ML25063A065
| ML25063A065 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/04/2025 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 90FR8721 | |
| Download: ML25063A065 (149) | |
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Kevin Kamps <kevin@beyondnuclear.org>
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3 3 25 KK comments re NRC EAFONSI.pdf Attached Kevin Kamps Radioactive Waste Specialist Beyond Nuclear 7304 Carroll Avenue, #182 Takoma Park, Maryland 20912 Cell: (240) 462-3216 kevin@beyondnuclear.org www.beyondnuclear.org Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.
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Page 1 ENVIRONMENTAL COALITION COMMENTS ON NRC EA/FONSI RE: PALISADES REACTOR RESTART PREPARED BY KEVIN KAMPS, RADIOACTIVE WASTE SPECIALIST, BEYOND NUCLEAR MARCH 3, 2025 COMMENTS ON: U.S. Nuclear Regulatory Commission and U.S. Department of Energys (Cooperating Agency) Draft Environmental Assessment and Draft Finding of No Signi"cant Impact for the Palisades Nuclear Plant Reauthorization of Power Operations Project; ML24353A157; NRC CEQ ID: EAXX-429-00-000-1734394646; DOE ID: DOE/EA-2285; Docket Number: 050-0255; Issued: January 2025 Draft for Comment.
Docket ID NRC-2024-0076 Submitted via email to: <PalisadesRestartEnvironmental@nrc.gov>
ORGANIZATIONS ENDORSING THESE COALITION COMMENTS:
INDIVIDUALS ENDORSING THESE COALITION COMMENTS:
OVERVIEW/
SUMMARY
1.
We request NRC do an Environmental Impact Statement (EIS). This Environmental Assessment is not sucient. We contest NRCs Finding of No Signi"cant Impact (FONSI).
This closed for good reactor restart scheme is unprecedented, unneeded, insanely expensive for the public, and extremely risky for human health and the environment (as well as safety and security). The very signi"cant impacts of this major federal action demand an EIS, in order to be compliant with the National Environmental Policy Act (NEPA). Once NRC publishes the requested EIS, we request an adequate comment period of six months, in order to adequately address the large number of very signi"cant impacts of this major federal action. Along similar lines, we request that a Programmatic EIS be performed, in order to comply with NEPA. As stated by multiple public commenters at the environmental scoping public comment meeting convened by NRC and DOE at Benton Harbor, Michigan on July 11, 2024, since the precedent being set by Palisades Nuclear Plant (PNP), in terms of closed for good reactor restart, a Programmatic EIS should be required, not this insucient, low-level EA. Other closed for good reactors already seeking restart permission from NRC, and very likely bailouts from DOE, other federal agencies, and state governments, currently include: Three Mile Island Unit 1 in Pennsylvania (recently preposterously renamed the Christopher Crane Safe Energy Center, likely an eort to shed the radioactive stigma of the Three Mile Island Unit 2 50% meltdown of 3/28/1979, considered by many to be the worst reactor disaster in U.S. history; Duane Arnold in Iowa is not far behind. Additional zombie reactors in the U.S. include Diablo Canyon Units 1 and 2 in California, which were supposed to close for good in 2024, and 2025, respectively, as well as Summer Units 2 and 3 in South Carolina, both abandoned midway through construction, in 2017. Given the precedent-setting nature of PNPs restart for all these other zombie reactors, with yet more possible in the future, a PEIS should be undertaken to comply with NEPA.
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2.
NRCs Purpose and Need statement is unacceptably shallow and woefully inadequate. NRC has stated that a recently enacted State of Michigan clean energy law mandates the Palisades restart. But nuclear power is not clean far from it. Besides, various supposed reasons have been given for Palisades restart, from restoring good paying jobs, to electricity needed for Arti"cial Intelligence (A.I.) data centers, energy storage battery facilities, charging the electric vehicle "eet, climate mitigation, reliability of electricity supply and the electrical grid, etc. All these moving target, throwing-spaghetti-against-the-wall-to-see-what-sticks, supposed justi"cations for Palisades restart will be challenged and rebutted in more detail below, even though NRC did not even bring them up, but rather only brie"y mentioned Michigans recently passed clean energy law, and also very brie"y mentioned Holtecs purported claims of electric reliability enhancement, and supposed independence from energy imports.
3.
NRCs Alternatives Analysis is unacceptably narrow in scope and woefully inadequate. Alternatives for the generation of 800 Megawatts-electric of carbon-free and nuclear-free electricity generation should not be con"ned to the tiny 432-acre Palisades site. The alternatives of wind power (both on-and o-shore), solar power (both household/
business-scale and industrial scale), and other renewable energy generation sources should be given the hard look required under NEPA. So too should the potential for energy eciency upgrades to prevent waste, and decrease demand. Energy storage technologies should also be analyzed as a complement to any intermittancy issues associated with renewables like solar and wind.
More detail on these alternatives will be discussed below, in the coalitions comments. Our coalitions detailed comments below include discussion of former Michigan Governor (and, more recently, U.S. Energy Secretary) Jennifer Granholms o-shore wind power plans for the Great Lakes State; Dr. Mark Z. Jacobsons comprehensive comparison of renewables versus nuclear power in terms of climate mitigation via greenhouse gas emissions reductions, which concluded that nuclear power costs too much and takes too long, while renewables are very time-and cost-eecitve in addressing the climate crisis; as well as Amory Lovins and Dr. Arjun Makhijanis similar conclusions.
4.
We support the No-Action Alternative: no PNP restart, but rather its closure for good, and retirement, as well as decommissioning, as long planned and promised to Michiganders, and residents of neighboring states around Lake Michigan. NRC, which is mandated to protect public health and safety, as well as the environment, should not authorize the restart of the Palisades reactor. DOE should not risk vast sums of federal taxpayer money $1.52 billion, and still counting on Holtecs scheme. Likewise, the U.S. Department of Agriculture (USDA) should not risk $1.3 billion on this scheme, namely grants to reimburse the Power Purchase Agreement (PPA) purchasers (the rural electric co-ops Wolverine, in Michigan, and Hoosier in Indiana and Illinois) for 25% of the costs of the exorbitantly overpriced electricity from Holtecs Palisades reactor, from 2025 to 2051 or even beyond. The electricity will cost 57%, or more, above market rates, according to Holtec itself, in its initial PNP restart strategy document and bailout application submitted in secret to DOE on 7/5/22, just a week after taking ownership of PNP, supposedly for decommissioning purposes only.
5.
We contest NRC and DOEs FONSI, Finding Of No Signi"cant Impact. Are NRC and DOE saying that the Great Lakes region, and the humans and other living things that call it home, are not signi"cant? This is the only logical explanation, given the very large negative impacts on health, environment, and safety, that a restart of the Palisades Nuclear Plant (PNP) clearly would have.
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6.
Two SMR-300s being constructed and operated on the tiny 432-acre PNP site, alongside 80 years altogether of extended operations, from 1971 to 2051, at the zombie reactor, represents a major cumulative impact. The way NRC essentially ignores all past public comments provided at past proceedings, like the 2006 license extension SEIS comments for the 60-year license at PNP, is objectionable. Its like NRC was born yesterday, and expects us to be as willfully ignorant and blind as they are, in regards to such large and cumulative impacts at, near, and from PNP. Tremendous eort was put into our environmental coalitions 2006 SEIS public comments. Yet NRC ignored most to all of them.
For that reason, they are still relevant. Just because NRC cites the 2006 SEIS repeatedly throughout this EA, does not mean NRC has adequately addressed those comments or concerns, or addressed them at all. For this reason, we incorporate by reference, as if fully written herein, the entirety of our environmental coalitions comments on the draft SEIS from 2006. Those comments are posted online here, at the following two links:
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 license extension. 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.
DETAILED COMMENTS:
PAGE 17 OF 242 ON PDF COUNTER (page xv) bhp break horsepower
[Should this instead read brake horsepower? Such technical terms, unfamiliar to most readers and members of the public, should be de"ned.]
P. 19/242 ON PDF COUNTER (page xvii)
N&S Report New and Signi"cant Report (from Holtec Decommissioning International, LLC [HDI])
[The actual title Holtec gave this document was very oddly worded; apparently, NRC has seen "t to help Holtec clear it up, by giving this document a more coherent title; NRC went so far as to accept Holtecs document in lieu of an Environmental Report, required under NEPA, which an environmental coalition intervening against the Palisades restart is contesting in Atomic Safety and Licensing Board proceedings.]
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P. 21/242 ON PDF COUNTER (page xix)
TRO total residual oxidant
[TRO, in the legal realm, stands for Temporary Restraining Order. The environmental coalition intervening against Holtecs Palisades Nuclear Plant (PNP) restart fully intends to take this matter to federal court, if an when necessary.]
PGS. 23-24/242 ON PDF COUNTER (pages 1-1 to 1-2)
[Entergys closure of Palisades for good, on May 20, 2022, which it certi"ed with NRC on June 13, 2022, was followed by Holtecs application to NRC for various waivers and exemptions to its so-called Operating License (one that no longer authorizes operation), to re"ect the purported, supposed, promised decommissioning status of Palisades. But beginning a week after it acquired PNP, supposedly for decommissioning purposes only, Holtec has sought to restart the reactor. This has led to Holtecs attempt to get NRC to approve a growing number of License Amendment Requests, a license transfer request, an exemption request, as well as massive bailout requests, as to DOE, USDA, and the State of Michigan. This roller coaster ride, from operating to decommissioning, back to operating, represents signi"cant waste, fraud, and abuse. All of Holtecs requested LARs, etc., cost signi"cant time and money, including for the concerned public. NRC Commissioner Bradley Crowell was quoted in ExchangeMonitor in Feb.
2023, questioning why proponents of PNP reactor restart waited till the 11th hour, or the last second, to even bring up the concept of reactor restart why didnt they start sooner?
Governor Whitmer "oated the trial balloon of not closing PNP, but rather operating it for decades to come, on 4/20/22, just a month to the day before Entergy closed it for good.
Although Holtec had secretly applied to DOE for many billions of dollars in bailouts on 7/5/22, just one week after taking over at PNP, the company would not go public with its restart plan announcement until 9/9/22. For many months and even years on end, "rst Entergy, and then Holtec, requested NRC grant license exemptions and waivers, re"ecting the change from operational to decommissioning status at PNP. But beginning almost immediately after taking over PNP, Holtec has since also been attempting to reverse the actions and requests of Entergy and even of Holtec itself. Why has Holtec spoken out both sides of its mouth? These changes to the Operating License, all approved by NRC to re"ect decommissioning status, only to be reversed again, taking not months but years, and demanding vast commitments of time and money, represent waste, fraud, and abuse on the part of Holtec, as well as a complicit NRC.
By the way, referring to it as an Operating License, or a Renewed Facility Operating License, which does not authorize operations, is quite Orwellian. Arent federal agencies like NRC supposed to communicate in plain, intelligible language? If not, why not? Is NRC attempting to intentionally blur the lines between operational status and decommissioning status at PNP?
How is such chaotic blurring of the lines not gaslighting of the public?]
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P. 24/242 ON PDF COUNTER (page 1-2)
- The September 28, 2023, request for an exemption (Holtec 2023-TN10538) from the 10 CFR 50.82(a)(2) (TN249) restriction that prohibits reactor power operations and emplacement or retention of fuel in the reactor vessel to allow for a one-time rescission of the docketed 10 CFR 50.82(a)(1) certi"cations.
- The December 6, 2023 license transfer request (HDI 2023-TN10838) for Palisades, which seeks NRC consent to, and a conforming amendment for, a transfer of operating authority from HDI to Palisades Energy, LLC under the Palisades RFOL No. DPR-20 and the general license for the Palisades Independent Spent Fuel Storage Installation.
- Approval of requisite license amendment requests (LARs) to the Palisades RFOLthe identi"ed requisite LARs are listed inTable 1-1 (see Section 1.1.1 of this environmental assessment [EA]). [Emphasis added]
[As mentioned above, the inexplicable roller coaster ride from operating status at PNP, to decommissioning status, back to operating status summarized by NRC above, has shown that Holtecs promise to decommission PNP was a con job, a bait and switch trick, a big lie.
How can NRC, DOE, USDA, and the public trust this company, which has never operated an atomic reactor before, to restart and operate PNP for decades into the future in a way that is safe and protective of the environment and human health?
Please note that a space is needed, above, between in and Table. Radioactivity can cause radiogenic insertions and deletions of vital components of DNA molecules, for example, resulting in genetic damage, birth defects, and cancer causation, but we didnt know it could delete needed spaces. Seriously though, given the high risks to the environment, human health, and public safety of the PNP restart scheme, and the large number of NRC and other federal agency sta listed as contributing to this EA, the public should be able to expect a high quality document, free from misspellings, bad grammar, etc.]
P. 24/242 ON PDF COUNTER (page 1-2)
Hereinafter, Holtec Palisades (licensed owner), HDI (current licensed operator), and Palisades Energy, LLC (planned licensed operator upon approval of December 6, 2023 transfer request) are collectively referred to as Holtec. This EA will generally refer to Holtec without specifying which company, unless necessary.
[As we pointed out above, HDI (current licensed operator) refers to an Operating License that no longer authorizes operation. This is Orwellian, misleading, and confusing. Is it intentionally so?]
P. 25/242 ON PDF COUNTER (page 1-3)
Table 1-1 Licensing and Regulatory Actions for Palisades Nuclear Plant Post Decommissioning Request to Reinstate the Palisades Emergency Plan to Support Resumption of Power Operations, dated May 1, 2024.
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[As members of our environmental coalition have communicated to NRC in the past, although it fell on deaf ears, the emergency evacuation plan and other emergency preparedness plans at PNP never should have been ended, even during the decommissioning phase, as large-scale risks remain on-site, even without the reactor operating. For example, around two-thirds, or more, of all the highly radioactive irradiated nuclear fuel ever generated at PNP between 1971 and 2022, is still stored in in the indoor wet storage pool. The pool is vulnerable to loss of cooling water and its recirculation, which could result in a catastrophic irradiated nuclear fuel zirconium "re, and the release of nightmarish quantities of volatile and hazardous radioactive isotopes, such as Cesium-137, into the environment. Such a catastrophe could surpass even Chornobyl and Fukushima in terms of the severity of consequences downwind, downstream, up the food chain, and down the generations, as warned about by Alvarez, et al. in 2003, (Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States), the U.S.
National Academies of Science in 2005 (Safety and Security of Commercial Spent Nuclear Fuel), Alvarez in 2011 (Spent Nuclear Fuel Pools in the U.S.: Reducing the Deadly Risks of Storage), von Hippel et al. in 2016 (Science, Spent fuel "re on U.S. soil could dwarf impact of Fukushima: New study warns of millions relocated and trillion-dollar consequences, May 24, 2016), the U.S. National Academies of Science (Lessons Learned from the Fukushima Nuclear Accident for Improving Safety and Security of U.S. Nuclear Plants: Phase 2, 2016), etc. In fact, a two-day dangle of a fully-loaded, 107-ton container of irradiated nuclear fuel above the wet storage pool at PNP brought home such dangers. But the dry cask storage at PNP is also vulnerable to disastrous releases of hazardous radioactivity, as long warned about by members of our environmental coalition dating back to the early 1990s, and as warned about by such scholars are Dr. Gordon Thompson of Institute for Resource and Security Studies (IRSS) in January 2003 (ROBUST STORAGE OF SPENT NUCLEAR FUEL: A Neglected Issue of Homeland Security). This is why many members of our environmental coalition have called for Hardened On-Site Storage (HOSS) since 2002, but NRC and DOE, as well as industry, have ignored our dire warnings.
We wish that the State of Michigan at PNP in the present day would follow the model set by the State of Massachusetts in the 1970s and 1980s, when it resisted inadequate emergency planning at/near the Seabrook nuclear power plant in New Hampshire. But instead, since 4/20/22, when Gov. Whitmer "oated the trial balloon of continuing to operate PNP instead of retire it as planned, her oce and even the state legislature have remained on the wrong side of history, something we hope will change in the future. By the way, this further undermines NRCs and DOEs purpose and need statement. Current State of Michigan policies could well change in the future, and hopefully will vis-a-vis PNP. Consider, for example, the global push back against nuclear power in the aftermath of the Fukushima Daiichi nuclear catastrophe in Japan, which began on March 11, 2011. Yet another reactor core meltdown, or highly radioactive waste "re, in the U.S. or even overseas, could well lead to a worldwide clamor against nuclear power, extending to Michigan and surrounding states, strong enough to force a restarted PNP back into retirement.]
P. 25/242 ON PDF COUNTER (page 1-3) 1.1.2 Proposed Action of the DOE The DOE LPOs Federal action is a decision on providing Federal "nancial 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 of 2005.
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[Members of our environmental coalition fought tirelessly against passage of the Energy Policy Act of 2005, for many long years. Ironically enough, the Energy Policy Act of 2005 was signed into law on August 8, 2005, which happened to be the deadline for our environmental coalitions petition to intervene and request for hearing regarding PNPs 2011-2031 license extension, which we opposed. One of the most important reasons we opposed this legislation was its authorization of the wrongheaded nuclear loan guarantee program. We also fought against the $22.5 billion in nuclear loan guarantee appropriations, enacted into law on December 23, 2007. And we fought against enactment of the In"ation Reduction Act of 2022, which amended the Energy Policy Act of 2005s nuclear loan guarantee program. In the beginning, nuclear loan guarantees were supposed to be limited to innovative new designs for reactors, and only one reactor per design. This was soon weakened by DOE to allow for multiple reactors of the same design. But the In"ation Reduction Act of 2005 weakened the loan guarantee program dramatically further, no longer requiring innovative new designs. Now, DOE has been authorized to award a $1.52 billion loan guarantee for a jalopy of a reactor, designed in the mid-1960s, constructed beginning in 1967, operated from 1971 to 2022, which was a nuclear lemon from the beginning, and now is very severely and dangerously age-degraded, including major safety-signi"cant systems, structures, and components. PNPs restart risks EXTRA LARGE, most signi"cant impacts on the environment, such as putting the Great Lakes at existential risk, as well as all who depend on them, and call them home.]
P. 26/242 ON PDF COUNTER (page 1-4) 1.2.3 Need for the Project Regarding the need for clean energy, Holtec cites the State of Michigans Public Acts of 2023, Act No. 235 (enrolled Senate Bill 271) (State of Michigan 2023-TN10671), which establishes a clean energy standard for electric providers to provide at least 80 percent clean energy by 2035 and 100 percent by 2040. Michigans Act No. 235 de"nes clean energy as including a system that Generates electricity or steam without emitting greenhouse gas, including nuclear generation.
In September 2023, Palisades Energy, LLC, and Wolverine Power Cooperative formalized a power purchase agreement (PPA) under which Wolverine Power Cooperative agreed to purchase up to two-thirds of the output from Palisades and the balance would be purchased by Hoosier Energy for the foreseeable future. This PPA is the economic impetus for Holtecs request to restart Palisades. The PPA also provides the option to include expected power output from the planned small modular reactors (SMRs) at Palisades (Holtec 2023-TN10540).
As opposed to being a regulated supplier providing wholesale power for dispatch by the independent system operator, the PPA would make Palisades a merchant generator and therefore not be directly subject to Michigans integrated resource planning process or a Certi"cate of Need ruling by the Michigan Public Service Commission (HDI 2024-TN10670:
RAI-GEN-2). Holtec also states that repowering of Palisades will greatly enhance electric reliability by generating consistent and carbon-free energy in Michigan and will decrease Michigans reliance on energy imports (Holtec 2023-TN10540).
[As we stated in our Overview/Summary above:
NRCs Purpose and Need statement is unacceptably shallow. NRC has stated that a recently enacted State of Michigan clean energy law mandates the Palisades restart. But
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nuclear power is not clean far from it. Besides, various supposed reasons have been given for Palisades restart, from restoring good paying jobs, to electricity needed for Arti"cial Intelligence (A.I.) data centers, energy storage battery facilities, charging the electric vehicle "eet, climate mitigation, reliability of electricity supply and the electrical grid, etc. All these moving target, throwing-spaghetti-against-the-wall-to-see-what-sticks, supposed justi"cations for Palisades restart will be challenged and rebutted in more detail below, even though NRC did not even bring them up, but rather only brie"y mentioned Michigans recently passed clean energy law, and also very brie"y mentioned Holtecs purported claims of electric reliability and supposed independence from energy imports, and also very brie"y mentioned Holtecs purported claims of electric reliability and supposed independence from energy imports.
Re: AI data centers, recent news about Chinas DeepSeek AI system sent shock waves around the world, in terms of how eciently it could be operated. That is, massive expansions of electricity supply would not be needed.
Besides, where is the NEPA-compliant treatment of these nascent AI data center proposals?
Treating AI data centers as a done deal, somehow justifying massive increases in electricity supply, including from restarting closed for good, dangerously age-degraded atomic reactors like PNP, is putting the cart before the horse. This lemming-like societal rush, perhaps over a cli edge, is unwise in the extreme. We resist and question it.
Energy storage battery facilities could be supplied by renewables like wind and solar, and many others. They do not need to be supplied by electricity from PNP. Besides, the Power Purchase Agreement between Holtec and the rural electric co-ops, Wolverine in Michigan, and Hoosier in Indiana and Illinois, is supposedly for all, 100%, of PNPs electricity supply from 2025 to 2051, if not longer. Are the rural electric co-ops associated with the purported AI data centers? If not, then there would be no PNP-generated electricity left over for use at AI data centers. If these rural electric co-ops are involved with powering ravenous AI data centers, how can $1.3 billion in USDA grants be justi"ed? Are AI data centers projects that USDA grants are meant to support? This makes no sense.
Re: charging electric vehicle "eets, renewables, backed up by energy storage battery facilities, could do this, instead of PNP.
Re: climate mitigation, the expert witness testimony provided by Dr. Mark Z. Jacobson of Stanford University, in support of the environmental coalition opposing Palisades restart before the Atomic Safety and Licensing Board, shows that renewables such as wind and solar, backed up by energy storage, are much more cost-eective and time-eective at reducing greenhouse gas emissions, than is restarting the PNP, and than are Small Modular Reactor new builds at Palisades and/or Big Rock Point.
We incorporate by reference, as if fully rewritten herein, the expert witness testimony of Dr.
Jacobson, posted online here:
{February 1, 2025 UPDATE: Beyond Nuclear, et al.s legal counsel, Wally Taylor of Cedar Rapids, IA, and Terry Lodge of Toledo, OH, submitted a notice and expert witness testimony by Dr. Mark Jacobson, professor at Stanford U. and internationally renowned greenhouse gas emission reduction strategist, to the NRC ASLB: Notice; Jacobson congressional testimony, dated Jan. 17, 2024, Seven Reasons Why New Nuclear Energy is an Opportunity Cost That
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Damages Eorts to Address Climate Change and Air Pollution; and Jacobson book chapter, Dec. 22, 2019, Evaluation of Nuclear Power as a Proposed Solution to Global Warming, Air Pollution, and Energy Security.}
Amory Lovins, also a professor at Stanford University, and a founder of the Rocky Mountain Institute, has long asserted that nuclear power takes too long, and costs too much, to qualify as a good idea for climate mitigation. He has been making such assertions for decades. He recently spoke about this (Press Brie"ng: Why Latest Nuclear Revival Is Already Doomed, October 3, 2024). The recording of the press brie"ng is posted online here:
<https://www.youtube.com/watch?v=2u8PYEyqr14>
We incorporate by reference, as if fully rewritten herein, the entirety of Amory Lovins testimony above.
Lovins also testi"ed about this subject matter at a Capitol Hill congressional brie"ng, Toward an Evidence-Based Nuclear Energy Policy; What Congress Needs to Know About Nuclear Decommissioning, Radioactive Waste, and Nuclear Energy as a Climate Strategy, on March 30, 2021. We incorporate by reference as if fully rewritten herein the entirety of Lovins presentation recording, including his slideshow, posted online here:
<https://www.eesi.org/brie"ngs/view/033021nuclear>
Dr. Arjun Makhijani, founder and president of the Institute for Energy and Environmental Research, and a Fellow of the American Physical Society, wrote an entire book on this subject matter, entitled Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy. We incorporate by reference as if entirely rewritten herein the entirety of this book, and related publications, posted online here:
<https://ieer.org/projects/carbon-free-nuclear-free/>
These authors and experts cited above provide extensive, comprehensive information about the alternatives that NRC and DOE should address in a higher level EIS, namely renewables (solar, wind, etc.), eciency, and storage, as ready, reliable, much more cost-eective, and time-eective, clean, safe and secure methods to mitigate the greenhouse gas emissions that cause global warming and climate chaos, as compared to the zombie reactor restart scheme at PNP, as well as to the SMR new builds scheme at Palisades and Big Rock Point.
None other than former Michigan Governor (and former Energy Secretary) Jennifer Granholm herself advocated in favor of developing o-shore wind power available to the Great Lakes State. A study by the Michigan State University Land Use Institute documented that more than 300,000 MW-e of o-shore wind power potential is available to be tapped on the Great Lakes.
Gov. Granholm, in 2010, convened an advisory council re: this subject matter. As conveyed by James Clift, a member of the council at the time, in a presentation he made at a renewable energy summit in South"eld, Michigan in June 2010, the council advised some two-dozen criteria to guide the development of o-shore wind power on the Great Lakes. These included
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avoiding impacts on "sheries, avoiding aesthetic impacts, avoiding historic shipwrecks, etc. The council recommended three areas of the Great Lakes for o-shore wind, based on the two-dozen criteria: extreme southern Lake Michigan, not that far from PNP actually; extreme northern Lake Michigan, not that far from the Big Rock Point nuclear power plant site, actually; and Saginaw Bay, where it opens out into Lake Huron. Just tapping a very small percentage of the o-shore wind power potential available to Michigan on the Great Lakes would far surpass the 800 MW-e that a restart PNP would provide, and far surpass the additional nuclear megawattage that two SMR-300s at PNP would provide, and would far surpass the nuclear megawattage one or more SMR-300s at Big Rock Point would provide. This o-shore wind power would also avoid reactor core meltdowns, radioactive waste "res, radioactivity, thermal wastewater, and toxic chemical releases at all these atomic reactors, and would do so cost-and time-eectively, compared to SMR new builds, and even the PNP restart.
We incorporate by reference, as if fully rewritten herein, the following: Governor Granholm Signs Executive Order Creating Great Lakes Wind Council, February 06, 2009. It is posted online here:
<https://www.michigan.gov/formergovernors/recent/granholm/press-releases/2009/02/06/
granholm-signs-executive-order-creating-great-lakes-wind-council>
Likewise, we incorporate by reference, as if fully rewritten herein, the following:
Report of the Michigan Great Lakes Wind Council, October 1, 2010.
It is posted online here:
<https://www.baycountymi.gov/uploads/GLOWreportOct2010_with%20appendices.pdf>
Why didnt NRC and DOE include a comprehensive analysis of o-shore wind power as an alternative to PNP restart in the EA? Why wasnt solar power (both household/business-scale, as well as utility-scale) comprehensively analyzed as an alternative? Why wasnt on-land wind power comprehensively analyzed? Where werent energy eciency and energy storage (such as batteries) comprehensively analyzed as an alternative, especially considering that battery stored has been trotted out as a supposed Purpose and Need for PNP restart?
And, as stated by multiple public commenters at the environmental scoping public comment meeting convened by NRC and DOE at Benton Harbor, Michigan on July 11, 2024, since the precedent being set by PNP, in terms of closed for good reactor restart, a Programmatic EIS should be required, not this low-level EA. Other closed for good reactors already seeking restart permission from NRC, and very likely bailouts from DOE, other federal agencies, and state governments, currently include: Three Mile Island Unit 1 in Pennsylvania (recently preposterously renamed the Christopher Crane Safe Energy Center, likely an eort to shed the radioactive stigma of the Three Mile Island Unit 2 50% meltdown of 3/28/1979, considered by many to be the worst reactor disaster in U.S. history; Duane Arnold in Iowa is not far behind.
Additional zombie reactors in the U.S. include Diablo Canyon Units 1 and 2 in California, which were supposed to close for good in 2024, and 2025, respectively, as well as Summer Units 2 and 3 in South Carolina, both abandoned midway through construction, in 2017. Given
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the precedent-setting nature of PNPs restart for all these other zombie reactors, with yet more possible in the future, a PEIS should be undertaken to comply with NEPA.
Re: reliability of electricity supply and the electrical grid, the lights have stayed on in Michigan since Entergy closed Palisades for good on May 20, 2022. This is because there is excess electricity on the grid, put in place to accommodate PNPs closure for good, as long planned, as well as to other anticipated or unanticipated peaks in demand, or anticipated or unanticipated temporary shutdowns of electrcity generators in the service area, as due to weather events, such as ice storms, wind storms, blizzards, etc.
Re: reducing need for importation of electricity into Michigan, this is an ironic Purpose and Need argument to make, given that Holtec plans to export electricity to Indiana and Illinois, as well as to distant parts of Michigan, such as the northern part of the Lower Peninsula, under the PNP PPA scheme. Why are Michigan state taxpayers, as well as American taxpayers from 48 other states, being forced to subsidize the purchase of overpriced PNP electricity (57% or more above market rates, according to Holtec itself in its 7/5/22 bailout application to DOE), by rural electric co-ops in Indiana and Illinois?]
P. 27/242 ON PDF COUNTER (page 1-5)
Context refers to the characteristics of the geographic area, for example the proximity to unique or sensitive resources or communities with environmental justice (EJ) concerns.
Depending on the scope of the action, the potential global, national, regional, and local contexts are also considered as well as the duration, including short-and long-term eects.
[Emphasis added]
[Senstive resources at/near PNP, which would be signi"cantly impacted by reactor restart, include the Great Lakes: 21% of worlds surface fresh water, 84% of North Americas surface fresh water, and 95% of the USAs surface fresh water. The Great Lakes are the drinking water supply for more than 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Indigenous Nations. Lake Michigan alone is drinking water supply for 16 million people in 4 U.S. states, and a large number of Indigneous Nations. These "gures are for current generations alone, let alone future generations yet to be born. Any impacts on Lake Michigan, from routine operations or catastrophes at PNP, would blow with the wind, "ow with the water, and contaminate the food supply, with negative impacts lasting a very long time, given the hazardous persistence of various radioactive isotopes released, measured as 10 to 20 half-lives.
Another senstive resource is the "sheries in Lake Michigan and the Great Lakes, as well as the rest of the aquatic ecology present there.
Another sensitive resource is the critically endangered sand dunes at/near the PNP itself, providing habtiat for remarkable biological diversity.
Both the Great Lakes and their adjacent sand dunes, including forested sand dunes with wetlands, are very fragile, exacerbating PNPs large impacts.
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Communities with EJ concerns includes the large number of Indigneous Nations mentioned just above, including the Pokagon Potawatomi (centered in Dowagiac, Michigan), and the Gun Lake Potawatomi (centered near Delton, Michigan), to name but two. Other communities with EJ concerns at/near PNP include the African American majority population of Covert Township, Michigan, which also has a high rate of low income individuals and households, and the African American majority population of Benton Harbor, Michigan, which also has a high rate of low income residents. Yet another category of communities with EJ concerns is the relatively large Latin American population of southwest Michigan, including seasonal workers, given the large concentration of agriculture in the region, as well as permanent residents.]
P. 28/242 ON PDF COUNTER (page 1-6)
The ESA eects determination for federally listed species are as follows:
- No eect: Federally listed species or critical habitat will not be aected, directly or indirectly.
- May aect but is not likely to adversely aect: All eects on federally listed species or critical habitat are bene"cial, insigni"cant, or discountable.
- May aect and is likely to adversely aect: An adverse eect to listed species or critical habitat may occur as a direct or indirect result of the proposed action and the eect is not:
discountable, insigni"cant, or bene"cial. [Emphasis added.]
[Critical habitat, as mentioned just above, includes critically endangered, and fragile, Great Lakes shoreline sand dunes and beach, including forested wetlands, as well as the Great Lakes themselves.]
P. 28/242 ON PDF COUNTER (page 1-6)
Cumulative Eectseach resource area will describe the incremental eects of the proposed actions when added to the environmental eects of other past, present, and reasonably foreseeable actions.
[2 SMR-300s being constructed and operated on the tiny 432-acre PNP site, alongside 80-year extended operations at the zombie reactor, represents a major cumulative impact.
The way NRC essentially ignores all past public comments provided at past proceedings, like the 2006 license extension SEIS comments for the 60-year license at PNP, is objectionable. Its like NRC was born yesterday, and expects us to be as willfully ignorant and blind as they are, in regards to such large and cumulative impacts at, near, and from PNP Tremendous eort was put into our environmental coalitions 2006 draft SEIS public comments.
Yet NRC ignored most to all of them. For that reason, they are still relevant. Just because NRC cites the 2006 SEIS repeatedly throughout this EA, does not mean NRC has adequately addressed those comments or concerns, or addressed them at all.
For this reason, we incorporate by reference, as if fully written herein, the entirety of our environmental coalitions comments on the draft SEIS from 2006. Those comments are posted online here, at the following two links:
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
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the Great Lakes Basin, regarding NRCs draft Environmental Impact Statement on the Palisades 20 year license extension. 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.]
P. 29/242 ON PDF COUNTER (page 1-7)
Cumulative Eectseach resource area will describe the incremental eects of the proposed actions when added to the environmental eects of other past, present, and reasonably foreseeable actions.
[In the context of Cumulative Eects, past, present, and future, both Holtec and NRC lied to us re: decommissioning in the past. Holtecs bait and switch trick/con game to get hold of Palisades in the "rst place, only to then announce its restart scheme, as well as SMR new builds scheme, has been enabled by NRCs own complicity and collusion, and now by DOEs, and even FEMAs, as well. The U.S. Congress is also complicit, as has been the White House.
Governor Whitmer and the Michigan state legislature have also participated in this complicity and collusion, as have local units of government, such as Van Buren County, the City of South Haven, and the Township of Covert. NRC promised to go away and never come back in September, 2022, at a "nal decommissioning public comment meeting (held at Lake Michigan Colleges South Haven campus, after Holtec had already publicly announced its restart scheme), but instead has aided and abetted Holtec in the restart and new build schemes. NRC has come back more often than ever before in the past two to three years.
In 2012, at the "rst annual commemoration of the Fukushima Daiichi nuclear catastrophe, which began on March 11, 2011, the Japanese Parliament known as the Diet published the "rst independent investigation in that institutions post-World War II history. It was a root cause determination for the nuclear catastrophe. The Japanese Parliament concluded that the root cause of the Fukushima Daiichi nuclear catastrophe was collusion, between the government safety regulatory agency, the company Tokyo Electric, and government ocials. Such potentially catastrophic collusion exists in spades at Palisades. It is why the unprecedented, previously unthinkable, nuclear nightmare of a reactor restart scheme at the problem-plagued-from-the-start, now dangerously age-degraded PNP, was undertaken at all in the "rst place, and has proceeded this far. Holtec, which has never operated a reactor, has never built a reactor, and has an infamous record of incompetence, corruption, and even criminality, is putting the entire region in dire peril, sailing into uncharted waters of risk. Holtec is doing this with the complicity and collusion of the federal and state governments.
We incorporate by reference, as if fully rewritten herein, the following three relevant and related backgrounders, written in early 2024 by Kevin Kamps, radioactive waste specialist at Beyond Nuclear. They are posted online at the following links:
A Peoples History of the Palisades Atomic Reactor (13 pages); Nuclear Nightmares:
Palisades Zombie Reactor Restart and SMR New Build Schemes (3 pages); Holtec:
Criminality, Corruption, Incompetence, and Inexperience (2 pages).]
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P. 33/242 ON PDF COUNTER (page 2-1)
The nearest population center is the township of Covert, which is approximately 2.5 mi (4 km) southeast of the Palisades site.
Van Buren State Park is located immediately to the north of the Palisades site, and Van Buren Trail State Park is located northeast of the site. The local terrain consists of wooded sand dunes along the lakeshore, and the area surrounding the plant is largely rural.
[Why is there no mention whatsoever here of PPCC, the 120-year old Palisades Park Country Club resort community, of more than 200 households, with a population of 2,000+ people in the peak of summertime? Doesnt PPCC qualify as a population center?! It is located immediately south of Palisades Nuclear Plant (PNP). In fact, PNP displaced a number of former PPCC cottages. PPCC is the name origin of PNP and the towering sand dunes in the area are the origin of PPCCs name.]
P. 33/242 ON PDF COUNTER (page 2-1)
The dunes are relatively stable topographic features with occasional blowout caused by wind action. The majority of the land area is heavily wooded, with occasional wetlands. Besides the transmission line and corridor, the facilities at Palisades are only publicly visible from Lake Michigan and the beach areas to the north and south of the plant boundary.
[The dunes are critically endangered habitat for biodiversity there are even forested wetlands amongst the sand dunes. These are rare and fragile ecosystems. PNP has had major impacts on them since 1967, when ground was broken.
Why is there no mention of the signi"cance of blowouts, wind-driven displacement of large amounts of sand from the dunes. Blowouts could have major impacts on reactor, radioactive waste, and radioactive contamination, in terms of safety, health, and environmental protection.
PNP is nestled in the dunes, to borrow a phrase from a top spokesman at Cook nuclear plant 30 miles south of PNP. But PNPs misdeeds, and their impacts, are not con"ned just to the dunes, which is bad enough; the impacts and potential consequences extend over a very large region actually. One can see Palisades Nuclear Plant (PNP) from the blus above the beach at South Haven, several miles away, a real eyesore. PNP can be seen from many miles out on Lake Michigan, again, a real eyesore. But also a cause for tremendous concern, if one understands what they are looking at, and the long, controversial (for good reason), and troubled history of PNP.]
P. 35/242 ON PDF COUNTER (page 2-3)
[Fig. 2-2 shows just how close the dry cask storage is to the Van Buren State Park campground.
What is the radiation dose, from gamma and neutron shine, from the dry casks to people staying at the campground area?]
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P. 36/242 ON PDF COUNTER (page 2-4)
[Fig. 2-3 "nally a mention of PPCC (Palisades Park Country Club! Why was it not mentioned above? The "gure also shows how very close dry cask storage is to the Van Buren State Park campground. Routine operations at PNP are bad enough impacts on these very close by population centers. Catastrophic releases of hazardous radioactivity at PNP would be even worse for people at these immediately adjacent locations, in terms of human health and environmental impacts.]
P. 37/242 ON PDF COUNTER (page 2-5)
Holtecs New and Signi"cant Report (N&S Report)
[Even NRCs attempt to clean up Holtecs very oddly titled document leaves a lot to be desired.
NRCs version does not even mention the word environment, which even Holtecs failure of a title did include. How are readers supposed to comprehend what this document is about, if NRC and Holtec slaughter its title so badly? More signi"cantly, NRCs adoption of this so-called document containing environmental information as the ocial Environmental Report required to comply with NEPA is a disservice to the public, and a violation of the letter and spirit of NEPA.
Why does NRC go so far out of its way to accommodate Holtecs carelessness and incompetence?]
P. 37/242 ON PDF COUNTER (page 2-5)
The replacement towers are cross"ow mechanical draft cooling towers, designed for a 32 degrees Fahrenheit (°F) (17.8 degrees Celsius [°C]) range and a maximum sound level of 90 A-weighted decibels at 3 ft (0.9 m) from the equipment (HDI 2023-TN10712; Holtec 2023-TN10538). The replacement towers included drift eliminators with a guaranteed drift rate of 0.001 percent of the circulating water "ow rate (HDI 2024-TN10670: RAI-TE-1).
[Does the drift contain hazardous, toxic chemicals, such as biocides? Does it contain radioactivity, such as tritium? If yes to either question, why is that not spelled out clearly here?
Even 0.001% of the "ow is still a lot of drift.
The commenter recalsl very thick fog experienced at Van Buren State Park in the past. Given the chorline in Lake Michigan (such as from road salts used to de-ice roads in the wintertime),
what kind of CISCC (Chlorine-Induced Stress Corrosion Cracking) risk/damage does that mean for all things metallic and corrodable at PNP, including safety-signi"cant systems, structures, and components (SSCs)? Our environmental coalition intervening against Palisades restart has retained Arnie Gundersen, chief engineer at Fairewinds, as an expert witness in that proceeding. Gundersen has warned about drift fog obscuring drivers visibility on nearby roadways, which includes Blue Star Highway and Interstate-196, just east, inland from PNP.
Why has such hazards for drivers from the cooling tower drift at PNP not been addressed in this EA?]
P. 37/242 ON PDF COUNTER (page 2-5)
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two new Diverse and Flexible Coping Strategies storage buildings
[These are post-Fukushima FLEX installations, so-called. Are they built to withstand impacts from extreme weather, or other natural disasters, or even terrorist attacks? If not, why not?
Shouldnt they be available under such circumstances? Isnt that their supposed function, to help prevent reactor core meltdowns and radioactive waste "res/releases at PNP under extreme conditions? If these facilities fail, what impact would that mean for PNP and the surrounding region?]
P. 37/242 ON PDF COUNTER (page 2-5) 2.2 Alternatives For EAs, NRC regulations in 10 CFR 51.30(a)(1)(ii) (TN250) call for a brief discussion of alternatives as required by NEPA.
[This is why an EA does not suce here. An EIS, even a PEIS, is demanded by the signi"cance of the potential adverse impacts of this major federal action, which will set the precedent for numerous additional zombie reactor restarts to follow, as mentioned above. NRC and DOEs Alternatives analysis in this EA falls very far short of what is needed. Instead of a hard look at alternatives, NRC and DOE have done hardly a look. This is a violation of the letter and spirit of NEPA.]
NEPA Section 102(2)(C) speci"es consideration of a reasonable range of alternatives that are technically and economically feasible, and meet the purpose and need of the proposal (TN661).
[The Preferred Alternative PNP restart is most unreasonable. It is unprecedented, unneeded, insanely expensive for the pubilc, and extremely risky for health, safety, security, and the environment. The No-Action Alternative, no restart, is most reasonable, compared to unreasonable Preferred Alternative.
Re: the insane expense of the PNP restart for the public more than $3 billion already awarded by the federal government and State of Michigan, with more than $5 billion more still requested by Holtec we incorporate by reference as if fully rewritten herein a Breakdown of Bailouts at PNP. This includes another $7.4 billion in nuclear loan guarantees requested by Holtec from the DOE for SMR design certi"cation, construction, and operation. The entire amount could be gobbled up by Holtec just for the two proposed SMR-300s at Palisades, and certainly if one or more additional SMRs get built at Big Rock Point. The Breakdown of Bailouts at Palisades (and Big Rock Point) is posted online at the following link:
https://beyondnuclear.org/breakdown-of-bailouts-at-holtecs-palisades/
It must be noted that Donald J. Trump has stated that he will revoke and repeal the In"ation Reduction Act of 2022, as well as the Infrastructure Investment and Jobs Act of 2021. If this happens, the federal bailouts for PNP restart could well be stopped, and those already awarded could be clawed back. Despite Holtecs con"dent talk about the status of the bailouts, there is still a lot of doubt about what lays ahead for these federal bailouts. And if the federal bailouts dont happen, the State of Michigan bailouts may not happen, either. This is because a requirement for the State bailouts to "ow, is for federal bailouts to "ow "rst.]
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P. 38/242 ON PDF COUNTER (page 2-6)
The no-action alternative would not meet the purpose and need of the proposed Federal actions to provide an option for baseload power and contribute to Michigans clean energy goal.
[Palisades is not clean energy far from it. The negative impacts on the environment and human health from the entire uranium fuel chain, including operation of PNP, are immense. But NRC and DOE are willfully blind to them, including in this EA. The State of Michigan, thus far anyway, is also willfully blind to them. Including nuclear power in the de"nition of clean energy is Orwellian.]
If it becomes necessary for utilities or other power suppliers to build other nuclear or non-nuclear power generation facilities to meet the demand, building those facilities would result in additional environmental impacts related to land disturbance and operation of construction equipment that would not be necessary if the already built Palisades is restarted.
[This is rich. Nuclear power has a million years more so of negative impact, in the form of highly radioactive irradiated nuclear fuel, and its hazards. As Dont Waste Michigan co-chair Michael Keegan has said, Electricity is but the "eeting byproduct from atomic reactors. The actual product is forever deadly high-level radioactive waste, a curse on all future generaions.
Renewables, eciency, and energyt storage, on the contrary, have nowhere near that negative impact on the environment and health. Please see the expert witness declarations provided by our intervening environmental coalitions expert witness Dr. Jacobson, above, which points out the time-and cost-eectiveness of renewables, eciency, and storage, in terms of reducing greenhouse gas emissions as climate mitigation. Dr. Jacobson testi"es that nuclear power fails these time-and cost-eectiveness tests.
NRCs and DOEs words here are also rich in that Holtec plans 2 SMR new builds at Palisades, in just the next several years, doubling the nuclear megawatte on the tiny 432 acre site talk about land disturbance, in a very fragile, biodiverse, crtically endangered habitat. NRC and DOE should not be segmenting o the impacts from the 2 SMR-300s, from the impacts of the zombie reactor restart. Such segmentation is a violation of NEPA.]
PGS. 38-39/242 ON PDF COUNTER (pages 2-6 to 2-7) 2.2.2 Alternatives Considered and Not Carried Forward for Further Analysis 2.2.2.1 Replacing Palisades Reactor with New Onsite Reactor
[But Holtec IS building new reactors onsite not to replace the Palisades zombie reactor, but to complement or supplement it, in addition to it.]
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This alternative would reuse land that had been previously disturbed by the existing reactor, but it would still result in additional noise, emissions, and other impacts from building new facilities.
[So on one hand NRC and DOE are saying this is to be avoided. On the other hand, they are expediting this very thing, in terms of 2 SMR-300 new builds. The federal agencies are talking out both sides of their mouth.]
However, building a new reactor would still require substantial costs beyond those needed to resume operation of an already built reactor. Additionally, building the new reactor would require substantial additional ground disturbance not needed to put the existing reactor back in operation. The unused lands on the Palisades site include sensitive dune, forest, shoreline, and wetland habitats. Using those lands to build a new reactor could result in loss or degradation of those habitats, as well as generate additional noise, emissions, and other impacts from building new facilities Neither of the alternatives described above were carried forward for detailed analysis because of the additional time and cost needed to build a new reactor and greater environmental impacts relative to resuming operation of the existing reactor.
[And yet, that is exactly what Holtec and NRC propose doing with 2 SMR-300s. DOE would be complicit if it awards Holtec the $7.4 billion in nuclear loan guarantees for its SMRs the company has requested.]
P. 39 ON PDF COUNTER (page 2-7)
Whether using non-nuclear or nuclear energy generation, implementing any of the possible alternatives would require building new power generation facilities. As noted in the section above, it would not be feasible to wait to fully decommission the existing Palisades reactor before building the alternative power generation facilities, but at least some of the new facilities could be built using other land within the Palisades site. It is however unclear whether enough land is available on the Palisades site to accommodate land-extensive power generation methods such as wind or solar. Otherwise, the new power generation facilities could be built on other sites capable of supplying energy to Michigans population, although those sites may not be served by the existing infrastructure already servicing the Palisades site such as transmission lines and roads. Using alternative power generation fuels or technologies to generate the additional energy would therefore result in substantial additional environmental impacts not needed to resume operation of the existing reactor, especially those related to additional land use, ground disturbance, and use of construction equipment.
None of the alternatives described above were carried forward for detailed analysis because of the additional time and cost needed to build the alternative facilities and greater environmental impacts relative to resuming operation of the existing reactor
[Please compare NRC and DOEs words here to the points made about the work and analyses provided by Dr. Arjun Makhijani of Institute for Energy and Environmental Research, Dr. Mark Z.
Jacobson of Stanford University, Amory Lovins of Stanford and the Rocky Mountain Institute, above.
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Also, compare NRC and DOEs words here to former Michigan Governor (and former Energy Secretary) Jennifer Granholms oshore wind power advocacy, above.
Renewables, eciency, and storage do not have million year or longer that is, forevermore negative impacts on human health and the environment in the form of high-level radioactive waste, per above.]
P. 39 ON PDF COUNTER (page 2-7) 2.2.2.3 Installing System Design Alternatives for Use with the Current Palisades Reactor System design alternatives would involve "tting the existing Palisades reactor with alternative system designs for processes such as heat dissipation, circulating water, and transmission systems. However, the systems already in place at the reactor meet regulatory requirements (e.g., U.S. Environmental Protection Agency (EPA) 316(b) [TN662]). As described in Chapter 3 of this EA, the NRC sta has determined that the environmental impacts from resuming operation of the existing facilities, with their existing systems, as called for in the proposed Federal action would be minimal. There is therefore no reason to carry any such alternatives forward for more detailed analysis.
[NRC and DOE have made a meaningless straw man argument here.]
P. 41 ON PDF COUNTER (page 3-1)
The resource areas listed below were identi"ed during scoping to not have the potential for signi"cant impacts or were covered by prior environmental review(s). Therefore, the NRC sta provides a brief discussion of these resource areas in Section 3 of this EA.
- Land Use and Visual Resources (Section 3.2)
- Nonradiological Human Health (Section 3.11.2)
- Waste Management (Section 3.12)
- Uranium Fuel Cycle (Section 3.13)
- Postulated Accidents (Section 3.14) [Emphasis added]
[PNP is an eyesore on what would otherwise be a very beautiful Lake Michigan shoreline.
Natures and the lands purpose and need, just to be left alone in a healthy state, should trump Holtecs purported purpose and need, and even the State of MIs misguided so-called purpose and need.
What about the use of hydrazine and other chemical toxins at PNP, such as for cleaning SSCs, as biocides in the cooling water intake and discharge pathways, etc.? Hydrazine is ultra-toxic in very small quantities, and yet Holtec has requested permission in PNPs NPDES permit to discharge large amounts into Lake Michigan, which would be a major negative impact on the environment and human health.
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Radioactive waste IS a signi"cant impact on human health and the environment.
Uranium mining and milling on Indigenous Nations lands is signi"cant impact. Major impacts on Navajo/Diné and Pueblo communities has resulted from uranium mining; and on Ute Mountain Ute communities from uranium milling. But these are just a small number of examples of such impacts.
Such signi"cant impacts are very possible at a restared PNP, as well as at SMR new builds on the PNP site.]
3.1.1 The Aected Environment Related to the Proposed Federal Actions As described in Section 1.3.4 of this EA, the environmental baseline or aected environment for Palisades and the proposed Federal actions under the NRC stas evaluation are the environmental conditions at the point in time prior to the commencement of the project.
[This comes very close to ignoring cumulative impacts what about PAST impacts on the same site FROM PALISADES?]
Transition to decommissioning resulted in Holtec reducing the number of workers employed at Palisades from approximately 550 employees in 2022 to 218 employees in 2023 (HDI 2024-TN10670: RAI-SE-1).
[The estimate for the number of jobs that would be restored if PNP restarts has been all over the place. This was on full display on March 27, 2024, at the PNP restart lovefest, starring Energy Secretary (and former Michigan Governor) Jennifer Granholm, and current Michigan Governor, Gretchen Whitmer. Granholm and Whitmer cited one set of in"ated "gures for the number of jobs that would be restored, while Holtec cited another, signifcantly lower "gure.
Holtecs own "gures have varied dramatically, including a signi"cant lowering of the number of jobs, as compared to the companys own "gures given recently before that.
Even NRCs "gure of 550 jobs above is dubious. PNP has claimed in the past to have provided up to 650 jobs. With such signi"cant disparities, it is impossible for the public to determine the truth of the matter.]
Holtec also removed two structures in the plant protected area during decommissioning because the buildings exhibited poor structural integrity (Holtec 2023-TN10538).
[There is poor structural integrity across the entire site, including with safety-signi"cant SSCs, the breakdown of which would cause catastrophic impacts on health and the environment, in the form of a reactor core meltdown, or radioactive waste "re.
Did Holtecs dismantlement of those two structures cost tens to hundreds of millions of dollars to carry out? Because that is how much money Holtec has drained from the PNP Decommissioning Trust Fund, just in the year or two after taking ownership of PNP on June 28, 2022. The vast expenditures have never been explained to the public, given that so very little, to no, decommissioning work has taken place at PNP.]
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Holtec continues to conduct routine herbicide application (HDI 2024-TN10670:
RAI-GEN-1).
[What are the impacts on endangered or threatened indigenous plants?]
P. 42/242 ON PDF COUNTER (p. 3-2)
Several of the activities involve ground disturbance that have the potential to aect environment resources and are listed in Table 3-1 and presented in Figure 3-1 below. The identi"ed potential land disturbances are in previously disturbed areas (Figure 3-2 of this EA).
Appendix I to this EA provides a set of historical photographs documenting the previous disturbance. The NRC sta considered these activities when determining the related environmental impacts.
[In other words, the site has long been previously trashed. Thus, its "ne to trash it more in the future. This is an unacceptably bad attitude, which will result in the site not recovering from the major impacts in"icted on it for a very long time, if ever.]
Expand access road at south end of protected area. The project includes a road lane inside the new security barrier and a road lane outside the security barrier for a total of approximately 85 ft in width. The deepest point into the previously disturbed critical dune will be approximately 45 vertical ft and is located on the east end of the roadway.
[45 feet deep is a huge negative impact, very destabilizing for these fragile, critically endangered sand dunes. Isnt the State of Michigan supposed to protect the dunes? Why is it not?]
Repair underground pipe, leaking condensate storage tank (T-2) piping, and leaking Utility Water Storage Tank (T-91) piping.
[Are these radioactive leaks? Are these toxic chemical leaks? Why is this not clearly explained?]
P. 45/242 ON PDF COUNTER (page 3-5) cooling system chemical decontamination
[Where does the mixed waste toxic and radioactive waste mixed together go to then?
Why is this information not provided? If chelating agents are used to perform chemical decontamination of radioactivity, isnt this like putting roller skates on the radioactive substances, as Beyond Nuclears emeritus board of president, Kay Drey, a 50-year long anti-nuclear organizer and educator, puts it. What impacts will such volatile mixed wastes at the so-called low-level radioactive waste dumps where they get buried? If it is at Waste Control Specialists in Andrews County, Texas, for example, this could endanger the Ogallala Aquifer over time. WCS is located adjacent to, or right on top of, the Ogallala. And as Dr. Marvin Resniko pointed out in his book Living Without Land"lls, every single radioactive waste dump in this country, once opened, has leaked hazardous radioactivity into the surrounding environment. This is a major negative impact.]
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3.1.4 Cumulative Eects Evaluation Cumulative eects are the eects on the environment resulting from the incremental eects of the Federal actions when added to the eects of other past, present, and reasonably foreseeable actions on a particular resource area.
[Treatment and consideration in this EA of the 2 SMR-300 new builds Holtec is targeting at the PNP site have been woefully inadequate. This is why an EIS/PEIS is needed, as we stated above.]
PGS. 45-46/242 ON PDF COUNTER (pages 3-5 to 3-6)
The NRC sta considered projects and actions within a 50 mi (80 km) radius of the Palisades site, except when speci"cally stated otherwise. Past actions include NRC past actions, e.g.,
licensing of operations, which are included in the cumulative eects analysis.
[The two gigantic reactors at Cook, 30 miles south of PNP, and the three reactors at PNP (the restarted zombie reactor, and the 2 SMR new builds), wouild represent a very major impact on Lake Michigan and the surrounding region, for decades to come. Such risks deserve a much harder look under NEPA than NRC and DOE have provided in this EA.]
P. 46/242 ON PDF COUNTER (page 3-6) 3.2 Land Use and Visual Resources
[At nighttime, PNP is all lit up by glaring bright lights. In daytime, an operating PNP emits a large amount of steam. These are major eyesores, all the way to South Haven, and a great distance out to sea for boaters. Otherwise, the Lake Michigan shoreline here would be quite beautiful, but for this monster on the beach, as the PPCC 100th anniversary yearbook (1905 to 2005) put it, in its chapter about PNP.]
Palisades is bordered by Van Buren State Park on the north and a privately owned residential and lakefront recreational community, Palisades Park Country Club, on the south (see Figure 2-3 of this EA). {Emphasis added.]
[This is one of the "rst explicit mentions of PPCC in this EA. Given the extremely high cancer incidence allegations coming from PPCC, NRC and DOE should have done a much more careful and methodologically robust analysis of negative health impacts on PNPs immediate neighbors to the south. Instead, NRC and DOE have engaged in a whitewash, and a greenwash, of these issues of the utmost importance.]
Palisades is also located within Michigans coastal zone and includes sandy beaches on the shoreline of Lake Michigan that play a role in the preservation and wildlife habitat quality of the critical dune area. The movement of sand via littoral drift from surrounding shoreline areas is important for maintaining the structure of replenishing the beach. Site observations by the NRC ecologists in 2024 noted that the adjacent beaches lakeward of the developed areas on the Palisades site were armored against erosion and subsequently narrowed relative to the beaches fronting undeveloped lands on the site. The unarmored beaches at the Palisades site
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are relatively robust and wider in comparison.
[PNP has caused major damage to the wildlife habitat of these critical dunes, since ground was broken in 1971. Armored is a strange word choice. During the historic high Lake Michigan water levels of spring 2020, signi"cant erosion took place, not far from PNP. This is a cautionary tale for what could happen at PNP itself in the future, meaning major impacts on the environment and health, if radioactive contamination is washed into the Lake or groundwater, if dry cask storage pads are destabilzed, and if even reactor operations are threatened by this form of "ooding, especially during extreme weather events connected to climate chaos.
Armored is also an ironic word choice, given the many, very serious security breaches PNP has experienced over the years and decades. Certainly the dry cask storage is not armored, despite calls by our environmental coalition since 2002 for Hardened On-Site Storage at PNP.
These calls have fallen on deaf ears at NRC and DOE, imperiling us all.]
Coastal Zone Management Act of 1972, as amended (CZMA) administered by Michigans Coastal Management Program.
[The presence of PNP in these critically endangered, fragile sand dune ecosystems, is a major betrayal of any sane notion of coastal zone management, preservation, or protection. PNP should retire as long planned. The old zombie reactor should not be restarted. SMRs should not be built. Radioactive contamination should be completely cleaned up. Radioactive waste should be safely and securely managed. And then the sand dunes, forests, wetlands, beach, and Lake Michigan should be allowed to heal, for the purposes and needs of the indigenous "ora and fauna that have been endangered and threatened by PNP since 1971. This is the No-Action Alternative that appeals to us the most.]
P. 48/242 ON PDF COUNTER (page 3-8) 3.2.3 Environmental Impacts from the Resumption of Power Operations
[Except of course the risk of meltdown is unacceptably high already, and will just get worse with time and age-related degradation.]
This extreme meltdown risk belies NRC/DOE NOT SIGNIFICANT determinations. So too the worsening leakage, of radioactive contamination and toxic chemical contamination, that should be expected at this nuclear rust bucket, that was a nuclear lemon from the get-go. NOT SIGNIFICANT? Are NRC and DOE referring to residents of the area, their health, safety, security, and environment? WE are NOT SIGNIFICANT? Is THIS what NRC and DOE mean when they say Finding of No Signi"cant Impact?]
3.2.4 Cumulative Eects Appendix G, Table G-1 identi"es other past, present, and reasonably foreseeable actions that could result in cumulative eects. The addition of SMRs on the Palisades site would be consistent with the existing industrial land use and appearance of Palisades. SMR operation could generate additional vapor plumes if the proposed SMR technology requires building additional cooling towers.
As discussed in Sections 3.2.2 and 3.2.3 of this EA, the proposed Federal actions would have
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not have a noticeable eect on the industrial use and visual appearance beyond what has been previously experienced. SMRs, if constructed onsite, would be consistent with the existing industrial use and appearance of Palisades. Therefore, the NRC sta has determined that incremental land use and visual eects of the proposed Federal actions when added to the eects of other past, present, and reasonably foreseeable projects would not have signi"cant cumulative eects.
[Meltdowns would not necessarily impact visual aesthetics, unless all the trees die, like they did in Chornobyls Red Forest. An entire pine forest near Chornobyl Unit 4 turned red and died, from its exposure to massive levels of radioactive contamination. Of course, the Chornobyl Dead Zone is also an eerie eyesore, in terms of its absence of human habitation, as it is too radioactive for people to live there, over a vast region, to this day.
But the PNP zombie reactor + 2 SMR new builds = potential domino eect multiple meltdown risk, as happened at Fukushima Daiichi in Japan, in March 2011 a meltdown would mean the site could no longer be used for industry, or anything else. It would be too hazardous to inhabit in any way, shape, or form, like in the Chornobyl and Fukushima Dead Zones, which, truth be told, should be much larger than they actually are. The risk of one or more meltdows at PNP would be all the more likely, given that both extreme ends of the risk spectrum would share the same tiny, 432 acre site: breakdown phase risks at the zombie reactor, and break-in phase risks at the two SMR new builds. Chornobyl Unit 4 in Ukraine in 1986, and Three Mile Island Unit 2 in Pennsylvania in 1979, are examples of break-in phase reactor catastrophes. So too is the We Almost Lost Detroit Fermi 1 partial core meltdown of 1966, in Monroe County, Michigan, on the Lake Erie shore.
Holtecs 300 MW-e SMRs are not so small. They would each be 4.5 times bigger than the 67 MW-e Fermi 1, and Big Rock Point, reactors. For its part, Big Rock Point released more than three million Curies of hazardous radioactivity during its 35 years of operations. This is a staggering amount, one of the very worst records of any American reactor. For more information, please see the following backgrounder and documents, incorporated by reference as if fully rewritten herein:
November 30, 2006: Kevin Kamps (NIRS/Dont Waste Michigan) press statement in opposition to Plutonium State Park at Big Rock Nuclear Power Plant near Charlevoix, Michigan.
November 30, 2006: Statement by Kay Drey, NIRS board of directors secretary, opposing state park at Big Rock nuclear plant in Michigan.
November 30, 2006: Statement of Michael J. Keegan, Coalition for a Nuclear Free Great Lakes, in opposition to state park at Big Rock nuclear power plant.
November 30, 2006: Coalition statement (two dozen grassroots groups) opposed to Plutonium State Park at Big Rock Nuclear Power Plant in Michigan.
November 30, 2006: Coalition Urges Rejection of Big Rock Nuke Site Park: Numerous Michigan Natural Resource Treasures Without Nuclear Waste Would be Better Choices for Limited Trust Fund Dollars. Press release.
November 30, 2006: Say Yes to Michigan, Say No to the "Plutonium State Park"! Backgrounder on Big Rock Nuclear Power Plant.
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Letter to Hayes Township Advisory Focus Group and Planning Commission, re: need for zoning at the former Big Rock Point nuclear plant to absolutely minimize human exposure to hazardous radioactivity, February 8, 2023.]
P. 50/242 ON PDF COUNTER (page 3-10)
Three "ood events were recorded during this period, with the most recent one occurring near South Haven on April 17, 2013 causing damage over 32 million dollars (NOAA 2024-TN10769).
[NRC and DOE seem to have neglected mentioning the historic high Lake levels in spring 2020 no "ood needed, per se, the high Lake levels just did signi"cant erosion damage to area beaches and blus, including close to PNP. In April 2002, the commentor here paced the distance from the Lakes edge, to the foot of the small blu behind which one of PNPs dry cask storage pads is located. The distance was a mere 30 paces, about 100 feet. The oft repeated claim by PNP that that dry cask storage was 150 yards from the Lake likely misstated it in spring 2002. The high Lake level brought the Lake much closer than 150 yards to the vulnerable dry cask storage on the beach. An extreme weather event, fueled by climate chaos, scoring a direct hit on this Lakeside dry cask storage at PNP, could result in catastrophe.]
The monitoring program procedure and quality assurance documents are maintained by the applicant within Holtec Procedure EM-33 (HDI 2024-TN10670: RAI-MET-1).
[Was QA maintained during the prolonged shutdown was any of the monitoring equipment itself dismantled or modi"ed, like the cooling towers? After all, most to all requirements were simply terminated by NRC, at Entergy and/or Holtecs request, in the lead up to Entergys closure for good of PNP on May 20, 2022, with ocial certi"cations delivered by Entergy to NRC on June 13, 2022. Are the long intervals between maintenance acceptable? After all, a third of EPA monitors nationwide were inoperable when Fukushima began, for various reasons having to do with neglected maintenance.
At PNP itself, such neglect of maintenance has resulted in a signi"cant increase in risk to safety, health, and environment. For example, on January 14, 2025, we "nally got veri"cation from an NRC staer, during an NRC-Holtec meeting, that Holtec had waited two full years before implementing chemically preservative wet lay up on the steam generators at PNP. This has resulted in accelerated degradation of the steam generator tubes, a major safety risk. Holtec has proposed mere BAND-AID "xes, such as sleeving degraded tubes, and NRC appears poised, as ever, to rubberstamp this dangerous idea. Holtec has also proposed unplugging tubes in the steam generators that were plugged 35 years ago as a safety precaution against vibration and rubbing that could cause yet more tube degradation. Needless to say, the rupture of a tube at PNP during operations would result in a release of hazardous radioactivity to the environment. The more tubes that rupture, in a cascading failure, would mean larger and larger quantities of hazardous radioactivity escaping into the biosphere. And if enough tubes failed at once, a reactor core meltdown would ensue, with catastrophic releases of hazardous radioactivity into the environment. This would have major negative impacts on the environment, as well as health and safety.
NRCs own report, Calculation of Reactor Accident Consequences, or CRAC-II, from 1982, contains shocking "gures for casualties and property damage if PNP melts down: 1,000 peak
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early deaths (acute radiation poisoning fatalities); 7,000 radiation injuries; 10,000 peak cancer deaths (latent cancer fatalities); and $52 billion in property damage. The report is most commoly referred to as the CRAC-II report because that is the computer program used in the calculations, but the report is also known as the 1982 Sandia Siting Study after Sandia National Lab in New Mexico, which NRC contracted to carry out the study or as NUREG/
CR-2239.
Adjusted for in"ation alone, this property damage "gure would now surmount $168.63 billion, expressed in Year 2023 dollar value "gures.
And as Associated Press investigative reporter Je Donn reported in his four-part series Aging Nukes after Fukushima, populations have soared around U.S. atomic reactors like Palisades, meaning casualty "gures would be correspondingly higher today, given more people in harms way.
We incorporate by reference, as if fully rewritten herein, the Aging Nukes series, posted online here:
The CRAC-II casualty and property damage "gures were so alarming, that NRC captured by the agency it is supposed to regulate tried to suppress the report. But the "ndings were outed by U.S. Representative Ed Markey (Democrat-Massachusetts), in a congressional hearing. Markey is now a U.S. Senator.
NRC similarly tried to prevent NAS from publishing a report about security risks at nuclear power plants, in the aftermath of the 9/11 attacks. The dispute between the two federal agencies generated major national media coverage. In the end, a redacted version of the report was published by NAS, but NRCs meddling led to a many months long delay in its publication.
NRC also engaged in trying hide a major near-miss with a indoor wet storage pool irradiated nuclear fuel "re in October 2005. It buried mention of the incident in an inspection report. NRC Region III OPA spokeswoman Viktoria Mytling, at a public meeting in South Haven, Michigan in April 2006, attempted to defend and justify NRCs actions (or lack thereof) by calling the cask dangle close call with catastrophe an unreportable event.
Such cover ups by NRC are of course unacceptable, a re"ection of the agencys dangerous collusion with the industry it is supposed to regulate.
For this reason, we incorporate by reference the following three documents about the 2005 cask dangle near-miss, as if fully rewritten herein:
March 18, 2006 Detroit Free Press front page, above the fold headline article, NUCLEAR SAFETY LEFT HANGING AS CRANE DANGLED FUEL RODS: MICHIGAN INCIDENT GOT WARNING BUT NO FINE;
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March 20, 2006: High-Level Atomic Waste Mishap at Palisades Nuclear Reactor Risks Radioactive Inferno with Casualty Potential of Thousands of Deaths Downwind. NIRS and coalition press release; April 4, 2006: Summary Report on High-Level Atomic Waste Mishap at Palisades Nuclear Reactor Risks Radioactive Inferno with Casualty Potential of Thousands of Deaths Downwind, Based Upon U.S. Nuclear Regulatory Commission Freedom of Information Act (FOIA) Response Documents, prepared by NIRS for release at press conference at the State Capitol in Lansing, Michigan.]
Winds are predominant from northwest and southwest during 2022 through 2023 at 197 ft (60 m) height. High wind speeds are more frequent during winter months and very low wind speeds are observed during summer months. The average wind speed showed a decreasing trend at both 33 ft (10 m) and 197 ft (60 m) heights from 1983 through 2023. An average wind speed of 7.67 miles per hour (mph) (3.43 m/s) was noted at 10 m and 13.6 mph (6.1 m/s) at 60 m during the period of 1983 to 2023. The atmospheric conditions were 25 percent unstable (A-C), 59 percent neutral (D-E), and 16 percent stable (F-G) during 2023. Stability frequencies are noted to shift toward the unstable classes in recent years (HDI 2024-TN10670: RAI-MET-1).
[What is the wind power potential on-site, and o-site on the Lake? After all, Holtec is willing to risk the future of Lake Michigan. Why not build wind turbines there/nearby, instead? This would have much less impact on the environment and health than restarting PNP. What about aesthetic impacts of oshore wind power? Its preferable to the aesthetic impacts of Palisades itself, let alone the radioactive impacts, and potentally much larger radioactive impacts. As Dr.
Arjun Makhijani put it at a book talk about Carbon-Free and Nuclear-Free: A Roadmap for U.S.
Energy Policy in Kalamazoo, Michigan in late October, 2008, we can either freeze in the dark without a job (live without electricity), bake the planet (climate chaos), kick the plutonium can down the road to our descendants (another risk of nuclear power weapons proliferation), or, we can deal with the view (wind turbines, solar panels).
Dr. Makhijanis framing led to a letter to the editor published in the Muskegon Chronicle, incorporated by reference herein as if full rewritten herein:
https://static1.1.sqspcdn.com/static/f/356082/10617450/1297055663983/
Muskegon+Chronicle+Nov+17+2008.pdf?token=TPctULtDlzyNFiK9y9wVPsCLoR0%3D IEER wrote the book on the many downsides of nuclear power, and why it is not a climate mitigation strategy. We incorporate IEERs book on the subject by reference, as if fully rewritten herein:
https://ieer.org/resource/books/insurmountable-risks-dangers-nuclear/
NRC and DOE should use IEERs framing, as in this book, in its hard look in an EIS/PEIS, re:
PNPs restart, as in a much more robust and comprehenive Alternatives analysis than was carried out in this woefully inadequate EA.]
The Palisades site experiences considerable cloud cover during most of the year, which can
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in"uence air dispersion of radioactive releases as cloud cover generally creates a more stable atmosphere with less atmospheric mixing. The vent release height for radioactive releases is 191 ft (58.1 m). The relative air dispersion (/Q) for routine releases were determined to be 1.8 x 10-6 at the site boundary, which is about 0.5 mi (0.8 km) from the release point. Short-term /Q was estimated as 1.55 x 10-4 for 0 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 4 x 10-5 for 0 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at the exclusion area boundary of 2,641 ft (805 m) (Entergy 2016-TN10765: Chapter 2)
[Even with cloud cover, solar power would still work at PNP itself, and/or nearby, and/or elsewhere in the service area. This would be a preferred alternative to PNP restart. Dr. Al Compaan, a solar power entrepreneur and patent holder, as well as emeritus chair of the Physcs Department at the University of Toledo, testi"ed as much to the NRC ASLB as an expert opposing the 80-year license at Point Beach NPP in Wisconsin. Dr. Compaan explained the solar power technology is growing ever more ecient and eective. Direct sunlight is not needed to generate electricity. Even diuse sunlight is sucient, through a process called insolation. That intervention petition and request for hearing testimony is incorporated by reference, as if fully rewritten herein:
http://static1.1.sqspcdn.com/static/f/
356082/28418937/1616559485077/3+23+21+Declaration+Compaan+PBN+"nal+-
+Declaration+Compaan+w+exhs+COMPLET.pdf?
token=v%2BxPAAS%2FxVFSzfOauZpj5Xnhstc%3D If solar power is viable at Point Beach, it is certainly viable further south, at PNP, as well as elsewhere throughout the entire Great Lakes region and service area.
Point Beach is also located on the Lake Michigan shoreline. Point Beach Unit 2 and Palisades are essentially tied for worst neutron-embrittled reactor pressure vessels, a pathway to meltdown that risks catastrophic environmental, health, and safety impacts.
NRC admitted Palisades and Point Beach Unit 2s worst in the U.S. RPV embrittlement in April 2013, after a heated public meeting attended by a very large number of concerned citizens and residents:
March 19, 2013: Kevin Kamps of Beyond Nuclear's questions to NRC re: the agency Webinar on RPV embrittlement/PTS risks at Palisades.* On April 18, 2013, NRC released a summary of the Palisades embrittlement webinar it had held on March 19th. This document has been referred to as: J. Geissner, Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant. It is available at ADAMS Accession No. ML13108A336. The slides from the NRC Public Webinar, Basis for NRC Requirements on Pressurized Thermal Shock, are available at ADAMS Accession No. ML13077A156.
Point Beach and Cook nuclear power plants, in WI and MI respectively, on the Lake Michigan shorelines, have no cooling towers. All the thermal waste heat generated is dumped into Lake Michigan as thermal pollution. The PNP zombie reactor would contribute to this thermal wastewater pollution as well, despite having cooling towers. So too would two new SMR-300s at PNP, and one or more at Big Rock Point. These are major impacts on Lake Michigans aquatic ecology, from nuclear power.
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Solar, as well as wind, ef"ciency, and storage, should the preferred alternatives, rather than PNP restart, given their signi"cantly smaller impacts. PNP should be retired as long planned, and kept closed for good, the No-Action alternative.]
There are no Prevention of Signi"cant Deterioration Class I areas located within 100 mi (161 km) radius of the Palisades site.
[Not even Michigan City, IN? Gary, IN? Chicago, IL? Is that because they just over 100-miles away? Or not even? NRC needs to expand its radius of concern, and recognize the areas of signi"cant concern that southern ring Lake Michigan, including at the PNP itself.]
P. 51/242 ON PDF COUNTER (p. 3-11)
Major emission point sources in Van Buren County include a natural gas "red 1,176 MW power plant and a pharmaceutical laboratory that operates gas boiler and emergency diesel generators.
[Why is there no mention here that a large Natural Gas-Fired Power Plant is located immediately across the highway from PNP? What a LARGE impact on local communities, including Covert Twp., given both pollution sources. Its an EJ violation, given the relatively large African American populations of Covert Twp. and Benton Harbor, as well as their high-level of low income individuals and households. There is also a large Latino population in the area, including migrant seasonal agricultural workers, as well as families which have settled in the area as permanent residents. Many are also low income. Then of course the Indigenous Nations nearby, such as Pokagon and Gun Lake Bands of Potawatomi.]
Gases found in the Earths atmosphere that trap heat and play a role in the Earths climate are collectively termed GHG. Climate change is a subject of national and international interest because of how it changes the aected environment. Commission Order CLI-09-21 (NRC 2009 TN6406) provides the current direction to the NRC sta to include the consideration of the impacts of the emissions of CO2 and other GHGs that drive climate change in its environmental reviews for major licensing actions. The GHG emissions estimates from a 1,000 MWe reactor and the scaling calculations for Palisades are presented in Appendix F. The NRC sta estimated the GHG emissions, using the assumptions discussed in Appendix F, of the proposed actions, 1,444,739 MT CO2(eq)this includes emissions from preparation activities and resumption of operations. The total life-cycle emissions (which also include decommissioning) were estimated to be about 1,474,000 MT CO2(eq).
[Thats a lot of GHG from Palisades restarting. Especially compared to just decommissioning it.
And what about the GHG from Holtecs 2 SMRs? What about cumulative impacts? And perhaps most signi"cantly of all, what about the climate impacts on PNP, both zombie reactor and SMR new builds. Extreme weather driven by climate chaos has the potential for catastrophic meltdowns at PNP, as well as radioactive waste "res. Dr. Mark Jacobsons expert witness testimony, above, clearly shows that renewables are much more cost-and time-eective at reducing GHG emissions that is nuclear power, such as the PNP restart and/or SMR new build schemes.]
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3.3.2 Environmental Impacts from the Preparations for the Resumption of Power Operations The NRC sta anticipate combustion and fugitive emissions from preparation activities would be NOT SIGNIFICANT.
[Again, when NRC and DOE say FONSI, do they mean they dont think the local areas/regions population is signi"cant enough to care about, so that any negative impacts, no matter how major, thus, cannot be signi"cant?]
P. 52/242 ON PDF COUNTER (page 3-12) 3.3.3 Environmental Impacts from the Resumption of Power Operations Cooling Towers The Palisades site has two banks of 65 ft (20 m) high mechanical draft cooling towers on the southern side of the plant, which replaced the original cooling towers in 2012 and 2017 (section 2.1 of this EA).
[If the cooling towers were so new, why did Holtec do minor modi"cations on them, of all SSCs at PNP? Some others date back to 1967. Holtec has told NRC that these minor modi"cations on the brand new cooling tower arrays are all easible reversible, so can be reversed for restat purposes. Such make work to make money is waste, fraud, and abuse against the already severely underfunded Decommissioning Trust Fund. This robbery of ratepayer funds is illegal, but the cop NRC is looking the other way, mistaking which de"nition of oversight is its mandate.]
In the 2024 LR GEIS (NRC 2024-TN10161), the NRC sta noted that all observable eects on vegetation from the cooling tower plume ceased after the plant stopped adding sulfuric acid to the cooling water prior to the initial license renewal for Palisades, and noted that there were no anticipated additional impacts associated with cooling tower drift from the original towers.
[So sulfuric acid impacts only persisted from about 1971 to 2012 on the one bank of cooling towers, and only from about 1971 to 2017 on the other array? That is a LARGE impact lasting more than 40 years at the one array, and more than 45 years at the second array. These impacts were on rare, threatened, and endangered plants indigenous to critica forested sand dune habitats, a unique and biologically diverse ecosystem serving as home to a diversity of plant species.]
There are no planned modi"cations to the cooling towers as part of the resumption of power operations (Holtec 2023-TN10538).
[Its funny (well, not really) that NRC and DOE say that. A Holtec spokesman admitted theyd already done minor modi"cations as of 3/20/23. It was the only example of any decommissio ing work whatsoever he made at the "rst NRC-Holtec regulatory pathway to restart meeting, for a decommissioning phase that began almost a year earlier. Again, per just above, why would they start decommissioning on the brand new cooling towers, when other SSCs across the Palisades site were decades older, some dating back to 1967? If Holtec planned to restart PNP, how is such modifcation work on the cooling towers not waste, fraud, and abuse? Did Holtec pay itself to do the decommissioning work, and then pay itself to undo the decommissioning work? How is this not illegal? Where is NRC oversight and enforcement? Where is Michigan Public Service Commission oversight and enforcement?]
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Since there would be no signi"cant changes in the manner in which the cooling towers are operated (e.g., cooling-water chemistry), and Palisades has replaced the original cooling towers with new towers with drift eliminators, there would be no signi"cant impact from the operations of the cooling towers
[is nrc so sure? What WERE the minor modi"cations? Why didnt nrc even mention there here?]
Emissions from Normal Operations
[there is nothing normal about operating a nuclear reactor. But yes, meltdowns are even worse.]
P. 52-53 ON PDF COUNTER (pages 3-12 to 3-13)
The Palisades site will also operate two emergency diesel "red generators (21.8 MMBtu/hr) with a stack height of 50 ft (15.2 m) above the ground. Palisades will perform routine testing of another diesel "red emergency generator (17.5 MMBTu/hr), 800 break horsepower (bhp) emergency diesel engine for auxiliary feedwater system, two 175 bhp emergency "re pumps, and two 10 bhp emergency air compressors. Based on the draft permit requirements, the renewal permit, if issued, will require that the applicant shall not exceed the sulfur content of 1.5 percent in fuel oil feed. The two boilers will have a stack height of 100 ft (30.5 m) above the ground with no pollutant control equipment.
[so much for carbon-free its another lie. Why not, in the year 2025? I thought Holtec cared about climate change? Oh yeah, forgot, theyve long had a fossil fuel division.]
P. 53 ON PDF COUNTER (page 3-13)
No emission units at Palisades are currently subject to the Prevention of Signi"cant Deterioration regulations of 40 CFR 52.21 (TN4498), because the process equipment was installed prior to June 19, 1978 (MEGLE 2022-TN10667).
[yet another exemption from modern evnl protection regulations, b/c pnp is so damn old! So much for caring about climate, air quality, etc.]
The annual emissions reported during 2018, 2022, and 2023 are provided in Table 3-3 below.
The NRC sta notes that Palisades shut down in May 2022, therefore the emissions from 2022 are representative of air emissions during partial operation and decommissioning, while 2023 is representative of air emissions during decommissioning.
[why no data from 2019, 2020, and 2021? Did they turn the monitors o those years? Were those years especially bad, so they decided to not report them here?]
The NOx emissions from fossil fuel combustion are relatively higher than other pollutants, but still much below than the threshold of 100 TPY. Additional contribution to
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ozone formation from NOx and VOC emissions should be insigni"cant.
[should be? But may be worse? But nrc doesnt care enough to look into that possibility? Of course, locals dont matter, so its all insigni"cant]
The Palisades site has surrounding counties which are in maintenance status for lead and sulfur dioxide.
[compare lead poisoning via drinking water in benton harbor; cumulative impacts]
Emissions of hazardous compound are also negligible (HDI 2024-TN10670: RAI-MET-6).
[certainly that statement is false re: radioactivity]
Table 3-3
[why is CO2 not included? Too high, didnt want to feature it?]
P. 54 ON PDF COUNTER (page 3-14) 3.4 Surface Water Resources
[21%, 84%, 95%; 40 M in 8 states, 2 provinces, and a large # of Indigneous Nations]
[be sure to include citation and URL to Kay Dreys routine releases pamphlet somewhere!]
P. 55 ON PDF COUNTER (page 3-15) reduction in potable and sanitary water use because the workforce decreased from approximately 550 in 2022 to 218 in 2023 and 449 currently (HDI 2024-TN10670: RAI-SE-1, RAI-SE-2).
[compare these job #s to holtecs previous claims, as well as granholm/whitmers, etc. they seem to have been all over the place do the cost per job calcs again. I saw up to 650 claimed in the past, but here they admit it was only 550 at closure. Compare cost per job to STATE OF mi average for 2023]
Currently, Palisades withdraws approximately 6,000 gallons per minute (gpm) of water from Lake Michigan for spent fuel pool cooling (HDI 2024-TN10669: RCI-SW-5, 6, and 7). This water is returned to Lake Michigan. Palisades uses approximately 2.8 gpm (16,000 cubic ft [ft3] per month) (10.6 lpm and 450 m3) of potable water from South Haven Municipal Water Authority (HDI 2024-TN10669: RCI-SW-5, 6, and 7).
[even in decommissioning phase, water usage is this high?!]
P. 55 ON PDF COUNTER (page 3-15)
The intake structure is inspected annually for integrity and other environmental conditions
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including zebra mussel buildup (HDI 2024-TN10669: RCI-SW-3). No dredging is currently performed at the intake structure.
[what biocides does PNP use? For zebra mussels and?]
Palisades also has a Michigan EGLE-issued Storm Water Management Industrial Site Certi"cation, I-18257, that expired on July 1, 2016 (HDI 2024-TN10670: RAI-GEN-3). Holtec has requested Michigan EGLE to issue a Clean Water Act (CWA) Section 401 water quality certi"cation or a waiver from the water quality certi"cation requirement. Michigan EGLE is currently reviewing Holtecs request
[can we trip them up on any of this?]
On October 30, 2023, a noncompliance of the NPDES permit occurred due to overapplication of sodium hypochlorite in the service water system that resulted in an exceedance of total residual oxidant (TRO) permit limit of a daily maximum of 300 g/L because of one TRO sample measuring 360 g/L (HDI 2023-TN10674). The daily average TRO limit of 200 g/L was not exceeded. Holtec noti"ed Michigan EGLE and took corrective actions. The event was documented in Palisades corrective action process (HDI 2023-TN10674)
[example of holtec violating mi and us envl laws and regs at pnp]
This topographic con"guration supports surface runo from cooling tower B area to the south toward grassy and wooded areas.
[any hazardous substances "owing with that, building up where it lands?]
P. 56 ON PDF COUNTER (page 3-16)
Stormwater for the rest of the Palisades site is drained by a stormwater drainage system that eventually discharges into Lake Michigan (Figure 3-3 below).
[how much radioactive and other hazardous contamination "ows with that, into the lake?]
Figure 3-3
[crazy that TURBINE BLDG. and HYDRAZINESTORAGE appear right next to each other.
What about hydrazine spill/release due to turbo-generator mechanical explosion, due to lack fo active maintenance for 2.5+ years and counting!]
P. 57 ON PDF COUNTER (page 3-17) installation of the new barrier/wall
[whats this about ?!]
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Holtec expects site employment levels to peak at 1,600 workers during the preparations for resumption of power operations (HDI 2024-TN10670: RAI-SE-1).
[another data point permanent v temporary workers]
Water withdrawn to support spent fuel pool cooling would continue to be returned to Lake Michigan and therefore would result in no consumptive water use. Therefore, the impact of this water use on surface water resources would be minor
[what about radioactive contamination of that water returned to Lake MI? What about trtitium concentration in it?! Other chemical toxins?]
P. 58 ON PDF COUNTER (page 3-18)
As part of the preparations for resumption of power operations Holtec is considering replacement of both CCW heat exchangers. The potential impacts of the proposed CCW heat exchangers on surface water resources are evaluated in Section 3.4.3.
[compare to arnies CCW objections, submitted as expert dec in licensing proceeding. See email to sheri mcwhorter]
3.4.3 Environmental Impacts from the Resumption of Power Operations Holtec expects site employment to be 600 workers during and after the resumption of power operations (HDI 2024-TN10670: RAI-SE-1).
[yet another data point on job predictions]
The evaporative loss in the cooling tower would be 12,000 gpm and the remaining 80,000 gpm of the withdrawn water would be returned to Lake Michigan.
[some of the evaporative losses would fall back into Great Lakes, but not all, would be lost to basin; do the math per hour, per day, per week, per year, per decade, per 25 years, etc. But how much worse will it become once two SMR-300s are also operational? Is NRC accounting for such cumulative impacts? Not adequately.]
Over a year of operations, the evaporative loss would be less than 0.001 percent of the water volume of Lake Michigan.
[death by a thousand cuts. Palisades being three big ones.]
The NRC sta has concluded that the plant water use following resumption of reactor power operation would be similar to Palisades previous power operation. In the 2006 SEIS, the NRC sta determined that all cooling system-related surface water use impacts for power operations at Palisades were small (NRC 2006-TN7346).
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[yes buthave there been any power uprates since 2006? Any planned by 2051? This would make the zombie reactor itself worse in these regards.]
Because there would not be any changes to power generation capacity and the circulating water system, the NRC sta expects that the thermal discharges to Lake Michigan would be comparable to previous power operations.
[but this is not correct. Cite Arnies submissions on CCW doubling in size. ahh, nrc does discuss this in next paragraph]
P. 59/242 ON PDF COUNTER (page 3-19)
Holtec is considering replacement of both CCW heat exchangers before resuming power operations at Palisades (HDI 2024-TN10670: RAI-SW-11). Palisades uses two existing CCW heat exchangers, each of which has a nominal 50 percent cooling capacity. The CCW system is the secondary, closed cooling loop that uses service water and is the intermediate cooling system between the radioactively contaminated systems and the tertiary, open loop service water system that comprises the ultimate heat sink. The existing system requires both CCW heat exchangers to be in service due to "ow rate limitations. The proposed CCW heat exchangers will each have a nominal 100 percent capacity, which allows operational "exibility.
Holtec would not make any changes to the service water side of the CCW heat exchangers and therefore no changes to the interface to the surface water environment are expected.
There is no change to the heat loads that are serviced by the proposed CCW heat exchangers. The total service water "ow rate is also not expected to change; the service water "ow may be through one or both proposed CCW heat exchangers depending on whether one or both proposed CCW heat exchangers are in use. There is no consumptive water use associated with the CCW heat exchangers. Therefore the proposed CCW heat exchangers would not aect surface water resources.
[again, compare with Arnies critique. Holtecs doubling of CCW makes no good sense, other than a make work money maker for holtec. If they were to do any such thing, it would be to double the cooling tower arrays, per arnie.
The highlighted part also makes no sense, given holtecs press release admission that lake michigan suraface water temps are signi"cantly increasing due to global warming]
P. 59/242 ON PDF COUNTER (page 3-19) a new spent fuel pad
[thats the "rst time Ive seen it in writing. Id heard others talk about it, but Id not seen it yet.
What about Indigenous Nations burial sites and other sacred sites on site? What about that pledge to be careful and stop work that Consumers Energy made in 2006-7?!] Have they forgotten all about it?]
potential subsequent license renewal (SLR) of Palisades continued operation of existing mines
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[80-year license, till 2051; why not 100-year license? Its been talked about, even by nrc, for decades now.
Continued operation of existing mines? What about new mines, including in MIs UP?!
What about surface water impacts near uranium mines, mills, etc? Near needed nuke waste dumps?!]
3.5 Geologic Environment and Groundwater Resources
[How about those drinking water wells the supply PPCC? If theyve dodged bullets all these decades, will they continue to?]
Mississippian age (358.9-323.2 million years ago) Coldwater Shale underlies the region and was identi"ed at 440 ft (130 m) above MSL within the vicinity of the containment building.
[does Holtec plan to frack the PNP site then?!]
There are no noted geologic resources in the vicinity of Palisades.
[but IF THERE WERE, holtec would be mining them as well, per just above]
There are 187 known active wells within 2 mi (3.2 km) of Palisades, the majority of which are domestic wells completed in unconsolidated glacial deposits (DTMB 2024-TN10677).
[thats a lot of potential contamination of drinking water by PNP. But most may be uphill?
Despite this, recall that Ian fairlie warns tritium can travel upstream, even in surface waters like rivers. So imagine the potential in contained groundwater, even just through diusion, let alone tritiums capacity to "ow upsteam.]
Within the vicinity of the Palisades site, groundwater is uncon"ned within the dune sand and "ows toward Lake Michigan (NMC 2005-TN10678).
[is nrc so sure there are no connections whatsover between groundwater at PNP and groundwater, used as well water for domestic use, at PPCC? recall, YM is one of the best known/most studied sites on Earth re: hydrogeology. And yet even there, there are many gaps in knowledge.
also, holtec has big plans to dig and disturb the site, such as building two SMR-300s. Who is to stay they wont pierce an aquifer divider, allowing PNPs contaminated groundwater to "ow into PPCC drinking water aquifers?
Regardless, Lake Michigan is also a source of drinking water. So PNPs contaminated groundwater "owing into Lake Michigan as well as surface contamination "owing down, or "owing directly in will do so as well.
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Treating groundwater as a radioactive industrial septic "eld. Treating Lake Michigan as a radioactive and toxic chemical nuclear-industrial wastewater sewer.]
P. 61/242 ON PDF COUNTER (page 3-21)
Palisades monitors 29 groundwater wells in support of the Industry Groundwater Protection Initiative (GPI)(NEI 2019-TN6775). Monitoring under National Emissions Inventory 07-07 continued after operations ceased at the plant (HDI 2024-TN10679). The wells are screened within the dune sand and sampled quarterly for gamma activity and tritium (Holtec 2023-TN10538). Between 2009 to 2022, Palisades reported experiencing 10 instances of elevated tritium detected in onsite wells (see Table 3-4 of this EA for details). From January 1, 2023 to June 26, 2024, tritium was detected in MW-2, MW-11, TW-17, and TW-18 at a maximum concentration of 1,441 picoCuries per liter (pCi/L) at TW-17 (HDI 2024-TN10679). Groundwater sample data from MW-2, MW-3, MW-11, and MW-13 indicate tritium releases have impacted onsite groundwater. However, tritium has not been detected in groundwater in the lower dune sand, indicating that impacted groundwater is within the upper 10-15 ft (3-4.6 m) of the aquifer (Holtec 2023-TN10538: Section 3.2.1.2).
[but what about the 645,000+ pCi/L tritium concentration brought to my attention by Princess from WWMT on 11/20/24? How come that is not included here?
As nrc admitted above, tritium in sand dune groundwater "ows into Lake MI, another impact on Lake MI, and its drinking water supply; cite RPHPs/Manganos EPA snapshot "gure from 2013 in open Lake Michigan surface water, four miles dilution factor north what concentration must it have been at when it was discharged at PNP?!]
[why is 2009 the oldest/earliest date in Table 3-4? Didnt PNP have a tritium leak scandal in 2007? Dont they want the public to know/think about those even earlier leaks?
Compare PG report, published 2010/updated 2015.
Compare mangano 2013, citing epa 1995-ish.
Both those reports would involve tritium leaks/release priort to 2009.
Cite Kay Dreys routine releases pamphlet. Especially gabis photo of PNP surface water wastewater discharge pathway.]
less than the EPA drinking water MCL of 20,000 pCi/L.
[in 2009-2013 Description. As if that is all right. Compare Arjuns articles about much stricter standards elsewhere, his 2024 book, and NAS linear no-threshold press release.
MW-11 and T-91 mentioned more than once, over time. So they never really did "x the leaks to begin with. They allowed continuing leakage from the same source. So, poor Root Cause and Corrective Action Holtec will likely be even worse than Entergy in this regard, given its inexperience, incompetence, and the fact it just doesnt care. At least Entergy had a lot more experience, even if it was also incompetent and just didnt care.]
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Tritium concentrations decreased below EPA MCL.
[again, per above, thats not saying much]
2019 No action taken as no new signi"cant dose pathway and release previously reported under a batch release process.
[oh great. yeah, just let it wash out into the Lake. Who cares? NRC = Nobody Really Cares.]
[Table 3-4== an epidemic, a plague of tritium leaks and releases PNP leaking like a sieve cite Barbara pellegrini increase of tritium concentrations in the Lake, b/c it is not natural it is arti"cial and its not just PNP its all the tritium sources around the Lake, including all the NPPs, but also tritium contaminated exit signs buried in leaking land"lls compare to kay dreys 3 to 24 pCi/L natural tritium in surface water "gures All such leaks can be expected to grow worse over time, especially given restarted operations, and renewed arti"cial tritium generation nrc and industry have blurried tritium risks for many decades, especially after the Braidwood scandal of the early 2000s]
May 2022 Elevated tritium detected in a water sample collected from the 1C switchgear sump within the protected area at a maximum concentration of 645,255 pCi/L.
[why did it take till 11/20/24 for me to "nd out about this? And from Princess at WWMT. Not from Entergy, nor Holtec, nor NRC, nor MI EGLE, etc.]
P. 63/242 ON PDF COUNTER (page 3-23)
Additionally, between April and September 2018, the P-8D Auxiliary Feed Water Pump and associated piping was installed. This area is a known area of previous inadvertent radiological releases. Almost 700 gamma isotopic analyses were performed, of which 19 samples contained detectable Co-60 and/or Cs-137. This material was disposed of as radioactive waste (HDI 2024-TN10843: RCI-GW-2a).
[cite health hazards]
P. 63/242 ON PDF COUNTER (page 3-23)
Palisades discharges some radiological waste into Lake Michigan after dilution in the mixing basin in accordance with criteria established in 10 CFR Part 50, Appendix I (NRC 2006-TN7346).
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[per Pellegrini, it is not dilution, it is increasing concentration of hazardous arti"cial radioactive istopes, generated at PNP.]
The NRC sta reviewed 5 years of available radiological release reports (2019-2023 monitoring results), in addition to radiological environmental monitoring program (REMP) results. REMP results are provided in Annual Radiological Environmental Operating Reports (Entergy 2020-TN10687, Entergy 2021-TN10686, Entergy 2022-TN10685; HDI 2023-TN10684, HDI 2024-TN10771).
[why not back to 1971? Why such a shallow review? 5 years back, instead of 50+?]
The cessation of operations at Palisades resulted in a decrease in liquid euent releases to Lake Michigan and to total tritium discharged via groundwater (Entergy 2022-TN10681; HDI 2023-TN10680, HDI 2024-TN10679).
[oh, but they are going to turn that around, big time, for many decades to come]
In 2023, Holtec estimated an activity of 1.82 x 10-3 Curies (Ci) was discharged from onsite groundwater to the lake, compared to 1.1682 x 10-1 Ci in 2021, Palisades last full year in operation (HDI 2024-TN10679; Entergy 2022-TN10681). The tritium discharged via groundwater over the past 5 years represents a small portion (1 percent in any given year) of the total liquid tritium discharged from Palisades. None of the surface water and drinking water samples collected as part of the plants REMP monitoring contained measurable radiological materials attributed to Palisades euents in the past 5 years (Entergy 2020-TN10687, Entergy 2021-TN10686, Entergy 2022-TN10685; HDI 2023-TN10684, HDI 2024-
[all the more reason to keep PNP shut down. All the more reason for analyses to go further back in time, to 1971]
P. 64/242 ON PDF COUNTER (page 3-24)
Holtec maintains a SPCC-PIPP for the management of inadvertent release of oil, salt, and polluting materials. Internal procedures are also in place for the storage, handling, cleanup, and disposal of chemicals at the Palisades site (Holtec 2023-TN10538). Additionally, a SWPPP that includes BMPs to prevent pollutants from entering stormwater, to direct the "ow of stormwater, and to treat stormwater is maintained by the Palisades site.
[any examples of shortcuts being taken at PNP? Like just dumping it in the Lake?]
3.5.2 Environmental Impacts from the Preparations for the Resumption of Power Operations Planned activities include underground pipe repairs to "x the leaking condensate storage tank (T-2) and the Utility Water Storage Tank (T-91) piping and the construction of two new buildings within the protected area.
[not a peep here anyways re: Indigenous burials and other sacred, cultural sites. Is this mentioned anywhere else in this EA?! Compare to 2006 supposed commitments.
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Talk is cheap. Who is going hold Holtec and NRCs feet to the "re on all this? No one. If something goes wrong and comes to light later, theyll just shrug, if that. The Trumpian school of never admit wrongdoing, deny deny deny]
Current groundwater use at the Palisades site is dierent from that described in the 2006 SEIS (NRC 2006-TN7346). Groundwater use at the Palisades site was discontinued in 2019 and groundwater is not anticipated to be used during the resumption of power operations. There are no current or planned continuous contaminant plume extractions or other dewatering activities at Palisades (Holtec 2023-TN10538). Site-speci"c programs (e.g., SPCC-PIPP, SWPP, NPDES) and BMPs are and will continue to be utilized at the site to manage and reduce the occurrence of inadvertent releases of nonradiological contaminants.
[they wont use groundwater, until they decide to use groundwater.
What about ADVERTENT releases of toxins, radioactivity?]
Palisades monitors onsite groundwater in accordance with the GPI to ensure timely and eective management of situations involving inadvertent releases of licensed material to groundwater. Since decommissioning, tritium is the only radionuclide detected onsite in the dune-sand aquifer due to previous unplanned releases. Groundwater containing tritium discharges to Lake Michigan represents a small portion (typically 1 percent) of the total tritium
[but tritium is often but the leading edge the canary in the coal mine for other even more hazardous radionuclides to follow.
P. 65/242 ON PDF COUNTER (page 3-25) discharged to the lake via regulated batch liquid euent releases.
[oh, so these inadvertent (but commonplace, unavoidable, inevitable) releases are nothing compared to the intentional ones cite Kays pamphlet]
No radiological material attributed to Palisades has been detected in drinking water or surface water samples near the plant, and there are no registered groundwater wells downgradient of groundwater "ow from the Palisades site.
[how can that possibly be. Doesnt this violate physics, chemistry, biology? South Havens drinking water intakes are 4 miles or less away. How can the tritium and other radioactive waste have disappeared into absolute nothingness in the Lake? clearly, they are not looking very hard. Its all like magic, isnt itmagical thinking anyway. Compare epa data point Mangano reported in 2013 on tritium itself. Are there other such data points to be had?
Obviously nrc cant be trusted to tell the truth or care]
Key past and present actions aecting groundwater resources include the planned construction of multiple SMRs and the potential SLR of Palisades. The SMRs are planned to be constructed within the Palisades site boundary and additional groundwater monitoring wells could be installed to supplement the current groundwater monitoring program (SMR 2024-TN10713). Excavation for the nuclear power block associated with the SMR modules may
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extend to a depth of approximately 140 ft (43 m) below grade (NRC 2018-TN7244), which would likely require the application of methods (e.g., grouting and dewatering) to stabilize the deep excavation during construction.
[keegan had mentioned high Lake water levels causing changes to groundwater "ows. Could high Lake levels push contaminated groundwater into aquifers used by PPCC for drinking water via wells?
Could SMR new build construction pierce aquifers, allowing contamination to "ow into PPCC drnking water wells?
And what about the critically endangered dune status all around PNP? How can large-scale construction unneeded at that be allowed at PNP in the year 2025, given the envl impacts?! The opposite of enlightenment, lessons (that should have been) learned (but were not).]
P. 65/242 ON PDF COUNTER (page 3-25) 3.6 Terrestrial Ecology
[critically endangered dunes, including forested dunes, including wetlands. Is there more fragile and critically endangered terrestrial ecological habitat than that? And yet Holtec plans to trash it even further than Consumers Energy did from 1967 to 2007, and Entergy from 2007 to 2022.
And NRC as well as other federal agencies (EPA, NHPA agency, etc.) blesses all of it, every single time. So too the State of MI. For shame.]
P. 66/242 ON PDF COUNTER (page 3-26) incorporating by reference where relevant
{we should do that too most especially our 2006 coalition comments]
As described in Section 3.2 of this EA, the entire Palisades site is protected under CZMA (MEGLE 2020-TN10692). In a letter dated August 30, 2024 (HDI 2024-TN10670: RAI-GEN-3, ), Michigan EGLE stated that the 2005 CZMA certi"cation and conditions remain valid through the expiration of Palisades operating license, if conditions outlined in the letter are met, and that it does not waive need for other permits.
[MI EGLE is not protecting it very well, I gotta say]
P. 67/242 ON PDF COUNTER (page 3-27) 3-27 Figure 3-4
[both of the two largest Freshwater Wetlands already appear signi"cantly impacted by Palisades, given how close they are to major developed land there. Including dry cask storage
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at the northernmost even the gamma and neutron shine would impact "ora and fauna, signi"cantly. Not a peep about any of this from NRC.]
Michigan regulates activities in designated critical dune areas (CDA) to protect coastal dunes along Lake Michigan, requiring a use permit for regulated activities within CDAs (Michigan Compiled Law § 353-TN10693).
[oh yeah, MI sure regulates. MI let them build an lemon of an atomic reactor there, thats been dangerous ever since.]
Approximately 244 ac (98.8 ha) of the CDAs are barrier dunes, and 3 ac (1.2 ha) are an exemplary dune associated plant community outside of designated dune formations (PC-43, Mesic Southern Forest).
[so that is a postage stamp sized vestige of what would otherwise have been throughout the site, had it not been nuked since 1967. And now they want to nuke it for many decades to come, both with zombie reactor operations, as well as SMRs]
The applicant has a current permit (MEGLE 2020-TN10696, expires 04/16/2025) from Michigan EGLE for maintenance dredging of sand along security fences, other security infrastructure, and stormwater outfall structures.
[any way to trip them up on this? Not likely, given Whitmers gung ho support]
P. 68/242 ON PDF COUNTER (page 3-28)
The NRC sta independently accessed the U.S. Fish and Wildlife Service (FWS) Information for Planning and Consultation database on May 21, 2024, and received a list of 11 species listed as threatened, endangered, or candidate under the Federal ESA (FWS 2024-TN10697).
[may 21, 2004 way before envl scoping was even announced, no? Is it legal for nrc to do work on an EA even before the public is noti"ed it is underway? b/c obviously, nrc is trying to accommodate holtecs rush job of a restart schedule, while also keeping the concerned public and opponents to restart in the dark for as long as possible, to put us at a disadvantage.]
The database indicated that no designated or proposed critical habitat occurs within the action area.
[but how could this possible be? Critically endangered, and fragile, sand dunes, including with forests and even wetlands?! Is it that the site has long been trashed already, so NRC is "ne with it being trashed inde"nitely into the future as well? Thats the attitude! This is the way the world endsin fact, nrcs words "y in the face of what theyd just acknowledged above, MIs designation for hundreds of acres of the site!]
the NRCs 2024 eects determination
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[the missing apostrophe must have suered radiogenic apoptosis?!]
During the NRC stas environmental review for the 2006 SEIS (NRC 2006-TN7346), the sta evaluated the eects of Palisades operations on four federally listed species (Indiana bat
[Myotis sodalis], Pitchers thistle [Cirsium pitcherii]; Karner blue butter"y [Lycaeides melissa samuelis]; Mitchells satyr butter"y [Neonympha mitchellii mitchellii] and one candidate species eastern massasauga [Sistrurus catenatus]). In 2016, eastern massasauga was federally listed as threatened (81 FR 67193-TN10698). Of these "ve species, only Pitchers thistle was then known to occur on the Palisades site, and the NRC eects determination was may aect, not likely to adversely aect. In a letter dated May 15, 2006 (DOI 2006-TN10699), FWS agreed that the 2006 SEIS did not involve any major construction or physical alteration of the action area and concurred with the NRC stas eect determinations for these species (summarized in Table 3-5 of this EA).
[well, the restart involves major construction; so too 2 new build SMR-300s so what gives now. How can they stand by this 2006 conclusion?!]
The 2006 SEIS did not consider six species that were either not designated under the ESA at that time or were federally listed but not expected to occur within the action area at that time (NMCCO 2005-TN10839): northern long-eared bat (Myotis septentrionalis, listed as threatened in 2015 [80 FR 17974-TN4216] and reclassi"ed as endangered in 2023 [87 FR 73488-TN8545]), tricolored bat (proposed for listing as endangered in 2022 [87 FR 56381-TN8546]),
rufa red knot (Calidris canutus rufa; listed as threatened in 2015 [79 FR 73706-TN4267]), piping plover (Charadrius melodus; listed as endangered in 1985 [50 FR 50726-TN5502]),
whooping crane (Grus americana; designated experimental, not essential populations in 2001
[66 FR 33903-TN9652]), and monarch butter"y (proposed as threatened in December 2024 [89 FR 100662-TN10959]).
[the number of endangered species has doubled since 2006; well then how was this NOT included in 2006, if it has been endangered since 1985? Doesnt that major oversight invalidate the entire EIS dated 2006?!]
P. 69/242 ON PDF COUNTER (page 3-29)
In the 1980s and 1990s, Pitchers thistle was known to occur near the cooling towers but was not present at this location in 2005 (NRC 2006-TN7346).
[so PNP extirpated this local population of this endangered species?! PNP, doing its part in the mass extinction under way on Planet Earth! Great work guys and gals!]
Table 3-5 NEP = in the vicinity of the action area, this species is part of a nonessential experimental population NE = No eect
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[how can this be said of Whooping Cranes there are mere hundreds left in the entire world!]
NEP = in the vicinity of the action area, this species is part of a nonessential experimental population.
NLAA = may aect, not likely to adversely aect. NE = No eect.
[these are signs that nrc, as well as nws fws and nmfs, are themselves a severe threat to these already threatened and endangered species. Their "ippant, could not care less attitude.]
n/a = not applicable, because the NRC sta did not evaluate this species in the 2006 SEIS (NRC 2006-TN7346
[and why the hell not? So since 2006, a number of these species became threatened or even endangered and nrc didnt give a shit enough to even consider them in 2006? Isnt this an indication that nrc really sucks at this?]
(c) Species has designated critical habitat, but it does not overlap the action area (FWS 2024-TN10697). DPS = distinct population segment
[how could this possible be the site is only 432 acres in size!]
(d) Species has proposed critical habitat, but it does not overlap the action area (FWS 2024-TN10697).
[how could this possible be the site is only 432 acres in size!]
[how could this possible be? Dont karner blue butter"ies and piping plovers "y around? So its their own damn fault?!]
P. 70/242 ON PDF COUNTER (page 3-30)
In the N&S Report, Holtec presented a list of Federal and State-listed species that occur in Van Buren and Berrien Counties (Holtec 2023-TN10538).
[why not out to at least 50 miles cite Jaczko at Fuku cite Mousseau at Chornobyl and Fuku]
Because Michigan Department of Natural Resources Directors Order No. FO-224.21 (MNRC/
MDNR 2021-TN10703) provides speci"c protections for amphibians and reptiles, Appendix J, Section J.1, Table J-2 presents habitat requirements for amphibians and reptiles listed as threatened and endangered that have not been seen since 2000, as well as those that are listed as species of Special Concern.
[but they jjust said above:
The ESA of the State of Michigan (Michigan Compiled Law Part 365-TN10704) speci"es the
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States responsibility for conserving, protecting, restoring, and propagating endangered and threatened species.
So once Palisades has extirpated species on site, no need for Holtec nor NRC to worry about it any longer, even though the habitat could and should be restored, which could see those species return from afar?! Illogical. cynical. This is how the world ends, with a whimper, and perhaps also a bang]
Two State-listed species have been observed at the Palisades site: the endangered prairie vole and the threatened eastern box turtle (HDI 2024-TN10670: RAI-GEN-3, Attachment 2).
[then why doesnt that put a stop to everything? b/c ESA is a jay walking statute. Hence the mass extinction goinng on, including in MI and across US]
Eagles and Migratory Birds The 2006 SEIS (Section 2.2.6, incorporated by reference) stated that 113 bird species have been documented on the site. According to the FWS IPAC report, accessed May 21, 2024 (FWS 2024-TN10697), 21 Birds of Conservation Concern have to the potential to occur on site.
Birds of Conservation Concern are bird species not designated as federally threatened or endangered that are of the highest conservation priority for the FWS. In addition, breeding bald eagles have the potential to occur on site (breeding period December 1-August 31), as do non-breeding golden eagles (FWS 2024-TN10697). Additional information on eagles and migratory birds is provided in Appendix J, Section J.2
[again, why no STOP WORK?! Our natl symbol!]
3.6.2 Environmental Impacts from the Preparations for Resumption of Power Operations Preparations for resumption of power operations would occur over an anticipated 18-month period.
[that IS a very aggressive schedule cite NRCs own words from Jan. 14th dont mistakes get made when things are rushed?]
The applicant proposes speci"c preparation activities to prepare for resumption of operation (HDI 2024-TN10670: RAI-GEN-1). The NRC sta reviewed these activities and associated shape"les provided by the applicant and conducted an independent analysis of the terrestrial habitats to be disturbed. The activities would disturb approximately 11 ac (4.5 ha) of sparsely vegetated land outside of existing built areas (HDI 2024-TN10670: RAI-GEN-1) (Table 3-1 of this EA). Preparation activities, including those in sparsely vegetated areas, are proposed only within areas of previously disturbed soils, mostly inside existing facilities and structures.
Disturbance of a few small or narrow vegetated areas would be necessary to install new cables to the cooling towers, a security fence upgrade, and widening an access road along the southern edge of the secure area. The applicant would have to obtain relevant permits for work within CDAs and Lake Michigan waters and shorelines from Michigan EGLE and U.S. Army Corps of Engineers.
[this focus on restart of course is blind to the major construction and eco-destruction associated with 2 SMR new builds, etc.]
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The applicant would continue routine application of commercial herbicides and other pesticides as necessary to maintain the grounds. Use would be limited to ground-based application in accordance with herbicide labels at labeled rates by certi"ed applicators, as described in nonradiological reports from 2019 to 2023 (Entergy 2020-TN10708, Entergy 2021-TN10707, Entergy 2022-TN10709; HDI 2023-TN10705, HDI 2024-TN10706). Approximately 34.5 ac (14.0 ha) of the proposed land disturbance footprint would fall within mapped CDAs.
However, all of this land disturbance would take place in existing developed areas or previously disturbed lands, and all Michigan EGLE permits required for work in the CDAs would be obtained. These permits would likely require restoration of indigenous dune vegetation to any areas of disturbed dunes. Associated preparation activities (Table 3-1 of this EA) within mapped CDAs include intake pipe and crib, cable trays to cooling towers, buried pipeline repair area, security fence upgrade, access drive, and the radiological waste location within the secure area.
[herbicides and pesticides in Critical Dune Areas?! No wonder "ora and fauna have gone extinct onsite, and beyond))
The NRC sta concludes that preparations for the resumption of power operations would be NOT SIGNIFICANT on terrestrial resources because: (1) the area likely to be disturbed, approximately 11 ac (4.5 ha), lies completely within already developed or previously disturbed parts of the Palisades site; (2) these activities are unlikely to alter patterns of wildlife use and migration across the site; and (3) required permit conditions and BMPs from Federal, State, and local agencies will minimize impacts to terrestrial resources. As noted in its biological evaluation in Appendix J, Section J.7, Table J-5, the NRC sta has determined that impacts to federally listed terrestrial species (Table 3-5 of this EA) would be no eect or may aect, not likely to adversely aect.
[weve already allowed it to be trashed since 1967; we are "ne with it continuing to be trashed till 2051 or beyond (restart), and 2110 or beyond (2030 + 80)/SMRs]
P. 72/242 ON PDF COUNTER (page 3-32)
The NRC sta analyzed in detail below three terrestrial resource issues that were not analyzed previously or could be dierent from current conditions: (1) exposure of terrestrial organisms to radionuclides (not analyzed in 2006 SEIS), (2) non-cooling system impacts on terrestrial resources (not analyzed in 2006 SEIS, potentially dierent from non-operating conditions), and (3) cooling tower impacts on terrestrial plants (potentially dierent from current non-operating conditions).
[WHY were they not considered in 2006? So the 2006 SEIS was incomplete, woefully inadequate. The 20-year license extension should be invalidated!]
Exposure of Terrestrial Organisms to Radionuclides The 2006 SEIS for Palisades (NRC 2006-TN7346) did not address exposure of terrestrial organisms to radionuclides because the 1996 LR GEIS (NRC 1996-TN288) did not include this issue from routine operations as an issue to analyze.
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[so the 1996 GEIS should also be invalidated. Thats a lot of license extensions nulli"ed!]
Palisades REMP has been ongoing since 1971 and is described in the 2006 SEIS (NRC 2006-TN7346). The NRC sta reviewed Holtecs analysis of this issue (Holtec 2023-TN10538) and reviewed Palisades Annual Radiological Environmental Operating Reports from 2019 to 2023 (Entergy 2020-TN10687, Entergy 2021-TN10686, Entergy 2022-TN10685; HDI 2023-TN10684, HDI 2024-TN10771). No measurable levels of radiation above baseline levels attributable to operations of Palisades were found through routine monitoring conducted in the Palisades vicinity from 2019 to 2022. Additionally, no measurable levels of radiation above baseline levels were detected during 2023 monitoring when the reactor was in decommissioning status. The NRC sta has concluded that exposure to radionuclides on terrestrial organisms would be NOT SIGNIFICANT.
[so all the radiation releases admitted to in the annual emissions reports simply, and magically, disappeared into nothingness? No "ora, fauna, nor humans were harmed? All the cancer in humans must have been caused by something else? All extirpations of species on the palisades site must have been caused some other way?]
P. 73/242 ON PDF COUNTER (page 3-33)
The NRC sta has concluded that non-system cooling impacts on terrestrial resources would be NOT SIGNIFICANT.
[another radiogenic mutation? Words out of order]
Cooling Tower Impacts on Terrestrial Plants As summarized in meteorology and air quality (Section 3.3.1 of this EA) and detailed in Rochow 1978-TN10666, Palisades initial cooling tower operations resulted in loss of forest vegetation, severe icing, and signs of chemically induced vegetation injury associated with sulfate deposition from the towers. Most vegetation damage occurred within 160 ft (50 m) of the towers, with trees and shrubs aected. As detailed in the 1996 LR GEIS (NRC 1996-TN288:
Section 4.3.5.1), woody species damage resulted from the unique Palisades topography, unusual operating and weather conditions, and use of sulfuric acid as a biocide (which was discontinued before the 2006 SEIS). Rochow 1978-TN10666 reported the tower drift design rate at the time of damage to be between 0.005 and 0.2 percent. The 2006 SEIS (NRC 2006-TN7346: pp. 4-10 through 4-11) rated the impacts of Palisades cooling tower operations on vegetation (crops, ornamental vegetation, and native plants) as SMALL. Both rows of cooling towers were replaced, in 2012 and 2017, respectively, within the same footprint (Holtec 2023-TN10538; Google Earth 2024-TN10690). The replacement towers have drift eliminators that have a guaranteed drift rate of not to exceed 0.001 percent of the circulating water "ow rate (HDI 2024-TN10670: RAI-TE-1).
[this severe damage was to Critical Dune Areas and their fragile ecosystems and habitats, including for threatened and endangered species, pushing them closure to extirpation, at least on the PNP site. Why is this not taken seriously as a cumulative impact?]
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Field surveys of potentially suitable dune habitat conducted by Holtec in 2024 identi"ed the only Pitchers thistle location onsite as occurring in a forest clearing situated approximately 1,000 ft (300 m) east (inland) of the cooling towers (HDI 2024-TN10670: RAI-SE-1). No information is available to NRC sta on the sensitivity of Pitchers thistle to cooling tower drift.
Considering the physical stresses inherent in surviving in dune habitat, it is possible that cooling tower drift could contribute cumulatively to adverse eects on a Pitchers thistle population. However, because the mechanical draft cooling towers are equipped with drift eliminators and are separated from the Pitchers thistle population by approximately 1,000 ft (300 m) of deciduous forest vegetation, it is reasonable to expect that noticeable drift is unlikely to reach the population. If substantially potent drift were to reach the Pitchers thistle populations onsite, the eects would likely be "rst visible on deciduous tree foliage at the edge of the cooling towers, giving nuclear power plant managers time to take corrective action. The NRC sta conclude that cooling tower impacts to Pitchers thistle to be may aect, not likely to adversely aect.
[well, those managers would have to care, and to notice very big ifs!]
P. 74/242 ON PDF COUNTER (page 3-34)
The NRC sta conclude that resumption of cooling tower operations would be less than those determined to be SMALL in 2006. This is based on: the changes in cooling tower operations from the initial conditions that led to vegetation damage; the replacement of both towers within the last 12 years; replacement tower drift rate of 0.001 percent; and a determination of may aect, not likely to adversely aect for Pitchers thistle for cooling tower operations. Therefore, the NRC sta concludes that the impact from resumption of cooling tower operations would be NOT SIGNIFICANT.
[what about the minor modi"cations Holtec admitted to on 3/20/23? They are not even mentioned here. Left hand doesnt know what right hand is doing at nrc!]
3.6.4 Cumulative Eects Appendix G, Table G-1 of this EA identi"es past, present, and reasonably foreseeable projects that could cumulatively contribute to the environmental eects of the proposed Federal actions. The projects in the vicinity of Palisades that may aect terrestrial ecology include future onsite construction (a new spent fuel pad and new SMRs); potential SLR of Palisades; continued operation of energy generation facilities; construction, upgrade, and rebuilding of power transmission infrastructure; continued operation of existing mines; residential, commercial, and industrial development; continued operation of water supply and wastewater treatment facilities; cleanup of contaminated sites; continued operation and upgrade of transportation infrastructure; and continued recreational activities. The general characteristics of the terrestrial habitats and ecological resources in the landscape on and surrounding the Palisades site would not be noticeably altered by the projects. The resumption of power operations would result in only small areas of terrestrial habitat disturbance situated in previously developed areas of the site. It is also anticipated that SMR development would mostly take place within previously developed areas of the site and aect only narrow or small areas of naturally vegetated terrestrial habitat adjoining areas of previous
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development, without noticeably intruding into areas of intact terrestrial habitat in relatively undeveloped areas of the site. Therefore, the NRC sta determined that the incremental eects of the proposed Federal actions related to terrestrial ecology when added to the eects of other past, present, and reasonably foreseeable projects would not have signi"cant cumulative eects.
[ this is very hard to believe PNPs nuclear megawattage would be nearly DOUBLED!]
P. 74/242 ON PDF COUNTER (page 3-34) 3.7 Aquatic Ecology
[see Lake MI related comments I made above]
1972 FES (AEC 1972-TN10603): Section V.C.1.a., Sources of Potential Biological Damage; Table V-1, Examples of Number and Length of Fish Counted Daily at the Intake Screens from January 23, 1972 - February 22, 1972; Appendix V-2, Outline Map of North America Showing the Southern Limit of Distribution of Lake White"sh
[were they killed? rescued? Left to die? How many "sh and other aquatic organisms has palisades killed since 1967?! incorporate by reference Licensed To Kill]
P. 75/242 ON PDF COUNTER (page 3-35) 3.7.1.1 Site and Vicinity Palisades is located along the southeastern shore of Lake Michigans main basin, which provides the source and receiving body for the plants cooling-water system. Lake Michigans main basin, which is separated into a northern and southern basin, contains cold, clear, nutrient-poor (oligotrophic) water with water depths ranging from 50 ft (15 m) at 1 mi (1.6 km) oshore, to a maximum depth of 923 ft (281 m), and average depths of 279 ft (85 m) (Michigan Sea Grant 2024-TN10710).
[compare those depths to the design criteria for HLRW shipping containers! What if a barge went o course and sank in such deep waters?! How close do the set courses come to such deep waters to begin with?]
Water moves slowly along the southeastern side of the lake in a generally northern direction toward the Strait of Mackinac to Lake Huron (Michigan Sea Grant 2024-TN10710; NOAA Undated-TN10711).
[well then NRCs and Holtecs dilution is the solution approach is suspect slow motion means slow dilution persistent concentration compare Manganos mid-1990s EPA data point for tritium o South Haven]
3.7.1.1 Site and Vicinity
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Palisades is located along the southeastern shore of Lake Michigans main basin, which provides the source and receiving body for the plants cooling-water system. Lake Michigans main basin, which is separated into a northern and southern basin, contains cold, clear, nutrient-poor (oligotrophic) water with water depths ranging from 50 ft (15 m) at 1 mi (1.6 km) oshore, to a maximum depth of 923 ft (281 m), and average depths of 279 ft (85 m) (Michigan Sea Grant 2024-TN10710). Water moves slowly along the southeastern side of the lake in a generally northern direction toward the Strait of Mackinac to Lake Huron (Michigan Sea Grant 2024-TN10710; NOAA Undated-TN10711). Surface water temperatures in Lake Michigan vary from a low of 36.9°F (2.7°C) in February to a high of 70.5°F (21.4°C) in August (NOAA 2024-TN10714). A 2021 study by NOAA revealed a warming trend in surface water temperatures based on a single location, which was hypothesized to be due to climate change (Anderson et al. 2021-TN10715). Using a 30-year dataset, NOAA found that the winter cooling season in the deep waters of the lake is shortening (less than 100 days) and the summer warming season is lengthening (greater than 200 days) which could lead to permanent changes in the lakes seasonal mixing patterns and disrupt the food web (Anderson et al. 2021-TN10715). The aquatic biological communities of Lake Michigan, including plankton, macrophytes, benthic invertebrates, and "sh, are described in detail in Appendix J, Section J.4 to this EA.
[related to Arnie's testimony re: the Component Cooling Water upgrade"]
3.7.1.2 Important Species and Habitats
[what species and habitats are NOT important?! What an attitude!]
3.7.1.2 Important Species and Habitats The Michigan Department of Natural Resources (MDNR) is responsible for "sheries management in Lake Michigan and co-manages some commercial and recreational "sheries from approximately Grand Haven, Michigan northward with Indian Tribes. The co-managed "shing areas end approximately 50 mi (80 km) north of Palisades and are not discussed further (MDNR 2024-TN10762). The aquatic region of the action area (as de"ned above in Section 3.6.1.2) encompasses the area of Lake Michigan in"uenced by the intake and discharge systems. These systems are described in the 2006 SEIS (NRC 2006-TN7346). There are no federally protected aquatic species, essential "sh habitat, or national marine sanctuaries located within action area (FWS 2024-TN10697; NMFS 2024-TN10304; NOAA Undated-TN10727). Additional information can be found in Appendix J, Sections J.4 and J.5 of this EA.
[this doesnt make sense. Grand haven IS 50 miles north of palisades. Reading this makes Lake Michigan sound like the paragon of health. But it is not. They seem to be whitewashing serious problems in lake michigan. And oh by the way, even routine operations at PNP are harmful, let alone a catastrophe.]
[and shouldnt the federal govt be more than "ip about Indigenous treaty rights to "sheries?!]
arent treaties the highest law of the land, equal in stature to the constitution itself? And yet nrc is so "ippant!]
[how is this not a violation of treaty rights, above and below, per Ians admonitions to americans?]
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Commercially Important Fisheries The only commercially "shed species in Lake Michigan since 2022 is the lake white"sh (Coregonus clupeaformis) although over the last "ve years small amounts of burbot (Lota lota),
chub (Squalius cephalus), round white"sh (Prosopium cylindraceum), smelt (Osmeridae), and sucker (Catostomidae) were also commercially harvested (MDNR 2024-TN10728; Michigan Sea Grant 2024-TN10729). Lake white"sh is a benthic cool water "sh that primarily feeds on zooplankton and Diporeia (Michigan Sea Grant 2024-TN10730). White"sh spawn in early winter in shallow rocky or sandy bottom lake waters less than 25 ft (7.6 m) deep, the young hatch in the spring and leave for deeper and cooler waters by early summer where they live in schools at P. 76/242 ON PDF COUNTER (page 3-36) depths of up to 200 ft (61 m) (MDNR 2024-TN10731). The lake white"sh population has declined rapidly in Lake Michigan over the past 15-20 years, with slow growth and poor body condition that correlates with the loss of their primary food source, Diporeia, to invasive Dreissena mussels (MEGLE 2022-TN10732). Since the early 2000s, white"sh populations have also experienced poor recruitment, the process of young "sh making it to the adult stage, which is thought to be a result of changes in water temperature, water levels, currents, and ice cover due to changing climate conditions (MEGLE 2022-TN10732).
[so all is NOT well with L. MI ecology! PNP contributes to the harm!]
Recreationally Important Fisheries Recreational "sheries in the Michigan portion of Lake Michigan are also regulated by MDNR.
Popular sport "sh include yellow perch (Perca "avescens), walleye (Sander vitreus), largemouth (Micropterus salmoides) and smallmouth bass (Micropterus dolomieu), sun"sh (Centrarchidae),
crappie (Pomoxis spp.), rock bass (Ambloplites rupestris), lake trout (Salvelinus namaycush),
and salmon (chinook, coho, steelhead; Oncorhynchus spp.). Lake trout is an important species that contributes to a multimillion-dollar Lake Michigan sport "shery. The Michigan United Conservation Clubs reported in 2019 that recreational "shing in Michigan, not just in Lake Michigan, generates $2.3 billion in economic activity (MUCC 2019-TN10733).
[all put at risk by PNP. No mention above about Dinosaur "sh sturgeon, important to Indiginous Nations]
A small number of these have had negative impacts to the ecosystem and "sheries including sea lamprey (Petromyzon marinus), alewife (Alosa Pseudoharengus), zebra mussels (Dreissena polymorpha) and quagga mussels (Dreissena rostriformis bugensis), round goby (Apollonia melanostomus), and the spiny water"ea (Bythotrephes longimanus) (GLFC 2024-TN10736). Invasive species of concern in Michigan include Asian clam (Corbicula "uminea),
grass carp (Ctenopharyngodon idella), Eurasian rue (Gymnocephalus cernuus), hydrilla (Hydrilla verticillata), Japanese/Oriental weather"sh (Misgurnus anguillicaudatus), New Zealand
[no mentino of asian carp. It would seem, given white "sh section above, that some invasive species have had MAJOR impact!]
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P. 77/242 ON PDF COUNTER (page 3-37)
The primary invasive species of concern related to Palisades operations is biofouling of the cooling-water intake system by invasive bivalves, such as zebra mussels and quagga mussels.
The spring 2024 intake crib inspection and cleaning reported 100 percent coverage of the bars along the sides of the intake crib by zebra mussels roughly 1.5 in. (3.8 cm) thick (HDI 2024-TN10843: RCI-AE-4a). Divers also found and cleaned out debris, including zebra mussels, just west of the traveling screens. These invasive mussels are controlled using biocides and cleaned out of the intake by divers annually; biocide use is regulated by Michigan EGLE as part of the discharge authorizations in permit no. MI0001457 under Section A, Part I (MDEQ 2014-TN10665).
[PNP use of biocides is a major eco harm; and what about PNP contributing to invasive species such as thermal wastewater driving away native "sh, attracting invasives? No mention of this dynamic?]
The NRC sta concludes that, based on the current SWPPP, the existing stormwater system, and the small area of potential surface disturbance or new impervious surfaces, the impacts to onsite streams from the proposed activities would be minimal.
[what? New construction just from restart, such as new pad; and what about SMRs?! Illegal segmentation!]
Holtec plans no changes to the water intake system from Lake Michigan, relative to the previously operating plant.
[arnie has questioned the logic of CCW v cooling towers]
3.7.2.2 Important Aquatic Species and Habitats
[what ARENT?!]
Four State-listed "sh species have occurred in the vicinity of Palisades, although the lake herring and shortjaw cisco have not been observed in 30 years (Table J-4 of this EA). The starheaded topminnow and spotted gar are expected to still be in the vicinity. The spotted gar is tolerant of warm waters and low dissolved oxygen. Both species can be found in shallow waters or near the surface and both spawn in shallow water, although the gar prefers heavily vegetated areas and the topminnow prefers gravel. Because of the applicants eorts to control sedimentation and the oshore location of the intake, the potential for impacts to these "sh species from activities at the site would be NOT SIGNIFICANT. There are also four State-listed
[march to extinction, without so much as a shrug]
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P. 78/242 ON PDF COUNTER (page 3-38) mussels, the slippershell, creek heelsplitter, "utedshell, and round pigtoe, that may occur within the vicinity of Palisades (Table J-4 of this EA). Holtec has not identi"ed any State-listed species in the intake or discharge systems during annual monitoring (HDI 2024-TN10843: RCI-AE-4a).
Therefore, the potential for impact to State-listed mussel species is expected to be NOT SIGNIFICANT.
[no observations reported? Did holtec even look?!]
3.7.3 Environmental Impacts from the Resumption of Power Operations The impacts from resumption of operation of Palisades would be similar to those described in the 2006 SEIS (NRC 2006-TN7346), which is incorporated by reference. In Section 3.3.1 of the N&S Report, the applicant states that no additional aquatic studies have been conducted and that the descriptions and discussions of aquatic resources in the 2006 SEIS remain valid (Holtec 2023-TN10538). The NRC sta has not identi"ed any new and signi"cant information during its independent review of the N&S Report (Holtec 2023-TN10538), the 2024 site visit, the scoping process for this EA, and the NRC stas evaluation of other available information
[if no addl studies have been done, how can holtec say with con"dence that the 2006 studies remain valid? How can nrc say this? Irgnorance is bliss? What a mockery of nepa! Hard look?
Hardly a look!]
While most of the water used for cooling would be returned to the lake, the cooling system would lose approximately 12,000 gpm or 0.0006 percent of the total volume of water in Lake Michigan to evaporation from the cooling towers each year.
[still, vapor that blows out of basin before condensing back into liquid is lost to the great lakes]
Impingement and Entrainment of Aquatic Organisms If approved and power operations resume, the resumed water intake would impinge and entrain aquatic organisms from Lake Michigan. Section 2.1 of this EA and the 2006 SEIS (NRC 2006-TN7346) describe the Palisades cooling and auxiliary water systems in detail. Smaller organisms, such as "sh eggs and larvae, can be entrained and pass through the system, where they are subjected to mechanical, thermal, and toxic stresses before the water is discharged back into the lake. Impinged organisms are collected at the trash racks or traveling screens and disposed as solid waste.
[compare to Licensed to Kill]
[the Ludington stored pumped water facility shoiuld be included in Cum Impacts as Fish Killer Monster built to accommodate nuclear generation at night]
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P. 79/242 ON PDF COUNTER (page 3-39)
Cooling-water intake from Lake Michigan to Palisades are authorized under NPDES permit no.
MI0001457. The current permit was issued in 2014 and is being operated under an administrative extension (MDEQ 2014-TN10665). The new draft permit was published in 2023 and a "nal permit is expected prior to the resumption of power operations (MEGLE 2023-TN10739). As part of the draft permit, Michigan EGLE reviewed the cooling-water intake structures (CWIS) and determined that they comply with the best technology available (BTA) standards for impingement mortality and entrainment to minimize adverse environmental impact in accordance with 40 CFR Subpart J under Section 316(b) of the CWA. The chosen method of compliance for impingement is 40 CFR Part 125.94(c)(1) (TN254)closed-cycle recirculating system. In addition, the Palisades CWIS is BTA as speci"ed by operating an existing oshore velocity crib under 40 CFR Part 125.94(c)(4).
[compare to MgCl plant in Tooele Valley, UT in chip wards Canaries on the Rim. BTA b/c it was a unique facility. And highly polluting. But BTA. So nuc industry could do better. But theyve decided THIS is good enough: BTA. Available perhaps, but not achievable!]
The impacts on impingement from the resumption of power operations of Palisades would be similar to those described in the 1972 FES, which analyzed impingement potential for principal "sh species during interim operations of Palisades in 1972 (AEC 1972-TN10603), and which is incorporated by reference. This issue was not further analyzed in the 2006 SEIS because it was considered a Category 1 issue. For the most part, "sh and free-swimming organisms would avoid impingement because the intake crib is located in the water column, about 6 ft (2 m) above the bottom, 3,300 ft (1,005 m) from the shoreline, and the intake velocity is only approximately 0.1 fps. The intake is well sited to avoid most "shes preferred habitat and distribution in the water column, apart from rainbow smelt, alewife, and bloater. During interim operations during start-up in 1972, the primary impingement mortality was of sculpins in January and February (AEC 1972-TN10603). Enercon Services, Inc. conducted an impingement estimate in 2000, estimating the impingement of 863 "sh, which included yellow perches, alewives, and spottail shiners, from July to November (Enercon/Normandeau 2018-TN10740).
The location of the intake and the low intake water velocity would help prevent any large "sh from being sucked into the intake crib and then the intake pipe. Small "sh and other aquatic organisms that are unable to swim against the 0.1 fps current at the intake would be drawn inside and impinged on the traveling screens and trash racks, or if small enough entrained. EPA data shows that 96 percent of studied "sh can avoid an intake structure when the intake velocity is 0.5 fps or less so, hence the resulting impingement is expected to be a relatively small amount in relation to nearby populations within the lake (EPA 2014-TN10834).
[but, species death by a thousand cuts, or impingements]
P. 80/242 ON PDF COUNTER (page 3-40)
Thermal Impacts of Discharges In the 2006 SEIS (NRC 2006-TN7346), the NRC sta discussed "eld surveys to assess the thermal plume after the MDCTs were installed, which is incorporated in the EA by reference. At its largest in the winter, the 3°F (1.67°C) isotherm encompassed approximately 286 ac (116 ha)
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of water surface and seldom extended below a depth of 5 ft (1.5 m) with discharge temperatures of 25 to 34°F (-3.9 to 1.1°C), except in peak winter when they reached 44°F (6.7°C) above the ambient lake temperature (NRC 2006-TN7346). In its current decommissioning state, Palisades is averaging a discharge temperature of approximately 2°F (1.1°C) above ambient water temperatures (MEGLE 2024-TN10741). The NDPES permit no.
MI0001457 limits the thermal discharge from Palisades to 2,100 MBtu/hr, with a daily monitoring requirement of the temperature at the intake and discharge (MDEQ 2014-TN10665; MEGLE 2023-TN10739). Based on the discharge limits of the NPDES permit, the NRC sta concludes that thermal impacts on aquatic organisms would be NOT SIGNIFICANT for the proposed preparation for the resumption of power operations.
Chemical Impacts from Discharges:
The "rst chemical issue concerns the potential eects of nonradiological contaminants on aquatic organisms that could occur from nuclear power plant operations. This issue initially became a concern because some nuclear power plants used heavy metals in condenser tubing that could leach from the tubing and expose aquatic organisms to these contaminants (NRC 2024-TN10161). Because aquatic organisms can bioaccumulate heavy metals, even when exposed at low levels, this can be toxic to "sh and other animals that consume contaminated organisms. However, Palisades has stainless steel condenser tubes that do not leach metals to the cooling-water discharge (Holtec 2023-TN10538). The NRC sta veri"ed that the issue associated with heavy metals leaching from condenser tubing, does not apply to Palisades.
[will that continue to be the case, as holtec makes changes, as to CCW?]
For certain plant equipment and systems Holtec will use, Michigan EGLE approved chemical additives to control pH, scale, corrosion, and biofouling. The 2006 SEIS (NRC 2006-TN7346) and the Environmental New and Signi"cant Review (Holtec 2023-TN10538) describe the P. 81/242 ON PDF COUNTER (page 3-41)
[thats a huge thermal impact!]
chemicals used and the discharge limits under the NPDES permit no. MI0001457 and are incorporated by reference. Section 3.4 of this EA addresses the discharge of metals in cooling system euent. As explained in that section, Palisades NPDES permit establishes allowable levels of metals including copper, silver, zinc, nickel, and lead (MDEQ 2014-TN10665; MEGLE 2023-TN10739). While the proposed preparation for the resumption of power operations would mean restarting chemical discharges from the CWIS into Lake Michigan, the chemical concentrations at the outfall are regulated by the NPDES permit. Also, no impacts to the aquatic environment from these chemicals were observed when Palisades was operating under its provisional license (1971-1991), full-term operating license (1991-2007), or its license renewal (2007-2022, expires 2031).
[isnt the hydrazine limit shockingly high? Get hold of list of toxins and describe their hazard]
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The other chemical issue concerns the potential impacts on aquatic organisms from exposure to radionuclides from routine radiological euent releases. The NRC requires nuclear power plants to maintain a REMP as per requirements speci"ed in 10 CFR Part 50, Appendix I, 10 CFR Part 20-TN283, and 10 CFR Part 72-TN4884, and through plant-speci"c technical speci"cations. These collectively require that licensees establish and implement a REMP to obtain data on measurable levels of radiation and radioactive material. The 2021 and 2022 REMP report did not show any measurable levels of radiation, above baseline environmental levels, detected in the vicinity of Palisades. If power operations resume, Palisades would be required to remain in compliance with NRC radiological euent limits and reimplement the REMP to ensure aquatic organisms exposure to any radionuclides are within acceptable limits.
[what does this even mean? Sounds like a whitewash/greenwash. Compare euent reports to this statement. How can they mask releases behind background? Compare 650 mR/yr to 180 or 150, per Arjun. Are they playing fast and loose again?!]
3.7.3.2 Important Aquatic Species and Habitats
[which ARE NOT?!]
As noted in Section 3.7.2.2, four State-listed "sh species have occurred in the vicinity of Palisades, although the lake herring and shortjaw cisco have not been observed in 30 years (Table J-4 of this EA).
[so did Palisades contribute to their demise?]
P. 82/242 ON PDF COUNTER (page 3-42)
The ISFSI expansion would occur in an area that is already concrete and not aect the surface water input.
[well, concrete or pavement means run o; contaminants, be they toxic chemical or radioactive, would enter that run o, entering surface waters, including on-site wetlands, streams, and lake michigan, as well as groundwater, once the surface run o enters and descends down through soil]
If the planned installation of multiple SMRs are approved, it will be subject to regulation by the NRC and the intake and discharge of any additional water from Lake Michigan will be subject to regulation under the CWA. Therefore, the NRC sta determined that the incremental eects of the proposed Federal actions related to aquatic ecology when added to the eects of other past, present, and reasonably foreseeable projects would not have signi"cant cumulative eects.
[holtec proposes nearly doubling Palisades nuclear mega-wattage and nrc shrugs and says eectively NO impact?!]
The NRC sta identi"ed, con"rmed, and validated only minor changes in the known aected environment as part of this EA.
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[per above, NRC is essentially entirely ignoring the 2 SMR-300s, the new cask pad, etc.
ignoring major impacts, cumulative eects, etc. So sue us. -NRC]
the APE analysis also includes a 1 mi (1.6 km) buer, which allows the NRC sta to evaluate the potential impacts to historic properties located nearby but outside of the Palisades site boundary.
[what about a 50-mile buer? Site jaczko at fuku. b/c if PNP melts down, impacts such as radioactive contamination could fallout at least that far. Cite Chornobyl for impacts 1,000 miles in all directions, or more Arctic Circle of Scandinavia (Lappland), Scotland, Indian Ocean, etc.)
P. 83/242 ON PDF COUNTER (page 3-43) 3.8.1.2 Cultural Background The 2006 SEIS (NRC 2006-TN7346) describes the long-term cultural history and chronology for this portion of the Great Lakes and southwest Michigan, speci"cally because Indigenous peoples lived in this region for at least the past 10,000 years.
[well, they still do. Use of the past tense is inappropriate. Not vanishing.]
The NRC sta characterized the cultural chronology which included a Paleoindian or First Peoples period between 10,000-8,000 Before Common Era (BCE), an Archaic period between 8,000-1,000 BCE, a Woodland period between 1,000 BCE-1050 Common Era (CE),
a Mississippian period between 1050-1600 CE, and a Contact/Post-Contact period from 1600 CE-present (NRC 2006-TN7346).
[yes, the French and LaSalle showed up by 1677 per historic sign in St. Joe. War of 1812 American POWs held near airport Titus Bronson by 1820s? Gun Lake Band moved to Delton Trail of Death = 1840] when was the founding of Chicago, acc. To current mayor?
Historic importance of Covert Twp. In terms of African American history Chicago massacre during War of 1812 Battle and Massacre at the River Raisin, 1813]
P. 84/242 ON PDF COUNTER (page 3-44) a built-environment survey of the Palisades facilities conducted by an architectural historian.
[per way above, and per email sent to Gents, what about demanding PNP be declared a Natl Historic Site anything to trip them up, slow them down]
Historic properties are de"ned as cultural resources which are eligible or listed on the National Register of Historic Places (NRHP) (NPS 2024-TN10772).
[the whole site quali"es designed in mid 1960s, ground broken in 1967 it is 60 years old, 1/4th as old as our country!]
Historic properties are de"ned as cultural resources which are eligible or listed on the National Register of Historic Places (NRHP) (NPS 2024-TN10772). Results from the archaeological
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survey indicated that there are three archaeological sites located at Palisades (20VA92, 20VA93 and 20VA94), but none of these sites are eligible or potentially eligible for the NRHP (SEARCH 2024-TN10846; HDI 2024-TN10669). The Michigan SHPO concurred with these determinations by letter dated September 18, 2024 (MI SHPO 2024-TN10850). All other P. 85/242 ON PDF COUNTER (page 3-45) regional site information within an approximate 1 mi (1.6 km) radius of Palisades remains the same as in the 2006 SEIS (NRC 2006-TN7346). Results from the architectural survey recommended that only the containment building was potentially eligible for NRHP listing (HDI 2024-TN10669; Theriot and Travisano 2024-TN10847; MI SHPO 2024-TN10844; MI SHPO 2024-TN10873), but after further evaluation and consultation, the Michigan SHPO determined that the containment building cannot be considered separately from the remaining parts of the Palisades facility and does not rise to the level of signi"cance required for listing in the NRHP under Criteria C for Architecture/Engineering by letter dated November 6, 2024 (MI SHPO 2024-TN10844). The NRC sta transmitted the archaeological report to the federally recognized Indian Tribes (NRC 2024-TN11054); no comments were received.
[no, the entire PNP a monument to human folly 50+ years of extreme risk taking, the entire Great Lakes at stake]
3.8.2 Environmental Impacts from the Preparations for Resumption of Power Operations Section 3.1 of this EA describes the activities Holtec is completing as part of the preparations for the resumption of power operations. Several of these activities have expected ground disturbance in and around the Palisades site. These ground-disturbing activities include the construction of a new access road, removal and construction of a new security fence, a re-cabling project between the reactor facility and the cooling towers, demolition of two current radioactive storage facilities, and construction of a new radioactive waste storage facility and a new digital storage facility (see Table 3-1 of this EA). These activities, as shown in Figure 3-1 of this EA, are all occurring within the western portion of the Palisades site, with the only exception being the construction of the digital storage facility.
[potential harm to Indigenous sites]
The western portion of Palisades was considerably modi"ed through ground disturbance, sand dune remediation, and shoreline modi"cation during the original construction of Palisades in the late-1960s and early 1970s (Appendix I to this EA) (SEARCH 2024-TN10846). Although no archaeological survey (e.g., shovel testing) occurred in the critical dune environment within the western portion of Palisades, if future ground-disturbing activities occur within this area, then a Michigan State critical dune permit would be required.
[remidiation? destruction!
Any Indigenous sites in that area were destroyed way back then, when no one really cared.]
P. 86/242 ON PDF COUNTER (page 3-46)
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Holtec will have procedures to address inadvertent discoveries and noti"cation protocols.
[so we are just supposed to trutn them? Who will enforce compliance? Talk is cheap dead letter promise?]
3.8.3 Environmental Impacts from the Resumption of Power Operations In 2006, the previous Palisades operator (Entergy) had existing historic and cultural resources procedures (NMC 2006-TN10743), which provided a screening tool and mechanism to protect archaeological sites and other resources that may be inadvertently encountered during day-to-day operations (NRC 2006-TN7346).
[not true entergy didnt take over till 2007]
The Michigan SHPO concurred with NRCs determination of no historic properties are aected as part of the 2006 SEIS (NRC 2006-TN7346), because while Palisades lacked archaeological and architectural surveys, Entergy had procedures in place to protect unidenti"ed cultural resources.
[nobody really cares enough to even require knowing a plan for a plan, a promise for a promise]
In accordance with 36 CFR 800.4 (TN513), this undertaking will have no historic properties aected as no historic properties have been identi"ed, and Holtec will have procedures to address inadvertent discoveries and noti"cation protocols. Additionally, no historic and cultural resources have been identi"ed within the APE. Therefore, the NRC sta determined that impacts to historic and cultural resources related to the activities associated with resumption of power operations would be NOT SIGNIFICANT.
[b/c no one bothered to look]
3.9 Socioeconomics
[why, if PNP has been a thang since the mid 1960s, is poverty so prevalent in the host township, more than a half centry later? PNP not sharing the wealth? Seems like. Well thats not very nice to your host! Recall 2013 annual perf review mtg where Tony Vitale bragged about
$100,000 in charitable contributions. ONLY?!]
P. 87/242 ON PDF COUNTER (page 3-47)
The following tables present demographic, income, and housing information about the two-county region of in"uence (ROI) from the Census Bureau. Based on the information presented in Table 3-6, racial and ethnic diversity in the ROI is similar to the State of Michigan as a whole.
[BULLSHIT Covert Twp. Has a large Af Am pop! Also a large below the poverty line pop]
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Table 3-6 Percent Black or African American race alone MI 13.5%
[Covert around 36% NRC is intentionally ignoring this MoFos Compare to NRCs EJ violations at Holtec NM]
Percent American Indian and Alaska Native race alone
[only b/c Native Americans were driven out of these counties by force and even genocide!]
[yes but nrcs scope is too narrow they dont want to know they dont want readers of the EA to know Gun Lake in Barry Co. (?), Pokagon in Cass Co. (?)!]
[what about threat to Native Americans out to a vast distance aka the Great Lakes?!]
Percent Hispanic, Latino, or Spanish Ethnicity of Any Race of total population Percent Hispanic, Latino, or Spanish Ethnicity of Any Race of total population Van Buren Co. 11.9%
[more than twice State of MIs 5.6% re"ection of agricultural workforce history migrants some have settled over decades address ag in VB Co.]
[why are other impacted counties, like Kalamaoo downwind, not mentioned?!]
[why is Benton Harbor in Berrien Co. not mentioned?]
P. 88/242 ON PDF COUNTER (page 3-48)
Table 3-7 Estimated Income Information for the Socioeconomic Region of In"uence of Palisades Nuclear Plant, 2018-2022, 5-Year Estimates
[nrc is hiding pockets of signi"cant af am poverty in covert and benton harbor behind these county "gures in this way, nrc commits its very own EJ violations]
Table 3-8 Housing in the Region of In"uence of Palisades Nuclear Plant, 2018-2022, 5-Year Estimate
[mention carters Habitat for Humanity work in Benton Harbor lead poisoning via water supply in Benton Harbor theft of Jean Klock Park for golf course and gated community]
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P. 89/242 ON PDF COUNTER (page 3-49)
In addition, the resumption of operations at Palisades would increase the amount of tax money paid to Van Buren County and the City of Benton Harbor. Annual property tax payments for Palisades paid to Van Buren County (with a small portion to the City of Benton Harbor) averaged $10 million per year prior to reactor shutdown and the commencement of decommissioning. Annual property tax payments during Palisades decommissioning decreased over a 6-year period to approximately $1.6 million. Annual property tax payments could increase up to $15.6 million in 2025 due to power plant modi"cations and improvements that could increase the nuclear plants valuation. However, Holtec expects property tax payments to return to pre-decommissioning levels (approximately $10 million per year) starting in 2027 (Holtec 2023-TN10538).
[why would holtec pay property taxes to the City of Benton Harbor, wjhich is located in Berrien Co., right? Do they actually mean Covet Twp? If they have confused Benton Harbor and Covert Twp, this is a case of all Black people look the same to me!!!!}
Other socioeconomic impacts from nuclear power plant operations include eects on community services, transportation (e.g., trac volumes), and the economic impacts of expenditures for goods and services including labor. These impacts are described in the 2006 SEIS (NRC 2006-TN7346), and NRC sta do not expect socioeconomic impacts to noticeably dier after the resumption of power operations. Based on this information, including information from Holtec (Holtec 2023-TN10538), the socioeconomic impacts from the proposed Federal actions and the resumption of reactor power operations would be similar to those described in the 2006 SEIS and would be NOT SIGNIFICANT.
[of course its signi"cant. PNP has a company twp, county, multi-county area (Van Buren, Berrien, and Allegan), and state. All have been bought o. It aint good. But it is.]
3.10 Environmental Justice P. 90/242 ON PDF COUNTER (page 3-50)
Minority Populations: Minority populations are identi"ed when (1) the minority population of an aected area exceeds 50 percent or (2) the minority population percentage of the aected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis. Meaningfully greater was used in this analysis to identify minority populations within a 50 mi (80 km) radius.
Low-income Population: Low-income populations in an aected area are identi"ed with the annual statistical poverty thresholds from the Census Bureaus Current Population Reports, Series P60, on Income and Poverty. Meaningfully greater was used in this analysis to identify low-income populations within a 50 mi (80 km) radius.
[compare Covert and Benton Harbor to VB Co. and Berrien Co., State of MI, and USA. again, NRC is hiding truth by narrowing scope. Lies, Damn Lies, and Statistics. If NRC cant "nd EJ violations/impacts with Holtecs CISF in NM, how can we expect them to see it at PNP?!]
Such eects may include biological, cultural, economic, or social impacts.
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[mention Coverts special Af Am cultural heritage. Pokagon and Gun Lake are within 50 miles con"rm. Also mention Benton Harbor]
3.10.1 Aected Environment For this review, the EJ aected environment is a 50 mi (80 km) radius of the Palisades site, P. 91/242 ON PDF COUNTER (page 3-51)
This radius encompasses nine counties in Michigan: Allegan, Barry, Berrien, Cass, Kalamazoo, Kent, Ottawa, St. Joseph and Van Buren, and three counties in northern Indiana: Elkhart, LaPorte, and St. Joseph.
[of course, impacts on Lake MI would harm Chicago, WI, and the entire Basin, downstream, downwind, up the food chain, and down the generations]
The Community Snapshot in Enclosure 18, Attachment 1 provides a detailed characterization of existing environmental burdens in Covert Township, utilizing the EPAs EJScreen tool.[footnote #] 4
[Footnote #] 4 EJScreen is EJ screening and mapping tool by EPA that helps identify areas with environmental burdens and vulnerable populations.
[by de"nition then, NRC and EPA seem to recognize that Covert is an EJ community! Hard to tell that by NRCs overall behavior, despite it all!]
Speci"cally, the analysis of Covert Township revealed high-energy costs, elevated asthma rates, transportation barriers, and signi"cant concentrations of toxic wastewater. Additionally, a broader examination of the EJ aected environment mirrors these "ndings, indicating systemic issues that aect community health and resilience.
[what an admission and yet, PNP has nothing to do with it? In a sense, thats true PNP wants nothing to do with it]
Sections A and B of the CBP (DOE 2024-TN10833), along with public comments during local meetings, provide an understanding of the current state of Holtecs EJ engagement.
Combined, these references re"ect a complex relationship between Palisades and local communities. Workforce development, service, and advocacy organizations all reported a lack of awareness about DOEs CBP and noted a decline in donations and volunteerism since the plants shutdown in 2022. They also noted signi"cant barriers to attracting a workforce, such as limited aordable housing and inadequate public transportation options, which contribute to the economic disadvantages in Benton Harbor and surrounding areas. Additionally, concerns about perceived health impacts from multiple local nuclear facilities, along with a historical context of racial disparities in community support and job opportunities, have led to mistrust among minority organizations. Although decommissioning did not drastically shift community needs, many residents look forward to potential economic bene"ts from the Palisades planned resumption of power operations. Community concerns primarily focus on housing,
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transportation, job training, and food security, with local organizations striving to support needs based on demand rather than speci"c income levels. Overall, the anticipated resumption of power operations has raised hopes for economic improvement, but signi"cant challenges remain regarding community engagement and equity (NRC 2024-TN10842).
[cite nooses in lockers, 2001-ish]
[desperately dependent company township Interesting they mention Benton Harbor, around 30 miles away. Covert is 3 miles away.
They have not explicitly mentioned Af Americans. In fact, above they said there is no there there, by masking Covert and BH behind County stats, as compared to State of MI stats.
Does covert have lead in drinking water too, like BH. But I thought Covert was on SH mun water?]
P. 92/242 ON PDF COUNTER (page 3-52 )
Figure 3-6 Environmental Justice 50 mi (80 km) Aected Environment. Sources: USCB 2023-TN11056, USCB 2022-TN11057
[it appears that more than half the land mass of VB Co, is minority and/or low income. Why is this, after nearly 60 years of PNP, if nuclear power is so great for the econony?! Especially considering 2 reactors at Cook, just 30 miles south, as well. I guess the NPPs are not sharing their vast wealth, eh?!]
P. 93/242 ON PDF COUNTER (page 3-53) 3.10.2 Environmental Impacts from the Preparations for Resumption of Power Operations Preparations for the resumption of power operations activities are not expected to have signi"cant human health or environment land use, air, water, or waste generation and disposal eects on EJ populations living near Palisades.
[odd nrc says that. 900 MT of HLRW at PNP is one of the greatest concentrations of any single NPP in the US. It has nowhere to go. It is vulnerable to catastrophe, as weve said a million times over.
Health impacts also denied by NRC, State of MI, etc.
Willful blindness by powers that be. But the company twp, county, multi-county area, state are all a part of this too.]
Given the presence of 590 EJ census block groups in the aected environment, EJ populations could experience disproportionate eects due to increased vehicular trac, the increased number of workers, and associated noise. However, since the human health and environmental eects would be similar to those experienced during previous Palisades refueling outages, as
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described in the 2006 SEIS (NRC 2006-TN7346), and would predominately occur within the developed areas of the industrial site, impacts to EJ populations would not be disproportionally high and adverse, and therefore, would be NOT SIGNIFICANT.
[how can nrc say this? Covert Twps Black population is 3 miles or so from PNP!]
3.10.3 Environmental Impacts from the Resumption of Power Operations Human health and environmental eects of nuclear power plant operations would be similar to those described in the 2006 SEIS (NRC 2006-TN7346), and the resumption of power operations at Palisades is not likely to result in any new, dierent, or increased human health and environmental eects beyond what has already been experienced.
[unless of course they have a catastrophic meltdown the risks of which were already high, and are now much higher, as due to Holtecs neglect of maintenance of safety-signi"cant SSCs]
Potential environmental eects include changes in socioeconomic conditions (such as trac volumes, demand for community services, job creation, income generation, and tax revenue changes), air and water quality, and waste generation and disposal. Given the presence of 590 EJ census block groups in the aected environment, EJ populations could experience disproportionate eects.
[well thanks for acknowledging that, but why no mention of radiological risks/impacts?!]
In addition, communities near nuclear facilities can face health risks from radiation exposure and contaminated water. EJ populations, in particular, are vulnerable due to limited means and resources to advocate for their health and safety, and pre-existing challenges such as elevated asthma rates and transportation barriers.
[ah there it is. but I already see the punchline coming]
Based on the human health and environmental eects conclusions for reactor operations at Palisades in the 2006 SEIS (NRC 2006-TN7346) and the review of human health in Section 3.11 of this draft EA, radiological or nonradiological health eects from the resumption of power operations would not be signi"cant.
Further, DOE concluded human health and environmental eects would be the same as was experienced during previous Palisades reactor operation (DOE 2024-TN10775). Since no special pathway receptors have been identi"ed, EJ populations near Palisades are not expected to experience disproportionately high and adverse human health and environmental eects from the proposed Federal actions. Therefore, the impact to EJ populations from the resumption of power operations would be NOT SIGNIFICANT.
[so, human health impacts from releases of radioactive poisons into the environment, and releases of toxic chemicals such as hydrazine and biocides, are zero, because all these releases disappear into nothingness, like magic? What about bioaccumulation, biomagni"cation, bioconcentration, as Rosalie bertell warned about?
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note that the two ghoulish agencies, NRC and DOE, used to be one AEC. But AECs rep was mud, so it was split into NRC (safety reg) and DOE (nuclear promotion). But we are back to the future/retro NRC is now very promotional too, with Congresss and Bidens blessing[]
[willful blindness]
P. 94/242 ON PDF COUNTER (page 3-54)
Table G 1
[radiogenic apoptosis of the dash mark]
The proposed reasonably foreseeable projects, such as SLR and the SMRs, are not expected to have any new or signi"cant disproportionally high and adverse human health or environmental eects on EJ populations or communities near Palisades beyond what has already been experienced. Therefore, the NRC sta determined that the incremental eects of the proposed Federal actions to EJ populations when added to the eects of other past, present, and reasonably foreseeable projects would not have signi"cant cumulative eects.
[so 3 reactors at PNP, and 2 more at Cook, would be no biggie for Covert, Benton Harbor, Pokagon, Gun Lake, etc. Again, no signi"cance, b/c NRC regards these communities as not signi"cant]
3.11.1 Radiological Human Health
[cite bag limits QHOs. Thanks Jennifer Uhle!]
In addition to reviewing data from actively monitored emissions, the NRC sta reviewed independent data collect by Michigan EGLE. The Michigan EGLE runs an independent REMP (MEGLE 2016-TN10744) for all nuclear power plants within the State, including areas surrounding Palisades. This data is published from 1958 up to 2016 and includes environmental P. 95/242 ON PDF COUNTER (page 3-55) sampling of air particulate, air vapors, milk, surface water, and direct radiation monitoring (MEGLE 2014-TN10865). The data collected by Michigan EGLE for the majority of plant operations demonstrate that Palisades emissions are low and con"rms submitted Annual Radioactive Euent Reports for the same time frame are within regulatory limits.
[well why the HELL did they end in 2016?! With PNP, Cook 1 & 2, and F2 still operating?!]
[and what about research reactors? Phoenix/Ford at U of M when did that close down? Any others? MI Tech?]
The N&S Report (Holtec 2023-TN10538) provides the most recent (2018-2022) average occupational radiation dose per individual; the total eective dose equivalent (TEDE) was
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0.225 roentgen equivalent(s) man (rem). The annual occupational TEDE limit is 5 rem, as outlined in 10 CFR 20.1201(a)(1).
[well, that is for PNP workers what about local residents?
Compare all this to the 2014 (?) CRDM seal leakage replacement job "asco. Average doses to workers 2.8 R for a one-month-long job!; including women of child bearing age, which entergy at "rst denied, but then quickly admitted to]
[and why is US worker dose up to 5 R per year, while internationally it is only 2 R/yr?!]
Also provided in the N&S Report (Holtec 2023-TN10538) are the doses to a member of the public for the last full year of operation (2021), which were: 0.112 millirem (mrem) for whole body, 0.117 mrem for thyroid, and 0.522 mrem for other organs.
[thats starting to add up!
0.112 mR 0.117 mR 0.522 mR 0.751 mR Approaching 1 R Half an international worker dose limit What about other radiation exposures to this same generic individual? From natural radiation, and other arti"cial sources, such as medicine, legacy pollution, and other reactors nearby 2 at Cook, 2 more at PNP, so many upwind and upstream in IL & WI, etc. why isnt all this included in Cumulative Eects? Radium contamination in Benton Harbor at Jean Klock Park, now a gated community and golf course]
The average occupational radiation exposure TEDE dose for the operational years 2006 to 2021 ranged from 0.09 rem to 0.39 rem (NRC 2024-TN9915). These dose results con"rm that Palisades was operating in compliance with 10 CFR Part 50, Appendix I, 10 CFR Part 20, and 40 CFR Part 190.
[how can this be, given the 2014 CRDM incident alone, impacting nearly 200 workers?]
The NRC sta investigated the reports of increased rates of cancer using data sources provided by the Michigan Department of Health and Human Services, such as the Centers for Disease Control and Preventions National Environmental Public Health Tracking Network (CDC 2024-TN10845) and the University of Kentuckys Cancer Incidence and Mortality Inquiry System (University of Kentucky 2014-TN10851). The provided data included total cancer rates and thyroid cancer rates for Van Buren County, the counties surrounding Van Buren County, and the state of Michigan as a whole. This data was used in conjunction with annual euent
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reports provided by the operators of Palisades and data collected through the Michigan REMP program.
Based on its review of this data, the NRC sta did not identify any higher incident rates of cancer, speci"cally for thyroid cancer in the counties around Palisades. This information is discussed in further detail in Appendix H, Discussion of Cancer Risks at and around Palisades Nuclear Plant. While Palisades did have enforcement actions applied during the time period reviewed (NRC 2024-TN10751), no enforcement actions were related to the radioactive emissions control systems described in Section 3.11.1.1 of this EA.
[so is nrc hiding the truth about PPCC behind county-wide numbers? Diluting the cancer rate across the whole county?
What about the fact that most PPCC residents are only there in the warm weather. Are there cancers recorded in their other county/state of residence, but not VB Co./MI?
Compare what Cindy Sauer revealed at Morris with this for real estate reasons, local pediatrician concealed truth most cancers got recorded in chicago, not Morris cause of death blurred truth, just as at Chornobyl, etc. cover up, minimization, secrecy (SCUM), per Je patterson]
Additionally, the State of Michigan Department of Health and Human Services, Department of Environmental Health provided the NRC sta with a letter sent to the township of Covert, Michigan on November 15, 2024 (MDHHS 2024-TN10866). The letter summarizes a review of the instances of thyroid cancer in Covert Township from 1985 to 2021. The number of recorded P. 96/242 ON PDF COUNTER (page 3-56) cases of thyroid cancer in permanent residents was 6, a number too low to conduct viable statistical analysis with other comparable locations. No temporal patterns were identi"ed with regards to thyroid cancer for the location during the review.
[PPCC reports 20 to 50 thyroid cancer cases. Are they lying?
What about those whose cases never get diagnosed or recorded, such as local residents who lack health care coverage, and simply die eventually, undiagnosed and untreated?
Methodological "aws, incuriosity, laziness SCUM Dave krafts shorthand]
3.11.1.3 Environmental Impacts from the Resumption of Power Operation Radiological impacts of normal operations are addressed in the 2006 SEIS (NRC 2006-TN7346), where the NRC sta noted that there would be no impacts of radiation exposures to the public during the renewal term beyond those discussed in the 2006 SEIS. Given that Palisades would be operated as before with no signi"cantly dierent radiological environmental impacts, the NRC sta has determined that the environmental impacts of radiological euent releases from the resumption of power operation at Palisades would be consistent with what was provided in the 2021 and 2022 REMP reports prior to the shutdown of operations in 2022 (Holtec 2023-TN10538), and therefore, would be NOT SIGNIFICANT. The operational impacts
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are minimized by compliance with radiation protection regulations in 10 CFR Part 20 (TN283),
10 CFR Part 50 Appendix I (TN249), and Occupational Safety and Health Administration (OSHA) regulations (29 CFR Part 1910-TN654) created by the Occupational Safety and Health Act of 1970 (TN4453).
[all those engineers at NRC, and yet they still seem unfamilliar with the concepts of corrison and other forms of age related degradation leading to more leaks, spills, etc., not to mention intentional releases]
P. 96/242 ON PDF COUNTER (page 3-56)
The proposed Federal actions would not have an incremental cumulative eect on the design con"guration, operational changes, or radiological monitoring at Palisades. The facility would return to the same operational state prior to decommissioning and would have the same level of impacts. The addition of SMRs, if pursued, must also meet the NRC regulatory requirements for euent releases. Additionally, the combination of all nuclear power plants on the site and within 50 mi (80 km) of Palisades would be required to meet the regulations of 40 CFR Part 190 (e.g., maximum annual dose equivalent no greater than 25 mrem for whole body) (TN739)
[is that per reactor, or for all 5 reactors combined? Even that much is not made clear. Are the dry cask storage exposures in addition to?]
P. 97/242 ON PDF COUNTER (page 3-57) 3.11.2 Nonradiological Human Health Chemical Hazards: State and Federal environmental agencies regulate the use, storage, and discharge, and management of chemical spills at the Palisades site as outlined in the 2006 SEIS (NRC 2006-TN7346). Water treatment discharge and management are regulated by an NPDES permit, which is under renewal and discussed further in Section 3.4.2 of this EA.
Occupational health impacts are managed through established industrial hygiene practices that comply with OSHA requirements (Holtec 2023-TN10538). Between 2018 and 2023, one reportable chemical spill occurred in September 2020, when a leak from a condensate storage tank exceeded the threshold for hydrazine (reportable quantity of 1 lb [0.45 kg]) and was reported to the state of Michigan (Entergy 2021-TN10707). The quantity of hydrazine released (2.7 lb [1.2 kg]) was not signi"cant enough to cause any human health eects
[compare nrcs whitewash on hydrazine to epa or wiki ]
[what about other toxic chemicals biocides]
Microbiological Hazards: As described in the 2024 LR GEIS (NRC 2024-TN10161),
microbiological hazards occur when workers or members of the public come into contact with disease-causing microorganisms, also known as etiological agents. As described in the N&S Report, the Palisades cooling system does not discharge to a small river; therefore, microbiological public health hazards are not applicable to Palisades (Holtec 2023-TN10538).
Microbiological hazards to plant workers are applicable to Palisades. As described in 2024 LR GEIS, nuclear power plant workers can be exposed to Legionella spp. when
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performing cooling system maintenance through inhalation of cooling tower vapors because these vapors are often within the optimum temperature range for Legionella spp. growth. In the N&S Report, occupational health impacts are managed through established industrial hygiene practices that comply with OSHA requirements (Holtec 2023-TN10538). In the 2006 SEIS (NRC 2006-TN7346), NRC concluded that there would be no impacts of microbiological organisms during the license renewal term due to potential impacts being controlled by continued application of industrial hygiene practices.
[what about PPCC and VB State Park lots of folks swimming or wading, as well as boating, in or near the Lake, in very close proximity the PNP cooling towers are immediately adjacent to PPCC are some cabins continually exposed to cooling tower plume fallout? What about that time of pea soup thick fog at VB State Park? Arnie raised related concerns in his expert witness testimony]
P. 98/242 ON PDF COUNTER (page 3-58)
Physical Hazards:
There are no Federal standards limiting exposure to electromagnetic "elds from power lines in the United States.
[well why not?! Shouldnt there be?!]
[what about nearly doubling transmission of nuclear mega-wattage with the SMRs 800 to 1,400]
[bring up sept. 2012 near-electrocutiion in control room]
As described in detail in the 2024 LR GEIS (NRC 2024-TN10161), noise is an unwanted or unwelcome sound generated by various sources. According to Holtecs N&S Report, the nearest residence is approximately 0.5 mi (0.8 km) to the southwest of the Palisades site (Holtec 2023-TN10538). Noise measurements for the Palisades site are unavailable; however, the cooling towers that were replaced in 2012 and 2017 produce a maximum sound of 90 A-weighted decibel at 3 ft (0.9 m) when operational. As the Palisades site is surrounded by sand dunes and vegetation and most equipment is inside the buildings, noise generation at Palisades is mitigated (NRC 2006-TN7346).
[ive heard otherwise, as from PPCC residents. Steam roars, sirens or alarms, etc. such a whitewash. So downplaying. Emergency sirens had better be audible, eh?!
Mention lack of transport re: emergency evac, especially for low income in area Covert, and beyond compare to hurrican Katrina in terms of black and poor residents dying; compare to "rst 50 casualties at Fukushima seniors in hospitals and nursing homes, abandoned in place]
[echo chamber nrc, doe, state of mi, local govts, chambers of commerce, holtec, etc. yes men and yes women, they cite each other]
P. 99/242 ON PDF COUNTER (page 3-59)
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3.12 Waste Management
[compare nrcs whitewash/greenwash to the rad waste bldg spill we cited in our feb. 24, 2021 intervention petition]
Mixed waste, regulated under Resource Conservation and Recovery Act of 1976, as amended (Resource Conservation and Recovery Act of 1976-TN1281) and Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.-TN663), include both radioactive and hazardous waste (EPA 2019-TN6956). According to Holtecs N&S Report (Holtec 2023-TN10538), Palisades has generated minimal mixed waste from 2018 to 2023
[really? Hows that? What about back to 1971?]
[cite WCS impacts out there; Resnikos all the dumps have leaked]
Section 2.1.5 of the 2006 SEIS (NRC 2006-TN7346) provides a description of the nonradioactive waste generation and waste management at Palisades prior to start of plant decommissioning. Generated nonradioactive waste includes chemical, biocide, sanitary, P. 100/242 ON PDF COUNTER (page 3-60) universal, site stormwater runo, and lubrication oil waste. Palisades has a nonradioactive waste management program and procedures to handle and dispose of this nonradioactive waste in accordance with Federal, State, and local regulations. Solid wastes are collected and stored onsite, then shipped osite for disposal.
[still pretty bad! What about THOSE dumpsites. Toxic culture.]
[how about even sanitary, with up to 1,600 workers on site?!]
However, in 2015, 2017, and 2019, Palisades has also been classi"ed as large quantity hazardous waste generator due to occasional episodic events (MEGLE 2021-TN10753).
[what were those?]
Palisades has typically been classi"ed as a small or very small quantity hazardous waste generator. However, in 2015, 2017, and 2019, Palisades has also been classi"ed as large quantity hazardous waste generator due to occasional episodic events (MEGLE 2021-TN10753). The NRC sta expects that Holtec would continue to implement plans and procedures for management of its waste types including an asbestos abatement or human-made mineral "ber removal plan (HDI 2024-TN10670: RAI-WM-1).
[poor sample documentation, poor QA]
Procedures, such SPCC-PIPP and the SWPPP
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[radiogenic apoptosis of the work as]
Procedures, such SPCC-PIPP and the SWPPP are in place for nonradioactive waste management and for the minimization and management of liquid chemical spills. With respect to unplanned, nonradiological releases, the NRC stas review of the annual nonradiological environmental operating reports over the period of 2018 through 2023 found one documented instance of a reportable chemical spill in September 2020, which is described in Section 3.11.2.1 of this EA. In the unlikely event of generation of a medical incident and generation of medical waste, the State of Michigan Medical Waste Regulatory Program provides procedures for managing medical waste, which would typically be handled by the supporting medical facility.
[compare to radioactive injured worker from Cook snafus galore, endangering ambulance drivers, EMTs, doctors and nurses at ER Compare to the testimony to MPSC in 2017 (?) in Lawton (?) or Lawrence re: the frothing discharge into Lake MI that so traumatized that grandmother over the safety of her grandchildren NRC tries to talk a good line here, but it aint so]
As discussed in Section 3.4.1 of this EA, if sediments are removed from the mixing basin as a result of the sediment level evaluation, removal would be performed under the appropriate permits, and sediments would be tested for radioactivity and other contaminants prior to disposal osite. Mixed waste production may result from the cleaning and removal of any residual contaminants that accumulate in the primary coolant system. Holtec maintains plans and procedures for management of radioactive and nonradioactive waste and plans to use existing processes for preparation of reauthorization activities resulting in waste generation (HDI 2024-TN10670: RAI-GEN-1, RAI-WM-1). Holtec estimated the total amount of radioactive wastes generated during refueling activities as part of the preparations for the resumption of power operations as 44,520 ft3 (1,260 m3) of Class A waste, 240 ft3 (7 m3) of Class B waste, and 1,770 ft3 (50 m3) of Class C waste (HDI 2024-TN10670: RAI-WM-1).
[future LLRW and HLRW newly generated would NOT be, if Palisades remains shut there would of course still be all the decommissioning wastes, already generated HLRW, etc.
Holtec said in 2020 PSDAR that ALL LLRW is going to WCS but is that even true?]
[compare that chemical chelating "ush already performed now the rad. Contamination is wearing roller skates, per Kay Drey. Work at risk? It seems NRC is "ne with Holtec just doing whatever it wants, even while this EA is still only in Draft form. Tail wags the dog. Holtec is in charge, and tells NRC what to do. Actually, they are business partners they are in it together.
Collusion. Complicity. The illusion and pretense of safety and env regulation]
Based on information in the review of Holtecs N&S Report, (Holtec 2023-TN10538), Holtecs response to NRCs RAIs (HDI 2024-TN10670: RAI-WM-1), and public scoping (Appendix B to this EA), the NRC sta has determined the proposed Federal actions would not alter radiological or nonradiological waste management processes currently in place at Palisades.
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Therefore, the NRC sta determined that radioactive and nonradioactive waste management impacts related to the activities from the preparations for resumption of power operations would be NOT SIGNIFICANT.
[More than 900 MT of HLRW stored on-site is already an EXTRA LARGE IMPACT]
p.101 3-61 3.12.3 Environmental Impacts from the Resumption of Power Operations Hazardous waste generation is not expected to increase during resumption of power operations.
As described in the N&S Report, Palisades is expected to continue as a small or very small hazardous waste generator upon renewed operations, but certain events such as cleaning of storage tanks may result in generation of large quantities of hazardous waste (Holtec 2023-TN10538).
[so it will be small, unless its large?! Nonsensical Compare to chelating "ush, per above]
In addition, the NRC sta have determined that radioactive and nonradiological waste management impacts analyses in the 2024 LR GEIS are relevant to the proposed Federal actions, including the resumption of power operations at Palisades. The 2024 LR GEIS (NRC 2024-TN10161) describes the environmental eects of reactor operations on radiological and nonradiological waste management as a result of license renewal. As explained in the 2024 LR GEIS, continued reactor operations and refurbishment activities at nuclear power plants have had little or no environmental eect on waste management.
Based on the review of the N&S Report (Holtec 2023-TN10538) and Holtecs responses to NRCs RAIs/RCIs, the waste management aected environment at Palisades has not changed to any signi"cant degree since the 2006 SEIS (NRC 2006-TN7346). Based on NRC stas review of the N&S Report and conclusions of the 2006 SEIS and the 2024 LR GEIS, NRC sta concludes that radioactive and nonradioactive waste management impacts from the resumption of reactor power operations would be NOT SIGNIFICANT.
[clearly NRC would not know an Extra Large Impact if it bit them on the ass]
[15+ MT of HLRW for each year of ops going forward 2 to 30 times that amount, at least in terms of each unit of electricity generated, at the SMRs, per Macfarlane and Ewing]3.12.4 Cumulative Eects Appendix G, Table G-1 of the EA identi"es past, present, and reasonably foreseeable projects that could cumulatively contribute to the environmental impacts of the proposed Federal actions.
No signi"cant design con"guration or operational changes are expected to impact waste management as a result of the proposed Federal actions. The facility would return to the same operational state prior to decommissioning and would have the same level of impacts as concluded in the 2006 SEIS. The addition of SMRs, if pursued, would be required to meet the
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NRC regulatory requirements for safe handling and processing of generated waste.
Additionally, the combination of all nuclear power plants on the site and within 50 mi (80 km) of Palisades would be required to meet the applicable 10 CFR Part 20 and Part 72 regulations for waste management. Therefore, the NRC sta determined that the incremental eects of the proposed Federal actions related to waste management when added to the eects of other past, present, and reasonably foreseeable actions would not have signi"cant cumulative eects
[radioactive waste generation ad nauseum, a curse on all future generations, for a little electricity, the "eeting byproduct victor mcmanemy & Michael keegan]
[has the 2014 GEIS on Cont Stor of SNF even been mentioned in this EA? Certainly not much!]
3.13 Uranium Fuel Cycle and Transportation
[U mining and milling impacts on Indigenous Nations; HLRW barges on Lake MI; EJ impacts of dumps]
p.103 The impacts to the uranium fuel cycle and subsequent transportation of fresh nuclear fuel and spent nuclear fuel (SNF) and radioactive waste during operation would be consistent with those described in the 2006 SEIS (NRC 2006-TN7346), the 2024 LR GEIS (NRC 2024-TN10161),
and the Continued Storage GEIS (NRC 2014-TN4117), along with Evaluation of Accident Tolerant Fuels (NRC 2024-TN10333). These documents describe the impacts bounded by Table S-3 and Table S-4 of 10 CFR Part 51 and impacts of SNF at-reactor and away-from-reactor storage. The documents listed above demonstrate that continued reactor operations at nuclear power plants have had little or no environmental eects due to the uranium fuel
- cycle, SNF management, and transportation of fuel and waste. No additional nuclear plant-speci"c analysis is required unless any new and signi"cant information is identi"ed.
[tell that to the Red Water Pond Road Community, Skull Valley Goshutes, Western Shoshone, etc. NRC is sociopathic, if not psychopathic]
p.103 3.13.4 Cumulative Eects Appendix G, Table G-1 of EA identi"es
[the suered radiogenic apoptosis]
[this 242 page document is not worth the paper its written on]
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3.13.4 Cumulative Eects Appendix G, Table G-1 of EA identi"es past, present, and reasonably foreseeable projects that could cumulatively contribute to the environmental impacts of the proposed Federal actions.
No signi"cant design con"guration or operational changes are expected to impact these resource areas as a result of the proposed Federal actions. The facility would return to the same operational state prior to decommissioning and would have the same level of impacts.
Fuel-cycle impacts would occur not only at Palisades but also at other locations in the United States. In addition to fuel-cycle impacts from the proposed SMRs, this cumulative analysis also considers fuel-cycle impacts from Palisades. The fuel-cycle impact of the proposed SMRs would be similar to that of Palisades. There is one other nuclear power plant within 50 mi of Palisades.
The addition of SMRs, if pursued, would result in an increased impact, but would remain bounded by the impacts described in 10 CFR Part 51 Tables S-3 and S-4 (TN10253). For example, a number of fuel-management improvements have been adopted by nuclear power plants to achieve higher performance and to reduce fuel and separative work (enrichment) requirements. The cumulative eects of reauthorization and subsequent operation are expected to be consistent with conditions described and analyzed in the 2006 SEIS for all nuclear power plants on the site and within 50 mi (80 km) of Palisades. Therefore, the NRC sta determined that the incremental eects of the proposed Federal actions related to uranium fuel cycle and transportation of nuclear fuel and radioactive waste when added to the eects of other past, present, and reasonably foreseeable actions would not have signi"cant cumulative eects.
[cumulative accumulating piling up just quantitatively alone they dont even acknowledge that estimate how much waste would result at the palisades site how many barge shipments etc.]
p.104 3.14 Postulated Accidents The impacts described in the 2024 LR GEIS summarize the estimated impacts of nuclear power plants within the United States and indicate the environmental impacts of design basis accidents (DBAs) and the environmental impacts from the probability-weighted consequences of severe accidents are generic issues with a SMALL environmental impact.
[probability-weighted? Compare Fukushimas probability, and actual real world consequences]
[NRC and Holtecs magical thinking American exceptionalism gone wrong]
The impacts described in the 2024 LR GEIS summarize the estimated impacts of nuclear power plants within the United States and indicate the environmental impacts of design basis accidents (DBAs) and the environmental impacts from the probability-weighted consequences of severe
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accidents are generic issues with a SMALL environmental impact. Palisades previously considered SAMAs on a site-speci"c basis in the 2006 SEIS. The NRC sta reviewed Palisades current site-speci"c information and found no new information that would change either the generic SMALL impact determinations for DBAs and severe accidents in the 2024 LR GEIS or the determination of SMALL impacts for DBAs and severe accidents in the 2006 SEIS for Palisades (HDI 2024-TN10669: RCI-A-1). Holtec con"rmed there would be no changes to the design basis which would require a reevaluation of the SAMA analysis (HDI 2024-TN10669:
RCI-A-1). Additionally, the NRC has stated in Table B-1 of 10 CFR Part 51 (TN10253) Appendix B, that, so long as a previous SAMA analysis has been performed, SAMAs do not warrant further plant-speci"c analysis because the demonstrated reductions in population dose risk and continued severe accident regulatory improvements substantially reduce the likelihood of "nding cost-eective signi"cant plant improvements.
[in other words, youve just got to live with the risk. Put your big boy pants on. But oh, trust us, probably nothing will go wrong. Or too wrong. Or so wrong that you cant handle it. besides, holtec needs to make its "lthy fortune, dontcha know?!]
[and reducing meltdown risks is not worth the cost since the area and regional population are insigni"cant anyways why bother? Not worth it]
Holtec con"rmed that the 2024 LR GEIS generic "ndings for Severe Accidents and SAMAs will remain applicable to Palisades during resumption of power operations for the duration of the RFOL(HDI 2024-TN10669: RCI-A-1). The current updated model of record for internal event and internal "ood risk for Palisades is 3.22 x 10-5/yr, which is within the 2024 LR GEIS, Revision 2 Table E.3-2 SAMA CDF range of 3.9 x 10-6/yr to 5.6 x 10-5/yr for pressurized water reactors and is a reduction over values used at the time of Palisades license renewal (4.05 x 10-5/yr). Both internal and external events were evaluated in the 2006 Palisades SEIS.
[compare to probability of Fuku Radioactive Russian roulette What if rolling the dice enough times they come up snake eyes?]
[what is the psychiatric disorder where high risk taking accelerates as time goes on doubling down]
p.105 Although the treatment of external events in the 2006 SEIS was limited by the unavailability an external event PRA, the NRC sta accounted for external event risk by increasing the estimated risk from internal events by a factor of 2 to account for risk from both internal and external events.
[the word of suered radiogenic apoptosis]
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[cost-bene"cial? We are not worth any such costs. Holtecs bene"ts cannot be challenged.]
On September 9, 2019, the Mitigation of Beyond-Design-Basis Events (MBDBE) rule (10 CFR 50.155; TN249) became eective. This rule primarily addresses mitigation strategies for a wide range of potential extreme events, including seismic events, "re, "ooding, and other natural phenomena, requiring nuclear power plants to have plans in place to maintain core cooling, containment integrity, and spent fuel pool cooling even when facing events beyond their design basis, including large-scale natural disasters. If the NRCs proposed actions are approved and the 10 CFR 50.82(a)(1) certi"cations are withdrawn, Palisades will again be required to comply with 10 CFR 50.155 (TN249).
As a result of the NRCs ongoing safety oversight and updates to NRC regulatory requirementsthe overall risk of a severe accident has been reduced. Because the NRCs regulations and safety oversight have provided additional severe accident mitigation and have further reduced the risk pro"le of operating reactors since the Palisades SAMA analysis in the 2006 SEIS, further SAMA analyses would be unlikely to "nd any cost-eective signi"cant plant improvements, as discussed in the 2024 LR GEIS (NRC 2024-TN10161).
[SAMA bene"ts prove you are worthy NRC doesnt think we are worthy, ever]
[radioactive radiogenic conjoined twins]
Based on information in the review of Holtecs N&S Report (Holtec 2023-TN10538), Holtecs response to the NRCs RCI (HDI 2024-TN10669: RCI-A-1), public scoping (Appendix B to this EA), and that the published impacts from postulated accidents are considered bounding, the NRC sta have determined the proposed Federal actions would not alter the previously determined impacts from design basis accidents and severe accidents, or the previous SAMA conclusions for Palisades in the 2024 LR GEIS (NRC 2024-TN10161); and therefore the environmental impacts of postulated accidents of the proposed Federal actions would be NOT SIGNIFICANT.
[how do these SAMAs compare to CRAC-II of 1982?]
3.15 Decommissioning Impact Evaluation This section describes the environmental impacts associated with the permanent cessation of power operations and the return to decommissioning of Palisades at a future date. All operating nuclear power plants will permanently cease power operations and be decommissioned at the end of their operating life when a decision is made to cease power operations.
[Holtec acquired PNP in the "rst place through a bait and switch trick, a con job, promising decommissioning but then announcing restart and SMR new builds instead. Given the various forms of fraud involved, Holtec should be tried in a court of law on various charges, rather than allowed to pursue its nefarious schemes with its ill-gotten PNP site. Also, anything Holtec has to say re: decommissioning is not to be trusted or believed, ever again. Same applies to NRC.]
p.106 As discussed in Section 1 of this EA, Palisades ceased operations and removed fuel from the
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reactor in 2022. Prior to cessation of power generation activities and removal of all fuel, Holtec submitted a PSDAR to NRC (Holtec 2020-TN10539), in accordance with 10 CFR 50.82(a)(4)
(TN249), to outline the proposed decommissioning activities and describe potential associated environmental impacts. In the PSDAR submission, Holtec concluded that the environmental impacts associated with the planned Palisades site-speci"c decommissioning activities would be bounded by appropriate, previously issued environmental impact statements, including:
[there again, the Holtec PSDAR was a lie, and part of the con job. It is worthless.]
- p. 107 4 CONCLUSIONS This EA describes the environmental review conducted by NRC and DOE LPO sta for evaluating the environmental eects of granting the licensing and regulatory requests necessary to reauthorize power operations at Palisades through March 24, 2031, which is the end of the current operating license term under the Palisades RFOL. DOE LPO acted as a cooperating agency on this review.
[funny, no mention of the $1.52 billion loan guarantee here. Is it mentioned earlier? Also funny that DOE LPO announced "nalization of the loan guar at almost the exact same time, or a bit after, the SG degradation extent was revealed, and weeks after the problem had been red "agged by the NRC PNO and Summary of Conference Call what were those dates in Sept. 2024? How could DOE LPO do that, given the red "ags?! Isnt there a safety criteria? I warned DOE LPO that NRCs word on safety was worthless and could not be trusted, at the mtg in Benton Harbor.]
The purpose and need for these proposed Federal actions are to provide an option for clean energy baseload power generation through the current licensing term of March 24, 2031 (see Section 1.2 of this EA).
[well the purpose and need have been violated then, because PNP is not clean energy. It is also not baseload. After all, it has been shut down for nearly 3 years it has not generated a single kilowatt-hour of electricity that entire time. This long term shut down should be included in any capacity factor determinations going forward, if it ever restarts.]
Additionally, there were no signi"cant cumulative eects identi"ed.
[this is quite absurd. Just look at the impacts since 19672051 would mark nearly a century of such impactsthe 2 SMRs would extend such impacts by decades moreso too would the zombies 100 year license out to 2071, etc. ad nauseum]
The NRC sta based its conclusions on an independent review of information provided in Holtecs licensing submittals, as well as other relevant information and sources.
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[I guess WE are irrelevant then, since they have ignored us from the very beginning, and still do. And Holtec speaks nothing but the gospel truth. NRC sees eye to eye with them, the nuclear rogues and crooks.]
- p. 109 Preparations for resumption of power operations activities would occur only in previously disturbed areas on the Palisades site, reducing the impact to soil resources, as there are no known geologic resources in the vicinity of Palisades.
[this statement strikes me as odd. It makes the PNP site sound like a wasteland, worthless.
They are striving to make it that, radioactively.]
p.108-112 Table 4-1 Summary of Environmental Impacts from the Preparations for Resumption of Power Operations and Resumption of Power Operations at Palisades Nuclear Plant
[all of these categories are for PNPs impacts on THEM. What about their impact on PNP?
What about extreme weathers potential impact on PNP, driven by climate chaos? What about a tsunami wave o the Lake? What about even a minor earthtquakes impacts on dry cask storage, for example. The list goes on and on. NRC, and Holtec, are willfully blind to the risks.]
p.108 Visual
[what an eyesore. What a terrifying sight, if you know what you are looking at. Radioactivity being invisible and all, but its potential and real consequences all too horrifying. Other than that, its just ugly. An industrial eyesore in an otherwise idyllic, beautiful place. Monstrosity up the beach, even per PPCC in their centennial year book]
p.109 Terrestrial and Aquatic Ecology
[how rude to say ruderal Ruderal adjective adjective: ruderal
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1.
(of a plant) growing on waste ground or among refuse.
noun noun: ruderal; plural noun: ruderals 1.
a plant growing on waste ground or among refuse.
What an odd thing to say. How very misleading. The PNP site is amidst critically endangered sand dunes on the shore of the Great Lakes. An area of tremendous biological diversity, that is very fragile, and critically endangered.
If PNP hadnt trashed the place, it would not be ruderal.
Cite the botanist who hails from south haven, and the museum dedicated to his memory.
This area is a haven for "ora and fauna, but has been trashed.]
The NPDES permit no. MI0001457 regulates thermal discharge and chemical releases into Lake Michigan.
[trashing the Lake itself, too. And putting it at existential risk of radiological ruin. PNP treats Lake MI like a radioactive wastewater industrial sewer. A meltdown could make the Lake(s) un"t for human consumption or contact.]
p.109 For federally listed terrestrial and aquatic species, activities associated with the preparations for the resumption of operations and the To p.110 resumption of operations will either have no effect on the species or may affect, not likely to adversely affect the species.
[what wishful thinking, that "ies in the face of the facts. Sociopathic if not psychopathic, not only in regards to ecological impact, but also on human health]
- p. 110
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Historic and Cultural Resources Historic properties under the NHPA do not occur within the APE, and thus there will be no historic properties affected as part of the preparations for resumption of power operations, and the resumption of operations. Additionally, no historic and cultural resources have been identi"ed within the APE. Ground disturbance will occur in areas of previous ground disturbance, and Palisades-speci"c procedures provide a control to monitor and protect cultural resources, if encountered on Palisades site during the resumption of power operations (and for activities occurring as part of the preparations for resumption of power operations).
[what utter disregard for the Indigenous burials, and other cultural signi"cant Indigenous sites that are very likely on the PNP site. Talk is cheap. Holtec, and NRC, lie. How can their word be trusted re: protecting Indigenous sites, if encounted, if they dont even bother to look for them very carefully pre-restart. And then there is SMR construction. That will disturb the ground like nothing seen at that site since 1967-1971, the construction of the now would be zombie. Of course, the radioactive contamination of the site is another LARGE impact, that NRC ignores. Quote Upton Sinclair.]
p.110 Socioeconomics 3.9 The number of workers at Palisades will peak at 1,600 during preparations for the resumption of operations (similar to the number of workers needed during refueling outages). Once operations resume, the number of workers will return to 600, similar to the number of workers at Palisades during previous operational periods. Holtec expects property tax payments to return to pre-decommissioning levels (approximately $10 million per year) starting in 2027. Any other socioeconomic impacts would
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be minimal.
["nd Holtecs "gure of 450, or was it Entergys, at one point. Their number for workers has "uctuated wildly over the years and decades.]
Environmental Justice 3.10 There would be no signi"cant human health or environmental effects from the proposed Federal actions that would be disproportionately high and adversely affect environmental justice populations.
[this is a false statement. Nrcs analysis and conclusions are themselves EJ violations. They do not care about the area residents in Covert Twp, Benton Harbor, Pokagon, Gun Lake, VB County, etc. disproportionatley high AF Am, Native Am, Latino, and/or low income populations. NRC is blind to EJ, but spouts false claims of EJ, and pats itself on the head for how great a job at EJ it does. NRC itself violates EJ, let alone with Holtec proposes to do.]
[$10 million per year in taxes? Thats nothing. They have projected at least $412.5 million per year in revenue. They are raking in up to $16+ billion in public bailouts, if they get all theyve asked for that we know about. $10 million per year in tax revenues is a pittance, pocket change, loose change in the couch cushions. And yet Covert Twp and City of South Haven and VB Co are desperate for it, addicted to it. Same for charitable donations. Entergys $100,000 of charity in 2012-13 is laughably small. But of course Holtec is now illegally looting the DTF, so Holtecs charity is largely that it seems.
Which will leave a very big mess, and no money to pay for its clean up, if they ever get around to that. Quote Winona LaDuke.]
p.110 Radiological and Nonradiological Human Health 3.11 The NRC staff expect radiological releases, doses to the public, and occupational doses
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would be less than the limits established for protection of human health and the environment in 10 CFR Part 20 and Occupational Safety and Health Administration (OSHA) regulations.
[worker regs in US are remarkably lax compared to intl regs 5 R/yr instead of 2 R/yr. Cite various health damage claims, from Mangano, to PPCC residents. Per above, cite NAS linear no threshold theory, gender and radiation studies Makhijani, Olson, etc.]
p.111 workers as part of the preparations for the resumption of operations and the resumption of operations. For nonradiological human health, Palisades maintains a safety program that addresses applicable OSHA standards that will be in place for preparations for resumption of power operations and resumption of power operations.
[rust bucket will leave worse than ever cite past tritium leaks]
Uranium Fuel Cycle and Transportation 3.13 A low quantity of uranium would be used during the 7-year operational period (resumption of operations). Fuel processes are bounded by Table S-3 and S-4 of 10 CFR 51.51.
Environmental impacts from storage of spent fuel would be less than the environmental impact described by the Continued Storage GEIS. The estimated volume of LLRW is less than or comparable to that of other reactors, and the NRC staff determined that there is adequate capacity for LLRW disposal. The on-site storage of spent fuel would have to meet the same regulatory requirements as currently licensed reactors and the currently stored spent fuel at Palisades. Transportation of fresh fuel to
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Palisades, and transportation of LLRW from Palisades, would be performed in compliance with DOT and NRC regulations and constitutes only a small percentage of the total materials of these types shipped each year.
[LLRW dumping impact on Ogalala cite Holtec PDSAR re: decommissioning waste plan.
Mention other potential dumps near Skull Valley Goshutes at EnviroCare, etc. EJ violation. Challenge HLRW nonchalance. Mention CISFs. Mobile Chornobyl. Barge shipments on Lake MI. Include fact sheet language]
p.111-112 Postulated Accidents
[cite Arnies 2014 essay. Chornobyl on the Lake MI shore. Fukushima. etc. cite CRAC-II]
p.112 4.2 Comparison of Alternatives In Section 2.2 of this EA, the NRC staff considered possible alternatives to the proposed Federal actions to reauthorize power operations at Palisades. Only one alternative was carried forward for further analysis, the no-action alternative. The NRC staff independently reviewed information concerning other possible alternatives and determined that none were reasonable alternatives warranting further evaluation
[cite ken bossongs most recent news release/report on renewables growth by leaps and bounds.
Cite Jacobsons expert witness report. Cite mark Cooper, Arnie gundersen, and al compaan at Pt. Beach, which is comparable given the locations of Pt. Beach and Palisades, in terms of renewable potential. Cite makhijani.]
As noted in Section 2.2.1.1 of this EA, taking no action would not meet the clean energy demand driving the purpose and need for the proposed Federal actions and could lead to a need to build new nuclear or non-nuclear power generation facilities.
[this is illogical. The non-nuclear power generation facilities that could be built would and should include renewables. Yet nrc refuses to consider them a viable alternative. But here says they could be. More cost effective, just as reliable if not more so compared to PNP, if storage is included, safer, more secure, cleaner, etc. NRC is willfully blind to all this.]
However, building new facilities would result in additional environmental impacts related to land disturbance and use of construction equipment. These impacts would be greater
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than those needed to put the already built Palisades facilities back into operation.
[interesting nrc says this. Since holtec also proposes building 2 smr-300s on the very same site.
And yet no mention of that here?!]
p.113 5 DRAFT FINDING OF NO SIGNIFICANT IMPACT The proposed Federal actions before the NRC are whether to grant requests for an exemption, a license transfer, and license amendments to support reauthorizing Palisades for power operations through the remainder of its licensing term (to March 24, 2031).
[they also ignore the 80 year license, 2031-2051. Chances are, PNP would also apply for a 100 year license at some point. That is reasonably foreseeable, as nrc and industry have been talking about 100 year licenses for decades cite Luis reyes, former EDO? Ignoring smrs for the most part, and license extensions beyond 2031, violate cumulative impacts requirements under nepa, ceq regs, and nrc implementation regs]
[this should not be treated as a paper game]
p.113
[request extension of public comment period; repeat demand for EIS]
p.117
[references = check the box exercises, nrc, doe, etc.]
[HLRW football "eld metaphor, hockey rink metaphor sure wouldnt want to be sitting in that stadium!]
[Covert, MI = no secrets hereNOTHING to hide]
p.121 HDI (Holtec Decommissioning International, LLC). 2023. Noti"cation from B. Turco, Holtec Palisades LLC, Chemistry/Environmental Supervisor - Palisades, to J. Rubio, Michigan Department of Environment, Great Lakes, and Energy, Water Resources - Kalamazoo District Of"ce, regarding an Upset Non-Compliance incident of the Stations [Palisades Power Plant]
NPDES permit. Palisades Power Plant, Covert, Michigan. TN10674.
[get on top of this]
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Holtec Decommissioning International. 2023. Letter from J.A. Fleming, Vice President Licensing, Regulatory Affairs & PSA, to NRC Document Control Desk, dated September 28, 2023, regarding Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82. Camden, New Jersey. ADAMS Accession No. ML23271A140. TN10538.
p.123 Holtec Decommissioning International. 2023. Letter from J.A. Fleming, Vice President Licensing, Regulatory Affairs & PSA, to NRC Document Control Desk, dated September 28, 2023, regarding Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82. Camden, New Jersey. ADAMS Accession No. ML23271A140. TN10538.
[the waste, fraud, and abuse of it all. Cite nrc commissioner crowell, feb. 2023. But even starting from scratch would still be waste, fraud, and abuse. Certinaly this ad hoc process is]
p.123
[The HDI docs dont mention many of the LARs, etc.]
MDEQ (State of Michigan Department of Environmental Quality). 2014. State of Michigan Department of Environmental Quality, Permit No. MI0001457, Authorization to Discharge Under the National Pollutant Discharge Elimination System. Lansing, Michigan. TN10665.
[hows that for an Orwellian title, concept, construct]
MDHHS (Michigan Department of Health and Human Services). 2024. Letter from K. Vang, Unit Manager, Health Statistics Surveillance Unit, Environmental Health Surveillance Section, Division of Environmental Health, to D. Persky, Health Of"cer, Van Buren/Cass District Health Department, dated November 15, 2024, regarding Findings of investigation of cancer incidence among residents of Covert Township, Michigan. Lansing, Michigan. ADAMS Accession No. ML25006A210. TN10866.
[they are blind to it. They are a part of the problem. They are a rear guard.]
p.124 MDNR (Michigan Department of Natural Resources). 2024. Invasive Species: Identify and Report. Lansing, Michigan. Accessed June 11, 2024, at https://www.michigan.gov/invasives/id-report. TN10737.
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[humans. But most especially Europeans. Compare to Winona laduke on John muir at yosemite, and her criticism of mr. 350.org]
p.124 MEGLE (Michigan Department of Environment, Great Lakes, and Energy). 2022. Renewable Operating Permit Staff Report, Holtec Palisades, LLC, Palisades Nuclear Plant. MI-ROP-B2934-2019a, Covert, Michigan. TN10667.
[there are no renewables involved. Thats the problem. Why wasnt gov. Granholms off-shore wind report included as part of the alternatives analysis?! There are no alternatives to this restart scheme! how absurd is that?! Renewables are the future, if we are to have a future.]
p.128 NRC (U.S. Nuclear Regulatory Commission). 1991. Letter from B.A. Boger, Director, Division of Reactor Projects III/IV/V, Of"ce of Nuclear Reactor Regulation, to G.B. Slade, Plant General Manager, Palisades Nuclear Plant, dated February 21, 1991, regarding Issuance of Full-Term Operating License DPR Palisades Plant (TAC No. 11218). Washington, D.C. ADAMS Accession No. ML020810482. TN11017.
[what were the reasons why a 20-year provisional license, 1971 to 1991? b/c it was a lemon from tne start? Cite consumers power v. Bechtel lawsuit. $300 M sought. $13 M in out of court settlement. Adjust for in"ation.]
p.130 NRC (U.S. Nuclear Regulatory Commission). 2022. Letter from S.P. Wall, Senior Project Manager, Plant Licensing Branch III, Division of Operating Reactor Licensing, to P.P. Oneid, Senior Vice President and Chief Nuclear Of"cer, Holtec International, Krishna P. Singh Technology Campus, dated June 28, 2022, regarding Palisades Nuclear Plant and Big Rock Point Plant - Issuance of Amendment Nos. 129 And 273 Re: Order Approving Transfer of Licenses and Conforming Administrative License Amendments (EPIDS L-2022-LLM-0002 AND L-2020-LLM-0003). Washington, D.C. ADAMS Accession No. ML22173A179. TN10545.
[provisional staff decision? But nrc commissioners "nalized it on July 15, 2022. We met short 20 day deadline to intervene on feb. 24, 2021. Nrc kept us waiting 1 year and 5 months, without a peep, even though I asked at annual perf review. Staff said be patient, we must wait for commissioners to make decision/rule. Of course staff acted "rst. Then nrc commissioners told us to go jump in a great lake. Even though MI AG got partially admission in secretive process, behind closed doors, she bashed nrc processes in joint friend of the court with NM re CISFs, recently]
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p.131 NRC (U.S. Nuclear Regulatory Commission). 2024. Letter from T. Smith, Acting Deputy Director, Division of Rulemaking, Environmental, and Financial Support, Of"ce of Nuclear Material Safety and Safeguards, to R. Blanchard, Tribal Chairman, Bad River Band of the Lake Superior Tribe of Chippewa Indians (Wisconsin); W. Gravelle, President, Bay Mills Indian Community; C.J. Chavers, Tribal Chairwoman, Bois Forte Band (Nett Lake) of the Minnesota Chippewa Tribe; H. Baker; Chairman, Chippewa Cree Indians of the Rocky Boys Reservation of Montana; J. Barrett, Chairman, Citizen Potawatomi Nation; J.A. Crawford, Chairman, Forest County Potawatomi Community; R. Deschampe, Chairman, Grand Portage Band of Lake Superior Chippewa; S. Witherspoon, Chairwoman, Grand Traverse Band; K. Meshigaud, Chairperson, Hannahville Indian Community; L.D. Taylor, Chairman, Lac Courte Oreilles Band of Lake Superior Chippewa; J.D. Johnson, Sr., President, Lac du Flambeau Band of Lake Superior Chippewa Indians; J. Williams Jr., Chairman, Lac Vieux Desert Band of Lake Superior Chippewa Indians; F. Jackson, Sr., Chairperson, Leech Lake Band of Ojibwe; L. Romanelli, Ogema Little River Band of Ottawa Indians; R. Gasco, Chairperson, Little Traverse Bay Bands of Odawa Indians; B. Peters, Tribal Chairman, Match-e-be-nash-she-wish Band of Pottawatomi Indians; G. Kakkak, Chairwoman, Menominee Indian Tribe of Wisconsin; D.G. Lankford, Chief, Miami Tribe of Oklahoma; M. Benjamin, Chairperson, Mille Lacs Band of Ojibwe; D. Rios, Chairperson, Nottawaseppi Huron Band of the Potawatomi; K. Dixon, Chief, Ottawa Tribe of Oklahoma; M.J. Wesaw, Chairman, Pokagon Band of Potawatomi Indians; J. Rupnick, Chairman, Prairie Band Potawatomi Nation; G. Johnson, President, Prairie Island Indian Community; J.D. Joaquin, President, Quechan Tribe of the Fort Yuma Indian Reservation (California and Arizona); N. Boyd, Chairperson, Red Cliff Band of Lake Superior Chippewa Indians (Wisconsin); D.S. Sr., Chairperson, Red Lake Band of Chippewa Indians (Minnesota);
T. Davis, Chief, Saginaw Chippewa Indian Tribe of Michigan; T. Fowler, Chairperson, Saint Croix Chippewa Indians of Wisconsin; A. Lowes, Chairperson, Sault Ste. Marie Tribe of Chippewa Indians; J. Azure, Chairperson Turtle Mountain Band of Chippewa Indians (North Dakota); and M. Fairbanks, Chairperson, White Earth Band of Minnesota Chippewa Tribe; dated November 4, 2024, regarding Area of Potential Effects Noti"cation and Continuing Section 106 Consultation for the Environmental Review of Holtec Decommissioning International, LLCs Licensing and Regulatory Requests for Reauthorization of Power Operations at Palisades Nuclear Plant (EPID Number: L-2024-LNE-0003) (Docket Number: 50-255). Washington, D.C.
ADAMS Accession Package No. ML24292A044. TN10840.
[keegan mentioned having all their emails and may have shared them already]
[what tribes are missing? Trip them up on this? Sauk and Fox, for one. But others too. Compare Kraesl art gallery list. What about Huron? What about Grand River Band of Odawa?
What about Canadian tribes? Since these tribal nations straddle the US/Canadian border, and are sovereign Indigenous Nations, why doesnt NRC have to notify them, too? What about the Western Shoshone, who could well be targeted again by NRC and DOE for the US HLRW dump? Skull Valley? All the tribes impacted by the CISFs. NRC
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should be fully aware of all of this, since they are central to licensing all these dumps.
Nuclear RACISM Commission.]
p.132 NRC (U.S. Nuclear Regulatory Commission). 2024. Memorandum from L. Willingham, Project Manager, Environmental Project Management Branch 3, Division of Rulemaking, Environmental, and Financial Support, Of"ce of Nuclear Material Safety and Safeguards, to D.
Barnhurst, Branch Chief, Environmental Project Management Branch 3, Division of Rulemaking, Environmental, and Financial Support, Of"ce of Nuclear Material Safety and Safeguards, dated August 12, 2024, regarding Summary of Public Scoping Meeting Related to the Potential Reauthorization of Power Operations for the Palisades Nuclear Plant (EPID Number: L-2024-LNE-0003) (Docket Number: 50-0255). Washington, D.C. ADAMS Accession Package No.
ML24221A033. TN10605.
[part of the rapid "re check the box exercise. I had to get my ass to benton harbor so often, for months on end. Technical mtgs too, but every other month for 2 years. Just on restart. I missed most to all of the SMR mtgs]
[re: covert history, compare cass county underground railroad storiescultural heritage put at risk, and completely ignored EJ issue]
p.138 Seema Verma, PNNL PhD Biological Sciences MS Biosciences BS Zoology Graduate Certi"cate in Regulatory Sciences 2.5 years of experience in navigating Federal agency regulations including Title 10 Code of Federal Regulations. Assessment of human health impacts from nonradiological contaminants and etiological agents for nuclear and renewable energy
[documents how complex this shit is]
p.135 APPENDIX A LIST OF PREPARERS
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[professional liars, damn liars, and statisticians. Well paid ones at that. Quote upton sinclair.]
p.143 APPENDIX C APPLICABLE LAWS, REGULATIONS AND OTHER REQUIREMENTS It is the NRCs policy to make sure that nuclear power plants are operated in a manner that provides adequate protection of public health and safety and protection of the environment through compliance with applicable Federal and State laws, regulations, and other requirements, as appropriate.
[seems like an admission that states should have say over radiological safety and health too, not just nrc]
p.143 In addition to carrying out some Federal programs, State legislatures develop their own laws.
State statutes can supplement, as well as implement, Federal laws for the protection of their air, surface water, and groundwater resources. State legislation may address solid waste management programs, locally rare or endangered species, and historic and cultural resources.
[stupidly, nrc cites mi so-called clean energy law mandates as purpose and need for zombie reactor restart scheme. Elections have consequences, becuase laws do, as does end of rule of law. Our mis-leaders got us in this mess, and so many others as well. But we let them, we enabled them. look in the mirror right?! Compare Harlem students on envt.
earlham book what an outrage blame the victim]
p.144 C.1 Federal and State Requirements The Palisades Nuclear Plant (Palisades) is subject to various Federal and State requirements.
As a convenient source of references of environmental requirements, Table C-1 below lists principal Federal and State approvals necessary for the resumption of power operations at Palisades.
[which ones can we block to block restart? = strategy and tactics]
Atomic Energy Act, (42 U.S.C. 2011
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et seq.)
[Judy J said we have to change the laws of the land to address these problems. Indeed we do.
That assumes rule of law, more recently in doubt going forward.]
p.144 Current operating license National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.)
NEPA requires Federal agencies to integrate environmental values into their process by considering the environmental impacts of proposed Federal actions and reasonable alternatives to those actions. NEPA establishes policy, sets goals (in Section 101), and provides means (in Section 102) for carrying out the policy. NEPA Section 102(2) contains action-forcing provisions to ensure that Federal agencies follow the letter and spirit of the Act. For major Federal actions signi"cantly affecting the quality of the human environment, Section 102(2)(C) of NEPA requires Federal agencies to prepare a detailed statement that includes the environmental impacts of the proposed action and other speci"ed information.
[nrc and does compliance with this is a joke in this EA. The alternatives section is a bad joke.
The purpose and need statement is simply self-ful"lling that alone is a violation of NEPA "nd citation]
NEPA Section 102(2) contains action-forcing provisions to ensure that Federal agencies follow the letter and spirit of the Act.
[yeah right thats NOT working! Not int his EA!]
For major Federal actions signi"cantly affecting the quality of the human environment, Section 102(2)(C) of NEPA requires Federal agencies to prepare a detailed statement that includes the environmental impacts of the proposed action and other speci"ed information.
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[the impacts analysis in this EA is also a bad joke willful blindness ]
p.145 Current operating license 10 CFR Part 20 Regulations in 10 CFR Part 20, Standards for Protection Against Radiation, establish standards for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC. These regulations are issued under the AEA and the Energy Reorganization Act of 1974, as amended. The purpose of these regulations is to control the receipt, possession, use, transfer, and disposal of licensed material by any licensee in such a manner that the total dose to an individual (including doses resulting from licensed and unlicensed radioactive material and from radiation sources other than background radiation) does not exceed the standards for protection against radiation prescribed in the regulations in this part.
[why do US workers have 5 R/yr dose limit, while their intl colleagues have a 2 R/yr limit?
Compare US govt human radiation experitmention report under Clinton and OLeary Compare PAGs at EPA, signed by Gina McCarthy on Obamas last day in of"ce!]
p.145 Current operating license 10 CFR Part 51 Regulations in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, contain the NRCs regulations that implement NEPA.
[theyve made a mockery of their own implementing regulations, and certainly of NEPA itself]
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The CAA is intended to protect and enhance the quality of the Nations air resources so as to promote the public health and welfare and the productive capacity of its population.
[productivity gods will! Protestant work ethic]
CAA Section 112 requires speci"c standards for release of hazardous air pollutants (including radionuclides). These standards are implemented through plans developed by each State and approved by the EPA.
[must be why nuke industry is so in control of radiation and indoor air of"ce at epa they comprise it, and control it their people run it; the industry runs it; completely captured cite PAGs above big boy pants comment the industry runs the agencies; the industry owns them; regulatory staff hope to get more lucrative jobs within industry, if they can win favor, impress with their rubberstamping abilities]
p.146 Air quality protection Natural Resources and Environmental Protection, Act 451 of 1994, Section 5506(1)
After the established compliance date, any source required to obtain a Title V operating permit under Section 502(a) of the Clean Air Act may not operate unless it holds a valid permit issued by the department.
[sounds like nrc does NOT have exclusive jurisdiction over radiologica health?!]
Air quality protection Natural Resources and Environmental Protection Act, Act
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451 of 1994, Section 5508 Under Michigan law, sources or equipment regulated by Federal air toxics standards under Section 112 of the Clean Air Act are exempt from state requirements for best available control technology for toxics or hazardous air pollutants.
[is this a federal or state law. Which department above? If Im reading this right, mi law is much weaker than federal law due to this exemption. How can federal law allow such a loophole?]
p.147 CWA NPDES The EPA is authorized under the CWA to directly implement the NPDES program; however, the EPA has authorized many States to implement all or parts of the national program
[which is the case here remember oct 2024 public comments to MI EGLE]
Water-resources protection Coastal Zone Management Act of 1972, as amended (16 U.S.C. 1451 et seq.)
Congress enacted the CZMA in 1972 to address the increasing pressures of over-development upon the Nations coastal resources. The National Oceanic and Atmospheric Administration administers the CZMA. The CZMA encourages States to preserve, protect, develop, and, where possible, restore or enhance valuable natural coastal resources such as wetlands, "oodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the "sh and wildlife using those habitats. Participation by States is voluntary. To encourage States to participate, the CZMA makes Federal "nancial assistance available to any coastal State or territory, including those on the Great Lakes, as long as the State or territory is willing to develop and implement a comprehensive coastal management program.
[voluntary?!]
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p.148 Water-resources protection Safe Drinking Water Act of 1974 (42 U.S.C. 300(f) et seq.)
The SDWA was enacted to protect the quality of public water supplies and sources of drinking water and establishes minimum national standards for public water supply systems in the form of maximum contaminant levels for pollutants, including radionuclides. Other programs established by the SDWA include the Sole Source Aquifer Program, the Wellhead Protection Program, and the Underground Injection Control Program. In addition, the SDWA protects underground sources of drinking water from releases and spills of contaminants.
[arnent private wells a major loophole no standards whatsoever?!]
p.149 Waste management and pollution prevention Nuclear Waste Policy Act of 1982 (42 U.S.C. 10101 et seq.)
The Nuclear Waste Policy Act provides for the research and development of repositories for the disposal of high-level radioactive waste, spent nuclear fuel, and low-level radioactive waste. Title I includes the provisions for the disposal and storage of high-level radioactive waste and spent nuclear fuel.
Subtitle A of Title I delineates the requirements for site characterization and construction of the repository and the participation of States and other local governments in the selection process. Subtitles B, C, and D of Title I deal with the speci"c issues for interim storage, monitored retrievable storage, and low-level radioactive waste.
[ironic they list this. SCOTUS on 3/5 re: CISFs]
Waste management and pollution prevention
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Low-Level Radioactive Waste Policy Act of 1980, as amended (42 U.S.C. 2021b et seq.)
The Low-Level Radioactive Waste Policy Act amended the AEA to improve the procedures for implementation of compacts that provide for the establishment and operation of regional low-level radioactive waste disposal facilities. It also allows Congress to grant consent for certain interstate compacts. The amended Act sets forth the responsibilities for disposal of low-level waste by States or inter-State compacts.
The Act states the amount of waste that certain low-level waste recipients can receive over a set time period. The amount of low-level radioactive waste generated by both pressurized and boiling water reactor types is allocated over a transition period until a local waste facility becomes operational.
[ironic. DWM formed to "ght LLRW dump in MI from 8 states (7 others, plus MI). And yet nrc wont recognize DWMs standing in this proceeding?! Thats how NRC treated AFES in NM so we are in good company.]
[isnt it ironic. Nrc would not recognize AFES standing. so, nrc said, it didnt even need to deal with AFESs contentions at all. AFESs contentions were about EJ. AFES was begging NRC to be EJ compliant. NRC has long bragged about its EJ performance. This is all so Orwellian.
Recall pandemic era mtg with nrc chairman Chris Hanson he bragged up EJ, with palisades aerial photo behind him; when I challenged his assertion, he seemed shocked, shocked]
p.149-150 Uranium Fuel Cycle Environmental Standards for Uranium Fuel Cycle (40 CFR Part 190, Subpart B)
These regulations establish maximum doses to the body or organs of members of the public because of normal operational releases from uranium fuel cycle activities, including uranium enrichment. These regulations were promulgated by the EPA under the authority of the AEA, as amended, and have been incorporated by reference in the NRC regulations in 10 CFR 20.1301(e).
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[another example of epa having jurisdiction over radiological health and safety not just nrc.
water? air? this]
p.150 Protected species Endangered Species Act (16 U.S.C. 1531 et seq.)
The Endangered Species Act was enacted to prevent the further decline of endangered and threatened species and to restore those species and their critical habitats. Section 7, Interagency Cooperation, of the Act requires Federal agencies to consult with the FWS or the NMFS on Federal actions that may aect listed species or designated critical habitats.
[nrcs ea violates the spirit and letter of these species protection laws]
p.150-151 Magnuson-Stevens Fishery Conservation and Management Act, as amended by the Sustainable Fisheries 28 Act of 1996 (16 U.S.C.
1801 et seq.)
[radiogenic insertion of the #28?]
p.152 Protected Habitat Sand Dunes Protection and Management (Part 353 of the Natural Resources and Environmental Protection Act)
To protect sand dunes along the shores of Lake Michigan and Lake Superior, Michigan designated approximately 74,000 ac of dunes as CDAs. Certain activities within CDAs require a permit from Michigan EGLE, including those that change dune contours, or propose new industrial or commercial uses. For shoreline activities within CDAs, applicants should submit a Michigan EGLE/USACE joint permit application.
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[compare this to nrcs allegation that PNP is a wasteland. PNP should never have been built where it is. it has done forever damage to the critical dunes area in the midst of which it was built. And now they want to compound the damage with 2 new SMRs]
p.152 C.2 Operating Permits and Other Requirements
[again, strategically, which card(s) to knock out to bring the whole house down?]
Renewed Facility Operating License NRC DPR-20 03/24/2031 Operation of Palisades(a)
(a) Currently, the Renewed Facility Operating License at Palisades exists but only allows authorization for decommissioning and associated activities, not for power operations or fueling of the reactor.
[Renewed Facility Operating License authorizing Operation of Palisades(a)
Is shown NOT to be the case, once you read the footnote! So NRC engages in deception, misleading, and obfuscation, yet again. Keep the public confused with "ssion and fusion.
Orwellian. Not plain English. Doesnt law require plain English?]
p.153 Management of the industrial sites storm water runo and storm water inspection program
[radioactive radiogenic apoptosis of the apostrophe mark]
p.154
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DNR = Department of Fish and Wildlife
[inaccurate, right? DNR = Department of Natural Resources, it would seem?]
EGLE = Michigan Department of Environmental, Great Lakes, and Energy
[inaccurate]
p.155 Rev. Edward Pickney
[misspelled Pinckneylook up spelling]
p.156 Grand River Bands of Ottawa Indians
[i dont remember them being listed above, as noted there]
p.157 Prairie Band Potawatomi Nation
[wasnt prairie island also mentioned above? But not here?]
Quechan Tribe of the Fort Yuma Indian Reservation
[why are they listed?]
Table D-1 List of Agencies, Organizations, Indian Tribes, and Persons Contacted by NRC during the Environmental Review of the Draft Palisades Nuclear Plant Environmental Assessment p.155 and following
[compare to list above, especially re: Indigenous Nations]
p.159 APPENDIX E CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE Table E-1 Environmental Review Correspondence for the Resumption of Power Operations Activities at Palisades 02/01/2023
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Holtec Decommissioning International, LLC Letter described regulatory path to reauthorize power operations at the Palisades Nuclear Plant ML23032A399
[tail wags the dog holtec tells nrc what to do If this is the case, why was wet lay up for SGs not implemented till may 2024?!
In fact, holtec and whitmer publicly announced holtecs restart scheme on 9/9/22 why was wet lay up for SGs not implemented till may 2024?]
In fact, whitmer "rst "oated the trail balloon for restart on 4/20/22 holtec acquired PNP on 6/28/22 why didnt entergy implement wet lay up for SGs at holtecs (and whitmers) request immediately upon permanent shut down on 5/20/22? Given all this, why wasnt SG wet lay up implemented till may 2024?!]
11/27/2023 U.S. Nuclear Regulatory Commission Memorandum for the Palisades Restart Panel Charter ML23297A053
[where it said, PNP WILL be restarted that is the mandate no ifs, ands, or buts]
p.160 04/03/2024 Holtec International Presentation on Palisades Construction Permit Application:
Initial Environmental and Site Characterization for Small Modular Reactors ML24086A582
[nearly two years after Krishna Singh "rst "oated the idea]
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p.160 06/21/2024 Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians Response to U.S. Nuclear Regulatory Commission email Notifying of Activities Regarding the Palisades Restart ML24214A066
[read this! This entry appears to be out of chrono order]
p.162 07/01/2024 U.S. Nuclear Regulatory Commission Letter initiating the scoping process to prepare an environmental assessment to the Michigan Department of Environment, Great Lakes and Energy (Kalamazoo District Oce)
[i didnt even know about the existence of this oce]
07/01/2024 U.S. Nuclear Regulatory Commission Letter initiating the scoping process to prepare an environmental assessment to the Michigan Department of Natural Resources (Fisheries Division)
[this may explain that mistranslation of the DNR acronym not far above]
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p.165 07/01/2024 U.S. Nuclear Regulatory Commission Letter initiating the scoping process to prepare an environmental assessment to the Prairie Island Indian Community ML24183A151
[its mentioned here. Its mentioned above. But skipped in the section in between, as I noted not far above.]
p.171 APPENDIX F CLIMATE CHANGE AND GREENHOUSE GASES F.1 Affected Environment The U.S. Nuclear Regulatory Commission (NRC or Commission) has determined climate change may alter the affected environment described in Section 3 of this environmental assessment (EA) during the period of preparation for the resumption or power operations or resumption of power operations at the Palisades Nuclear Power Plant (Palisades) (the renewed operating license issued in 2007 expires in 2031). Climate change is a global phenomenon, and the activities associated with the continued operation of Palisades are not expected to appreciably alter these trends. However, climate change may create a new environment that could result in changed impacts from the ongoing operations or impose operational restrictions on the sites safety and performance. This section documents the NRC staffs assessment of the potential effects of climate change on its evaluation of the environmental impacts of the proposed continued operation of Palisades.
[the highlighted sentence seems to undermine/contradict the purpose and need statement, which is that Palisades' restart is to ful"ll the MI clean energy law (never mind that nuclear power is not clean). The next sentence after the highlight admits there could well be trouble brewing for Palisades, from climate chaos induced extreme weather]
Climate change projections in the latest USGCRP reports (i.e., NCA5) cover the period through 2100 and are generally expressed as a change expected for the mid-21st century (e.g., 2036-2065) or late 21st century (e.g., 20712099) relative to average conditions existing in the near-present (19912020). These projections are relevant to the evaluation of Palisades continued operation, particularly as the plant proposes to operate until 2031.
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[but this is of course willfully blind to PNPs stated intent to apply for a 2031-2051 license extension, not to mention two SMR-300s, which could operate past 2100]
p.172 These temperature changes have implications for energy demand and infrastructure: under a very high emissions scenario, the annual electricity demand is projected to increase by 40-50 percent from 2020 to 2050, while rising air temperatures are expected to reduce summer transmission line capacity by 6 percent in the region.
[thats a vicious cycle!]
[Much of Appendix F would seem to bolster Arnie's climate related contentions, especially this passage on p. 172 of 242 on PDF counter:]
Beyond atmospheric warming, Lake Michigan's summer surface water temperatures have also been rising. From 1980 to 2021, the July to September average surface temperature of Lake Michigan increased by about 0.1°F (0.05°C) per year (USGCRP 2023-TN9762), and further increases are anticipated. Other observed changes in the Great Lakes region include increased variability in lake levels, higher evaporation and water temperatures, more intense precipitation events (including lake-effect snow), and shorter durations of snow and ice cover.
F.3 Environmental Consequences of Preparation to Resumption of Power Operations and the Resumption of Power Operations
[badly worded not good English for might have worked, but not to]
p.173 Starting from the table (NRC 2018-TN5405) that identi"es plausible connections between nuclear power station resource area concerns and likely climate change-caused alterations to the existing environment, the NRC staff generated a resource table speci"c to the Palisades region by removing irrelevant USGCRP climate impacts and NRC resource area issues from the master table. For example, climate impacts related to sea level rise were removed because of the sites inland location.
[well, it may be inland, but it is on the shore of the Great Lakes, which could well also rise, with all that increased precipitation NRC just admitted to just above]
p.173
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p.173 This suggests that, although winter and spring "ooding may pose signi"cant challenges, drier summer conditions are likely to persist, potentially affecting water availability in the region.
[water unavailability, in the Great Lakes State?! Just ask Flint, Benton Harbor, etc.]
The NRC staff used the site-speci"c resource table (PNNL 2024-TN10878) to assess whether the potential effects of climate change would alter the environmental impacts of the proposed action described in Section 3 of this EA.
The NRC staff concluded the expected impact determinations (not signi"cant) assigned in Section 3 of this EA would not be altered by the projected effects of climate change. The NRC staff provides the following resource-speci"c justi"cations.
[what about extreme weather risks of reactor core meltdown? Pool "re? Even dry cask storage pad failure, as into Lake Michigan major "ooding impact]
[landsmans warning in feb. 1994 was of earthquake risks. But what about beach/dune erosion due to "ood, including tsunami wave? Not only underwater submersion risk, but also burial under sand risk]
Land Use and Visual Impacts Projected climatological changes are not expected to impact land use or visual resources at Palisades. Changes in temperature and humidity could slightly alter the visual appearance or frequency of vapor plumes from the cooling towers, but the staff does not expect that those changes would be noticeable because vapor plumes from operation are an occasional occurrence under certain atmospheric conditions and winds off the lake can dissipate plumes p.174 close to the ground. Other visual impacts of operating the plant, would not substantially be affected by climate change. The sites industrial zoning remains appropriate, with no reclassi"cation needed, even as regional ecological plans evolve to address climate changes.
Access to land and water resources, including Lake Michigan, will remain stable, with only minor access restrictions possible if lake levels "uctuate. Overall, land use and zoning designations at Palisades are expected to remain consistent, with no major construction anticipated due to climate-related factors. The NRC staff expects that climate change would not alter conclusions made in this EA.
[this makes no sense. NRC = Nobody Really Cares. What about historic high Lake levels in spring 2020? Major erosion took place not far from Palisades. Of course, erosion at Palisades could implicate such safety-signi"cant SSCs as dry cask storage, other radioactive waste facilties, and even the reactor(s). As weve communicated to NRC numerous times in the past,
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the sand dunes at Palisades are very vulnerable to blow outs. Extreme weather, such as "ooding, high winds, etc., due to climate chaos, could in"ict major damage to PNP, implicating health, safety, security, and the environment out to great distances.]
Meteorology and Air Quality Climatological changes may have a minor impact on air quality and meteorology during the resumption of power operations. Projected increases in temperature, humidity, and lake surface water temperature could lead to a small increase in the aerosol concentrations within the cooling tower plume; however, this impact is expected to be minor as the substantial majority of aerosol concentrations in the plume are directly attributable to plant operations and are not signi"cantly in"uenced by environmental conditions. Similarly, air quality impacts may see a slight increase in ground level ozone levels but are not signi"cant enough to change the overall impact assessment as the precursor emissions attributable to Palisades are minimal. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[extreme weather, including extreme meteorology, due to climate change could prove disastrous to and at PNP. Arnies expert witness declaration rebtus this.]
Water Resources Midcentury climatological changes, including increased winter and spring runoff and warmer Lake Michigan surface temperatures, may slightly alter surface runoff and in"ltration patterns in southwest Michigan. However, these changes will be managed under applicable State and Federal water quality standards, such as the National Pollutant Discharge Elimination System permit, with best management practices in place. Although variability in Lake Michigan water levels and ice cover may occur, the volume of ef"uent discharges from Palisades will remain minimal compared to the lakes capacity, resulting in no signi"cant impact on water quality or ice cover. Water use by Palisades is projected to remain minor relative to Lake Michigans total availability, with no substantial effect on regional water resources or other users. Climate change is not expected to have a signi"cant change in the consumptive water use for the cooling towers because evaporation from the cooling towers might increase under a warming climate but would not be distinguishable from an inter-and intra-annual variability in current evaporation amounts. Climate change would have a minor impact on the volume of intake water because the warming experienced at the depth of the intake structure, 35 feet below, would be negligible especially when compared to the heat load removed by plant systems. Thus, despite probable shifts in hydrology due to climate projections, Palisades resumption of power operations are required to comply with environmental regulations, resulting in minimal impact on water quality and availability. The NRC staff expects that climate change would not alter conclusions made in this EA.
[climate change could in"ict LARGE impacts on PNP, meaning large impacts on Lake Michigan and the Great Lakes downstream, and all who depend on them. Rising Lake levels could alter
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"ow dynamics at and around PNP. Radioactive contamination could "nd fast "ow pathways into groundwater, and/or the Lake, both of which are drinking water supplies. Fisheries in the Lake could experience bioaccumulation of radioactivity. Irrigation water, whether drawn from groundwater or the Lake, could contaminate the food supply. Apex predators on the food chain, from humans to eagles and other carnivourous wildlife, would then be exposed to the worst, bioaccumulated doses.
Radioactive contaminants from PNP do not dilute in Lake Michigan, they build up. They are arti"cial, not natural. Arti"cial tritium doesnt dilute, it builds up. It should not be there in the "rst place. And it also bio-accumulates/magni"es/concentrates.
Ecological Resources Projected increases in temperature and precipitation are not expected to substantially alter how Palisades affects the terrestrial habitats on the site and surrounding landscape. Climate changes could potentially alter the hydrology of wetlands in the area, including potentially suitable habitat for the eastern Massasauga and several State-listed species, but the Palisades facilities would not substantially in"uence these changes. The vegetational composition of natural upland habitats in the region could also change, potentially affecting wildlife, but the p.175 presence of the Palisades facilities would not in"uence those changes. Increased precipitation could eventually allow more mesic vegetation and invasive plants to establish in the specialized open dune habitat presently suitable for Pitchers thistle, but the Palisades facilities would not alter the dynamics of that change. If climate changes alter the water elevation in Lake Michigan, the width and littoral dynamics of the beaches in the region could change, affecting habitat for the rufa red knot and piping plover. However, the presence of the Palisades facilities would only in"uence the directly adjoining beaches, which have already been too heavily disturbed by armoring to provide suitable habitat for these species.
Projected increases in temperature and precipitation are not expected to signi"cantly impact Palisades' effect on the aquatic ecology of Lake Michigan. The plants in"uence extends to less than 0.0006 percent of the Lake, and potential changes in water levels or minor temperature increases have not historically resulted in notable ecological impacts. While a slight warming of Lake Michigan may affect biodiversity and food web dynamics, the localized discharges from Palisades, which affect a small area, are unlikely to cause noticeable changes to the broader aquatic ecosystem. Additionally, because the volume of water moving through the screen would not noticeably increase, any increases in impingement and entrainment would not be noticeable. Climatological changes may bene"t invasive species more tolerant of warmer temperatures, but Palisades limited area of in"uence is not expected to signi"cantly alter the presence of such species. Enhanced coordination for aquatic resource protection may be needed, but the overall impact on aquatic ecology remains minimal. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[Palisades has had a LARGE impact on ecological resources since 1967. Climate change adds its own LARGE impacts on an ongoing basis. Indigenous species are being extirpated. Extinction
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rates will increase, due in part to Palisades impacts, as well as to the impacts of climate change.
NRC shrugs off these LARGE impacts, in violation of NEPA.]
Historic and Cultural While rising temperatures and increased runoff during spring and winter could potentially expose additional historical and cultural resources at the Palisades site, no impacts from climatological changes are expected on currently identi"ed resources. There are no historic properties or other historic and cultural resources identi"ed within the area of potential effects.
Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[If increased runoff due to climate change were to expose burials, or buried cultural sites, this would be a MAJOR impact on those Indigenous sacred sites. Again, how can NRC downplay this?]
[hard look, v. Hardly a look]
Socioeconomics The resumption of operations at Palisades is not expected to have a signi"cant impact on local socioeconomic factors, including housing, public schools, recreational resources, emergency services, or transportation infrastructure. Although southwest Michigan may face increased rainfall and "ood risks midcentury, potentially challenging transportation resilience, the plant's operations are not anticipated to affect these infrastructure systems. Impacts on employment, income, output, and tax revenue are projected to remain stable, with no additional climate change mitigation measures required. Therefore, anticipated climatological changes are unlikely to alter the established socioeconomic impacts for Palisades. The NRC staff expects that climate change would not alter conclusions made in this EA.
[i thought jobs jobs jobs was purportedly part of the purpose and need, at least in the words of gov. Whitmer and energy secy granholm on march 27, 2024, before, and since? And what about DOEs so-called Community Bene"ts Plan? But now socioeconomics will barely notice PNPs restart? Proponents of restart cant have it both ways.
Low income and/or people of color communities will be disproportionately impacted by climate change. They already are so by PNP. So the synergism of the two in the local region will be a double-whammy on these vulnerable communities.]
p.175 Environmental Justice The EJ analysis for the Palisades site found no signi"cant subsistence behaviors, cultural practices, or resource dependencies within the EJ affected environment. Although combined stressors from pollution, climate change, and the resumption of power operations could potentially exacerbate health disparities, the assessment projects these effects as not p.176
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disproportionately high and adverse. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[NRC EJ practices, and analyses, are themselves a violation of EJ. This has long been the case, and given this EA, still is. Palisades is a LARGE EJ violation. So too is climate change, as exacerbated by not only Palisades owners fossil fuel divisions (Consumers Energys, Entergys, and even Holtecs), but also exacerbated by the climate mitigation opportunity costs that PNPs zombie reactor restart, and SMR new builds, represents.]
Human Health, Waste Management, Transportation and Accidents Projected midcentury climate changes could in"uence the prevalence of etiological agents and occupational health risks; however, existing worker protection regulations are expected to remain effective or adapt as necessary. Climate change is not anticipated to alter operational noise levels at Palisades, so noise-related impacts should remain unchanged. While potential impacts from electromagnetic "elds are uncertain, regulatory measures are expected to adjust to maintain occupational and public safety. Overall, nonradiological health impacts, including noise, etiological agents, and occupational risks, are projected to remain minimal. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[is the plan to make a plan, or the vague promise to make a plan, a good enough hard look under NEPA? Or hardly a look punting, kicking the can down the road, deferring to the future]
Climatological changes are not expected to impact radiological exposure levels or doses for humans or non-human biota at Palisades. Ongoing compliance with radiological regulations will ensure the safety of workers, the public, and the environment through established monitoring protocols and exposure limits. Consequently, the radiation health impacts outlined in this environmental assessment are anticipated to remain unchanged. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
[extreme weather due to climate chaos causing a meltdown would contradict this. So too accelerated "ows of radioactive and toxic chemical contamination into the Lake, or aquifers, due to rain bombs, "ooding, forest "res, etc., made more frequent and worse by climate change]
p.176 Projected climatological changes are not anticipated to affect nonradiological health, nonradiological waste, transportation of radioactive materials, or the likelihood of accidents at Palisades. Noise, etiological agents, and occupational injury risks will continue to be regulated to ensure the protection of human health, while compliance with applicable Federal, State, and local requirements will govern nonradioactive and mixed waste management. The transportation of radioactive materials will remain mitigated through adherence to U.S. Department of Transportation regulations. Therefore, the NRC staff expects that climate change would not alter conclusions made in this EA.
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[extreme weather could well increase disaster risk, per above.
So too WCS leaking radioactivity into the Ogallala Aquifer, stemming from PNP origin radioactive wastes. HLRWs too for that matter, at ISP and/or Holtecs CISF(s).
HLRW storage at PNP itself could see increased catastrophic risks, as due to extreme weather.]
Furthermore, Palisades engineered safety features reduce the likelihood and mitigate the consequences of hypothetical accidents, as required by NRC safety regulations. As stated in the 2024 LR GEIS (2024 LR GEIS - ref):
Adaptation of nuclear power plants to climate change is addressed through the NRCs existing regulations. NRC regulations require that plant structures, systems, and components important to safety be designed to withstand the effects of natural phenomena, such as "ooding, without loss of capability to perform safety functions. Furthermore, nuclear power plants are required to operate within technical speci"cations in accordance with their NRC-issued operating license, which includes speci"cations for coping with natural phenomena hazards. Any change in technical speci"cations would require the NRC to conduct a review before allowing licensees to make operational changes because of changing environmental conditions.
Additionally, the NRC continually evaluates nuclear power plant operating conditions and physical infrastructure through its reactor oversight program to ensure ongoing safe operations If climate change happens more quickly or changes more substantially than what is currently forecasted, the NRC will evaluate the new information to determine whether any safety-related changes are needed at existing nuclear power plants.
[nrc likes to toot its own horn. But cite GAO on NRCs failures re: climate. Isnt there a Yale report that says the same thing?]
p.177 F.4 Greenhouse Gases
[cite Jacobsons expert dec at every such opportunity incorporate by reference as if fully written herein]
As described in the 2024 LR GEIS, gases found in the Earths atmosphere that trap heat and play a role in the Earths climate are collectively termed greenhouse gases (GHGs). These GHGs include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), water vapor (H2O),
and "uorinated gases, such as hydro"uorocarbons (HCFs), per"uorocarbons, and sulfur hexa"uoride. Operations at nuclear power plants release GHGs from stationary combustion sources (e.g., diesel generators, pumps, diesel engines, boilers), refrigeration systems, electrical transmission and distribution systems, and mobile sources (worker vehicles and delivery vehicles). However, the GHG emissions from nuclear power plants are typically very
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minor because such plants do not normally combust fossil fuels to generate electricity.
[and yet, GHG emissions associated with nuclear power are quite signi"cant. U fuel chain.
Forever waste management. Radioactive Carbon-14 generated by reactors. Cite Jacobson.
CFC-114 at Paducah and Portsmouth U enrichment citation 4,000 MW-e of dirty old coal, every kilowatt-hour going into U enrichment for several decades on end.
etc.]
During the resumption of operations, CO2, and a small quantity of methane and N2O will be emitted from natural gas boilers and diesel equipment as discussed for criteria pollutants. The applicant calculated these emissions for operations using standard emission factors like other pollutants (HDI 2024-TN10670: RAI-MET-6). The GHG emissions for workforce traf"c during 40 years of operations have been provided for a 1,000 MW reactor in COL/ESP-ISG-026, Appendix A (NRC 2014-TN3768). These estimates were scaled down for 7 years of operation and 800 MWe power output. Similarly, these emissions were scaled down for the projected 18-month preparations duration.
[compare Jacobsons opportunity costs analysis also, its not 2025 to 2031; its clearly planned to be 2025 to 2051, and perhaps even longer if and when they go for a 100-year license; they also neglect the SMR new builds, yet again]
The NRC staff estimated the life-cycle greenhouse gas (GHG) emissions of various activities associated with the preparations for resumption of power operations, resumption of power operations, and return to decommissioning for Palisades. The GHG emission estimates include direct emissions from the nuclear facility and indirect emissions from workforce and fuel transportation, decommissioning, and the uranium fuel cycle. The NRC staff estimated these emissions for the Palisades site using best available data from various sources.
[they probably ignored Jacobson even though he is our expert in this very proceeding. How does NRCs analyses compare to Jacobsons which they ignore?]
p.177 Section 3.12.1 of the 2024 LR GEIS discusses other sources of GHG emissions from nuclear power plants, including sulfur hexa"uoride used in electric power transmission and distribution applications (substations, circuit breakers, and other switchgear). Fluorinated gas emissions from refrigerant sources and from electrical transmission and distribution systems can result from leakage, servicing, repair, or disposal of sources. While the NRC staff does not have speci"c information for Palisades, NRC staff conservatively estimates that these gases are present in the transmission systems at Palisades as these gases are commonly used in
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transmission systems. However, even if present, they would not be signi"cant contributors to total GHGs for Palisades. This is based on the NRCs analysis presented in Section 4.12.1 of the LR GEIS that shows that the quanti"ed GHG emissions from nuclear power plant operations, when compared to annual State-level GHG emissions, or annual county-level GHG emissions, or replacement power alternatives, are orders of magnitude lower across all nuclear power plant sites presented in Table 3.12-2. Additionally, the 2024 LR GEIS found that the environmental impacts would be the same or similar at all nuclear plant sites, and that the
[false. Cite jacobson.]
p.178 impacts of GHG emissions on climate change from continued operations and refurbishment during the initial LR and SLR terms and any refurbishment activities would be SMALL.
The indirect GHG emissions from uranium fuel cycle is also provided in COL/ESP-ISG-026 Appendix A that accounts for fossil fuel combustion for centrifuge enrichment and process heat.
These emissions were also scaled down for 7 years of operations and 800 MWe for the Palisades unit.
[not 2031, but 2051, and likely beyond. What about SMRs? What about cumulative impact of Portsmouth and Paducah? What about GHG emissions associated with imports of HEU from Russia, Canada, Australia, etc.?]
Decommissioning activities include SAFSTOR workforce for a period of 40 years and demolition activities for 10 years that include emissions from fossil fuel "red equipment and workforce.
Staff included an estimate of Greenhouse Gas Emissions from decommissioning because the potential approval of the Federal actions would delay the impacts of decommissioning by up to 7 years. The decommissioning emissions for 1,000 MW power plant in COL/ESP-ISG-026 was scaled to the 800 MWe capacity of Palisades.
[also misleading. Cite 2/24/25 email to MATT.]
Table F-2 below provides the emissions estimates for each of these activities. The estimated emissions of the proposed actions are 1,444,739 MT CO2(eq)this includes emissions from preparation activities and resumption of operations. The total life-cycle emissions (which also include decommissioning) were estimated to be about 1,474,000 MT CO2(eq).
[well thats a LOT!]
Table F-2 Nuclear Power Plant Life-Cycle Greenhouse Gas Emissions Estimates for Preparation Activities at Palisades Nuclear Plant (18 months), Operations (7 years) and Decommissioning
[compare to Jacobson]
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F.5 Conclusions The NRC staff concludes that the potential effects of climate change would not alter the impact determinations in this EA for the preparation for the resumption of power operations and for the resumption of power operations at Palisades.
[we contest this false conclusion]
p.181 APPENDIX G PROJECTS CONSIDERED IN CUMULATIVE EFFECTS However, because of the uniqueness of each environmental resource area evaluated and its associated geographic area of analysis, Section 3 does not consider or explicitly evaluate every project and action listed in Table G-1.
[why not? not a hard look, rather hardly a look]
Table G-1 Projects and Actions U.S. Nuclear Regulatory Commission Staff Considered for Cumulative Effects Impact Analysis for the Resumption of Power Operations Activities at Palisades Nuclear Power
[the word Plant was radiogenically apoptosisd from the very end]
Energy Facility -
Donald C Cook Nuclear Power Plant 2,161 MWe pressurized water reactor 28 mi N Operational since 1975
[S radiogenically mutated into N.
Cook is south of PNP, not north of it. NRC really should keep better track of where gigantic NPPs like Cook are located]
p.182
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Energy Facility -
Zeeland Generating Station Power station with two natural gas combined cycle plants and two natural gas simple cycle units 40 mi N Unknown Consumers Energy.
Natural Gas Generation.
https://www.consumer senergy.com/about-us/electric-generation/natural-gas
[why is the status unknown. Is nrc that lazy? Nobody Really Cares about cumulative impacts, actually. NEPA violation, of letter and spirit of the law.]
Transmission Infrastructure -
New Buffalo Rebuild ~20 mis of power lines
~40 mi Construction expected early 2026 through Fall 2027 AEP Transmission.
New Buffalo -
Bridgman Transmission Line Rebuild Project.
https://aeptransmissio n.com/michigan/NewB
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uffalo-Bridgman/
[radiogenic mutation of the spelling of the abbreviation mi to mis also, why is the direction from Palisades not included?]
p.183 Transmission Infrastructure -
Niles Improvements including upgrades to substations and retiring, upgrading and building new transmission lines
~35 mi SE Constructed expected from 2024 through 2026 AEP Transmission.
Niles Area Transmission Improvements Project.
https://aeptransmissio n.com/michigan/Niles Area/
[construction, not constructed such sloppiness indicates/re"ects a half-hearted effort on the EA altogether]
Transmission Infrastructure -
South Cass Building new transmission lines and expanding Substation
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~40 mi Construction expected early 2025 through early 2026 AEP Transmission.
South Cass County Transmission Line Project.
https://aeptransmissio n.com/michigan/South CassCounty/
[why is direction from PNP not included?]
Transmission Infrastructure -
South Bend Rebuilding ~12 mi of transmission lines and upgrading substation
~40 mi Construction expected early 2025 through early 2026 AEP Transmission.
South Bend - Niles Transmission Line Project.
https://aeptransmissio n.com/indiana/SouthB end-Niles/
[why is direction from PNP not indicated?]
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Transmission Infrastructure -
New substations (Northridge, Jaguar, Meyer)
Multiple substations construction within 50 mi
https://www.itc-holdings.com/project-category/michigan/
[why is the direction from PNP not included?]
Brown"eld Project -
Redevelopment Development of a brown"eld from coal, lumber, and chemical storage to construction of two residential buildings, a community center, and community garden 40 mi E Ongoing Michigan EGLE.
RenewMI Project Viewer.
https://experience.arc gis.com/experience/a3 db431c6b154b87a481 e1122f726101/page/P roject-
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Viewer/?utm_campaig n=splash&utm_conten t=RenewMI-Project-Viewer-App&utm_medium=w eb&utm_source=gis-app Brown"eld Project -
Redevelopment 8 ac site contaminated with petroleum and metals to be converted to a mixed use residential/work-live development 40 mi E Ongoing Michigan EGLE.
RenewMI Project Viewer.
https://experience.arc gis.com/experience/a3 db431c6b154b87a481 e1122f726101/page/P roject-Viewer/?utm_campaig n=splash&utm_conten t=RenewMI-Project-Viewer-App&utm_medium=w eb&utm_source=gis-app
[these sound like Kzoo area projects; dicey, living and even gardening on toxic sites!]
Brown"eld Project -
Redevelopment Cleanup of a 0.89 ac site
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contaminated with petroleum related compounds for future development 40 mi E Ongoing Michigan EGLE.
RenewMI Project Viewer.
https://experience.arc gis.com/experience/a3 db431c6b154b87a481 e1122f726101/page/P roject-Viewer/?utm_campaig n=splash&utm_conten t=RenewMI-Project-Viewer-App&utm_medium=w eb&utm_source=gis-app
[this one too, per just above]
p.186 Manufacturing & Air Emission Sources -
Pharmacia & Upjohn Company, LLC Chemicals 50 mi E, Kalamazoo, Michigan Operational U.S. Environmental Protection Agency.
Greenhouse Gas Reporting Program https://www.epa.gov/g hgreporting/data-sets
[very old names for it. It is now P"zer. Has been for a long time.]
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[sand dune mining could be included above more negative impacts on fragile sand dune ecosystems, in addition to those at PNP, and Cook NPP]
- p. 187 Land"ll -
Elkhart County Solid Waste Solid waste land"ll 50 mi NE, Elkhart, Indiana Operational Elkhart County Land"ll. Land"ll Drop Off Information.
https://www.elkhartcou ntyland"ll.com/land"ll
[radiogenic mutation of directions Elkhart is SE of PNP, not NE]
p.188 Transportation -
Kalamazoo/Battle Creek International Airport Airport 40 mi, E, Kalamazoo, Michigan Operational Kalamazoo/Battle Creek International Airport.
https://"yazo.com/
[they say airport is 40 mi E. But they say P"zer is 50 mi E. Airport and P"zer are not 10 miles apart. They are single digit miles at most. About 1 mi apart Id guess. So they are an order of magnitude off on this. Not good, with 50-mile radius EPZ in play, for example. Such carelessness could cost lives in an emergency.]
[why isnt the airport just east of PNP, but mere miles if that, not listed here? Is PNP security as ignorant of that airports existence as this table would seem to indicate?]
p.188
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Transportation -
Rebuilding U.S.-131 from 76th Street to 100th St in Byron Township Rebuild freeway 20 mi, NE, Grand Rapids, Michigan Scheduled May 2024-November 2024 Michigan Department of Transportation -
U.S.-131 rebuilding-Kent County.
gov/mdot/projects-studies/us-131-kent-county
[again, GR is 50 miles from PNP, not 20 mi]
Parks/Recreation -
Van Buren State Park Day use and camping area with miles of trails
<5 mi, Van Buren County, Michigan Operational Pure Michigan. Van Buren State Park.
org/property/van-buren-state-park
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[5 mi? It is immediately N of PNP. The distance from PNP is 0 miles, technically speaking. The campground is merely hundreds of yards, if that, from PNP dry cask storage pad. Getting this distance wrong is outrageous, especially in the context of emergency planning, but also health and envl impacts from so-called normal or routine operations. How could NRC get this wrong? Not know this?]
p.189 Parks/Recreation -
North Point Conservation Area 17 area conservation area
<5 mi, Van Buren County, Michigan Operational Van Buren County.
North Point Conservation area.
https://www.vanburen countymi.gov/438/Nort h-Point-Conservation-Area
[acre, not area]
Parks/Recreation -
Black River Preserve 120 ac preserve 6 mi, Van Buren County, Michigan Operational Southwest Michigan Land Conservancy.
Black River Preserve.
https://swmlc.org/proje ct/black-river-preserve/
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[why is direction from PNP not included?]
[all of these listed parks and rec areas are at risk of ruination from a meltdown at PNP]
p.190 Parks/Recreation -
Warren Dunes State Park 1,500 ac park 32 mi S, Berrien County, Michigan Operational Department of Natural Resources Michigan.
Warren Dunes State Park.
.mi.us/parksandtrails/
Details.aspx?id=504&t ype=SPRK
[if Cook NPP is 30 miles S, how can Warren Dunes be 32 mi S. Warren Dunes is several miles NORTH of Cook; distance is wrong]
[why isnt Enbridge Oil pipeline included in this table? esp. considering impacts from July 2010 worst inland oil spill in US history into the Kzoo River]
p.193 APPENDIX H DISCUSSION OF CANCER RISKS AT AND AROUND PALISADES NUCLEAR PLANT
[incorporate by reference Mangano studies]
[also cite CRAC-II latent cancer fatality "gure]
[cite NAS LNT]
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The NRCs mission is to protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste facilities.
[well, NRC is failling miserably at this. Compare Sarah Sauers experience at Dresden/
Braidwood]
The NRCs regulations in Title 10 Code of Federal Regulations (10 CFR) Part 20 (TN283) set forth regulatory standards for radiological protection to protect workers and the public from the harmful health effects (i.e., cancer and other biological impacts) of radiation on humans.
[compare NRCs allowable worker doses to intl counterparts 5 R/yr v 2 R/yr]
The models recognized by the NRC are for use by nuclear power reactors to calculate dose incorporate conservative assumptions and account for differences in gender and age to ensure that workers and members of the public are adequately protected from radiation.
[this sentence needs some commas]
p.193 This theory is accepted by the NRC as a conservative model for estimating health risks from radiation exposure, recognizing that the model probably overestimates those risks.
[there are those who think the LNT theory understates cancer risks such as supra-linear at low doses; the Petkau Effect; etc. Also, models understating doses due to bad assumptions, mismeasurements, etc.]
Additionally, 10 CFR 20.1301(e) requires each nuclear power reactor to comply with applicable environmental radiation standards in 40 CFR Part 190 (40 CFR Part 190-TN739), such as the total annual whole body dose to a member of the public outside the facility does not exceed to 25 mrem (0.25 mSv).
[delete]
The amount of radioactive material released from nuclear power facilities is well-measured, well-monitored, and known to be very small.
[uh, not BRP more than 3 million Curies, with numerous years missing from the accounting]
The doses of radiation that are received by members of the public as a result of exposure to nuclear
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power facilities are so low (i.e., less than a few millirem) that resulting cancers attributed to the radiation have not been observed and would not be expected.
[uh, not at Chornobyl; not at Fukushima; so the radioactivity disappears into nothingness? What about bioaccumulation?]
[this section is a whitewash, and a greenwash]
[incorporate by reference:
Fairlie and Folkers; Bertell; Gofman; Makhihani; etc.]
In addition to NRCs requirements to monitor radioactive ef"uents (routine and inadvertent) discharged into the environment, the NRC requires each nuclear power plant to maintain a monitoring and surveillance program under the regulations at 10 CFR Part 50, Appendix I (TN249), such as with a radiological environmental monitoring program (REMP).
[incorporate by referece Kay Dreys pamphlet]
p.194 This implementation also measures radioactivity from other nuclear facilities that may be in the area (i.e., other nuclear power plants, hospitals using radioactive material, research facilities, or any other facility licensed to use radioactive material).
[cite radiological contamination in the stolen Jean Klock Park part of the reason boardwalks had to be incorporated through nature trails radioactive ones, that is]
p.194 To obtain information on radioactivity around the plant, samples of environmental media (e.g., surface water, groundwater, drinking water, air, milk, locally grown crops, locally produced food products, river, ocean, or lake sediment, and "sh and other aquatic biota) are collected from areas surrounding the plant for analysis to measure the amount of radioactivity, if any, in the samples.
[cite Manganos 2013 citation of EPA tritium "gure from mid-1990s]
As part of its environmental review, the NRC staff reviews REMP reports to look for adverse data or evidence of a buildup of radioactivity in the environment.
[as Barbara pellegrini has pointed out, above, radioactive discharges into Lake MI from PNP are arti"cial. They do not dilute. They build up.]
The State of Michigan conducts an independent REMP program through the Michigan
$123
Department of Environment, Great Lakes, and Energy (MEGLE 2016-TN10744). The Michigan Radiation Environmental Monitoring Program monitors ambient radiation levels, and collects
- air, water, precipitation, and milk samples from areas surrounding all of the nuclear power plants in Michigan, including Palisades.
[cites "gures for dairies from Coreys milk jugs in 1999]
This program has been operated by the State since 1958.
[b/c of Fermi 1? Phoenix/Ford research reactor at U of M?]
The collected and analyzed data is published periodically and is currently reported through 2016.
[thats nearly a decade ago now!]
p.194-195 Total cancer rates and thyroid cancer rates were reviewed on these levels from 2006 (the year of publication of the license renewal) to the most recent data available. These statistics are shown in Table H-1 H-3 below and indicate that occurrences of cancer and thyroid cancer in the area surrounding Palisades do not vary from rates regionally.
[shouldnt NRC have gone back way earlier than 2006? If by 2006 35 years after Palisades "red up, and 31 years after Cook 1 & 2 "red up, to name but three reactors on Lake MI cancer rates had already increased signi"cantly, this would skew the analysis to make higher cancer rates, caused by nuclear power, look normal or to be expected, as radiogenic cancer continued at the same high rates from 2006 to 2025. This seems methodologically "awed.
I wonder if the true extent of thyroid cancer and cancer in general at PPCC for one is hidden or masked by the cancers being recorded in the home county/state where the sufferers live for the rest of the year, while only living at PPCC (and contracting cancer due to radiation or toxic chemical releases from PNP) during the summer months?
Compare how childhood cancers in Morris, IL were hidden, on purpose, by the local pediatrician who also was a major real estate owner there he didnt want his real estate values to decrease, so he intentionally concealed childhood cancers from the records. Also, the childhood cancer specialists were in Chicago, so sometimes the cancers got recorded in Chicago, not in Morris.
The same kinds of shenanigans were played in the USSR after Chornobyl, and in Japan after Fukushima.]
Table H-1 Age-Adjusted Incidence Rate of Thyroid Cancer Per 100,000 Individuals in a
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Population in Select Michigan Counties in Over 5 Years (CDC 2024-TN10845)
[Allegan Countys thyroid cancer rate seems to have more than doubled from 2001 to 2020 what explains that?
In Berrien County, it went up by 50% between 2001 and 2015 what explains that?
Why is there no data in Cass County from 2001 to 2010, but then high rates from 2010 to 2020?
What explains the high rate in Kalamazoo County from 2006 to 2010?
For Van Buren County, again, are thyroid cancers in PPCC not even being counted as VB Co.
thyroid cancer cases, because the sufferers thyroid cancer are being recorded back in their home county, elsewhere in MI, or even in another state entirely, while the sufferers only spend the summer in PPCC?]
Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have been conducted, there are no studies to date that de"nitively demonstrate a correlation between radiation dose from nuclear power facilities and cancer incidence in the general public.
[Oh really? How about the increased childhood leukemia in Germany? The still births and sterility at La Hague in France, and Sella"eld in the UK? And how about around Chornobyl and Fukushima? How about around TMI per Steve Wing? This is a false and misleading statement by NRC.]
[Mention the canceled nuclear power-cancer causation study NRC cancelled, and the reasons why.]
The following is a listing of radiation health studies that the NRC recognizes:
- In 1990, at the request of Congress, the National Cancer Institute conducted a study of cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The study covered the period from 1950 to 1984 and evaluated the change in mortality rates before and during facility operations. The study concluded there was no evidence that nuclear facilities may be linked causally with excess deaths from leukemia or from other cancers in populations living nearby (NCI 2011-TN10889).
[methodologically "awed, according to Cindy Sauer. Also cite Joe Sauers study]
In June 2000, investigators from the University of Pittsburgh found no link between radiation released during the 1979 accident at the Three Mile Island Nuclear Generating Station and cancer deaths among nearby residents. Their study followed 32,000 people who lived within 5 mi (8 km) of the plant at the time of the accident (Talbott et al. 2000-TN10890).
[rebut with Steve Wings study]
p.197
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The State of Michigan Department of Health and Human Services, Department of Environmental Health conducted a review of the thyroid cancer statistics for the area of Covert Township in Michigan (MDHHS 2024-TN10866). The State identi"ed six instances of thyroid cancer in Covert Township from 1985 to 2021. The small number of recorded cases in a population of 2,510 was too low to conduct viable statistical analysis with other comparable locations. No temporal patterns were identi"ed with regards to thyroid cancer for the location during the review. The data was obtained from the Michigan Cancer Surveillance Program. It is important to note that part-time residents with a separate primary residence or individuals that were diagnosed after moving away from the county would not be identi"ed as individuals diagnosed in Covert Township.
[well thats a huge methodological falw then, isnt it?]
[thyroid pathology after Chornobyl an epidemic Belarus necklace cite Adi Roche]
[Gerald and Martha Drake spina bi"da near Big Rock Point 3 M Curies+ of releases compared to Sella"eld compare I-131 releases at the two mention that BNFL was contracted to do BRP decommissioning, and reported it was the most radioactively contaminated decommissioning job in its history, which is really saying something, given the history at Sella"eld]
The average occupational radiation exposure TEDE dose for the operational years 2006 to 2021 ranged from 0.09 rem to 0.39 rem (NRC 2024-TN9915). These dose results con"rm that Palisades was operating in compliance with 10 CFR Part 50 (TN249), Appendix I, 10 CFR Part 20 (TN283), and 40 CFR Part 190 (TN739) for members of the public and occupational dose limits.
[compare to the 2.8 R average dose, on a one month long job, gotten by close to 200 workers at PNP, including some women of child bearing age CRDM seal leak repair job, in 2014]
[so the studies above are mostly to entirely the ones NRC likes, and which af"rm their predetermined and desired result; the only one that seemed to indicate a problem was this one:]
Nuclear workers provide valuable information on the effects of ionizing radiation in contemporary exposure scenarios relevant to workers and the public. A 2023 article presented in the International Journal of Epidemiology titled, Ionizing Radiation and Solid Cancer Mortality Among U.S. Nuclear Facility Workers, included an analysis of greater than 100,000 nuclear workers in the United States, exposed to an average 2,650 mrem (26.5 mSv) of external penetrating ionizing radiation. This study notes that higher rates of solid cancers including lung cancers were observed for workers of "ve nuclear facilities between the years of 1944 to 2016. The analysis given in the article bolsters the body of evidence suggesting there are radiogenic risks associated with several types of solid cancers (Kelly-Reif et al. 2023-TN10917).
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[why did NRC ignore all those studies Ive listed, which is just a small number of examples that could be given? What about the Downs syndrome study in MA near Yankee Rowe? What about the many anti-nuclear groups that grew out of childhood cancer support groups, from CORE in the UK near Sella"eld, to Parents Against Santa Susan Field Lab in CA?]
ACS (American Cancer Society). 2001. Cancer Facts & Figures-1998. Atlanta, Georgia.
ADAMS Accession No. ML071640135. TN10891.
[thats nearly 30 years old!]
p.198 MDHHS (Michigan Department of Health and Human Services). 2024. Letter from K. Vang, Unit Manager, Health Statistics Surveillance Unit, Environmental Health Surveillance Section, Division of Environmental Health, to D. Persky, Health Of"cer, Van Buren/Cass District Health Department, dated November 15, 2024, regarding Findings of investigation of cancer incidence among residents of Covert Township, Michigan. Lansing, Michigan. ADAMS Accession No. ML25006A210. TN10866.
[MDHHS as rear guard for industry; compare American Thyroid Assn. compare Peter Crane.]
MEGLE (Michigan State Department of Environment, Great Lakes, and Energy). 2016.
Radiological Monitoring & Reporting. Lansing, Michigan. Accessed September 18, 2024, at https://www.michigan.gov/egle/about/organization/materials-management/radiological/monitoring#:~:text=The%20state%20of%20Michigan%20established, environment%20are%20not%20adversely%20impacted. TN10744
[this is nearly a decade old! What about 2016-2025?!]
p.199 University of Kentucky. 2014. Cancer Incidence and Mortality Inquiry System, Version 7.0, Michigan Cancer Surveillance Program. University of Kentucky/Kentucky Cancer Registry, Lexington, Kentucky. Accessed November 18, 2024, at https://www.cancer-rates.info/mi/.
TN10851.
[even if accessed last year, the data appears to be 12 years old need for updated data, eh?]
[UNSCEAR cite Alfreds critiques]
[Cite Ian Fairlies TORCH report in 2006, compare it to IAEA 93,000 deaths attributable to Chornobyl, instead of just 40 cite Yablokov, Nesterenko, and Nesterenko 986,000 deaths, just from 1986 to 2004.]
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p.201 APPENDIX I SUPPLEMENTAL INFORMATION PERTINENT TO SECTION 106 CONSULTATION AND THE HISTORIC AND CULTURAL RESOURCES REVIEW I.1 National Historic Preservation Act Section 106 Consultation The National Historic Preservation Act of 1966, as amended (NHPA) (TN4157), requires Federal agencies to consider the effects of their undertakings on historic properties and consult with applicable Federal, State, Tribal, local groups or agencies, individuals, and organizations with demonstrated interest in the undertaking before taking the action.
[thats us! Thats me!]
[protection of historic properties PNP, as monument to mans folly quoute Blue Oyster Cult Godzilla song]
12 federally recognized Indian Tribes.
[many more than that this go round yeah?]
35 federally recognized Indian Tribes
[yes indeed]
The NRC initiated consultation with the Advisory Council on Historic Preservation, Michigan State Historic Preservation Of"ce (Michigan SHPO), and 35 federally recognized Indian Tribes via a letter dated July 1, 2024, with the Michigan SHPO, the ACHP and 35 federally recognized Indian Tribes. All consultation letters are presented in Appendix E to this environmental assessment (EA), with individual contacts presented in Appendix D to this EA.
[a long and poorly written sentence]
p.201 The NRC sent a summary of the in-person site visit and information session with all federally recognized Indian Tribes on October 9, 2024.
[many hundreds, or just the 35?]
p.202
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By emails dated September 18, 2024, and October 2, 2024 (NRC 2024-TN10879), the NRC sent Holtecs archaeological survey report (SEARCH 2024-TN10846) to federally recognized Tribes for review and comment. To date, no comments regarding the archaeological report have been received. On November 4, 2024 (NRC 2024-TN10879), Holtec sent its historic and cultural resource procedures to address inadvertent discoveries and noti"cation protocols to federally recognized Indian Tribes. To date, no comments have been received.
[we helped win this victory. Larry guided us to.]
All consultation letters are presented in Appendix E to this environmental assessment (EA), with individual contacts presented in Appendix D to this EA.
[they may have been cited; they were not presented; wed have to chase them down via the ML
- , if ADAMS worked that day, it often doesnt]
On November 6, 2024, Michigan SHPO determined that the containment building could not be considered separately from the remaining parts of the Palisades facility and did not rise to the level of signi"cance required for listing in the NRHP under Criteria C for Architecture/Engineering (MI SHPO 2024-TN10844).
[ah cmon! It IS of historic signi"cance as a monument to the folly of man! Quote Godzilla song; cite the English translation of the novel incorporate by reference, as if fully written herein]
I.2 Historic Land Disturbance Photographs and Maps In 1965, Consumers Power Company and the Detroit Edison Company completed a joint study to identify suitable locations in Michigan for a proposed nuclear power plant (AEC 1972-TN10603). Of the locations studied, Consumers Power Company selected Palisades due to its location being: (1) immediately adjacent to Lake Michigan, (2) near existing and nearby railroad facilities, and (3) close to existing transmission line infrastructure. Palisades was also selected because it was the location of a former sand quarry. In 1966, grading and vegetation clearing activities began at Palisades
[watch out for sand quarries. Compare to NTS.]
p.203-204
[First two images how heartbreakinly beautiful]
- p. 205 The Palisades Nuclear Plant Site on September 6, 1966, Showing the Early Stages of Vegetation Clearing and Grading. The Original Photograph Caption States, burning trees.
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[yes how awful; bulldozing dunes, too]
p.206 Figure I-4 Heavy Equipment Operating on the Beach on the Northern Portion of the Palisades Nuclear Plant Site on September 22, 1966. Photograph Looking to the Northwest. Source: HDI 2024-TN10670.
[beach disposal beach despoilment disposal like trash, trashing it. It was essentially a wilderness, but for the quarry; PNP would make look small by comparison]
Figure I-5 Heavy Equipment Grading the Beach at the Palisades Nuclear Plant Site on October 17, 1966. Photograph Looking to the North. Source: HDI 2024-TN10670
[panoramic view was prettier before they bulldozed it]
p.207 Figure I-6 A Photograph from December 1966 Looking Southwest across the Palisades Nuclear Plant Site Showing the Extent of Land Grading Activities at That Time. Note the Cleared Vegetation and Road Cut into the Sand Dune behind the Crane. Source: HDI 2024-TN10670.
[They paved paradise and put up a parking lot Joni Mitchell]
p.208 Figure I-7 A Topographic Map Highlighting the Disposal Area along the Shore of Lake Michigan for Construction of Palisades Nuclear Plant. Source: HDI 2024-TN10670.
[disposal area earth disposal area disposing of Mother Earth despoiling Mother Earth trashing the planet, to borrow Dixie Lee Rays slogan she was a gung ho trasher of the planet]
p.209 Figure I-8 A Topographic Map Highlighting the Disposal Area along the Shore of Lake Michigan for Construction of Palisades Nuclear Plant. Source: HDI 2024-TN10670.
[such strange language for it, but revealing]
p.210
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Figure I-9 A Photograph from April 25, 1967, Looking Northeast over Palisades Nuclear Plant Site. Note the Cleared Vegetation and Road Cut into the Sand Dune to the Right of the Circular Footprint of the Future Reactor Vessel Building and the Land Grading and Vegetation Clearing along the Beach to the South of the Site. The Original Photograph Caption States, The lake is washing sand from the south disposal area. Source: HDI 2024-TN10670.
[yeah, sand from dunes and beach, before PNP destroyed all that. It took millenia to form, and a very short time to bulldoze, burn, and destroy. But they were just getting started. The radioactive and toxic chemical contamination would follow.]
p.211 Figure I-10 A Photograph from April 25, 1967, Looking Northeast over Palisades Nuclear Plant Site. Note the Cleared Vegetation and Road Cut into the Sand Dune to the Right of the Circular Footprint of the Future Reactor Vessel Building and the Land Grading and Vegetation Clearing along the Beach to the South of the Site. The Original Photograph Caption States, The lake is washing sand from the south disposal area. Source: HDI 2024-TN10670.
[whoops. Wrong caption. Just cut and pasted from the previous page. Sloppy, rushed work. Any copy editing or proofreading performed? Who got paid for this?]
p.212 Figure I-11 A Photograph from June 1968, Looking South over Palisades Nuclear Plant Site. Note the Cleared Vegetation and Road Cut into the Sand Dune to the Right of the Reactor Vessel Building and the Land Grading and Vegetation Clearing along the Beach to the South of the Site. Source: HDI 2024-TN10670.
[again, wrong caption. Photo looks east, and says so. Caption says something else. Sloppy work.]
p.214 Figure I-13 A Photograph from August 31, 1967 Looking Southeast from the Auxiliary Building Foundation of Palisades Nuclear Plant. Note the Cleared Vegetation and Road Cut into the Sand Dune behind the Crane. The Existing Transmission Pole on Top of the Sand Dune Is Located Where the Current Transmission Lines and Structures Are Located Today. The Sand Dune Has Already Undergone Revegetation. Source: HDI 2024-TN10670.
[again, caption does not match photo]
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[and how about that state park? And PPCC? These are all historic sites, worthy of protection.
PNP could take them all out.]
[no mention of this in this EA. Why not? b/c it hasnt happened? In order to protect PNP? To grease the skids for it?]
p.221 APPENDIX J ECOLOGY ANALYSES AND TABLES J.1 State-Listed Terrestrial Species The U.S. Nuclear Regulatory Commission (NRC or Commission) reviewed the information in the 2006 supplemental environmental impact statement regarding State-listed species, Holtecs exemption request (Holtec 2023-TN10538), updated lists of species known to occur in Van Buren and Berrien counties (MNFI 2024-TN10861, MNFI 2024-TN10862), and other information provided by the applicant (HDI 2024-TN10670: RAI-GEN-3, Attachment 2) and incorporates these species lists by reference. Table J-1 and Table J-2 below present the 58 State-listed species that have been observed in these two counties since 2000.
[why only Van Buren and Berrien? Why not Allegan, Cass, and Kalamazoo, at the very least?
They cited all those counties for other analyses in this same EA. NRC should be consistent in this regard, by expanding its ECOLOGY ANALYSES AND TABLES here.]
Two State-listed species have been observed at the Palisades site: the endangered prairie vole and the threatened eastern box turtle (HDI 2024-TN10670: RAI-GEN-3, Attachment 2). The prairie vole is a small rodent that has not been seen in Van Buren County since 1960 and Berrien County since 1962 (MNFI 2021-TN10874).
[so is this an admission by NRC that the construction and operation of PNP, beginning in 1967, contributed to the extirpation of the prairie vole? NRC did not speci"cy WHEN these two species were observed at the Palisades site, but saying the vole has not been seen in VB Co.
since 1960 would indicate it had already been extirpated before PNP groundbreaking? By what, the sand quarry previously operated on the PNP site?]
Table J-1 State-listed Endangered and Threatened Terrestrial Species That Are Not Federally Listed and That Have Been Observed in Berrien or Van Buren County, Michigan since 2000 Are Not Amphibians or Reptiles
[is the word And missing? And Are Not Because otherwise, it doesnt read right, and is confusing]
- p. 222
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Vascular plant Collinsia verna Blue-eyed Mary T
Moist soil rich beech-maple forests with a rich humus layer, and on levees and terraces within "oodplain forests.
[no Year Last Observed provided on this entry]
p.225 Vascular plant Primula meadia Shooting star E
Wet-mesic to mesisaic prairies and prairie fens.
2013
[what does this word mean? It is so obscure that NRC should de"ne it here]
p.226 X = Presumed Extirpated but would be treated as State Threatened.
[in key; that doesnt seem right; shouldnt it be: would be treated as State Endangered.
Threatened is less dire than Endangered. Extirpated is much more dire than Endangered.]
p.226
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Year Last Observed in Van Buren or Berrien County
[re: this, are biologists et al. looking but not seeing, or are they not looking?]
p.226 Table J-2 Amphibians and Reptiles Listed as State Endangered or Threatened That Have Been Observed in Berrien and Van Buren Counties Before 2000 or That are Listed as Species of Special Concern and Have Been Observed in Berrien and Van Buren Counties
[why not further back in time? The year 2000 was only 25 years ago. Flora and fauna have been here since time immemorial not thousands, but likely millions of years, Ice Age excluded so at least 12,000 years, right? Was MI under ice that recently? Who/what lived ON or IN the ice?]
[again, why not more counties that just these two? Including Kent, Ottawa? Consistency needed]
p.228 Reptile Terrapene carolina carolina Eastern box turtle T
Known from site (HDI 2024-TN10670 Enclosure 3, ). Forested habitats with sandy soils near a source of water such as a stream, pond, lake, marsh or swamp; adjacent thickets, old "elds, pastures, or vegetated dunes. Access to unshaded nesting sites in sandy, open areas, is critical for successful reproduction.
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[Last seen in 2021 at the site? Could this, or any other T, E, or SC species listed here, or others not listed here, be used to stop PNP restart/SMR new builds, under ESA law, for example?]
J.2 Eagles and Migratory Birds The Palisades site is located in the Mississippi "yway, an important bird migration route which extends from the Gulf Coast to the Arctic Circle. Migrant birds often "y at night, landing to rest early in the morning. Suitable habitats that allow migratory birds to feed, rest, and avoid predators are called stopovers. Large natural barriers may create crowded stopover locations because "ights over the barriers mean long stretches without opportunities to rest or feed. Along the Mississippi "yway, Hudson Bay and the Great Lakes are major barriers. Many species of migratory birds likely use the Palisades site and vicinity during the spring and fall migrations p.229 Plankton Plankton are small and often microscopic organisms that drift or "oat in the water column. In some nearshore areas, there is excessive growth of the nuisance algae Cladophora spp. and toxic blooms of cyanobacteria occur in Green Bay, Wisconsin. While cyanobacteria that produces cyanotoxins have been found in inland lakes in Michigan there were no reported blooms in Lake Michigan during 2022 or 2023 (MEGLE 2024-TN10716).
[but wont PNP restart, and/or SMRs, worsen thermal wastewater impacts, contributing to toxic blue-gree algae blooms?]
Macrophytes Aquatic macrophytes are large plants, both emergent and submerged, that inhabit shallow water areas. Macrophytes within Lake Michigan include duckweed, cattails, and rushes. The U.S. Environmental Protection Agency Coastal Wetland Monitoring Program considers the coastal wetland vegetation in the southeast side of Lake Michigan to be degraded but less so when compared to plant communities in Lakes Ontario and Erie (EPA 2023-TN9721). The U.S. Environmental Protection Agency attributes this to less nutrient runoff and less invasive species as compared to the other Great Lakes. The areas directly adjacent to Palisades Nuclear Plant (Palisades) are sandy beaches, suggesting a relatively high-energy shoreline without much, if any, terrestrial vegetation.
[well of course there are dune grasses and even forests, just inland from the Lake]
p.229-230 Benthic Invertebrates
[quagga and zebra mussels are an excuse PNP uses for biocides that harm Lake Michigan]
p.230 Juvenile and Adult Fish
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The Michigan Department of Natural Resources (MDNR) is responsible for managing "sheries in the State and Palisades is located within the Southern Lake Michigan Management Unit.
Managed "sheries in the vicinity of the plant include trout (brown [Salmo trutta], non-native rainbow [Oncorhynchus mykiss], and steelhead [Oncorhynchus mykiss irideus]), salmon (Salmonidae), largemouth bass (Micropterus salmoides), perch (Perca spp.), walleye (Sander vitreus), and white"sh (Coregonus spp.). Walleye are stocked into waterbodies in the Southern Lake Michigan Management Unit in early spring, late spring, and fall by MDNR (MDNR 2019-TN10724).
[close parenthesis needed]
p.231 J.6 State-listed Aquatic Species Table J-4 State-listed Aquatic Species That May Occur Within 1 mi (1.6 km) of Palisades Nuclear Plant
[why just 1 mile radius so small especially for species that migrate much greater distances, including within short distance from PNP, such as 1 mile]
[other thermal, radioactive, and toxic wastewater impacts, from routine releases, but also catastrophic releases]
[give it a rest; retire and decommission, as planned and promised; close for good; permanent shutdown]
p.232 J.7.1 Endangered Species Act Section 7 Consultation As a Federal agency, the NRC must comply with the Endangered Species Act of 1973 (ESA),
as amended (16 U.S.C. 1531 et seq.-TN1010), for any action authorized, funded, or carried out by the agency. The NRC proposed action is to reauthorize nuclear power operations at the Palisades in Covert Township, Michigan and refueling of the reactor.
[Nuclear Plant missing here]
J.7.1 Endangered Species Act Section 7 Consultation As a Federal agency, the NRC must comply with the Endangered Species Act of 1973 (ESA),
as amended (16 U.S.C. 1531 et seq.-TN1010), for any action authorized, funded, or carried out by the agency. The NRC proposed action is to reauthorize nuclear power operations at the Palisades in Covert Township, Michigan and refueling of the reactor. Under Section 7 of the ESA, the NRC must consult with the FWS and the National Marine Fisheries Service (NMFS)
(the Services [collectively] or Service [individually]), as appropriate, to ensure that the proposed action is not likely to jeopardize the continued existence of any endangered or threatened species or result in the destruction or adverse modi"cation of designated critical habitat.
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[what about that Eastern boxed turtle mentioned above as having been seen on site recently?
3,000 truck deliveries they could run over the turtles not to mention all the workers driving in and out]
p.232 J.7 Biological Evaluation If the preliminary information reveals that listed species or critical habitats may be present, the action agency then typically prepares a biological assessment or biological evaluation to evaluate the potential effects of the action and determine whether the species or critical habitats are likely to be adversely affected (50 CFR 402.12(a);
16 U.S.C. 1536(c)-TN4459).
[which is higher level and which is lower level review. PNP restart should always receive the highest level review available]
p.233 Biological assessments are required for any Federal agency action that is a major construction activity (50 CFR 402.12(b) (TN4312). A major construction activity is a construction project or other undertaking having construction-type impacts that is a major Federal action signi"cantly affecting the quality of the human environment under the National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.)(NEPA)(51 FR 19926-TN7600). However, the proposed action to reauthorize Palisades is not a major construction activity and therefore does not require the preparation of a biological assessment. Nonetheless, the NRC staff still must consider the impacts of this action on federally listed species and designated critical habitats.
This consideration is presented below as a biological evaluation. Whether through a biological assessment or biological evaluation, if an action agency such as NRC "nds that a proposed action may affect ESA-protected species or habitats, it must seek written concurrence from the relevant Service(s) under ESA Section 7.
[it is too a major construction activity an ongoing one that began in 1967. The SMR new builds will only exacerbate this]
The NRC staff structured its biological evaluation in accordance with de"nitions from 50 CFR 402.12(f) (TN4312). Sections 3.6.1 and 3.7.1 of this EA de"ne and describe the action area and state that no critical habitat for listed species occurs within it. Table J-5 describes each ESA-protected species potentially present in the action area, assesses the potential effects of the proposed action on each species, and presents the NRCs effect determination for each of species. Table J-6 compares the conclusions from this 2024 biological evaluation with those developed for a supplemental environmental impact statement prepared by NRC in 2006 for license renewal of the Palisades plant. Finally, Section 4.2 addresses the potential effects of the no-action alternative.
[B.S. Cite likely impacted species, by NRCs own account; what about the turtle!
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That is, challenge NRCs "ippant NLAAs
- p. 240, key to table NLAA = not likely to adversely affect Also challenge NEs NE = No effect.
The radioactivity and toxic chemicals alone, let alone getting run over by vehicles, being killed by major construction activities such as new rad waste building construction, new dry cask storage pad destruction, and most destrutive of all, the closely connected SMR new build scheme]
p.234 Indiana bat Baseline Information: According to the recovery plan (FWS 2007-TN934),
the Indiana bat is a "ying, insectivorous mammal that hibernates in caves and mines and forms maternity roosts in mature trees over 5-in. diameter at breast height, especially trees with exfoliating bark. It roosts and forages in forested or semi-forested areas. Threats include disturbance to the hibernacula, loss and fragmentation of forested swarming and roosting habitat, chemical contaminants, collision with wind turbines, and white-nose syndrome.
[PNP restart would emit toxic and radioactive chemicals into the surrounding environment; SMR construction would likely lead to further deforestation on the site has Holtec ever revealed where, exactly, on the site, the two SMR-300s would be built?]
Preparation Impacts:1-5 Proposed activities would occur only in previously developed areas of site, and no forest would be disturbed (Figure 3-5 of this EA). Preparation activities are expected to occur over an 18-month period.
The applicant has estimated that approximately 3,000 truck deliveries would take place over this period (HDI 2024-TN10670: RAI-GEN-1). Temporary increases in noise and traf"c over this time period are unlikely to alter Indiana bat use of the site. Bat collisions with vehicles and human-made structures at nuclear power plants are not well documented but are likely rare based on available information (NRC 2024-TN10161: p. 3-63).
[thats not very persuasive; sounds more like wishful thinking]
Operations Impacts:1-5 For the 2006 SEIS (NRC 2006-TN7346),
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operational impacts were determined to be NLAA. Proposed operational activities are anticipated to be similar in magnitude and frequency as the previous operations characterized in the SEIS. No forest would be disturbed.
Indiana bats, if present in the area, have likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Holtec reports no bat incidents at the Palisades site and states that it would consult with FWS as an administrative control for any unanticipated construction or tree removal activities during operations (Holtec International 2023-TN10538:
pp. 94-95). The NRC staff recognizes that individuals may have to reacclimate to the resumption of past operational conditions, but based on the relatively short duration of the shutdown it is the staffs professional judgment that the adverse effects would not be substantial.
[again, wishful and self-justifying thinking. The bats probably have used the PNP site for 12,000 years, after the glaciers retreated at the end of the most recent Ice Age. PNP groundbreaking only began in 1967. That was only 55 years of construction and operational activity a blip in the natural history of these bats. 2022-2025 closed for good status returned the site to what the bats had been used to for the better part of 12,000 years. Now NRC wants to bless Holtecs activities that would further stress these bats.]
p.235 northern long-eared bat (NLEB)
[challenge NRCs NLAA, for same reasons we gave re: IN bat]
tricolored bat
[challenge NRCs NLAA, for same reasons we gave re: IN bat]
p.235-236 eastern massasauga
[challenge NRCs "ippant NLAA]
Preparation Impacts:1-5 No activities are proposed in or adjacent to wetlands or other suitable habitats. It is possible that individuals in undeveloped areas of the site could experience infrequent injury or mortality from vehicles using adjoining roadways. However, the roadways on the site
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are separated from favorable eastern massasauga habitats by roadside clearings several feet in width, and the potential for snake collisions are no greater than for other arterial roadways in the surrounding rural landscape.
Operations Impacts: Impacts from operational activities were determined to be NLAA in the 2006 SEIS (NRC 2006-TN7346). Proposed operational activities are anticipated to be of the same magnitude and frequency as anticipated in 2006.
[snakes could enter PNP site from outside, seeking habitat that NRC admits here exists on the site.
extinction by a thousand vehicle strikes. PNP roadways are no LESS of a threat than arterial roads in the surrounding rural landscape. NRC admits 3,000 vehicle deliveries associated with restart. Not to mention increasing numbers of workers coming and going, which has already begun.
Several FEET in width? I think the snakes could cross that, into the roadway danger zone.
Dont tread on me, literally including tire treads Operational radioactivity and toxic chemical releases from restart, in addition to what PNP has already disgorged since 1971, will also harm the snakes.]
p.236 rufa red knot
[challenge NRCs "ippant self-serving NLAA]
[industrial activity and car/truck strikes could harm birds, in addition to hazardous emissions from PNP. Cite similar reasons as IN bat protection.
Site should be allowed to return to natural state, providing sand dune forested wetland habitat, and restored natural beach habitat, for indigenous species, including this one]
p.236-237 Operations Impacts:1-5 The rufa red knot was not previously evaluated in 2006 SEIS (NRC 2006-TN7346; NMCCO 2005-TN10839). Undeveloped, unarmored beaches on or near site could potentially provide habitat but would not be disturbed or altered by operational activities. Holtec has a current permit (MEGLE 2020-TN10696) allowing for maintenance dredging of sand and placement of dredged materials on the beach (Section 3.6.1.1).
Dredging locations occur only in previously disturbed areas (Holtec International 2023-TN10538: p. 95). Holtec reports no new and signi"cant
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information regarding bird collisions with plant structures or transmission lines (Holtec International 2023-TN10538: p. 4.3-2). Continued implementation of permit requirements, environmental protection plans, and BMPs for operational activities would be protective of the terrestrial habitats used by this species
[stop doing that. PNP restart is not even needed. State framing at the very top. Along with intro/
summary.
Cite bird kills from "ying into Shield Building at Davis-Besse Holtec and NRC looking the other way, and assuming the best. Not acceptable given threats to such species as this.]
p.237 piping plover (Great Lakes DPS)
[challenge nrcs "ippant LLAA I think I saw piping plovers at Lake MI College in South Haven at a NRC-Entergy meeting. So sometime between 2007-2022.]
Site Occurrence: The piping plover is not known from the Palisades site.
The beach fronting the developed area has been too narrowed by past armoring to offer potentially suitable piping plover habitat (site observations by NRC ecologists in 2024). Undeveloped beaches on or near site could potentially provide habitat. Adults may pass through the area when moving to more suitable habitat along Lake Michigan.
[well, per above, Ive seen them just several miles northwest. And they do have wings]
whooping crane
[challenge NRCs "ippant NE]
p.238 Site Occurrence: The whooping crane is not known from the Palisades site.
Individuals from experimental populations are possible in Michigan, and even those are unlikely. Furthermore, none of the large marshes favored by the
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species occur on or near the Palisades site (Section 3.6.1 of the EA).
[challenge this cite reference above of a marsh not far from PNP site perhaps in Cumulative Impacts appendix?]
[cite impacts on Whooping Cranes from Fort Saint Vrain nuclear power plant risk of contamination to Platte River, upstream of Nebraska]
[species measured in only the hundreds of individuals continent wide Non-essential habitat is really objectionable, given the critically endangered status of this species.]
p.238 Continued implementation of permit requirements, environmental protection plans, and BMPs for operational activities would be protective of habitats used by this species uses.
[more sloppy, rushed, careless writing]
Karner blue butter"y (KBB)
Baseline Information: The KBB is a "ying insect that favors oak savanna and pine barren habitat containing blue lupine (Lupinus perennis) (FWS 2024-TN10778). Recent (2024) IPaC searches did not mention this species, but the NRC staff is evaluating it because it was addressed in the 2006 SEIS.
Site Occurrence: The KBB is not known to occur on the Palisades site, and the specialized habitat it requires is not present on the site or in the surrounding landscape.
Preparation and Operations Impacts: No preparation or operational activities would take place in or adjacent to habitat for the KBB.
[compare habitats mentioned nearby, as/per just above. Butter"ies have wings. They can move and migrate.]
Mitchells satyr butter"y (MSB)
Baseline Information: The MSB is a "ying insect with nine known populations in Michigan (FWS 2021-TN10883), and otherwise known or suspected to occur in Alabama, Indiana, Michigan, Mississippi, Ohio, and
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Virginia (FWS 2021-TN10882). Primary habitat is sedge-dominated wetlands, including fens and wetland edges of beaver ponds, swamps, and seeps (FWS 1998-TN10884, FWS 2021-TN10883). Threats include wetland habitat loss from urban development and adjacent human activities, hydrologic alteration, over-collection by butter"y collectors, inadequacy of existing regulatory mechanisms, limited ability to colonize new habitat patches, infection with the reproductive bacterial parasite Wolbachia, and climate change (FWS 2021-TN10883: p.19-24).
Site Occurrence: The MSB is not known to occur on the Palisades site. No sedge-dominated fens favored by the MSB are present on site (NRC 2006-TN7346: p. 4-34).
Preparation and Operations Impacts: No preparation or operational activities will occur in or adjacent to habitat for this species.
[challenge NRCs "ippant NE. Compare w/habitats mentioned in EA, per above. Butter"ies DO have wings]
[in terms of catastrophic radiation release impacts, including on birds, insects, etc, cite Mousseau; cite the German biological artists who won the Nuclear-Free Future Award for Education in 2016]
Monarch butter"y
[challenge NLAA Based on sightings and presence of mildweed alone see just below Need to save this iconic species]
p.239 Site Occurrence: Flying adults were observed by NRC staff in September 2024 visiting the Palisades site. Widely scattered, occasional milkweed (Asclepias spp.) plants were observed by NRC staff in 2024 south of Van Buren State Park, on vegetated dunes close to the beach, and on dunes along the access road.
Monarchs and milkweeds are known from Van Buren State Park and site vicinity based on a review of iNaturalist in 2024 (https://www.inaturalist.org/).
Larvae are potentially present wherever milkweeds are present.
Preparation Impacts:1-5 Ground disturbance as part of preparation could disturb widely scattered milkweed plants growing amid sparse and ruderal
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vegetation in areas of previously disturbed soils. However, milkweed is a common, quick-growing herbaceous plant that is present at least sparsely in most areas of non-forest vegetation in the area. None of the affected areas contain dense or extensive patches of milkweed. While it is possible that a few milkweed plants containing monarch larvae could be killed, it is unlikely that the losses would noticeably affect monarch populations in the region. If a few milkweed stems are killed by herbicide applications, the losses are likewise not likely to result in noticeable effects on the regional population.
Any insecticide applications would likely be limited to in or around buildings or paved areas where milkweed is not present.
[extinction by a thousand cuts herbicide applications, vehicle strikes, etc.]
Pitchers thistle
[challenge NLAA]
Site Occurrence: Pitchers thistle has been observed in undeveloped dune areas on the site, on open sand dune and "ats (NRC 2006-TN7346: p. 2-45; HDI 2024-TN10670). The species was known from 1980s and 1990s to occur near the cooling towers. However, none was reported near the cooling towers in 2005.
[cite acid vapor plume from cooling towers for decades on end as a contributing factor, likely a major one]
p.239-240 Site Occurrence: Pitchers thistle has been observed in undeveloped dune areas on the site, on open sand dune and "ats (NRC 2006-TN7346: p. 2-45; HDI 2024-TN10670). The species was known from 1980s and 1990s to occur near the cooling towers. However, none was reported near the cooling towers in 2005. But 113 individuals (9 mature and 104 "rst year plants) were reported in 2005 in the northern end of the site on a beach grass stabilized dune community and "ats adjacent to Van Buren State Park. In a "eld survey in 2024, 64 individuals were observed approximately 1,000 ft east of the south cooling tower, in a naturally occurring dune clearing surrounded by deciduous forest. But none was observed in the previous locations where it had been once seen on the site.
Preparation Impacts:1,4,5 No activities such as land disturbances, mowing, or herbicide application would take place in or adjacent to areas where Pitchers thistle is known to occur or previously occur.
Operations Impacts:1,4,5 In the 2006 SEIS (NRC 2006-TN7346), operational impacts were determined to be NLAA based on the following: (1) Pitchers thistle did not occur in locations where it would be affected by operations,
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(2) no refurbishment or ground-disturbing activities were proposed during the LR period, (3) the applicant had pre--disturbance procedures in place to evaluate impacts to federally listed species, and (4) Michigan EGLE regulates the dune habitats, so any ground disturbance in habitat for this species would require a permit. The same assessment applies to resumption of operations at the present time. The population found in 2024 would not be affected by routine site operation or management, for the following reasons:
(1) No disturbances, mowing, or herbicide application to areas where populations are known to exist; (2) continued operations and maintenance activities would be similar and be of same magnitude and frequency as previous operations; (3) dredging (MEGLE 2020-TN10696) would continue to disturb beach and dune areas, likely preventing establishment of new plants; (4) applicant has pre--disturbance procedures in place to evaluate impacts to federally listed species; (5) Michigan EGLE regulates dune habitats, so any ground disturbance in habitat for this species would require a permit; and (6) population found in 2024 separated from the mechanical cooling towers by approximately 1,000 ft of mature deciduous forest. The cooling towers are equipped with drift eliminators. Any drift would be unlikely to penetrate the dense forest, even in leaf-off conditions. See Section 3.6.3 of the EA for a discussion of cooling tower impacts on terrestrial plants.
[well they are now!
Which under Whitmer they seem very poised to rubberstamp SMR construction will majorly disturb vast swaths of the site Oh good, so PNP activities are guaranteed to prevent this E/T/SC species from ever re-establishing itself on the PNP site anti-ESA!]
See Section 3.6.3 of the EA for a discussion of cooling tower impacts on terrestrial plants
[given the key habitat at PNP and nearby, this species deserves the utmost protection including no restart, and no SMR new builds]
p.241 NEP = in the vicinity of the action area, this species is part of a nonessential experimental population.
[outrageous thing to say about Whooping Cranes, given their critically endangered small numbers how can any population, even individual(s), be considered nonessential? How can they be called experimental? Their decline and loss is human caused.]
Potentially Present in the
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Action Area?
[challenge NRCs "ippants Nos of course they are all potentially present, or could be, if let alone, not disturbed. The only reason they have not been seen on site is due to Cumulative Impacts, on the site, and beyond, as well as perhaps no one at PNP is really looking for them with any required regularity?]
FWS Concurrence Date
[how to in"uence TBDs? FWC concurrences? FWS should do its job, protect these and other species, and reject concurrence with NRC, where Nobody Really Cares. FWS should care. Its their job]
p.241 NLAA = may affect, not likely to adversely affect. NE = No effect.
[kety to table]
p.241 (c) The ESA does not require Federal agencies to seek FWS concurrence for no effect determinations. For n/a = not applicable; TBD = to be determined; the NRC will seek the FWSs concurrence following the issuance of this draft EA.
[challenge all NRC NLAA and NE conclusions]
Endangered Species Act Section 7 Consultation with the National Marine Fisheries Service As discussed in Section 3.7.1.2 of this EA, no federally listed species or critical habitats under NMFSs jurisdiction occur within the action area. Therefore, the NRC staff did not engage the NMFS pursuant to ESA Section 7 for the proposed Palisades reauthorization.
[well, they should have, given impacts on Lake MIs aquatic ecology and species in decline]
J.8 Magnuson-Stevens Act Essential Fish Habitat Consultation The NRC must comply with the Magnuson-Stevens Fishery Conservation and Management Act of 1996 (MSA), as amended (16 U.S.C. 1801 et seq.-TN7841), for any actions authorized, funded, or undertaken, or proposed to be authorized, funded, or undertaken that may adversely affect any essential "sh habitat (EFH) identi"ed under the MSA.
In Section 3.7.1.2 of this EA, the NRC staff concludes that the NMFS has not designated any EFH under the MSA within the action area and that the proposed Palisades reauthorization would have no effect on EFH. Thus, the MSA does not require the NRC to consult with the
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NMFS for the proposed action.
[all agencies are shirking their responsibilities under the act, to the detriment and harm of Lake MIs EFHs]
p.242
.9 National Marine Sanctuaries Act Consultation The National Marine Sanctuaries Act of 1966, as amended (16 U.S.C. § 1431 et seq.-TN7197),
authorizes the Secretary of Commerce to designate and protect areas of the marine environment with special national signi"cance due to their conservation, recreational, ecological, historical, scienti"c, cultural, archaeological, educational, or aesthetic qualities as national marine sanctuaries. Under Section 304(d) of the act, Federal agencies must consult with the National Oceanic and Atmospheric Administrations Of"ce of National Marine Sanctuaries if a Federal action is likely to destroy, cause the loss of, or injure any sanctuary resources.
In Section 3.7.1.2 of this EA, the NRC staff concludes that no marine sanctuaries occur near Palisades and that the Palisades reauthorization would have no effect on sanctuary resources.
Thus, the National Marine Sanctuaries Act does not require the NRC to consult with the National Oceanic and Atmospheric Administration for the proposed action.
[Lake MI at/near PNP sure quali"es for this! again, each of the agencies has dropped the ball, in violation of the letter and spirit.
Lake MI at/near PNP should be under consideration and development of NMSA status. Compare the one that ELPC celebrated just several years ago in Lake Huron? Thunder Bay? yes, near Alpena!]
ADDITIONAL COMMENTS:
Rust buckets leak Nuclear lemon Jalopy You cant kill a million people with your car Unless its got a nuclear weapon, or dirty bomb, in the trunk So we come full circle or reactor meltdown/HLRW "re
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