ML25063A062
| ML25063A062 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/03/2025 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 90FR8721 | |
| Download: ML25063A062 (14) | |
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[External_Sender] Docket ID NRC-2024-0076 - Comments of CIECP & PHASE on Palisades Draft EA (pdf version)
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NRC_2024_0076_Comments_CIECP_PHASE_Palisades_Dra ft_EA..pdf Re: Docket ID NRC-2024-0076
Dear NRC:
These comments were submitted on behalf of the below groups earlier on March 3, 2025 as an email. We hereby submit them additionally in the format of a pdf, should that be more useful for the Commission.
Sincerely, Michel Lee, Esq.
On behalf of Council on Intelligent Energy & Conservation Policy (CIECP)
Promoting Health and Sustainable Energy (PHASE)
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[External_Sender] Docket ID NRC-2024-0076 - Comments of CIECP & PHASE on Palisades Draft EA (pdf version)
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1 March 3, 2025 Comments of CIECP & PHASE to U.S. Nuclear Regulatory Commission (NRC) and U.S. Department of Energy (DOE) Re: Draft Environmental Assessment and Draft Finding of No Significant Impact for the Palisades Nuclear Plant Reauthorization of Power Operations Project, Docket ID NRC-2024-0076, DOE ID DOE-EA-2285 (March 3, 2025)
TO:
Office of Administration Attn: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-001 Via email to: PalisadesRestartEnvironmental@nrc.gov
Dear NRC,
On behalf of the Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) it is respectfully submitted that 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.
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 respect to The Palisades Nuclear Plant (Palisades), which has been shut down for years (already closing in on 3). 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.
Entergy Operations, Inc. (Entergy), the prior licensee, permanently ceased operation of Palisades reactor on May 20, 2022 and submitted the certifications for permanent
2 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 has sought 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) multiple license amendment requests.
The NRC must not capitulate to Holtecs effort to turn the NRC into a rank rubberstamping operation.
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).
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.
3 (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.
(7) The potential for cyberattack, attacks on the regional electric grid, and sabotage of site operations. Notably, Michigan in recent years has experienced domestic terrorism.
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. 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 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 a thorough 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.
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.
4 Palisades was designed for a world which no longer exists.
Below we emphasize certain areas which must be comprehensively investigated and candidly explored in an EIS.
The full consequences of a major accident or successful malignant insider saboteur and/or terrorist attack.
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.
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.
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 fire, for example, could render many thousands of square miles uninhabitable for the remainder of the 21st century.
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 remainder of the century, it is no longer valid to assume that the necessary level of access or emergency response capability will be available.
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
5 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.
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.
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. (See e.gl., Wuebbles 2019) Temperature and water levels have
6 fluctuated dramatically over the past few decades. In general, a substantial decrease in ice cover due to warmer winters has 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 en masse are also likely to increase in the future.
The critical point is that the EIS must fully consider the panoply of conditions and risks plausibly presented by climate change. These impact the likelihood of radioactive and toxic releases and of accidents, as well as the heightened severity of consequences.
Further, the NRC 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. (Dorfman 2021; Smith 2006; Stranahan 2019. See also U.S. GAO 2024.)
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. (Makhijani 2006; Mothersill 2014; Nichols 2024)
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.
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
7 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.
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.
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.
Part of the equation will be the additional costs and complexities of ultimate decommissioning and remediation of the site.
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 US 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.
8 Regardless of the fate of CISFs, as determined by the judicial branch, the conditions which make CISFs and a large nuclear waste transportation regime which would span decades highly risky will continue.
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.
Should an 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. (See e.g., Von Hippel 2016)
The calculus of costs should include security, first responder and emergency planning, equipping, training, and staging costs.
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.
Cheaper, cleaner, safer, more sustainable and broadly supported and desirable alternatives to both nuclear and fossil fuel generation exist today. Barnaby 2007; Benham 2023 ; Bond 2024; Bradford 2017; Brown 2018; Cooper 2021; Diesendorf 2016; Dunai 2019; Jacobson 2023; Jacobson 2020; Jacobson 2018; Lovins 2020; Lovins 2018; Makhijani 2018; Mez 2016; Perez 2019; Ramana 2024; Ramana 2018; Schlissel 2024; Sovacool 2020; Smith 2006)
Wind, solar, and small hydroelectric, backed up by storage, modernization of the grid, and smart grid management will improve reliability. These are the energy solutions which are expanding rapidly globally. Indeed, efficiency technologies and renewables and storage/battery solutions are viewed by the International Energy Agency (IEA) and other world authorities as the systems which will do the heavy lifting for the energy transition which is now well underway. (Benham 2023; Bond 2024; IEA Energy Efficiency 2024; IEA Renewables 2024)
In sharp contrast to nuclear, 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.
The NRCs Alternatives Analysis is a case study in the disregard of alternatives to nuclear power.
Environmental justice, especially the environmental and health impacts on indigenous, lower income and communities of color.
9 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.
Population growth.
Additional population growth in the region would exponentially increase the potential damage calculation for virtually every area of concern.
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.
CONCLUSION.
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.
The EAs finding of No Significant Impact (FONSI) is patently absurd and the Purpose and Need Statement is facile.
We support the No-Action Alternative. Palisades should not be permitted to restart and small modular reactors must not be built at either Palisades or Big Rock Point.
Sincerely, M. Lee, Esq.
On behalf of:
Council on Intelligent Energy
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