ML25149A025
| ML25149A025 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/27/2025 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 90FR16008 | |
| Download: ML25149A025 (5) | |
Text
From:
PSR Wisconsin <info@psrwisconsin.org>
Sent:
Tuesday, May 27, 2025 10:43 AM To:
PointBeach-SLRSEIS Resource Cc:
ROSEMARIE CARBINO; PSR Wisconsin
Subject:
[External_Sender] Public Comments - Docket ID NRC-2020-0277 Attachments:
Point Beach testimony notes.docx Attached please find public comments for Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 23, Second Renewal, Regarding Subsequent License Renewal for Point Beach Nuclear Plant, Units 1 and 2, Second Draft Report for Comment (second draft report).
Thank you, PSR Wisconsin www.psr-wisconsin.org
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To the Nuclear Regulatory Commission:
May 23, 2025 My deepest concerns about re-licensing the Point Beach nuclear reactor are that radioactive release from the PBNR will severely damage the health of humans and wildlife for all the foreseeable future. I am old enough to remember the 3-Mile Island nuclear debacle, so I know enough NOT to trust those who back nuclear power to safeguard me and the other living things on the planet. It is up to the Nuclear Regulatory Commission to do the right thing.
I would like you to address many concerns:
(1) relicensing a now-aged and brittle nuclear reactor! For 80 more years!
(2) anticipating and coping with damage from clearly accelerating climate change (3) the eternal hazards of nuclear waste disposal/maintenance (4) the health effects on us humans of all ages, including WI tribes, and for all wildlife in the area on land, Lake
& in the sky.
(5) the very high costs of this venture, compared to NCC alternatives to nuclear power.
Re (1) aging, brittle, nuclear reactor I understand that nuclear reactors, including PBNR, were were designed (and licensed) to operate for only 40 years. Due to its age and brittle condition now, it is already at risk for cracking and release of radiation in the event of an accident. I read that there is no way currently to test the PBNR for embrittlement and that it reached its embrittlement screening limit in 2017!. How can anyone agree to a licensure extension of another 40 years, let alone 80 years??
Should not the NRC reject a renewal of the operating license based on the degree of embrittlement?
How can the NRC determine that embrittlement is not a problem, considering that Point Beach Reactor was identified as one of the most embrittled reactors in the country in 2013?
AS I see it, the risks of accidental cracking of this very old reactor, resulting in increased cancers in humans and wildlife; property damage (in billions); and contamination of drinking water for millions of people, are far too high to grant this re-license.
Re (2) Climate Change I see little evidence that the best climate change projections for 2030-2055 (and beyond) are rigorously being considered in re-licensing.. ask the Nuclear Regulatory Commission to do the right thing, More frequent, more extreme weather events challenge the Point Beach site stability, building stability, and operational and safety capacities of this complex facility on the shore of Lake Michigan.
I believe that a comprehensive review is needed of the climate parameters expected from 2030 -2055 for reactor operation, and decades beyond that for storage of nuclear waste on-site. Many questions are as yet unanswered:
- Are all aspects of this complex facility built and maintained sufficiently to withstand damage from plausible future extreme weather events?
- With intensity and volume of rainfall increasing, is theon-site water management adequate to handle extreme imaginable conditions, able to avoid flooding and operational disruption? (Remember Fukushima!
- How would Intense windstorms and thunderstorms damage buildings and electrical structures?
- URGENT: How would they affect the dry cask storage containers lined up outside on concrete pads?
- How much higher and lower might these lake levels be over the coming decades, and how would those new extremes impact site stability, operations, and safety?
Re (3) Nuclear Waste disposal/maintenance There is still NO safe, permanent solution anywhere in the world for the nuclear waste problem.
Currently, all radioactive waste generated by U.S. reactors is stored at the reactor site, either in fuel pools or waste casks. The casks are vulnerable and should be hardened until a better solution is found Any repository must be safeguarded for tens of thousands of years, and if anything goes wrong, future generations risk profound widespread and permanent pollution.
I read that, by 2033, an estimated 1,242 metric tons of radioactive waste will be in dry cask storage at the PBNR. This waste contains highly poisonous chemicals like plutonium and uranium pellets and poses a threat to agriculture, water sources, and all living things. Also, nuclear reactors and waste disposal sites are not built to withstand war. (Note the 2/14/25 drone attack on the Chernobyl nuclear plant in Ukraine.)
I have these questions (and more) about safety planning:
What plans does the PBNR have to safeguard the nuclear waste at its reactor site?
Are the dry casks containing nuclear waste monitored for radiation leaks and cracking and protected from flooding? What are the procedures for repairing them?
the PBNR states they have 5 days of backup power in case of an outage. Where are the backup generators located? How are they safeguarded?
Re (4) health risks for humans and wildlife I believe the NRC needs to also consider the risks of radiation exposure to women, infants, children and teenagers.
Tribal impact: The NRC needs to compare how continued operation of the PBNR for 20 years may negatively affect the federal rights of Wisconsins tribal nations to fish, hunt and gather, compared to the effects on these same rights with electricity created from alternative renewable energy sources. I read that an updated EIS was sent only to WI Tribal chairs, but not to the Great Lakes Indigenous Health, Research & Education Center. I believe that the re-licensing proposal and all relevant documents must be officially reviewed by these Tribal entities.
Tritium: All nuclear plants,, release Tritium. The following are questions the NRC needs to ask:
Where is Tritium measured in the air (locations of monitors on the PBNR site)?
Where is Tritium measured in water (both locations of monitoring wells and from water released after cooling into Lake Michigan) from PBNs 2 units?
How often are these samples retrieved and analyzed?
What laboratory does the analysis of these samples?
Where are they reported and made available to the public?
Microbiological Hazards: The latest EIS document discusses 2 bacteria/amoeba present in water at high temperatures that potentially could affect human health: an amoeba: N. fowleri, and cyanobacteria (blue-green algae). Both risks are considered small in the document. Cyanobacteria blooms and amoeba-like N. fowleri incidents increase as water temperatures increase.
Is the NRC concerned that projected increases in Lake Michigan temperatures due to climate change and thermal effluents will increase the risk for cyanobacteria and N. fowleri for populations recreating nearby?
How often is the temperature of the thermal effluent discharge from PBNR (now approximately 915 million gallons/day at temperatures up to 24.3 degrees F hotter than lake temperatures) measured, and where is this information released to the public?
In addition to the risks to humans, will these harmful organisms also threaten the health and life of lake mammals, reptiles, water fowl, and shore birds?
How will impacts to federally listed, endangered, and threatened species be monitored, and what contingency plans are in place to preserve their habitat?
How much more water will be needed to cool PBN as water temperatures increase with climate change?
Re (5) costs For rate-paying customers of WE Energies and WPPI, it is not in the public interest to avoid a comprehensive look at energy burdens for ratepayers receiving energy from nuclear power generation in comparison to lower energy costs per kilowatt hour from renewable energy sources.
I read from expert testimony in 2021 (by Mark Cooper, PhD) that costs for ratepayers will be more than $5 billion by 2030, compared to energy costs from NRC-offered alternatives to nuclear power, or about $300 more per year per household.
In conclusion The cost in dollars is far too high. Much more serious than dollar costs are the significant risks to humans and wildlife from an aged nuclear reactor; accelerating climate change; nuclear waste disposal/maintenance; and microbiological hazards. For our well-being for tens of thousands of years to come, I beg of you: Do not relicense the Point Beach Nuclear Reactor.
Rosemarie Carbino 1410 Morrison St. Madison WI 53703 508-238-3710 rcarbino@wisc.edu