ML25153A002
| ML25153A002 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/02/2025 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 90FR16008 | |
| Download: ML25153A002 (7) | |
Text
From:
ANN T BEHRMANN <atbehrma@wisc.edu>
Sent:
Monday, June 2, 2025 12:37 AM To:
PointBeach-SLRSEIS Resource Cc:
info@psrwisconsin.org; ANN T BEHRMANN
Subject:
[External_Sender] Comments to the NRC Office of Nuclear Material Safety and Safeguards NUREG-1437 Supplement 23 Second Renewal
Dear NRC Office of Nuclear Material Safety and Safeguards,
RE: NUREG-1437 Supplement 23 Second Renewal I am a retired pediatrician living in Madison, Wisconsin and the Treasurer of Physicians for Social Responsibility Wisconsin (PSR WI) and am concerned about Next Era's application to renew the license for Point Beach Nuclear Power Plant (PBNP), Units 1 and 2, to operate for an additional 20 years, from 2030-2050 and from 2033-2053. As a health professional, most of my detailed comments are focused on the health effects of continued operation of these nuclear plants. As you know, these 2 PBNPs were initially licensed to operate, for Unit 1 on 10/05/1970 and for Unit 2 on 03/08/1973, and both licenses renewed for an additional 20 years on 12/22/2005. Both of these units were constructed before the National Environmental Policy Act in 1969 resulted in power plants being constructed with cooling towers to reduce water consumption and mitigate pollution from thermal effects. Now PBNP's 2 units discharge an average of 915 million gallons of Lake Michigan water each day at up to 24.3 degrees Fahrenheit hotter than ambient lake temperatures.
Below are my specific concerns that the NRC should consider with this application to have PBNP operate for 60-80 years:
HEALTH Examining potential effects of radiation on the communities, particularly those on PBN workers and residents working and living within 10 miles of PBN, The NRC should consider the following issues:
- 1. Reference Man Reports of radiation risks to health continue to be based on Reference Man (white, 70 kg, 20-30-year-old male) when well-researched data indicates that women, fetuses, infants, children, and teens are affected at lower radiation doses than men (Healthy from the Start, n.d.).
Populations surrounding PBN should have answers to the following:
Why are the risks of radiation exposure to women, fetuses, infants, children, and teens not considered?
- 2. Tritium Discharges and Potential Leaks
All nuclear plants, including PBNPs units I and 2, release Tritium, a radioisotope of Hydrogen or H-3. This updated EIS reports that Tritium releases into water through monitoring of onsite wells and effluent at PBNP have been below the current EPA drinking water standard of 20,000 picocuries/liter for Tritium.
There was a significant leak of Tritium at the 54-year-old (similar age to PBN units 1 and 2)
Monticello Nuclear Plant located on the Mississippi River in the fall/winter of 2022-23. Elevated levels of Tritium were identified in monitoring wells close to the Mississippi River, with concerns that this radiation would contaminate the Minneapolis Water Works Reservoir 37 miles downstream from Monticello NPP, potentially contaminating the Twin Cities' drinking water.
The drinking water standard of 20,000 picocuries/liter for Tritium was recommended in 1960 by the Federal Radiation Council based on extrapolation from measurements of radionuclides in water supplies contaminated by fallout from nuclear weapons testing, but it was not based on a rigorous analysis of health risk. Federal expert guidance (EPA's FGR 11) suggests a more health-protective standard based on health risks to women and children and scientific advancements should be 400 picocuries/liter (Makhijani et al., 2007).
The following are questions of concern regarding Tritium risks:
Where is Tritium measured in air (locations of monitors on the PBN 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?
- 3. Microbiological Hazards to the Public The latest EIS document discusses two thermophilic (or bacteria/amoeba that are present in water at high temperatures) organisms that potentially could affect human health: an amoeba, Naegleria fowleri (N. fowleri), and cyanobacteria (commonly known as blue-green algae). Both risks are considered SMALL in this document.
However, the following should be considered:
N. fowleri Amoebic Encephalitis: A rare brain infection, but has been identified twice in Minnesota lakes, and continues to have a 97% mortality rate (Boutros-Khoury & Kudlac, 2023).
Blue-Green Algae (Cyanobacteria): There have been increased reports of cyanobacteria in Lake Superior and elsewhere in Lake Michigan (Wisconsin Department of Natural Resources, n.d.). Cyanobacteria were documented in August 2024 in Muskegon County, MI, just north and west of Palisades Nuclear Plant, across the lake from PBNP (Michigan departments of Environment, Great Lakes, and Energy (EGLE); and Health and Human Services (MDHHS), n.d.).
These cyanobacteria blooms and amoeba-like N. fowleri incidents increase as water temperatures increase.
Water Temperature: Annual Lake Michigan surface temperatures are projected to increase by 1.28-2.56°F (in 2030) and 1.92-3.24°F (in 2049) (United States Nuclear Regulatory Commission, 2025).
Questions of concern include:
Is the NRC concerned that projected increases in Lake Michigan ambient temperatures due to climate change and continued 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 Point Beach Nuclear(now approx. 915+ million gallons/day at temperatures up to 24.3 degrees F hotter than ambient lake temperatures) measured, and where is this information released to the public?
In addition to the risks to humans, if increasing lake temperature promotes the presence of blue-green algae blooms and N. fowleri, will these harmful thermophilic organisms also threaten the health and life of lake mammals, reptiles, water fowl, and shore birds?
ONE HEALTH My last question above connects effects of PBNP's continued operation for an additional 20 years to the health of the entire ecosystem in which we live.
- 4. One Health of the Environment for Surrounding PBN Communities:
Here is a short explanation of what I am referring to re One Health concepts--
One Health is the collaborative effort of multiple disciplines to attain optimal health for people, animals, and the environment. The One Health concept arose from the realization that human, animal, and environmental health are inextricably linked and that a holistic approach is needed to understand, protect, and promote the health of all species.
One Health seeks to improve communication and encourage collaboration between veterinarians, physicians, environmental scientists, public health professionals, and others to find multidisciplinary solutions to shared challenges such as emerging infectious diseases, antibiotic resistance, and emergency preparedness (Global Health Institute, University of Wisconsin-Madison, n.d).
Of concern for the relicensing of PBN are the following:
Effects on the One Health Environment:
This includes climate change effects (temperature and precipitation changes) on endangered species stressed by the marked loss of insect populations (from habitat loss, pesticides such as neonicotinoids, and invasive species) (Fox, 2021).
This subsequent license renewal states that for federally listed, endangered, or threatened species, the PBN continued operations may affect, but is not likely to adversely affect, northern long-eared bat, tricolored bat, piping plover, and monarch butterfly (United States Nuclear Regulatory Commission, 2025).
Questions of concern for this topic include:
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 ambient water temperatures increase with climate change?
Finally, I want to speak to the deletion of Environmental Justice as a topic in this NUREG-1437 Supplement 23 Second Renewal. I am dismayed that the NRC staff has had to strike out its detailed look at energy burden for ratepayers whose electricity is purchased from PBNP due to the Executive Order 14173 of January 21,2025, concluding erroneously that this exemption is in the public interest.
- 5) Environmental Justice For rate-paying customers of WE Energies and WPPI, avoiding 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 (wind and solar) is NOT in the public interest. Specific issues are described below:
Energy Rates and Energy Burden See PSR WI's previous expert testimony in 2021 by Mark Cooper, PhD, on expected increases in energy costs predicted for ratepayers if PBNs two units are relicensed to continue to produce energy for 60-80 years (Cooper, 2021). He concludes that costs for ratepayers will be more than
$5 billion (when licensing ends for one PBNP unit) by 2030, compared to energy costs from NRC-offered alternatives to nuclear power, or about $300 more per year per household.
Tribal Impact This exemption also avoids looking at how PBNP's continued operation for an additional 20 years may negatively affect fishing, hunting, and gathering federal rights for Wisconsins tribal nations in legally ceded territories compared to the effects on these same treaty rights with electricity created from alternative renewable energy sources (Wisconsin Public Radio, n.d).
Although this updated EIS was sent to WI Tribal Chairs, it was not sent to the Great Lakes Inter-Tribal Council, and especially to their health, research, and education, and their epidemiologic center, the Great Lakes Indigenous Health, Research & Education Center (GLITEC https://www.glitc.org/). PSR WI recommends that this SLR should be officially reviewed by the native nations health and environment government entities. Regarding tribal impact, a suggested question is:
Why is the impact on legally ceded territories not considered in the revised EIS?
- 6) Emergency Response Capacity Manitowoc and Kewaunee counties vary in their preparedness for a nuclear-related emergency.
Manitowoc County includes an active link to NextEra resources in its emergency management website, while Kewaunee County does not (Manitowoc County WI, n.d.).
References Boutros-Khoury, H., & Kudlac, K. E. (2023, May 1). Keep primary amoebic meningoencephalitis on radar during summer months. AAP News.https://aap2.silverchair-cdn.com/aap2/content_public/autogen-pdf/cms/24185/24185.pdf?Expires=2147483647&Signature=LUin31SGDTJzQ2a7oY6gGTZ7YeW x-I-aDIly2uqNv0lZXz2l5n5~bF-fN0VM8CwiGCTu9hy8USZNvqOCTgZYSgeEp6jReKj3U4EAJGmrAveLUgT35S3OCa3EU8OAEczQEx TNuyf~TKRpZi Cockburn, A. (2022, January). Spent Fuel, the Risky Resurgence of Nuclear Power. Harper's.
Cooper, M. (2021, March 23). United States of America Nuclear Regulatory Commission Declaration of Mark Cooper, PH.D.
https://static1.squarespace.com/static/55b8f343e4b01341cb1a19e6/t/605b2db3954e6e40818 c2f70/1616588214730/Cooper+DONE.pdf Fox, K. (2021, July 25). The insect apocalypse: 'Our world will grind to a halt without them'. The Guardian. https://www.theguardian.com/environment/2021/jul/25/the-insect-apocalypse-our-world-will-grind-to-a-halt-without-them Global Health Institute, University of Wisconsin-Madison. (n.d.). One Health.https://ghi.wisc.edu/one-health/
Healthy from the Start. (n.d.). TALKING POINTS Healthy from the Start: Campaign to Include Women, Children, and Future Generations in Environmental Health Standards. Healthy from the Start. https://ieer.org/wp/wp-content/uploads/2009/01/healthy-from-the-start-talking-points.pdf Makhijani, A., Smith, B., & Thorne, M. C. (2007, February 1). Healthy from the Start: Building a Better Basis for Environmental Health Standards Starting with Radiation. Institute for Energy and Environmental Research. https://ieer.org/wp/wp-content/uploads/2012/01/SDA-14-4.pdf Manitowoc County, WI. (n.d.). Emergency Management Department. Emergency Management Department.https://manitowoccountywi.gov/departments/emergency-management/point-beach-nuclear-plant/
Michigan departments of Environment, Great Lakes, and Energy (EGLE), and Health and Human Services (MDHHS). (n.d.). Michigan Harmful Algal Bloom Reports. Michigan Harmful Algal Bloom Reports.
https://mdhhs.maps.arcgis.com/apps/webappviewer/index.html?id=b05d6b7498ca4ce29a586f 1f2b9cefeb The Monarch Butterfly Problem - Field Station. (2024, March 27). UW-Milwaukee. Retrieved May 12, 2025, from https://uwm.edu/field-station/bug-of-the-week/the-monarch-butterfly-problem/
As in my earlier comments on the first EIS, I continue to be concerned about
- 1. the embrittlement of PBNP's Unit 2 and reliance on computer models to assess risks of cracking of the pressure vessel during emergency shutdown leaking significant radiation into the immediate environment,
- 2. the lack of a Congressional solution to permanent off site storage of spent nuclear fuel along with continued production of tons of more nuclear waste accumulating onsite if PBNP continue to operate for an additional 20 years past 2030/2033 and
- 3. climate change causing more numerous extreme weather events (such as the derecho that caused significant damage to the Duane Arnold Nuclear Plant in Iowa)--causing flooding or unanticipated drought that would raise or lower lake levels, affecting PBNP's once-through cooling operation or endangering the integrity of stored spent fuel at the Point Beach site.
Finally, NextEra who is a leader in renewable technologies, should realize funds spent to continue to operate these 50+ year old nuclear power plants for an additional 20 years is wasting money that should be invested in more renewable technologies--solar, onshore wind and battery storage. Electricity from renewables would benefit both their company's financial future, their shareholders' investments AND benefit those who farm in communities surrounding Point Beach Nuclear Plant and lower electricity costs for ratepayers--a huge win all around.
Thank you for the opportunity to submit these questions and comments.
Sincerely, Ann T. Behrmann MD Ann Behrmann MD Pediatrician Treasurer, Physicians for Social Responsibility Wisconsin Past Program Director, AAP ICATCH grants https://www.aap.org/icatch Adjunct Faculty, U WI Center for South Asia
Federal Register Notice:
90FR16008 Comment Number:
8 Mail Envelope Properties (SA0PR06MB69222C275E8498B05CFDD3A6AA62A)
Subject:
[External_Sender] Comments to the NRC Office of Nuclear Material Safety and Safeguards NUREG-1437 Supplement 23 Second Renewal Sent Date:
6/2/2025 12:37:21 AM Received Date:
6/2/2025 12:37:36 AM From:
ANN T BEHRMANN Created By:
atbehrma@wisc.edu Recipients:
"info@psrwisconsin.org" <info@psrwisconsin.org>
Tracking Status: None "ANN T BEHRMANN" <atbehrma@wisc.edu>
Tracking Status: None "PointBeach-SLRSEIS Resource" <PointBeach-SLRSEIS.Resource@nrc.gov>
Tracking Status: None Post Office:
SA0PR06MB6922.namprd06.prod.outlook.com Files Size Date & Time MESSAGE 14627 6/2/2025 12:37:36 AM Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date: