project cannot possibly be in the state, federal, and rate payers interest. (118-3 [Blind, Alan])

Comment: And I'm an independent nuclear energy supporter, where I just love to have the cheap electricity that's clean. I'm going to be living here for a long time and I'm going to be experiencing the impact of climate change. And luckily, nuclear energy is a great way to address that. And so, I really hope that the NRC takes that into account. We should be taking a cost-benefit analysis to this. (143-15-2 [McLean, Michael])

Comment: Another thing that we're not pricing out is the cost of the nuclear waste, because we can't price out the cost of the zillions and I'm sorry for using that silly word, miles of transportation of nuclear waste from here to there.

And moving it to, from one place to another, and the plans to move it to New Mexico, and from there to move it to a deep geologic repository. These are costs that should be priced out. (143-38-3 [Boudart, Jan])

Comment: One speaker mentioned the high power costs in California. Well, as a Californian, I am well aware that the high electricity costs impacting customers of investor owned utilities in California, or the Diablo Canyon as well as the now shutdown San Onofre nuclear power facilities.

Also, the suppression of rooftop solar in recent years hasn't helped. (143-41-3 [Campbell, Bruce])

Comment: So, I did want to talk about the jobs that were mentioned a number of times tonight.

I've been trying to follow the bailouts proposed requested to Holtec. $300 million from the state has been approved, unfortunately.

Another $1.5 billion in loans by DOE on March 27. So that's $1.8 billion thus far.

But it's the tip of the iceberg. The figure that I have but it's not all encompassing because the subsidies continue. Some of them are general in nature for the whole country, but Holtec will benefit.

But specifically to Palisades, I have added up $8.3 billion. $8 billion $300 million dollars in requested bailouts related to the restart.

And another additional $7.4 billion requested from the Department of Energy in nuclear loan guarantees, for the construction and operation, as well as the design certification of these two SMRs at Palisades itself. And perhaps more at Big Rock Point. (143-42-1 [Kamps, Kevin])

Comment: The company has admitted that only 280 jobs will be restored by this restart. So you divide $8.3 billion by 280 restored jobs and you're pushing $30 million per restored job. This is of course, absurd.

So, opportunity costs have been mentioned tonight. In the state of Michigan last year, state subsidized job creation averaged $29,000.00 per new job created.

That makes this proposal for the restart in terms of job creation, 1,000 times more expensive than the state average.

So, in your environmental review for the restart, I would urge you to look at what other societal benefits could be purchased for $8.3 billion. Even just in the energy sector. (143-42-3 [Kamps, Kevin])

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C.2.9 Comments Concerning Outside Scope - Miscellaneous Comment: 5. ENERGY EFFICIENCY AND ENVIRONMENTAL BEST PRACTICES A. The Applicant indicated a daycare, visitor center, parking garage, and training facility are proposed.3 Energy efficient design and material selection for construction of the proposed Project could reduce operation costs while also protecting the environment and further reducing climate change effects.

Recommendations for the Draft EA:

1.

Consider permeable pavement or porous pavers as an alternative to asphalt or gravel to reduce runoff from the daycare, visitor center, and training facility. If asphalt is selected, consider green stormwater management practices to filter stormwater before reaching waterbodies (e.g., bioswales).

2.

Consider replacing carbon-intensive Portland cement in concrete.

3.

Consider the use of energy-efficient and/or sustainable building materials (e.g., south facing skylights and windows, motion-sensor lighting) for the daycare, visitor center, and training facility.

3 Page 23 of Environmental New and Significant Review. (63-1-13 [McClain, Krystle Z.])

Comment: I'd like to know that if NRC, who has not had had strong checks heretofore on this plant up to today, is willing to assure the public through monitoring wells/sources throughout Palisades Park Country Club and other local areas including water tests and adhere to strong oversight, at minimum.

Very disappointed. (86-3 [O'Connor, Gerry])

Comment: Our state should prioritize: Expanding transmission capacity; Investing in large-scale solar and wind energy installations; Developing energy storage solutions to stabilize the grid; Enhancing energy efficiency and demand response programs; Removing barriers to distributed and community-owned energy generation.

By focusing on these areas, we can meet our energy needs without the risks and high costs associated with nuclear power. (108-6 [Quinn, Francis])

Comment: Nuclear energy is risky, dirty, dangerous, slow, and expensive. Instead, our state should be pursuing our cleanest, quickest, safest, and cheapest energy options. -Saddling our state with the high costs and the dangers of nuclear energy is not needed to ensure Michigan will continue to have reliable power. Palisades hasn't been providing power for two years now.

We've heard over and over that companies considering investment in Michigan have passed on our state because we do not have functional public transit, and this is what we are investing in?

How many homes could be insulated, solarized and converted to non-fossil fuel heating sources instead? With $300 million let alone $1.5 billion from feds for this. Think of how many more jobs we could create? Rather than doubling down on this risky plant we should be:

-Enabling new transmission capacity throughout our region;

-Expanding and expediting investments in large-scale solar and wind energy installations;

-Developing more utility scale, residential, and commercial storage capacity to provide energy in high demand times, further stabilize the grid and incur less cost to residents;

-Ramping up efficiency and demand response programs to help residents and businesses conserve energy, save money, and shave peak demand;

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-Removing the barriers and restrictions on distributed and community-owned energy generation;

-Seeking the best and most innovative solutions for Michigan's power needs.

For example, Green Mountain Power in Vermont taps into homeowners' batteries during peak times, lowering the cost and peak demand of electricity for all -Many independent voices and studies show that with a combination of renewables, energy efficiency, storage, demand response, and things like distributed generation, we can absolutely meet our energy needs without nuclear. This is just a waste of taxpayer money.

According to the independent World Nuclear Industry Status Report, nuclear energy "meets no technical or operational need that low-carbon competitors cannot meet better, cheaper and faster." (109-4 [Ferry, Carolyn])

Comment: The U.S. defense establishment has been tasked to move to a zero CO2 energy consumption policy. The USN has two major advantages in doing this. First, the only reliable zero CO2 replacement for base load is nuclear power with which the U.S. has decades of experience with small (almost modular) nuclear power plants used on many of its ships especially submarines; and second, most of its large bases are located in coastal areas. To get a quick start on such a project, the U.S. could consider the refueling and reuse of many mothballed reactors currently on hand. These were designed to be used in a floating submersible platform and could likely quickly be rehoused in a large pre-stressed concrete pressure vessel -a large diameter pipe with two hemispherical end caps -designed to float vertically in the water column -possibly moored underwater deep enough to avoid surface shipping and wave action and tsunamis. Placed three miles offshore, the U.S. will only have to deal with Federal environmental and safety regulations which have already been demonstrated by decades of accident-free operation of its reactors. A U.S. owned undersea power cable can deliver stable base power directly to Naval installations and perhaps sell excess power to civilian power operators. The U.S. could also consider using new nuclear power plants that were recently designed for the Virginia and Columbia class submarines which are now coming online

-if production can be ramped up without causing problems in delivering new submarines as contracted, Once the U.S. has demonstrated that this is a safe and viable concept to provide shore power, it could lead to more widespread adoption of commercial siting using the numerous modular designs now available.

Perhaps this will be a reason to look at floating modular thorium molten salt nuclear fission reactors that are inherently safe and produce little waste to provide reliable base load power for the country (and possibly for export as these reactors do not use bomb materials). Floating reactors can be positioned in the Pacific Ocean, Arctic waters, the Gulf of Mexico, and the Atlantic Ocean as most of the population is near coasts and they are out of sight under water and likely over the horizon as well -yet relatively near where the power is needed. Many land-based nuclear power plants are reaching the end of their life and are being shut down with few, if any, replacements. The International Energy Agency published a report (JUN 2919) declaring that without more nuclear energy, global carbon dioxide emissions will surge and "efforts to transition to a cleaner energy system will become drastically harder and more costly." How costly? The IEA estimates that "$1.6 trillion in additional investment would be required in the electricity sector in advanced economies from 2018 to 2040" if the use of nuclear energy continued to decline. That, in turn, would mean higher prices, as "electricity supply costs would be close to $80 billion higher per year on average for advanced economies as a whole. New land based nuclear generating plants will be expensive and tied up for years (forever?) in litigation; while floating nuclear plants -more than three miles offshore -will only need Federal regulatory approval and have no land acquisition costs (or neighbors). The only leverage any state has is to regulate these commercial nuclear plants are the undersea transmission lines -

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but they will likely have to issue such regulations to accommodate offshore wind farms (with new model turbines able to produce twelve megawatts each) and it will be difficult (if not impossible) to discriminate transmission regulations based on the power source -indeed, it will likely be cost effective to place the floating modular nuclear plants further out to sea (where they are largely immune to tsunami issues) and then just run undersea cables to use the wind farm grid, transmission lines and shore stations. Note that the wind farms themselves may be more than three miles offshore for aesthetic reasons. Nuclear startup NuScale has received (SEP 2020) a landmark final safety evaluation report (FSER) for its 50 MW (moving toward 60MW) modular reactor design. NuScale's design uses classic nuclear fission water reactor technology but is a natural circulation light water reactor with the reactor core and helical coil steam generators located in a common reactor vessel in a cylindrical steel containment. The reactor vessel containment module is submerged in water in the reactor building safety related pool, which is also the ultimate heat sink for the reactor. The pool portion of the reactor building is located below grade. In the event of any runaway reactor event, the reactor quenches itself in its pool, making it "passively safe". The small size and tall cylindrical form factor is a good fit with a vertical floating reinforced concrete capsule design where the reactor will be below sea level -

a potential second layer of passive coolant. This design could come online quickly while a thorium molten salt design is perfected. (135-1 [Bibee, Bruce])

Comment: The biggest issues that anti-nuclear power people and organizations cite are safety issues related to siting near population centers which is where the power is most needed (largely eliminated by the new passive safe designs); and the disposal of radioactive waste The Federal government is bringing online processing plants that can reliably take care low and medium level waste. High level waste is actually very valuable, and it consists largely of 'spent' fuel rods which can be reprocessed into new fuel if there is the political will to do so -especially if the market for fuel expands with a large number of new and/or repurposed reactors. This highly radioactive end product produces a lot of heat, which is why they sit in cooling ponds for years on end wasting this resource. The thermal atomic battery is any device that converts the heat emitted by radioactive isotopes to electricity. Like nuclear reactor, the power generated by thermal atomic battery is ultimately derived from atomic energy. However, atomic battery relies solely on the spontaneous radioactive decay of atomic nucleus, rather than artificially triggered nuclear fusion or fission in a nuclear reactor. Although currently costly, an atomic battery has an extremely long-life span and high energy density compared to a chemical battery. Therefore, they are usually used in situations requiring long operation without battery replacement or recharging, such as unmanned scientific deep seabed facilities, unmanned underwater vehicles, (all of potential use to the USN) and etc. The atomic battery can be categorized by the form of energy converter and radioisotopes that it uses. The thermal atomic battery converts the atomic energy into heat first and then electricity. While thermal-to-electric conversion techniques have been studied extensively, there are many of them that are available to be generalized to heat source powered by radioisotopes. To date, thermal converters include the following forms:

thermionic converter, radioisotope thermoelectric generator, thermos-photovoltaic cell, alkali-metal thermal to electric converter, and Sterling radioisotope generator.

The conversion of atomic energy to heat is quite simple. In thermal conversion atomic battery, the radioisotope, called fuel, is placed in a container. Alpha particles generated by alpha decay or beta particles generated by beta decay can easily interact with atoms of shielding materials and lose energy. This part of energy is dissipated in the form of heat. Therefore, the container and the radioisotope itself are used as heat source in thermal conversion atomic battery.

In thermionic converter, the heat generated from radioactive decay is used to heat a hot electrode to emit electrons through thermionic emission at temperature 1500-2000°K. The emitted electron is collected by a cold electrode. Plasma, usually consisting of Cs vapor, is

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maintained between the two electrodes to reduce the work needed for electron emission, magnify the current to increase efficiency and modify the electron conducting property between electrodes. The efficiency can also be increased by lowering the potential difference between the top of the potential barrier in the interelectrode space and the Fermi level of the anode.

However, in practice, the efficiency of thermionic converter can be close to 20%.

Radioisotope thermoelectric generator makes use of Seebeck effect to directly transfer the temperature difference between heat source and heat sink to electricity. Its structure is quite simple. The hot end of a thermopile is attached to the heat source, and its cold end is attached to the heat sink, usually the ambient temperature. Thermopile for power generation is usually made of pairs of connected P-type and N-type semiconductors. In presence of temperature difference, the velocity of charge carrier in both semiconductors is different, which forms current.

Due to its simplicity, radioisotope thermoelectric generator is very reliable and can be made very small, and thus widely used in spacecraft. However, the efficiency of this converter is very low, about 7% in practical use. One possible way to improve efficiency is to hybridize the system with another converter. The working temperature of a typical radioisotope thermoelectric generator is much lower than that of thermionic converter. The hot end temperature is 811°K while the cold end temperature is 394°K. low, about 7% in practical use. One possible way to improve efficiency is to hybridize the system with another converter. The working temperature of a typical radioisotope thermoelectric generator is much lower than that of thermionic converter.

The hot end temperature is 811°K while the cold end temperature is 394°K.

There are at least three possible uses for high level waste, two of which can significantly overlap with US operations. First, both the US and the scientific community would like to place sensors on the deep seabed that would sit passively and collect / transmit data for long periods of time.

Both the US and oceanographic research would be interested in environmental data while the US would be most interested in acoustical tracking of enemy surface and sub-surface military activity, and the research establishment in seismic, salinity, current flow, temperature, and other such data. A large number of such instruments placed on the deep seabed would use as much high-level waste that can be funded -removing it from human contact for very long periods of time -especially those placed in subduction zones. The US has a mature capability for placing sea mines on the seabed and can likely easily adapt this capability for the placement of sensors-they can be simply dropped through the water column and be guided to their desired location using built in fins; and perhaps be stabilized by a simple low-cost biodegradable drogue that detaches somewhat before impact. A simple system of pipes can direct water at the sensors to keep them clean and functioning using a small pressure pump. Another dual use is a deep running long duration undersea drone which can collect both seabed ISR and scientific data. A commercial adaption of this vehicle would be scaled up to a deep-sea cargo vessel that uses and recharges smaller collection drones which would cruise just above the seabed and collect valuable metallic nodules with minimal environmental impact. The collected cargo would periodically collected by simply using electrolysis to create sufficient gas to lift the cargo to a waiting surface transport. The operative principle here is to reuse the 'waste' and not just try to bury it on land where contact with humans is more likely. Feel free to share. Have a good day. (135-2 [Bibee, Bruce])

Comment: I really like tonight I learned the crux is business decision versus human health, and that's really unfortunate that we have to put it in two separate buckets. (143-13-2 [Holst, Jacqueline])

Comment: So again, business decision versus human health; it's unfortunate that's what this is coming to. (143-13-6 [Holst, Jacqueline])

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Comment: That understanding of craftsmanship is also the reason that we would like to see that project labor agreements and maintenance agreements are maintained throughout the construction of this plant, and throughout the maintenance of the plant throughout its life. (143-33-4 [Currant, Jonathan])

Comment: I want to talk about big numbers, because we've been talking about the big numbers. The amount of taxes that are going to the state of Michigan, and Van Buren County.

The number of jobs, and how many people are going to be making good livings working in the plant.

And so, I also heard that this nuclear plant, these nuclear plants are the hallmark of America, which I thought was quite fulsome as a statement.

So, when we're talking about these big numbers and the large amounts of money involved, I would like to talk about those things that cannot be calculated. And use our imaginations to figure out how much thing are really, really going to cost.

The first thing is pricing out the cost of renewable energy versus the cost of nuclear energy. And I think that if this were priced out, and we were to compare the number of good jobs that make a living in renewable energy versus the number that could make a living in nuclear energy, we would find that the number of jobs in renewables is not only greater, the jobs are safer. Not completely safe, that I do understand.

But the jobs are safer (143-38-1 [Boudart, Jan])

Comment: the next thing I would like to see priced out is the cost of the loss of tourism.

Tourist families go down through generations. There are many, many jobs in the future for tourism among this absolutely stellar, spectacular part of Michigan.

And we don't count the number of tourism jobs that could be lost if the radiation levels go up in Van Buren County.

And then, we're not pricing out the medical cost. There is a huge medical cost now for cancers, and I don't think we should stop at cancers.

Many, many other kinds of health problems are caused by nuclear radiation. But this goes down through generations.

We're not pricing out how much it's going to cost our grandchildren and our great-grandchildren, to treat their cancers.

And we're not going to be pricing out how much it's going to cost for birth defects in the future.

These are costs that we cannot calculate. (143-38-2 [Boudart, Jan])

Comment: We never price out their ideas. We say oh look, we're paying attention to the indigenous people. We're listening to them.

But we don't price out their ideas, which means we're really not listening to them. (143 4 [Boudart, Jan])

Comment: Another thing is the amount of carbon that is put into the air while we're waiting for nuclear plants to get started, is a factor that we need to pay attention to. (143-38-5 [Boudart, Jan])

Comment: And I'm sorry but this is really important. People who say nobody died at TMI never saw the movie Radiation: The Women of Three Mile Island.

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And now there's a movie, SOS, about San Onofre, and there is a new movie, Atomic Africa, which is very, very expressive about the cost of uranium mining to the uranium miners. Not to the owners. Not the capitalists, but the people who go down in the mines and do the work.

And in the area that the movie, Atomic Africa treats, there were six cases of extreme birth defects when there had never been any birth defects in that community. Not no birth defects, because that's not possible.

But it was like 6:1 from the time that they started mining uranium.

These costs are not priced out. We cannot calculate this enormous cost. (143-38-6 [Boudart, Jan])

C.2.10 Comments Concerning Outside Scope - Other Non-Restart Action C.2.10.1 Comments Related to Outside Scope - Other Non-Restart Actions Comment Summary 1 Comment: HOLTEC has been found guilty of felonious bribery in its dealings with the Tennessee Valley Authority and is under investigation for deceptive business practices in New Jersey and Ohio. Our suspicions have been proved true: HOLTEC had no intention of decommissioning Palisades NP but has been drawing down its decommissioning fund for years, with nothing to show for it. HOLTEC's business model, though devious, seems profitable, as it is no applying for $1.5 billion loans to repermit and "restart" Palisades NP, with no experience whatsoever in this highly technical industry. (5-4 [Muhich, Mark])

Comment: Please do not forget Holtec's fundamental business model, which subsists on public grants. It is a decommissioning company, which makes money by spending less on decommissioning a plant than the government allocates for it. It is now interested in re-starting a plant, because the government has made available two billion dollars to do so. (8-3 [Moevs, Christian])

Comment: The NRC has long been held responsible for ensuring that nuclear power plants are operated in a safe manner to protect the safety of life & health of the surrounding community by holding the owner-operator to strict standards.

The fact that Holtec is a demolition firm with no plant operational experience; coupled with a record of significant, large past financial fines by the NRC, the State of NJ & the state of MA; gives their request for approval of a plant restart plan no credibility whatsoever. How can Holtec be trusted to comply with the NRC regulations? (11-1 [Reed, Dillon])

Comment: Does oversight corporation Holtec have a large enough financially secure monetary savings to remediate 20% of the worlds fresh water supply? We know they have been sued and are in court regularly for their shoddy performance, failure to comply and general poor management. The NRC is quite possibly an in pocket captured agency, but we the people see you. (33-3 [Birdsall, Sheila])

Comment: To allow an unqualified demo contractor to rebuild and to waste huge amounts of public funds to do so is counterproductive and extremely risky. (41-2 [Connor, Bill])

Comment: We were surprised to hear that Holtec has done nothing regarding dismantling the reactor. With the funding they received one would think that they would have started something.

But no, Holtec seemed to be proud, in answering the question, saying nothing was done. We expect they meant they were postponing demolition, while being handsomely paid from the trust

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fund. If the delay were to present a restart proposal, one would suspect that the use of trust funds dollars was inappropriate. (42-4 [Sahagian, Linda G.] [Stewart, Douglas A.])

Comment: Why would we skip doing the repairs and the environmental studies when we have hundreds of millions of dollars of public funding to do it right? (53-3 [Schultz, Kraig])

Comment: Holtec is strictly a demolition company with no experience in running a plant.

Holtec's ethical reputation has been repeatedly sullied, since they have been cited for inappropriate actions & subsequently fined in the past by the NRC, the State of NJ, & the State of MA. (66-2 [Reed, Dillon])

Comment: An additional risk here is the requested issuance of a new license to an entity that has never operated a nuclear power plant. (68-3 [Unknown, Unknown])

Comment: It is incredible that the plant may be restarted at all, and more so by an owner who has no experience running a nuclear power plant. (72-2 [Hoskin, John])

Comment: These risks have actually increased since permanent shutdown on May 20, 2022, due to lack of active maintenance by Holtec -- which has no experience operating an atomic reactor -- on safety-significant systems, structures, and components. This includes: lack of chemically-preservative "wet layup" on the steam generators, accelerating already severe corrosion; no testing of valves and pumps to ensure reliability; and no regular rotation of the turbine-generator shaft, which is thus bending under its own immense weight. The latter could lead to a mechanical explosion, hurling chunks of shrapnel weighing hundreds of pounds each outwards, including into the control room, where operators could be injured or killed, and safety/cooling systems could be rendered inoperable. Such a mechanical explosion of the bent turbine-generator shaft at Fermi Unit 2 in Monroe County, MI on Christmas Day, 1993, led to two million gallons of radioactive wastewater being dumped into Lake Erie's biologically rich --

but shallow, and fragile -- Western Basin. (76-1-10 [Kamps, Kevin])

Comment: Making all the risks and impacts LARGER and worse is the fact that, in addition to its inexperience (the company has never operated, nor constructed, an atomic reactor), it is also incompetent, corrupt, and even criminal. Newly revealed scandals swirl around Holtec on a frequent and continuing basis. As but the latest example, a long-serving, top Holtec advisory board member, George E. Norcross III, was recently indicted by the State of New Jersey Attorney General on 13 racketeering felony charges (https://beyondnuclear.org/long-serving-holtec-board-member-indicted-on-racketeering-in-new-jersey/). For more background info., see:

Holtec: Criminality, Corruption, Incompetence, and Inexperience (https://beyondnuclear.org/wp-content/uploads/2024/03/2-29-24-Holtec-two-pager.pdf)

(2 pages, published March 27, 2024). Also see an earlier annotated bibliography, "Radioactive Skeletons in (https://archive.beyondnuclear.org/centralized-storage/2019/7/25/radioactive-skeletons-in-holtec-internationals-closet.html) Holtec's Closet," chronicling the company's countless misdeeds. (76-1-17 [Kamps, Kevin])

Comment: Holtec is the subject of much controversy, and it is not clear how that can be trusted with spent full as well running a nuclear power plant. (91-2 [Dembs, Barb])

Comment: Now to the point of HOLTEC. This company has no developed process to repair damaged or leaking casts.

Holtec purchased this shutdown plant with the sole purpose of demolishing the structures and remediating the property; not to resume operations. Holtec has no plant operational experience, they are a demolition company. They are advocating the use of unproven technology, using high grade Uranium fuel. (93-3 [Ebert, Robert])

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Comment: Holtec International, the company seeking to restart Palisades, has a poor track record and lacks experience in operating nuclear reactors. Their expertise lies in decommissioning plants, not running them. This raises serious concerns about their ability to safely manage the plant. (108-2 [Quinn, Francis])

Comment: Bringing a nuclear plant back online has never been done in the U.S. and the company Holtec International who has a bad track record, is better known for decommissioning nuclear plants, not building one. They have never held a reactor operating license. (109-3 [Ferry, Carolyn])

Comment: Holtec (trying to gain federal money to start back up Palisades) has never operated a nuclear power plant - tearing them down is what they do.

-In fact, a Holtec CFO whistle blower was asked by the President of Holtec to inflate the balance sheet by 3/4 of a billion dollars - a criminal act (111-3 [Huffman, Mary])

Comment: Lyman is skeptical about the company's plans, "considering its dearth of experience in nuclear operations. They have no experience at any level in running nuclear power plants, yet they want to take this on soon and then possibly start building additional small modular reactors at the same site," he said. "...I'm really questioning whether they've demonstrated that they have the capability to do all this safely."

Holtec is NOT a nuclear plant company, they lack expertise, they lack historical knowledge from Entergy's engineers, they are gone. The maintenance did not take place, and the institutional memory is gone with Entergy as well. It will be a very green staff, without knowledge of an incredibly old plant. (112-5 [Anonymous, Anonymous])

Comment: Governor Whitmer, said "Holtec are experts in nuclear energy." They are NOT experts; at best they are proficient in nuclear decommissioning. (112-10 [Anonymous, Anonymous])

Comment: Holtec has shown a cavalier approach to nuclear waste disposal in the past and has not been reassuring in any possible changes. (113-2 [Somes, Claudia])

Comment: I'm writing about the impact that restarting the Palisades Nuclear Plant would have on me and on my family. My cousins and brother and I own our family cottage in Palisades Park, having inherited it from our fathers, who inherited it from their father. Though it is a summer home, it is our true family homestead, and has been since 1945, when our grandparents, who had been coming to Palisades since the 1920s, bought their own cottage as my uncle came home from being a POW in WWII. We later bought another lot, just below our cottage. Our two properties are home for all of us. My grandfather did much work on the cottage, and my grandmother painted murals on the walls. All of our family have put many hours of toil keeping it in good shape, and many hours of pure joy being at our beloved cottage, and spending time with each other. My father's ashes are spread on our property around the cottage, the one place he could truly relax, a place he had first come to in 1928 as an infant. It is not just a place we go in the summer. It is our home, the one constant in our lives. If there were to be an incident and we could never return, it would be a loss of more than property. And it is deeply disturbing to imagine what would happen if we were there during an accident (and concerning to imagine what would happen to everyone in the miles around the plant). Though I am for nuclear power as clean energy, I am deeply concerned about a company which has never run a nuclear plant restarting a nuclear plant, an effort which has never been attempted before. (119-1 [Eldredge, Tamesin])

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Comment: Holtec is experienced in shutting down nuclear power plants and maintaining them in a shutdown state. They have no experience in restarting or running a nuclear power plant and they do have a history of safety violations. This seems like a very unwise choice of company and power plant to try this on. (133-3 [Goetzinger, Laurel Eldredge])

Comment: Also, while Holtec is experienced in shutting down nuclear power plants and maintaining them in a shutdown 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. (134-4 [Lombardi, Joan])

Comment: The other thing, Holtec is not experienced. They're doing a horrible job with the nuclear reactors that they're dismantling. I can't believe that anybody is as sloppy and irresponsible as the way they're doing things -- just slamming things around, and they want to dump nuclear waste into Cape Cod, nuclear waste into the Hudson River, nuclear waste into Lake Michigan probably. So, I don't think they should be allowed to take over such a risky business. (143-16-3 [Barnes, Kathryn])

Comment: On July 10th, just a day ago, there was an article by Evan Halper on The Washington Post. He was present at a nuclear industry meeting in Las Vegas.

Here's a quote from Holtec's Patrick O'Brien. Quote: "We will keep the plant in a condition where anything we do can be reversed." End quote.

This plant needs to [be] reversed -- back to closed, shut down, and decommissioned. When it was shut down in 2022, supposedly, because, quote, "the electricity it produced cost too much,"

end quote, it was also shut down because it was, and still is, the most compromised of any power plant in the United States.

Neutron-embrittled reactor, pressure vessels, steam generators, inadequate sump pumps, compromised reactor head or lid -- no one knows which that one is -- so unsafe and compromised, so expensive to fix that the plant shut down early.

We've heard that the hundreds of millions of dollars given by the State to Holtec will not be used for the purpose of fixing things for safety. No plans to fix.

Mr. Nick Culp of Holtec recently stated that they, Holtec, no longer have plans to repair or replace. That means the dangerous, degraded steam generator, all of these other things I mentioned. This means more money in their pockets and more risk to the public.

One week after Holtec purchased the Palisades plant, as decommissioning licensees, they submitted an application to the NRC to become licensed operators. Yes, a totally inexperienced company wants to operate a plant that is so compromised it was shut down early.

Yet, Holtec's spokesman Patrick O'Brien was quoted as saying, "This is not something we expected to do." Unquote. What a lie. They had the paperwork ready to go.

Holtec is a notoriously cheap, dangerous, financially corrupt, and 100 percent inexperienced company that flouts NRC's safety rules and puts workers in risky positions, exposing them to radiation. Everything this company does is in redacted form, relying on, quote, "proprietary," end

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quote, information and forgiveness by the NRC stamped all over it. (143-29-1 [Drechsler, Jacqueline])

Comment: Holtec, the current owner of the plant, has a controversial track record and there are substantial concerns about the company's ability to safely manage the plant, and the associated waste. (143-40-4 [Cabala, Tanya])

Comment: So, I commented on Holtec's so-called decommissioning clean-up plan for Indian Point on the Hudson River a few years back.

Scandalously, they planned to go only, they planned to go no deeper than 4 feet in their clean up, this despite realizing that there's a radioactive aquifer beneath the facility, which is connected to the Hudson River system.

But instead, they'd rather pocket the juicy decommissioning funds and do a half-assed study, and maybe site something else there. Anyway, they're a bad company.

Also, they have their fingers in so many pies that there should be anti-trust investigation into Holtec. (143-41-7 [Campbell, Bruce])

Comment: I would just like to say that something that I didn't manage to get in before is that this company Holtec, is actually notorious for raiding decommissioning trust funds as well.

Using money from the decommissioning trust funds to show how much they are good neighbors, by paying for things that decommissioning trust funds are not supposed to be used for.

And so, I just want everyone to be aware of they're doing this at Indian Point. They're doing it at the Pilgrim Plant in Massachusetts.

They have done it at the Oyster Bay Plant in Camden, New Jersey.

They have a repeated pattern of very bad behaviors, and I really do feel that the NRC needs to be looking at repeated patterns.

But the other thing that I'd like to say is they've exposed people. There is a person at the Pilgrim Plant who can't work there anymore because he was so exposed to radiation that the beepers go off whenever he walks in.

So, there's a lot of safety issues inherent in the Palisades Plant to begin with, but also inherent in Holtec and their decommissioning methods. Let alone the fact that they've never operated a plant.

So, I just wanted to bring that up. (143-43-1 [Drechsler, Jacqueline])

C.2.10.2 Comments Related to Outside Scope - Other Non-Restart Actions Comment Summary 2 Comment: SMR-300s are not small. They are 4.5 times larger than Big Rock Points previous reactor one of the worst radioactive polluters in the entire country, despite its relatively small, 67-MWe size. Fermi Unit 1, also a relatively small 67-MWe, partially melted down on October 5, 1966 and we almost lost Detroit. (1-1 [Doenmez, Sarah])

Comment: Holtecs proposed SMR-300 new builds at Palisades (and also at Big Rock Point),

due to loss of economy of scale, would each generate more highly radioactive waste, per unit of electricity generated, than the zombie reactor. Drs. Allison Macfarlane, and Rodnew Ewing, President Obamas NRC chair and U.S. Nuclear Waste Technical Review Board chair, respectively, reported recently that, depending on their specific design, SMRs will generate 2 to

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30 times the radioactive waste, as compared to current reactors, per unit of electricity generated. But similar things can be said regarding thermal wastewater discharges, cost per unit of electricity generated, etc. Thus, Holtecs SMR new build schemes would exacerbate its zombie reactor restart scheme.

[I] steadfastly oppose the idea of building SMRs at the site of lake Michigan, a national treasure which cannot be further endangered by radioactive contamination. (1-4 [Doenmez, Sarah])

Comment: If the Palisades nuclear energy plant in Michigan is restarted, it will displace the building of any new fossil fuel electrical generation. Thus, carbon emissions will be lowered by a lot. Holtec is planning to build some SMRs at the Palisades site. Could these SMRs be used to blackstart the largest reactor during a regional gird blackout? If true, the Palisades plant could be the first nuclear plant with blackstart capability using clean energy.

Last Friday, I watched the PBS program, Energy Switch. As I watched the episode on the Environmental Land Impact of Energy, Mark Mills bought up three parameters which need our focus when we decide on our energy solutions. These parameters are 1) Reliability, 2) Cost, and 3) Environmental Land Impacts of Energy. I would like to add a fourth parameter to the list:

average carbon intensity over an 80-year period. (57-2 [Gibson, Robert])

Comment: The so-called "Small Modular Reactors," of 300 Megawatts-electric each, will have their own break-in phase risks. Chornobyl Unit 4 in Ukraine in 1986, Three Mile Island Unit 2 in Pennsylvania in 1979, and Fermi Unit 1 in Monroe County, Michigan in 1966, are examples of break-in phase reactor disasters. Three reactors operating on the tiny, 432-acre Palisades site would also represent a risk of multiple, domino-effect reactor core meltdowns, as happened at Fukushima Daiichi, Japan in March 2011, and which was narrowly averted at the four-reactor Chornobyl complex in 1986, but only through extraordinary efforts and self-sacrifice by plant personnel, fire fighters, etc., who paid a very heavy price with their health and even their lives.

---SMR-300s are not "small." They are 4.5 times larger than Big Rock Point's previous reactor -

- one of the worst radioactive polluters in the entire country (http://archives.nirs.us/reactorwatch/decomissioning/bigrockbackgrounder272007.pdf), despite its relatively small, 67-MWe size. Fermi Unit 1, also a relatively small 67-MWe reactor, partially melted down on October 5, 1966 -- and "we almost lost Detroit.

(https://archive.beyondnuclear.org/nuclear-power/2016/9/26/october-5-2016-50-years-since-the-we-almost-lost-detroit-par.html)" As Holtec CEO Krishna Singh himself has pointed out, the two SMR-300s at Palisades would nearly double the nuclear mega-wattage on the small 432-acre site (800 MWe + 600 MWe). This would represent a very concentrated amount of nuclear risk and radioactive environmental impact on the tiny site. (76-1-13 [Kamps, Kevin])

Comment: The small modular reactors that Holtec wants to install (SMR's) have NEVER been deployed in the U.S. Why would you risk installing them next to the largest source of fresh water for Michigan, Illinois, and Wisconsin, especially on a live, shifting sand dune? Why not move to a safer location? Or not at all because of the incredible amount of waste they create? The project to build NuScale's small modular reactor units at an Idaho site was terminated after 10 years of work due to careful consideration of safety and cost. (112-6 [Anonymous, Anonymous])

Comment: They are also excited to expand this plant. (143-33-2 [Currant, Jonathan])

Comment: And these SMRs. Anyway, the SMRs would be lucky to get going by 2030 or 2033.

Plus I hear they create more radwaste per unit of electricity produced, than do larger reactors. (143-41-6 [Campbell, Bruce])

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C.2.11 Comments Concerning Outside Scope - Safety Comment: It should be noted the previous operator of Palisades NP, ENTERGY, failed to maintain the plant according to accepted industry standards. It should be further noted that the original owner/building of Palisades NP, Consumers Power, sold the plant to ENERGY with the view of avoiding more than a billion dollars of repairs and upkeep; such repairs were never accomplished by ENERGY.

In example, Palisades NP's pressure vessel is the oldest in the United States, and is long past its operational life. Even so, neither the NRC nor ENTERGY are willing or able to ascertain the brittleness of the pressure vessel due to neutron bombardment.

A new and robust analysis of the environmental destruction caused by a serious malfunction at Palisades must be undertaken. It should be remembered that vast swaths around the defunct Chernobyl plant in Ukraine will be uninhabitable and unfarmable FOREVER. (5-3 [Muhich, Mark])

Comment: Also, regardless of the location within the Michigan Basin, the plant is situated on a Fukushima-like setting, vulnerable to within striking distance of the New Madrid Seismic Zone with potential tsunami forces. Such a risk cannot be definitively known, is not zero, and therefore is significant. These are scenarios that, even if considered under planned engineered precautions, make this endeavor an unwise choice. Its not worth the potential risks at the expense of decentralized energy projects that can benefit all citizens. (7-3 [Brown, Robert])

Comment: Furthermore, we request that you codify the Safety Standards of the industry and require the Palisades Nuclear Plant to be "brought up to code" and have to meet the same safety standards that are required of a new plant coming online. I understand that the reopening of this plant is to provide a model for the rest of the world to bring their decommissioned plants back online. For that reason, the NRC needs to do everything in its power to make sure it is done with safety as the number one priority; not the speed in which it can be accomplished. A great deal of information has been learned in the 53years since this plant originally went online from disasters that took place at Chernobyl & Fukushima to name just a few. Edmund Burke wrote: "Those who don't learn from history are condemned to repeat it". We need to heed that wisdom and make sure we do it correctly so that we do not suffer the same fate! This power plant has had a less than favorable track record since its opening which makes it even more imperative, to ascribe to the current safety standards set by the NRC; to do otherwise is a dereliction of duty. (10-2 [Davis, Bruce])

Comment: I knew personally people who worked there and reported an environment, infrastructure, physical structure and administrative groups they felt were inadequate and not even interested in what was told them about the inadequacies and danger of the power plant.

They all left there because the hardware/building/oversight were clearly not maintained nor safe.

They didnt want to die. Neither do I. (33-1 [Birdsall, Sheila])

Comment: Now the lingo comes to the fore where the NRC says that disaster will never happen, and well be safe and blah blah blah. We know thats not true. We know it from history around the world, from review of NRC inspection forms of this plant and others that show years of it not being true. Always a failure, rarely completely in compliance or meeting expectations.

We in west Michigan got the notices for inappropriate tritium and steam, leaking water and other odds and ends that ARE too technical for us to grasp. So what? Failure at this point in this location is the most fearful selfish narcissistic plan I can think of. We have an entire planet about to go insane for fresh water and were going to risk 2-0-% of it to satisfy our little stateside emergency? That is a dimwitted short -sighted plan that is doomed to fail even as we watch

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the safe cask system sit on the shores of a sandy area knowing humans NEVER can keep anything safe forever.

Please dont try to sell me this ridiculous "corporate paid for" environmental testing safety nonsense. (33-4 [Birdsall, Sheila])

Comment: We are writing this letter to the Nuclear Regulatory Commission to express our wishes as you consider the restart of operations at the Palisades Nuclear Plant.

We are neighbors and have a history with the plant's operations from the original owner, Consumers, to their sale to Entergy to the 2021 shutdown and transfer to Holtec for demolition.

Nuclear Power Generation, if done well and safely is a reliable source of electrical power. The Palisades faculty has a history of questionable starts and stops. The latest operator, Entergy, had determined that the economics of operating was a net negative. As we were told, there were structural issues that would be too costly to repair. I wish I were better versed on those issues. But, as concerned neighbors, our family was deeply concerned, When Entergy entered into the agreement with Holtec we looked to a safer future. Now this is unravelling with an effort to resume operations in perhaps a less than prudent way. (42-1 [Sahagian, Linda G.] [Stewart, Douglas A.])

Comment:

Dear Chairman Hanson,

I am writing to you today with a sense of urgency and responsibility towards our community and the environment. The Palisades Nuclear Plant, with a troubled history spanning over five decades, has been a source of concern for many of us. Its track record of serious problems and violations since its inception in 1971 has painted a picture of a facility that has been a public risk, both financially and environmentally. The Nuclear Regulatory Commission (NRC) once classified Palisades among the four worst-performing nuclear plants in the country. This raises critical questions about the wisdom of such a decision and the potential risks it poses to our community and the environment. (46-1 [Schalk, Tracy])

Comment: Remember Chernobyl, Three Mile Island and Fukushima nuclear accident. NOT HERE PLEASE. Plenty of alternatives. (49-1 [Donahue, James])

Comment: A spent fuel pool fire or a loss of coolant accident at Palisades could cause Chernobyl or Fukushima-scale damage to our environment. I request that the NRC consider both the environmental and financial impact of a Chernobyl or Fukushima-scale disaster should one occur right here in West Michigan. We must think about the damage it would do to the Lake Michigan drinking water source for millions of people, what it would do to our agriculture, and what it would do to us financially.

The reason I am concerned about an accident at Palisades is that I can see the NRC allowing Holtec to cut corners to rush this plant (which is 50 years old and has known serious degradation) back into production without doing all the necessary repairs to bring it back to like-new condition. (53-2 [Schultz, Kraig])

Comment: We must conduct an in-depth study of the risks versus the rewards of relicensing this age-degraded plant as opposed to other options available to our community. The reason we've had the safety record we've had for the last fifty years in this country and the U.S. military is due to strict adherence to safety protocols and preventative maintenance. When the NRC allows shortcuts and gives exceptions to the license, we are greatly increasing the risk. (53-4 [Schultz, Kraig])

Comment: My family has had a cottage in Palisades Park for five generations, since the park opened early in the last century.

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We are well aware of the history of that plant and the reasons it was eventually shut down. The plant has a history of safety violations and emergency shut downs; it was not properly maintained and did not have the proper investment or funding. And now, be handed over to Holtec, a company with apparently no experience operating a nuclear plant. It is unthinking to go forward without a full and honest assessment of the big picture that demands attention here. (54-2 [Williams, Bonnie])

Comment: The Government Accountability Office reported that the NRC was not considering climate change vulnerabilities to nuclear facilities. What are the plans for extended grid outages due to storms including geomagnetic events, cyberattacks or direct attack to the grid. Will there be steps taken to secure fuel for diesel generators to keep operations and cooling stable? (58-1 [Mcardle, Edward])

Comment: As a Safety officer for the Federal Government, I am shocked to believe this project is even being considered as I read through the numerous findings of dangerous leaks and needed but neglected repairs: as former Entergy senior engineer Alan Blind, who worked for six years at Palisades, has explained. All these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by 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.

Yet, a government agency, paid to protect the safety of the residents of the U.S. are considering to approve such a project to a company with no experience in nuclear power generation and doing it safely. This plant, like other closed nuclear reactors need to be safely decommissioned as soon as possible to ensure no further mishaps occur and the responsible parties pay for such actions rather than the public getting stuck with the bill. Do the right thing to ensure the safety of the region. Thank you. (61-2 [O'Byrne, Paul])

Comment: Discuss and evaluate safety concerns from potential flooding and other storm events. Large storm events are occurring with increasing frequency and intensity in the Midwest due to climate change. Describe changing climate conditions (i.e., temperatures and frequency and severity of storm events) and assess how such changes could impact the proposed Project.

Consider increases in frequency and severity of storm events, flooding, and periods of high heat (e.g., more severe/frequent flooding). As part of this process, evaluate storage plans for spent nuclear fuel to prevent contamination in the event of flooding at the site. (63-1-11 [McClain, Krystle Z.])

Comment: I recognize the need for power in the coming years. New devices ask for more and more energy. How will power be produced to meet the demand. I believe a combination of different methods are the answer. Nuclear power is one source of energy. What the public wants is a safe creation of that power.

Palisade Nuclear Power Plant has the distinct opportunity to lead the way for restarting previously closed power plants. Public safety should be your prime directive. Technology has advanced since the original construction of the Palisades plant. Take advantage of those gains and demand not only Palisade, but any future start up bring their facility up to today's code. This give a clear message to all providers of energy what is involved in restarting a closed nuclear power plant. Management need guidelines now is the time to provide those guidelines.

Lake Michigan is a precious resource of fresh water, as well as, recreation for millions. I am just one person, but your commission has been assigned the task of representing my concerns.

Safety first for production and storage. (64-1 [Grigoa, Salvatore])

Comment: I would like to state our concern that the Palisades Plant does not get reopened until it is safe. (65-1 [McCleary, Dennis])

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Comment: 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 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. (68-2 [Unknown, Unknown])

Comment: Being an active, highly regulated power plant that undergoes rigorous tests and standards is very different from what Holtec is trying to do now. 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 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[1]existing license. The NRC granted waivers for safety upgrades that otherwise would have been required but for the imminent shut down. (74-2 [O'Brien, Kevin])

Comment: Climate Chaos Effects Must Be Investigated and Analyzed in an EIS Notably, there are two 300 MWe small modular reactors, or SMRs, anticipated to be constructed on the Palisades plant compound site in the 2030s. Difficulties caused by climate chaos effects to those power plants may have synergistic or cumulative implications for the Palisades Nuclear Plant.

A. Extreme Weather and Natural Disaster Potential Extreme weather from the onset of climate chaos, and its possible interactive effects with natural disasters pose risks for Palisades.3 The possibility of earthquakes, lake seiches and variable Lake Michigan water levels all are present at Palisades. In 2020, Lake Michigan had historic high-water levels. This meant that the lakeside dry cask storage was significantly closer than the often cited 150 yards to the waters of Lake Michigan. Whether from tornadoes, hurricanes (like the deadly White Hurricane blizzard of 1913 on Lake Huron, the natural disaster causing the largest loss of life on the Great Lakes and its shores in history), floods, shoreline erosion of fragile sand dunes and beaches, wildfires, etc., the list of extreme weather threats to the reactor(s) and radioactive wastes at Palisades is long and will grow with intensifying climate destabilization. The Government AccountabilityOffice4 (GAO, Congress's investigative arm), and a Yale University scholar5 have excoriated NRC for neglecting climate risks and have questioned the U.S. nuclear power industry's ability to operate reactors (and on-site radioactive waste storage, for that matter) safely, during ever more extreme weather conditions. The GAO found a high prospective flood hazard level at Palisades that would be attributable to unstable climate circumstances.6 (75-3 [Lodge, Terry J])

Comment: Holtec appears not to have performed active maintenance of safety-significant systems, structures, and components since taking over on June 28, 2022. Holtec has not put the steam generators into wet layup, so significant degradation may have already occurred.21 Respecting the huge turbine shaft that turns the generator, Arnold Gundersen states:

The main plant turbine generator weighs well in excess of one million pounds and is about 100 feet long. If left idle for extended periods, the weight of the turbine will cause the main shaft to bend, and the bearings will develop flat spots. Hence, if Entergy had planned to restart Palisades, it would have placed the turbine on a turning gear to keep it slowly rotating while it was shut down. Since Palisades was sold as scrap, no such precautions would have been

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taken. When a plant is decommissioned, no such wet layup and preventive maintenance would be required as the reactor has become non-functioning scrap. Holtec knew it bought a non-functioning scrap reactor from Entergy that was meant to be entirely dismantled.22 Holtec has not operated pumps and valves, so these may not function properly if called upon during full power operations.23 An NRC-commissioned, Sandia National Lab 1982 CRAC-2 report has documented the shocking number of casualties and property damage that would result from a core meltdown at Palisades. CRAC is short for Calculation of Reactor Accident Consequences. The report is also referred to as the Sandia Siting Report, as well as NUREG/CR-2239.24 For Palisades, CRAC-2 reported that a reactor core meltdown would cause 1,000 peak early fatalities (acute radiation poisoning deaths), 7,000 radiation injuries, and 10,000 latent cancer fatalities. CRAC-2 reported property damage would be more than $52 billion.

Adjusting for inflation alone, those property damage figures from 1982 would surmount $163 billion in present day dollar figures. And as Associated Press investigative journalist Jeff Donn reported in his post-Fukushima four-part series Aging Nukes, populations have soared since1982 around reactors like Palisades, so today expected casualties would be significantly worse.

Fire protection25 and containment coating/sump strainer upgrades, also needed 20 years ago, have likewise been largely to entirely neglected. According to retired Union of Concerned Scientists nuclear safety director Dave Lochbaum, fire represents 50% of the risk of core meltdown at atomic reactors. And inadequate sump strainers mean that containment coating debris could clog emergency cooling water flow pathways, as former Entergy senior engineer Alan Blind, who worked for six years at Palisades, has explained.26 All these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by 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 because the industry-captured NRC, in full regulatory retreat, did not require it.27 Now Holtec plans to continue to run Palisades into the ground, with at best inadequate monitoring and minimal repairs.

21 Gundersen Declaration, Apx. 10, p. 11.

22 Gundersen Declaration, pp. 12-13, Apx. 10.

23 Id 24 https://www.nrc.gov/docs/ML0723/ML072320420.pdf 25 https://archive.beyondnuclear.org/safety/2016/7/9/beyond-nuclear-backgrounder-re-fire-securityrisks-at-palisa.html 26https://podcasts.apple.com/us/podcast/radioactive-raindrops-the-view-from-inside-palisades/id1745885298?i=1000655273297 27https://www.ap.org/media-center/press-releases/2012/aging-nukes-a-four-part-investigative-seriesby-jeff-donn/

(75-8 [Lodge, Terry J])

Comment: Cumulative and Synergistic Site Risks from Construction of Additional Reactors Onsite Yet another risk to consider is Holtecs publicly stated intention to build two so-called SMR-300s (Small Modular Nuclear Reactors of300-Megawatts-electric capacity each) at the Palisades site.28 SMR-300 newbuilds would bring together breakdown phase risks at the age-degraded restarted Palisades reactor with break-in phase risks at the SMRs.

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Palisades will continue to experience worsening age-related degradation, breakdown phase risks, from August 2025 to 2051 (Holtec has announced application for a 2031 to 2051 license extension, amounting to 80years of operations, twice the initial 40 years.) The two SMRs will each have their own break-in phase risks. Chornobyl Unit 4 in Ukraine in 1986, Three Mile Island Unit 2 in Pennsylvania in 1979, and Fermi Unit 1 in Monroe County, Michigan in 1966, are examples of break-in phase reactor disasters. Fermi Unit1s partial core meltdown in Monroe County, Michigan, on October 5, 1966, documented in We Almost Lost Detroit.29 Three reactors operating on the tiny, 432-acre Palisades site would also represent a risk of multiple, domino-effect reactor core meltdowns, as happened at Fukushima Daiichi, Japan in March 2011.

NEPA requires the evaluation of projects which are likely to be accompanied by significant environmental events to be based, in part, on potential or actual public health effects, and also for the assessment of direct and indirect project impacts to be cumulative. NEPA requires an agency to evaluate cumulative impacts along with the direct and indirect impacts of a proposed action. TOMAC, Taxpayers of Michigan Against Casinos v. Norton, 433F.3d 852, 864 (D.C. Cir.

2006) (citing Grand Canyon Tr. v. FAA, 290 F.3d 339,345 (D.C. Cir. 2002)). A cumulative impact is the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. 40 C.F.R. § 1508.7. Consideration of cumulative impacts must also consider "[c]losely related and proposed or reasonably foreseeable actions that are related by timing or geography." Vieux Carre Prop. Owners, Residents, Assocs., Inc. v.

Pierce, 719 F.2d 1272, 1277 (5th Cir.1983).

These potential accident scenarios, and others, must be made part of the risk assessment conducted for the restart of Palisades and disclosed in the NEPA document.

28 https://holtecinternational.com/2023/12/04/first-two-smr-300-units-slated-to-be-built-at-michigans-palisades-site-for-commissioning-by-mid-2030/

29 Fuller, John, We Almost Lost Detroit, https://www.amazon.com/Almost-Lost-Detroit-John-Fuller/dp/0345252667 (75-9 [Lodge, Terry J])

Comment: Irradiated Fuel Management and Storage Issues A. Voluminous Radioactive Waste Is Stored at Palisades Past and potential present and future environmental impacts resulting from the ongoing problem of radioactive waste storage at Palisades are significant. More than 800 metric tons of highly radioactive irradiated nuclear fuel have accumulated onsite at Palisades. Around two-thirds is still stored in the wet indoor storage pool; one-third is stored in a growing number of outdoor dry casks, near the Lake Michigan shore. As with operating reactor core meltdowns, catastrophic amounts of hazardous radioactivity can also be released into the environment from radioactive waste disasters, such as a fire in the pool-stored waste, or a dry cask breach. As a matter of fact, Palisades narrowly averted catastrophe in October 200546 under previous owner Consumers Energy, due to the near-drop of a 107-ton load into the pool: the floor could have been pierced, draining cooling water, leading to overheating and ignition of the zirconium metal cladding of the stored highly radioactive irradiated nuclear fuel. Since the pool is not located within a radiological containment structure, radioactivity releases from the hundreds of metric tons of densely packed fuel would be large-scale, and directly into the environment. Princeton University researchers reported in2016 that a radioactive waste pool fire could contaminate a large region of the United States downwind, leading to millions of nuclear evacuees, and trillions(with a T) of dollars in property damage.47 A near-miss waste pool fire at Fukushima

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Daiichi Unit 4 in March and April 2011, very narrowly averted through sheer luck,48 led the then-serving Japanese Prime Minister, Naoto Kan, to order an emergency contingency plan to evacuate 35 to 50 million people from northeastern Japan and metro Tokyo. He said it would have been the end of the Japanese state. The Palisades pool is more densely packed with irradiated nuclear fuel than was the pool at Fukushima Daiichi Unit 4.

B. Cask No. 4, an Experiment No One Needs Dry cask storage at Palisades has been controversial and risky from the start in 1993. The fourth cask to be loaded, in summer 1994, was quickly announced by then-owner Consumers Energy to be defective. Weld defects were detected in the 130-ton VSC-24 cask after it was loaded in 1994. Engineers for then-owner Consumers Energy predicted that placing the thermally hot inner canister which contains the thermally hot SNF into the 100 degree F. indoor storage pool water while the SNF was at 400 degrees C. (750 degrees F.) could cause a steam flash and thermal shock to container and fuel. The steam flash could expose workers to dangerous radiation doses, while the thermal shock could degrade the canister and fuel, making physical conditions even worse than they already are. They determined that the SNF could not be adequately cooled during the short window of time to cut into the storage cask and move SNF into a transfer cask. Disruption of the convection air flow needed, by design, to cool the casks contents would cause overheating and violate the casks technical specifications.

Directors Decision DD-97-1, Consumers Power Company (Palisades Nuclear Plant), 45 NRC 33, 37-38 (1997). As a result, Cask No. 4 was not opened and has been left on the storage pad at Palisades in defective condition for the ensuing 30 years. Remediation in order to move the SNF in Cask No. 4 will have to happen someday, and whenever it takes place, it will be dangerous and expensive.

The continued and possibly unstable presence of Cask No. 4must be investigated under NEPA and disclosed for its environmental effects and implications of those effects.

C. Seismic Problems with Dry Cask Storage Pads In February 1994, Dr. Ross Landsman, dry cask storage inspector at NRC Region 3 in Chicago, warned the agency that the original storage pad at Palisades for dry casks, just 150 yards or less from the water of Lake Michigan, violated NRC earthquake safety regulations.49 This was due to the pad floating on 55-feet of loose sand underneath, anchored to nothing. He warned that even a mild earthquake could part the beach, allowing the Lake to fill the void. One or more dry casks could be buried under sand, leading to overheating. Or they could tumble into the Lake, submerging. Breaches of casks could then lead to radioactive releases into the Lake.

Dr. Landsman, then retired from NRC and serving as an expert witness for the environmental coalition opposing Palisades, warned in 2006-2007that the second pad at Palisades, located somewhat further inland from the Lake, also violated NRC earthquake safety regulations.50 In Holtecs own December 2020 Post-Shutdown Decommissioning Activities Report, the company seemed to lend credence to Dr. Landsmans warning about the nearer-Lake, older pad Holtec proposed transferring all the dry casks to the newer pad, further inland. But given Dr.

Landsmans 2006-2007 warning about the newer pad, this could simply be jumping from the frying pan into the fire.

A breached, submerged cask could lead to an inadvertent nuclear criticality event within the highly radioactive waste. If the waste formed a critical mass during the disaster, infiltrating Lake water could serve as a neutron moderator, sparking a chain reaction. This would worsen radioactive releases into the Lake and would make emergency response operations a potential suicide mission, given the fatal radiation emissions due to breach of radiation shielding, as well as containment.

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46 http://archives.nirs.us/reactorwatch/licensing/caskdanglesummaryreport4406.pdf 47 https://archive.beyondnuclear.org/on-site-storage/2016/5/26/spent-fuel-fire-on-us-soil-could-dwarf-impact-of-fukushima.html 48 https://static1.1.sqspcdn.com/static/f/356082/27045322/1464275575100/May+2016+SNF+pool+Fukus hima+Lessons+Learned.pdf?token=E8jQplcGhGcRqI3caKiMOa5lqOc%3D 49 http://archives.nirs.us/reactorwatch/licensing/021794rosslandsmanltrnrcchairmanselin.pdf (75-13 [Lodge, Terry J])

Comment: Concerns, usually framed as safety-related, are also most relevant to negative environmental impacts, including LARGE ones. A reactor core meltdown at the Palisades zombie reactor would have extremely LARGE negative environmental impacts, in the National Environmental Policy Act (NEPA) lingo. Palisades has long had multiple high-risk pathways to meltdown. They include the single worst neutron-embrittled reactor pressure vessel in the country, and perhaps the world, at risk of through-wall fracture. They also include steam generators, and a reactor vessel closure head, or lid, that have needed replacement for two decades. Fire protection (https://archive.beyondnuclear.org/safety/2016/7/9/beyond-nuclear-backgrounder-re-fire-security-risks-at-palisa.html) and containment coating/sump strainer upgrades, also needed 20 years ago, have likewise been largely to entirely neglected.

According to retired Union of Concerned Scientists nuclear safety director Dave Lochbaum, fire represents 50% of the risk of core meltdown at atomic reactors. And inadequate sump strainers mean that containment coating debris could clog emergency cooling water flow pathways, as former Entergy senior engineer Alan Blind, who worked for six years at Palisades, has explained (https://podcasts.apple.com/us/podcast/radioactive-raindrops-the-view-from-inside-palisades/id1745885298?i=1000655273297). All these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by Palisades' initial owner (http://archives.nirs.us/reactorwatch/licensing/pg2.jpg), Consumers Energy, to the Michigan Public Service Commission, in spring 2006 (http://archives.nirs.us/reactorwatch/licensing/pg2.jpg). Yet Entergy never fixed any of this, during its ownership tenure from 2007 to 2022 -- because the industry-captured NRC, in full regulatory retreat, did not require it (https://www.ap.org/media-center/press-releases/2012/aging-nukes-a-four-part-investigative-series-by-jeff-donn/). (76-1-7 [Kamps, Kevin])

Comment: 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, Entergy's 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 BAND-AID fixes (https://beyondnuclear.org/wp-content/uploads/2024/03/Lochbaum-Headaches-at-Palisades-CRD-seals-new-LG2-20100716-pal-ucs-brief-leaking-crd-seals-5.pdf). 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. In just one episode a decade ago, nearly 200 workers -- including women of child-bearing age -- got on average 2.8 Rem of exposure (https://archive.beyondnuclear.org/home/2015/1/9/192-entergy-palisades-workers-exposed-to-28-r-in-month-long.html) during just a short, month-long CRDM seal replacement job.

Internationally, nuclear workers are limited to 2 Rem of exposure for an entire year. CRDM seal leaks involve reactor core primary coolant water, so represent yet another pathway to meltdown. (76-1-9 [Kamps, Kevin])

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Comment: The extremely LARGE negative environmental impacts of a meltdown at the Palisades zombie reactor would include large-scale airborne fallout and water-borne outflow of hazardous radioactivity into Lake Michigan, as well as wind-driven/precipitation-delivered fallout onto land. Such airborne fallout from Chornobyl in 1986 severely contaminated not just the "breadbasket of Europe" (Ukraine), but also sheep farms in Scotland, Sámi reindeer herding grounds in the Scandinavian Arctic, Lake Constance bordering Bavaria, Germany, and elsewhere -- not just hundreds, but even thousands of miles downwind. Radioactive fallout and wastewater discharges into the Pacific Ocean from Fukushima Daiichi in Japan did not end in spring 2011 -- the tritiated wastewater discharges will now continue for decades, intentionally, despite the risks to humans via Pacific fisheries. These are cautionary tales for Van Buren, as well as Berrien, Allegan, and Kalamazoo counties -- a major agricultural breadbasket of Michigan, not to mention a "Pure Michigan" tourism/recreation Mecca. The late, great Maynard Kaufman, a Bangor farmer-author, founder father of Michigan Organic Food and Farm Alliance, and watchdog on Palisades since before ground was even broken in 1967, warned about these impacts on Palisades-area agriculture for decades on end. And, as an expert witness for the environmental coalition opposed to Palisades' restart -- Arnie Gundersen, chief engineer at Fairewinds -- warned (https://www.fairewinds.org/demystify/downstream?rq=downstream) a decade ago, a Fukushima-scale radioactive disaster at Palisades would be catastrophic for Lake Michigan, and the rest of the Great Lakes downstream and downwind. The Great Lakes comprise 21% of the world's surface fresh water, 84% of North America's, and 95% of the U.S.A.'s. The Great Lakes serve as drinking water for more than 40 million people in eight U.S.

states, two Canadian provinces, and a large number of Indigenous Nations. To put this all at risk with the unneeded Palisades zombie reactor restart is nuclear madness. The hazardous persistence of artificial radioactive pollutants that would escape into the environment due to a reactor core meltdown are nightmarish: Tritium (radioactive Hydrogen, which can go anywhere in the human anatomy, right down to the DNA molecule), 123 to 246 years of hazard; Cesium-137 (a muscle-seeker), around 300 to 600 years of hazard; Strontium-90 (a bone-seeker),

around 300 to 600 years of hazard; Carbon-14 (which can also go anywhere in the human body, right down to the DNA molecule), 55,000 to 110,000 years of hazard; Plutonium-239, 240,000 to 480,000 years of hazard; Iodine-129, 157 to 314 million years of hazard; to name but a small number of the more than 200 hazardous artificial radioactive isotopes contained in irradiated nuclear fuel -- or, worse yet, NOT contained, but blowing with the wind, and flowing with the water, contaminating air, soil, food, drinking water, and the rest of the ecosphere, in the event of a meltdown! (76-1-11 [Kamps, Kevin])

Comment: As with operating reactor core meltdowns, catastrophic amounts of hazardous radioactivity can also be released into the environment from radioactive waste disasters, such as a fire in the pool-stored waste, or a dry cask breach. As a matter of fact, Palisades narrowly averted catastrophe in October 2005 (http://archives.nirs.us/reactorwatch/licensing/caskdangles ummaryreport4406.pdf) under previous owner Consumers Energy, due to the near-drop of a 107-ton load into the pool: the floor could have been pierced, draining cooling water, leading to overheating and ignition of the zirconium metal cladding of the stored highly radioactive irradiated nuclear fuel. Since the pool is not located within a radiological containment structure, radioactivity releases from the hundreds of metric tons of densely packed fuel would be large-scale, and directly into the environment. Princeton University researchers reported in 2016 (https://archive.beyondnuclear.org/on-site-storage/2016/5/26/spent-fuel-fire-on-us-soil-could-dwarf-impact-of-fukushima.html) that a radioactive waste pool fire could contaminate a large region of the United States downwind, leading to millions of nuclear evacuees, and trillions (with a T) of dollars in property damage. A near-miss waste pool fire at Fukushima Daiichi Unit 4 in March and April 2011, very narrowly averted through sheer luck (https://static1.1.sqspcdn.com/s tatic/f/356082/27045322/1464275575100/May+2016+SNF+pool+Fukushima+Lessons+Learned

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.pdf?token=E8jQplcGhGcRqI3caKiMOa5lqOc%3D), led the then-serving Japanese Prime Minister, Naoto Kan, to order a secret emergency contingency plan to evacuate 35 to 50 million people from northeastern Japan and metro Tokyo. He revealed the secret a year later and said it would have been the end of the Japanese state. The Palisades pool is more densely packed with irradiated nuclear fuel than was the pool at Fukushima Daiichi Unit 4. This is a part of the scandalous con job, or bait and switch trick, Holtec pulled to get its hand on Palisades in the first place. Holtec said it would decommission Palisades, not restart it. An early part of its "prompt decommissioning" was to have been expedited transfer of spent nuclear fuel from the indoor wet storage pool to safer (but still not safe) dry cask storage. But Holtec's zombie reactor restart scheme has led it to keep the pool packed to the gills, for an indefinite period, exacerbating pool fire risks. (76-1-19 [Kamps, Kevin])

Comment: In February 1994, Dr. Ross Landsman, dry cask storage inspector at NRC Region 3 in Chicago, warned the agency (http://archives.nirs.us/reactorwatch/licensing/021794rosslandsmanltrnrcchairmanselin.pdf) that the original storage pad at Palisades for dry casks, just 150 yards or less from the water of Lake Michigan, violated NRC earthquake safety regulations. This was due to the pad "floating" on 55-feet of loose sand underneath, anchored to nothing. He warned that even a mild earthquake could part the beach, allowing the Lake to fill the void. One or more dry casks could be buried under sand, leading to overheating. Or they could tumble into the Lake, submerging. Breaches of casks could then lead to radioactive releases into the Lake. Dr. Landsman, then retired from NRC and serving as an expert witness for the environmental coalition opposing Palisades, warned in 2006-2007 that the second pad at Palisades, located somewhat further inland from the Lake, also violated NRC earthquake safety regulations (http://archives.nirs.us/reactorwatch/licensing/020207landsmandec.pdf). In Holtec's own December 2020 Post-Shutdown Decommissioning Activities Report, the company seemed to lend credence to Dr. Landsman's warning about the nearer-Lake, older pad -- Holtec proposed transferring all the dry casks to the newer pad, further inland. But given Dr. Landsman's 2006-2007 warning about the newer pad, this could simply be jumping from the frying pan into the fire.

---A breached, submerged cask could also lead to an inadvertent nuclear criticality in the highly radioactive waste. If the waste formed a critical mass during the disaster, infiltrating Lake water could serve as a neutron moderator, sparking a chain reaction. This would worsen radioactive releases into the Lake and would make emergency response operations a potential suicide mission, given the fatal radiation emissions due to breach of radiation shielding, as well as containment. Another pathway to such a catastrophe is Holtec's, and DOE's, proposed barge shipments of highly radioactive waste, from Palisades to the Port of Muskegon (https://www.nirs.org/wp-content/uploads/factsheets/mibargefactsheet92804.pdf). The more waste Palisades generates, the more pressure Holtec will exert, and the more shipments there would be, involving barging highly radioactive wastes on Lake Michigan, bound for the company's proposed dumpsite in New Mexico (https://beyondnuclear.org/radioactive-waste/centralized-storage/). (76-2-1 [Kamps, Kevin])

Comment: Exacerbating the LARGE and worsening nuclear risks for and radioactive impacts to the environment described above is the issue of extreme weather and natural disasters due to climate chaos. (http://archives.nirs.us/climate/background/ieerpresentationjuly82006.pdf) In 2020, Lake Michigan had historic high-water levels. This meant that the Lakeside dry cask storage was significantly closer than the often cited 150 yards to the waters of Lake Michigan.

Whether it is tornadoes, hurricanes (like the deadly White Hurricane (blizzard) of 1913 on Lake Huron, the natural disaster causing the largest loss of life on the Great Lakes and its shores in history), floods, Lakeside erosion of fragile sand dunes and beaches, wildfires, etc., the list of

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extreme weather threats to the reactor(s) and radioactive wastes at Palisades is already long, and growing with worsening climate destabilization. Institutions such as the Government Accountability Office (https://beyondnuclear.org/gao-excoriates-nrc-for-abandonment-of-climate-crisis-licensing-and-oversight-at-us-reactors/) (GAO, Congress's investigative arm), and a Yale University scholar (https://beyondnuclear.org/nuclear-industry-avoiding-accountability-for-climate-crisis-impacts/), have excoriated NRC for neglecting climate risks, and have questioned the U.S. nuclear power industry's ability to operate reactors (and on-site radioactive waste storage, for that matter) safely, during ever more extreme weather conditions associated with worsening climate chaos. NRC cannot be allowed to ignore such climate risks in the context of the Palisades zombie reactor restart and SMR new build schemes, nor their inevitable potential for extremely LARGE negative impacts on the environment. (76-2-4 [Kamps, Kevin])

Comment: Hazards of particular concern for Palisades, which are additive, interactive and affect multiple domains of risk are:

(1) Extreme variability in conditions of Lake Michigan, including biota and chemistry changes and temperature and water level.

(2) Erosion and kinetic water action undermining the foundational landscape upon which Palisades sits.

(3) Flooding. As noted in an April 2024 report from the Governmental Accountability Office (GAO) titled NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change, the area where Palisades is situated faces a high prospective flood hazard.

Further, a combined effect flood (i.e., a combination of intense precipitation and maximum surge and seiche with wind-wave activity and very high lake water level) could seriously affect numerous structures and systems at the site.

(4) Earthquakes. Structures and systems such as water tanks and mechanical and electrical equipment and aging inaccessible pipes and cables are located at a site which is underpinned by a good deal of sand amidst the dunes of the shoreline, meaning that the vibrations from an earthquake would be amplified. The 2011 earthquake in Mineral, Virginia was felt at Palisades.

(4) The vulnerability of an appreciable amount of the areas aging non-nuclear infrastructure, including power transmission facilities and corridors and roadways in the surrounding area. Such vulnerability is particularly relevant to accident mitigation.

(5) Extreme storms and other weather conditions and natural phenomena which, while rare in the past, must be recognized as plausible with climate change.

(6) Palisades unique operational history of leaks, delayed (or skipped) maintenance, and documented safety problems. These include, but are hardly limited to: (i) the badly embrittled reactor pressure vessel; (ii) the deteriorated reactor lid; (iii) steam generator problems; (iv) the periods in which the plant suffered a chilled safety culture, which may have led to some conditions going unreported and undiscovered; (v) radioactive leaks; (vi) cooling system problems; and longstanding control rod drive seal problems, which even led to the reactor being shut down 11 days ahead of its scheduled final (or presumed final) operation. (77-1-6 [Lee, Michel])

Comment: Safety and security are matters intricately tied to environmental impacts and public health. Hence safety and security and may not legitimately be deemed out-of-scope in the EIS. The potential impacts of a catastrophic accident are well documented. A spent fuel pool

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fire, for example, could render many thousands of square miles uninhabitable for the remainder of the 21st century. (77-1-14 [Lee, Michel])

Comment: The known unknowns and prognosticated effects and conditions of global warming.

The extreme storms, droughts, floods, wildfires, and dramatic temperature swings experienced in Michigan in just the first 20-odd years of this century provide stark warning of what may be ahead.

Lake Michigan is classified as highly stressed and deteriorating with significant flooding and erosion issues. Temperature and water levels have fluctuated dramatically over the past few decades. In general, a substantial decrease in ice cover due to warmer has winters strengthened the ice-albedo feedback and caused increase in summertime water temperatures. In some years, high water levels have led to severe flooding and storms have accelerated natural erosion processes. Higher hotter lake water conditions are projected to predominate in the future. Yet, climate change is also expected to bring severe and sometimes abruptly visiting extreme cold fronts which can lead to the formation of river ice-and-debris clumps which can block water intake systems. Hot temperatures and the removal of the lid of winter ice can also markedly increase evaporation rates with implications for water availability.

Blooms of cyanobacteria and fish kill events where populations of fish die in masse are also likely to increase in the future.

The critical point is that the EIS may not properly rely on historic conditions. More critically, hubris needs to be shelved. Climate experts warn that the dynamics and interaction of climate change conditions will present many unpleasant surprises. (77-1-18 [Lee, Michel])

Comment: Population growth.

Additional population growth in the region would exponentially increase the potential damage calculation for virtually every area of concern. (77-2-7 [Lee, Michel])

Comment: I strongly expect the NRC to apply the same rigorous safety standards at Palisades that would apply to all nuclear plants. There should be no exceptions, no waivers. (80-2 [Scott, Robert James])

Comment: I attended the presentation by the NRC in Benton, MI on July 11, 2024. The term baseline was repeatedly stated as what the environmental assessment would establish and then it would be determine what effect a restart of the Palisades Nuclear Plant would have from baseline.

This is concerning because it wasnt made clear that if the baseline was a high safety risk would this require mitigation BEFORE a restart could occur? If a restart of an unsafe plant slightly impacted the safety profile (minimal change from baseline), would it be allowed to proceed because the restart was not that impactful? (87-1 [Cordell, Cyndy])

Comment: The Palisades Nuclear Plant has been completely shut-down, was built in the 1970s without todays advanced technology and has been cited by the NRC as having one of the worst safety records. A restart is unprecedented, hence there is no road map as to what is required. At the very least, the process for relicensing should serve as the guide for the minimal standards for a restart. The NRC needs to evaluate all the safety citations that occurred 2-3 years prior to shut-down and their resolution as its been stated that the mitigation was not as rigorous due to the impending shut-down.

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Due to the unprecedented nature of this restart by a company (Holtec) that is mired in controversy with no track record of running a nuclear plant, let alone restarting one, the NRC has to require that any restart puts safety as the highest priority. Michigan residents and the 40 million people that depend on Lake Michigan for drinking water need energy but also need to feel that this restart will not impact their health or quality of life. (87-2 [Cordell, Cyndy])

Comment: I have grown up spending summers at Palisades Park and it is my most treasured place on earth. We have been good neighbors to the nuclear power plant and yet have witnessed times when the plant has failed to maintain the level of safety promised to its neighbors and the state of MI.

As Holtec pursues the reopening of the Palisades plant I feel we (as its next door neighbors and longtime observers) have a responsibility to point out it's faulty history and urge the NRC to leave no stone unturned SHOULD it decide to approve a re-opening. I implore you to take EVERY possible precaution to guarantee that if re-opening is a serious consideration, it is done with excruciating oversight every step of the way.

From a personal perspective, I know that I share the perspective of many that the issue of concern is not nuclear power, but rather the reopening of a plant that has been poorly run, poorly (if at all) maintained, had construction concerns from the get-go, and a number of near disasters. Certainly it is in no ones interest to allow unnecessary risk to human life in favor of political optics and business opportunity. Additionally, please consider the impact on one of our greatest fresh water sources should things go awry. (92-1 [Sloan, Jamie])

Comment: The Palisades plant was shut down in early 2022 due to failure of the control rod drive mechanism used to control the reactor operation. Restarting this plant is a clear danger to the safety of life of the citizens in the surrounding communities, due to a possible catastrophic malfunction not to mention explosion which could scatter radioactive uranium fuel rods.

This Palisades Plant is over 50 years old and has experienced numerous operational safety violations in that time frame. (93-4 [Ebert, Robert])

Comment: We are very concerned with the lack of inspection/information regarding the unprecedented re-opening of a shuttered nuclear plant. Before this action is approved to move forward, we, the public, need more information regarding the safety of re-opening a shuttered and deteriorating plant. (98-1 [O'Brien, Thomas])

Comment: I was diagnosed with Thyroid disease when I was 11 years old. It is extremely rare for an otherwise healthy individual to be diagnosed of that disease at that age. Yet, I have lived with it my entire life, perhaps due to the close proximity I had to nuclear energy production.

As an urban designer and researcher who focuses my career on the relationship between the places we live and our abilities to develop healthy routines, I am confident there is a negative impact of the reopening of this power plant without proper storage plan or maintenance to fix the safety issues, that the health of more people in my community will be damaged by this reopening.

I am a strong believer in renewables and even believe in nuclear energy, but not without proper safety and storage plans in place. Not without speaking with and talking to the community. (99-1 [Flynn, Olivia])

Comment: When the Palisades plant finally closed, the entire SW Michigan coastline dodged a Chernobyl bulletan environmental disaster that would have wiped out the entire Great Lakes basin. The safety record at Palisades and its glaring facility issues were among the worst for all

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power plants in the country. The facility is aged and brittle, and in the years prior to closing, maintenance was minimal. It was a ticking time bomb. Who knew that Holtec, a company with no experience operating a power plant, had no intention of following through with their contracted duty to oversee the permanent shut down and ongoing security of this fossil. When federal money became available to extend the life of currently operating plants, Holtec decided to get in on the gravy train by pretending Palisades was still in operationand not closed down prematurely and permanently for safety and cost reasons. (103-1 [Jacobs, Kristen])

Comment: For years, PNP operator ran the plant knowing it was on a schedule to be shut down permanently. PNP's operator deferred maintenance and investment based on this timeline.

Holtec's request presents a unique situation to the NRC & DOE and an important 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 operate safely without causing unacceptable risk to the immediate community, environment and the cherished resources of the Great Lakes? There is no experience in restarting a plant after being shut down and the concern. (104-2 [Quinn, Mary])

Comment: What can be done, and what I am most concerned about right now, is the steps being taken to ensure that the Power Plant will do everything to go above and beyond to ensure the safety of this facility. I am not an expert, but from what I am hearing Holtec has been trying to work around some of the oversight that should be done. (105-2 [Hohman, Kevin])

Comment: The environmental risks associated with restarting Palisades cannot be ignored.

Rising Great Lakes water levels, storm surges, and heavy rainfall pose significant threats to the safety of nuclear plants storing waste along our waterways. The costs of making these plants climate-resilient are substantial and should prompt a reevaluation of nuclear energys role in our states energy strategy. (108-4 [Quinn, Francis])

Comment: As rising Great Lakes water levels, storm surges and heavy rainfall erodes coastal and inland flood defenses, Palisades and other nuclear plants storing waste along our waterways are not a safe bet in a changing climate. Efforts to build and upgrade plants resistant to climate change will significantly increase the already considerable expense involved in building, operating and decommissioning nuclear plants. This should prompt a substantial reassessment of nuclear's role in helping Michigan and this country reach net zero emissions. (109-5 [Ferry, Carolyn])

Comment: Then in 1967 construction began on the Palisades nuclear plant which then started producing power in 1973. The Palisades plant has not been a good neighbor to our community.

There have been numerous well documented safety issues over the years putting our community and surrounding communities and frankly, the world at risk. (110-1 [Scott, Ann])

Comment: There are well documented safety issues and actual accidents that have potential for catastrophic outcomes. Spent nuclear fuel that is stored in cement casks precariously perched on fragile, easily eroded sand dunes. all of this - alongside the World's second largest fresh water supply. YOU WILL PUT THE WORLD AT RISK. (110-3 [Scott, Ann])

Comment: Please take the time to consider the following facts as presented by Arnie Gunderson, of Fairwinds Energy Education. Arnie is an expert in the area of nuclear power -

please don't take my word only regarding his expertise, simply google Arnie Gundersen to read and understand his extensive credentials regarding anything Nuclear Power.

Please consider the below facts (per Arnie):

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-built in 1964 to last only 40 years. Sadly, the incorrect welding material (that holds the reactor together) was used which resulted in the reactor being brittle causing many, many incidents of serious problems - too numerous to detail.

-because of the continuing problems, Entergy pulled the plug and left. If the plant were to ever be reopened, many deferred maintenance procedures needed to be performed. To name a few:

-reactor with wrong weld, needed a new head - not done

-should have put chemicals to the water part of the process to prevent rust - not done

-even now, many precautions in case of a start up again should be ongoing - not being done

-all the intelligence of the Palisades Power Plant was let go, including the operators, engineers and the maintenance experts - all gone. (111-2 [Huffman, Mary])

Comment: How much nuclear waste can continually be stored in a live sand dune? We have seen what happens to a sand dune after a tremendous storm. We were relieved when the plant closed. Now, to think it might reopen with MORE risks than ever is a bad joke on us. Please, think long and hard about this. Who is holding Holtec's feet to the fire? Who is making sure this is a safe use of our resources? (112-7 [Anonymous, Anonymous])

Comment: The Palisades plant has 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, Entergy's 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 BAND-AID 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. In just one episode a decade ago, nearly 200 workers --

including women of child-bearing age -- got on average 2.8 Rem of exposure on a month-long CRDM seal replacement job. Internationally, nuclear workers are limited to 2 Rem of exposure for an entire year. CRDM seal leaks involve reactor core primary coolant water, so represent yet another pathway to meltdown. Furthermore, the loaded hot cask fiasco from 1994 is still violating the earthquake regs of NRC and any conversion to SMR site or even any operating extensions cannot be initiated before the site is as pristine as in 1966! Holy Shiva, Holtec Krishna is turning into Mr. Burns with little regard for Federal or State regulations. (114-1 [Anonymous, Anonymous])

Comment: Definition of "Is it Safe?".

My standard of safety is met when any nuclear plant, including Palisades, meets all NRC Design Criteria. 10 CFR 50 includes all of the NRG requirements, including Design Criteria.

Current Design Standards includes all of the collective experience over the last 50 years of commercial power design, building and operations. (118-1 [Blind, Alan])

Comment: 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

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know, all these admissions about safety-significant systems, structures, and components in need of replacement, or significant upgrade, were made by 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. (123-4 [Bogen, Doug])

Comment: Additional[l]y, 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. (123-5 [Bogen, Doug])

Comment: Please consider and review Derecho potential impact on Palisades. [The] July 15, 2024, Derecho ripped through the Midwest impacting Chicago and spinning off over a dozen tornados. [The] May 30, 2024, Derecho ripped through Grand Haven, MI. Early May tornados ripped through Kalamazoo, MI. In short extreme weather events have must be taken into consideration regarding Palisades Environmental Review. (125-1 [Keegan, Michael J.])

Comment: When the NRC questioned Holtec about the Quality Assurance Manual in place during the period of system restoration, Holtec said they would modify the in place decommissioning Quality Assurance Plan to cover the activities being performed at the plant during the restoration period.

It seems reasonable such a QA plan would be at least equal in scope and importance as the operating QA program.

Holtecs own analysis was the operating QA program was more then editorial and would require prior NRC approval.

It does not appear Holtec's plan to revise its decommissioning QA program for the for the period of system restoration, without NRC approval is allowed. (141-7 [Blind, Alan])

Comment: The NRC inspection plan of restart activities, based on the Holtec schedule of activities should be available to the public. (141-8 [Blind, Alan])

Comment: The itemized listing of resort issues from NRC inspection Manual should be made available to the public. (141-9 [Blind, Alan])

Comment: It is critical that the GAOs report on the nuclear industries preparedness for climate change be analyzed and addressed in writing point by point so that the public is comfortable that the nuclear waste on the shores of Lake Michigan will be safe from all the unexpected storms, extreme temperatures, massive rains, droughts. This should be a priority. (142-1 [Flynn, Jody])

Comment: Safe operations and safe nuclear waste storage is paramount for the safety of local residents. For the current and future reputation of nuclear energy, thorough attention to the prevention of any risk is of the utmost importance. (143-10-1 [Fetzer, Darby])

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Comment: Dog-tailing off of what she was saying, I feel like the GAO produced a pretty damning document about the nuclear energy's preparedness for climate change. I feel like it's largely being ignored. I haven't heard any response from the NRC, and particularly, the environmental. I would think that it would have the highest priority for you.

I would really appreciate it if you could give some response to that because it does not seem like the nuclear energy, the NRC is making any sort of adjustments into climate change. And maybe you'll say that your external hazards, or whatever, that part, your arm of your -- is addressing it, but I certainly haven't seen anything, and I haven't heard one peep from the NRC about the GAO's damning report.

So, I would love to get a commitment from you to respond to that report point-by-point, so that we can feel a little bit safer; that you're actually taking into consideration something that is absolutely critical -- with all that nuclear waste on the shores. I guess I can't get that commitment. Could I? (143-11-1 [Flynn, Jody])

Comment: You know, so these plants, DC Cook, Palisades, all these don't have the track records. They should not be allowed to destroy the records. Everything is, if you followed the history of Palisades, it's got a really horrible track record.

It almost had a meltdown, five minutes to a meltdown, because they had a bad sump pump.

They took it out and they ran it with another sump pump without backup. So, when the sump pump failed, they didn't have another sump pump. And so, they brought in all these engineers.

They decided to put the one that was in pieces together and put it back on, but it was like five minutes to a meltdown.

And it really didn't make it into the news, but we have come so close to meltdowns in Michigan.

Fermi, that almost had a meltdown. There's a book. They almost lost Detroit.

These things are just deadly. And also, you've got these things like earthquakes, tsunamis, all these climatic things. You know, you just can't count that, even if everybody does a good job, you can't count that these things are going to be safe. You know they're not. You know they're a risk, and it's not worth the risk. You know? It's a stupid way to make energy. (143-16-6 [Barnes, Kathryn])

Comment: I just want to say -- and I've heard it said many times tonight -- this is unprecedented. This is plant that's been shut down, and then, you're going to build it back up.

So, I really encourage you during your scope to really take that perspective, especially on some of these safety issues.

I heard from many Representatives; they're saying how it's safe, safe, safe. You know, in 2012, the NRC actually rated Palisades one of the four worst-performing safety plants in the Nation.

So, there's been safety issues.

Also, in the perspective, because they knew they were shutting down, there were some significant safety issues that weren't addressed as adequately as if it was going to continue to run. (143-18-1 [Cordell, Cyndy])

Comment: First of all, I would like it to be known that Palisades Park was formed in 1905, and a lot of the families that started it back then are still around. So, we've been there and on this property all that time.

I can certainly understand the NRC's granting of exceptions to Entergy for key safety features because they're very close to the end of their operating life. And so, as just a person in the

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public, I can sort of understand that thinking, where you're not going to make this huge financial investment if they're going to close down in five years or 10 years, or whatever.

But there's no way this plant should restart if it doesn't meet the current safety standards. And it's well-documented, lots of systems that they've got exceptions on, and those should all be put back in place. And this plant should be as safe as any new plant coming online. And really, to impact their environmental assessment if they're not, that's going to have a huge influence on your assessment and your findings. (143-20-1 [Flynn, Tom])

Comment: And over the last decade, I think I've attended pretty much every public meeting at Palisades by the company or by the NRC. And I've noticed a disturbing trend, and that is what I'm very concerned about. And this is my comment:

Well, first of all, please consider the environmental impact of, both the financial and the environmental impact of the Chernobyl and Fukushima disasters and place those right here in west Michigan and think about the damage that it would do to the drinking water for millions of people and what it would do to our agriculture, and what it would to us financially.

We don't want to have a nuclear disaster anywhere. But the reason that I want you to include that in your scope is to consider what would happen if we had that scale of a disaster here, if we had a spent fuel fire or if we had a loss-of-coolant accident. And what would it do? (143 1 [Schultz, Kraig])

Comment: And the reason I'm concerned about a disaster is because I see that we're cutting corners and we're trying to rush this plant that has operated nearly 50 years back into production. And yet, we have hundreds of millions of dollars of public funds to do it right. We could do the repairs. We should do the repairs. (143-21-2 [Schultz, Kraig])

Comment: And the reason that we have the safety record we have in this country and in our U.S. military is because of our adherence to strict safety protocols. And when we're shortcutting and giving exemption after exemption to the license, that's just going to get us into trouble.

So, as we embark on another -- you know, Holtec has said that they are going to pursue a license past 2031 -- you know, if we're really going to embark on another 50 years of trying to operate these plants, something no one has ever done, we need to really be doubling-down and actually increasing our regulation to make sure that we don't have a nuclear disaster here or anywhere in the world. (143-21-4 [Schultz, Kraig])

Comment: And if you aren't from the area, you should know that we had a whole town disappear. It was buried in sand not too far from here and around Saugatuck. So, I want you to consider that. We have high wave damage that also will affect the sand and movable sand.

(143-23-3 [Pierman, Bette])

Comment: The other thing I would urge you to do -- you know, back when our houses were built in Palisades, there was no building code. Back when this plant was built, there really was no building code. Okay? We learned and we developed building codes over the years by looking at bad things that happened.

Bad things have happened in Fukushima, Three Mile Island, Chernobyl, and we've learned from those mistakes. One of the biggest things, somebody mentioned there was a near-meltdown in Palisades because of a sump pump. That is absolutely true. The previous owner was supposed to fix that.

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They only had 5 square feet of sump action to get that water. The thing from the NRC before said they needed 3,000 or 5,000 square feet. I don't know what the exact number was, but incredibly -- incredibly -- under-engineered.

And those things have to be addressed and be taken care of. You know, Edmund Burke said, "Those who don't learn from history will be condemned to repeat it." Do we want to be the next Chernobyl? I don't think so. I don't.

We need to make sure we do it, get it right. And I would charge you, your body, to codify what the building standards are for present-day plants. This plant, just because it's being brought back online, shouldn't have to have lesser safety standards than a new plant being built. (143-26-5 [Davis, Bruce])

Comment: And the waste is being stored on unstable shores. Add in the issues of unsafe storage of nuclear waste onsite and the potential of fuel from SMRs, and we have a potential catastrophe waiting to happen. Add in the effects of climate change on nuclear reactors and triple the risk. (143-29-3 [Drechsler, Jacqueline])

Comment: Because you now have a parade of zombie reactors in this country. Palisades set the precedent, followed by Duane Arnold in Iowa, Three Mile Island Unit 1, and we wait to hear who else will join this parade of zombie reactors.

So, some of the safety problems with Palisades have been mentioned, and I would just like to agree with someone on the panel who said there are overlaps between safety and environmental impact.

Craig Schultz pointed out that a Fukushima-scale catastrophe or a Chernobyl-scale catastrophe at Palisades would certainly have environmental impacts.

So, the extremely large negative environmental impacts of a meltdown at the Palisades zombie reactor, would include large-scale airborne fallout, and waterborne outflow of hazardous radioactivity into Lake Michigan, as well as wind driven precipitation delivered fallout onto land.

Such airborne fallout from Chernobyl in 1986 severely contaminated not just the breadbasket of Europe, also known as Ukraine, but also sheep farms in Scotland, Sami reindeer herding grounds in the Scandinavian Arctic, Lake Constance, which borders Bavaria, Germany, and elsewhere.

Not just hundreds, but even thousands of miles downwind.

Radioactive fallout and wastewater discharges into the Pacific Ocean from Fukushima Daiichi in Japan, did not end in the spring of 2011, they began then.

The tritiated wastewater discharges will now continue for decades intentionally, despite the risks to humans via Pacific fisheries.

These are cautionary tales for Van Buren, as well as Berrien, Allegan, and Kalamazoo Counties, a major agricultural breadbasket of Michigan.

Not to mention a tourism and recreation Mecca for the Great Lakes state.

The late, great Maynard Coffman, a Bangor farmer and author, the founding father of the Michigan Organic Food and Farm Alliance, and a watchdog on Palisades since before ground was even broken in 1967, warned repeatedly about these impacts on Palisades area agriculture, for decades on end.

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And as an expert witness for the Environmental Coalition opposed to Palisades restart, Arnie Gunderson, chief engineer at Fairwinds, warned a decade ago, a Fukushima-scale radioactive disaster at Palisades would be catastrophic for Lake Michigan, and the rest of the Great Lakes downstream, and downwind.

The Great Lakes comprise 21 percent of the world's surface fresh water. Eighty-four percent of North America's and 95 percent of the USA's.

The Great Lakes serve as drinking water for more than 40 million people in eight U.S. states, two Canadian provinces, and a large number of indigenous nations. (143-35-3 [Kamps, Kevin])

Comment: To put this all at risk with the unneeded Palisades zombie reactor restart, is nuclear madness.

The hazardous persistence of artificial radioactive pollutants that would escape into the environment due to reactor core meltdown, are nightmarish.

Tritium, radioactive hydrogen, which can go anywhere in the human anatomy right down to the DNA molecule, 123 to 246 years of hazard.

Cesium-137, a muscle seeker, around 300-600 years of hazard.

Strontium-90, a bone seeker, around 300-600 years of hazard.

Carbon-14, which can also go anywhere in the human body right down to the DNA molecule, 55,000 to 110,000 years of hazard.

Plutonium-239, 240,000 to 480,000 years of hazard.

Iodine-129, 157 to 314 million years of hazard.

To name but a small number of the more than 200 hazardous artificial radioactive isotopes contained in the irradiated nuclear fuel at Palisades, as well as in its operating reactor core. (143-35-4 [Kamps, Kevin])

C.2.12 Comments Concerning Outside Scope - Security and Terrorism Comment: Ive read Shawn Connors fictional exposure book about the future use of spent fuel rods for new nuke tech. Weve got to be looking at 20-30+ yrs on that. Two or 3 things struck me about that. First was, his outcomes are hook line and sinker based on industry clap trap about safety. There isnt any safety on sandy shores of a fresh water (20% of worlds water) in our present climate change uproar and terrorist agendas. (Just think how many of our major Midwest cities they could wipe out with that plan! Chicago, Detroit, Cleveland, all the shoreline around 4 states and Canadas border, thats an international 3pointer. Itd certainly be a juicy choice if you really wanted to create havoc.) (33-6 [Birdsall, Sheila])

Comment: The potential for cyberattack, attacks on the regional electric grid, and sabotage of site operations. Notably, Michigan in recent years has experienced domestic terrorism. (77 7 [Lee, Michel])

Comment: Obvious security issues which are in the public record may not reasonably be excluded from consideration and discussion. These include threats posed individually and interactively from the cyber realm; drones (such as with drone swarms which have already occurred over US nuclear plants); and from emerging AI. While risks resulting from sabotage and terrorism may be unquantifiable, they still demand due recognition in the EIS. (77 13 [Lee, Michel])

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Appendix D EPA LETTER

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