ML25055A277
| ML25055A277 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/06/2025 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 90FR8721 | |
| Download: ML25055A277 (4) | |
Text
From:
Shawn Connors <shawn15888@gmail.com>
Sent:
Thursday, February 6, 2025 7:37 PM To:
PalisadesRestartEnvironmental Resource
Subject:
[External_Sender] Public Comment Draft EA and FONSI Palisades Nuclear Plant Repowering
Dear NRC Regulators:
I am in support of the Draft Environmental Assessment (EA) and finding no significant impact (FONSI) for the Palisades nuclear plant repowering. On July 11, 2024, I attended an NRC public meeting on the Palisades Repowering when the environmental review process was discussed in advance. During that meeting several members of the Palisades Country Club neighborhood, located on the plant's southern boundary, claimed a cluster of thyroid diseases in their neighborhood had developed among their population, and then asked the NRC to conduct a study to determine if the cause might be the nuclear plant. I recall NRC officials had requested any supporting data from the neighborhood representatives, but none seems to have been published. NRC officials also explained the request was beyond the role of the NRC to evaluate a connection between the plant and thyroid diagnosis, and that the group needed to contact the State of Michigan, Department of Health, which Holtec would have cooperated with. I have not been successful in finding any data in public databases or news that supports the neighborhood's claim of elevated thyroid disease, and there does not appear to be any study planned or being conducted by the Michigan Department of Health related to this issue. NRC Officials also explained that tritium levels (a suspected carcinogen at high doses) emitted from the plant have never been detected at unsafe levels in any of the wells surrounding the plant. There has also never been an unsafe level of atmospheric radiation outside of the plant in its 54 years of operation.
I used a portion of my in person public comment on July 11th., 2024, to offer sympathy to the Palisades neighbors, but shared why I thought it was highly unlikely the plant was the cause of any elevation of thyroid disease in their community. If the neighborhood has not offered health officials a valid data set to back up their diagnostic claims, and the State of Michigan Department of Health has not been contacted or does not find merit in the concern, then there is no need for a full Environmental Impact Statement (EIS) as a result of this alleged issue. I mention the thyroid disease narrative put forth by Palisades Park Country Club neighborhood members because a lot of media attention and anecdotal articles have been published about it. Anti nuclear groups like Beyond Nuclear, The Sierra Club, and
others have attempted to make broad claims of nuclear plants causing thyroid cancer, but none of the claims are tied to any peer reviewed medical studies.
Public comments have also been made suggesting nuclear plants in general and Palisades specifically may not have access to cool water because Lake Michigan may be warming due to climate change. First, the water intake to Palisades is approximately 20 feet below the surface, where the water is cooler. Lake Michigan averages 60 degrees fahrenheit in the summer months, with 81.3 degrees fahrenheit the high recorded in 1995. Also, as part of the plant's upgrade Holtec is to install a new Cooling Water Heat Exchanger which will cool water in the primary loop if need be to keep the reactor running efficiently. It appears that top water temperature requirements are different for each nuclear plant. Someone in the crowd mentioned Palisades upper limit was 77 degrees fahrenheit, but I was unable to verify that information. The NRC did allow the Millstone Power Plant to use 80 degree fahrenheit temperature intake water from the Long Island Sound, which has a previous limit of 75 degrees. The temperature of Lake Michigan's intake water should not be a concern, and the temperature of the discharge water will be within the NRC's regulatory parameters.
Another climate change related fear was the shifting sand dunes of Lake Michigan. The Palisades Nuclear Plant has been in operation for 54 years, and shifting sand dunes have not threatened the safe operation of the plant. Van Buren State Park, right on Lake Michigan, on Palisade's immediate northern boundary appears exactly as it did when the plant started operation in 1971. I was there many times during that era, and still ride my bicycle through the State Park several times per week in the summer.
The plant itself appears to be about 25 feet above the level of Lake Michigan, and some of the used fuel storage casks about 40 feet above Lake Michigan's level, and about 500 feet back from the lake. There is no climate model I know of where Lake Michigan will rise more than 20 inches by 2050 (and that is the most extreme estimate), and the Intergovernmental Panel on Climate Change (IPCC) makes no comment on their confidence in Lake Michigan's water level in regards to climate change. Tod Allen, Chair and Professor, University of Michigan Nuclear Engineering & Radiological Sciences, and Director of Fastest Path to Zero Initiative has been an advocate for keeping Palisades in operation. Dr. Allen has suggested a sea wall placed in front of the plant would be a precaution against rising lake levels. Riprap is a shoreline protection method that uses large rocks and gravel to prevent erosion, and is common with many lakeside neighborhoods north and south of Palisades. The used fuel dry casks could be moved back from the lake to a secondary storage area on the Palisades property. These solutions are available if extreme predictions of water levels were exceeded, and would be predictable far before the events became critical.
I also made a public comment on the reissuance of NPDES Permit M10001457, which was approved. Here is an excerpt of my comment, "It appears Palisades is meeting all the standards for effluent limitation guidelines under Part 31 of the Natural Resource of and Environmental Protection Act (NREPA), Part 21 Rules, Wastewater Discharge Permits, Part 4 Rules, Water Quality Standards, and Part 8 Rules, Water Quality Based Effluent Limit Development for Toxic Substances."
I followed the license extension application for Turkey Point's units 3 and 4 in Homestead, Florida for 2052 and 2053 respectively. The extensions were finally granted in September 2024. But in February 2024 the NRC reversed their decisions based on the Environmental Assessment language. I understood the technical reasons for a decision to modify the license expiration over what amounted to an edit in the documentation. Beyond Nuclear, Friends of the Earth, National Resource Defense Council and Miami Water Keepers managed to delay the extensions and add considerable costs to the process for no safety
enhancement. These are some of the same organizations opposing the repowering of the Palisades nuclear plant. I implore the NRC to stick with this draft of the Environmental Assessment (EA) and the Finding of No Significant Impact (FONSI). I expect the issues I brought up in this statement and others will be used by groups opposed to Palisades' being repowered. If the plant should not be repowered because it cannot be done safely, then so be it. But a required edit in a document, computer models and estimates about extreme far future weather events, unsubstantiated health risks claims, and accusations that the data the NRC refers to in responses to citizens' concerns are false, should not be relevant reasons to delay the final issuance of the favorable draft of the Environmental Assessment.
Thank you for the opportunity to make this public statement, and for your public service, Shawn Connors
Federal Register Notice:
90FR8721 Comment Number:
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Subject:
[External_Sender] Public Comment Draft EA and FONSI Palisades Nuclear Plant Repowering Sent Date:
2/6/2025 7:37:15 PM Received Date:
2/6/2025 7:37:33 PM From:
Shawn Connors Created By:
shawn15888@gmail.com Recipients:
"PalisadesRestartEnvironmental Resource" <PalisadesRestartEnvironmental.Resource@nrc.gov>
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