ML25154A004
| ML25154A004 | |
| 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: ML25154A004 (4) | |
Text
From:
Alfred Meyer <alfred.c.meyer@gmail.com>
Sent:
Monday, June 2, 2025 11:28 PM To:
PointBeach-SLRSEIS Resource
Subject:
[External_Sender] Public Comment on Docket ID: NRC-2020-0277 Docket ID: NRC-2020-0277 Comments on the Draft SEIS for Point Beach These comments regarding supplemental license extensions for the two reactors at Point Beach will focus on the need to fully consider the severe accident risks posed by climate change, the changing weather patterns and events that are characterized by greater volatility and greater extremes - hotter hots, colder colds, wetter wets and dryer dries.
The Draft SEIS includes section 3.15.3.2 titled Climate Change. I thank you for responding to my comments in 2021 decrying the use of outdated data in the previous version of this document. We face rapidly changing conditions over the past two decades as we develop an understanding of what these changes mean today and portend for years to come. You updated many of your climate data sources which makes this a stronger document.
The Draft SEIS states that there has been a 45% increase in the number of extreme precipitation days in the Midwest from 1958-2021. [Page 3-81, lines 11-13]. As a side comment, I wonder what the percentage of change would be if the time frame was changed to 2000 or 2010 till 2025, since the impacts of climate change are much more evident in more recent years. The Draft SEIS further states that observed increases in heavy precipitation events are projected to continue across the Midwest, including eastern Wisconsin. [Page 3-85, lines 17-19]
These statements would appear to show that the NRC is not only cognizant of the increasing severe accident risks posed by climate change, but also considering them as factors in granting license extensions. However, tucked in the middle of the Climate Change section on page 3-84 is the statement that The effects of climate change on Point Beach structures, systems, and components are outside the scope of this Category 2 issue. The environmental review documents the potential effects from continued nuclear power plant operation on the environment. Site-specific environmental conditions are considered when siting nuclear power plants. [page 3-84, lines 1-4] (my emphasis added).
My primary concern is what could be the effects of climate change on Point Beach structures, systems and components in terms of site stability and operational safety? Before the operating licenses are extended, this topic must be comprehensively addressed and solved.
The claim that Site-specific environmental conditions are considered when siting nuclear power plants highlights the problem at hand. The siting of these two reactors on the shore of Lake Michigan took place during the 1960s when there was no concept of climate change risks, nor were the increasingly severe weather events so increasingly prevalent.
What might have been an adequate site in 1960 is, today, due to changing climatic conditions, a different site which needs a full and comprehensive evaluation to account for todays conditions and our best projections of future conditions.
Having worked as a builder for 35 years, I am well aware of how weather can impact built structures. While I trust that the 1960s determination of site suitability was adequate then, using 60 year old conditions and engineering calculations is not a basis for determining suitability going forward 28 years until 2053 for reactor operation, and beyond those years for on-site storage of high level nuclear waste.
When this site was first evaluated in the 1960s, the concept of changing weather patterns with greater volatility and greater extremes was not considered. As we experience dramatically changing weather events, they must be fully considered as accident risks, and steps taken to mitigate these risks. Site safety must be fully reassessed in light of current and projected weather events. While historical weather data provides useful understanding of past patterns, it is imperative that thorough and complete consideration be made of the expected and potential future weather events that will take place during the period of time for this license extension.
For example, variations in the water level in Lake Michigan must be fully considered. Please note that a record low Lake Michigan water level occurred in 2013, and just seven years later in 2020, a record high level occurred. What conditions can be expected in the years from 2030 to 2053? Site stability must be assessed assuming potentially greater extremes over a number of years. Also needing to be addressed are operational safety considerations relative
to water supply and water temperature for safe reactor operation and the cooling of irradiated spent nuclear fuel in the fuel pools, and very importantly, protection of the dry cask storage pads from flooding.
The site must also be evaluated for risk of flooding and erosion during extreme precipitation events. As atmospheric conditions change to carry more moisture, with atmospheric rivers forming and large storms sometimes stalling over areas, are the measures for onsite water management sufficient to handle extreme precipitation events to avoid flooding and site erosion? Remember that it was the flooding at the Fukushima Di-ichi reactors that caused the meltdowns.
An additional climate threat are derecho storms, with strong horizontal winds and waves. In August 2020, the Duane Arnold nuclear plant in Iowa was damaged and closed down by such a storm. Clearly the climate change threat had a dramatic effect in this case. Were these types of storms considered in the 1960s and 1970s evaluation of site stability and safety?
Using just these three aspects of climate change as an example, how does the NRC evaluate and assess each factor individually, AND in combinations of events? For example, how do you answer the following two scenarios, two among many different potential threats?
Lets assume an extreme rainfall event at Point Beach of 9 inches, (an assumption which is midway between the 1990 Green Bay one day rainfall record of 4.9 inches, and the 1946 Mellen rainfall of 11.7 inches). Such an event would likely saturate the ground at Point Beach, likely causing flooding and/or erosion of the site. Are these effects fully considered and addressed? Are gutters, downspouts and water management structures sufficient to handle such a rainfall? And a rainfall 2 or 3 times that, or whatever the upper boundaries of potential rainfall are?
Then consider that immediately following this extreme rain event, a derecho hits the site. How do the high winds and big waves impact the rain saturated site? Will it cause soil erosion and subsidence of the site, and/or flooding? Has the shoreline been designed to withstand a combination of these two back to back events in the cases of either a record high lake level, or at a record low lake level? What are the impacts on Point Beach in terms of site stability and operational safety?
The Draft SEIS must address these pressing questions and provide adequate answers before extending the operating licenses for Point Beach. To say that NRCs Reactor Oversight will address these issues does not adequately and fully address the concerns. These are new and different circumstances for reactor operation which must be addressed.
As a member of the public calling for the NRC to adequately address climate change, I am not alone.
The Government Accountability Office (GAO) in April 2024 issued a report titled: NUCLEAR POWER PLANTS; NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change https://www.gao.gov/products/gao-24-106326.
This report concludes: As NRC makes licensing, license renewal, and oversight decisions, adopting an approach that incorporates the best available information on climate risks and ways that those risks may affect nuclear plants, would provide greater assurance that licensees have adequate measures to address risks from climate change (p. 40),
saying that NRC needs to demonstrate that the safety margins for nuclear power plants established during the licensing period are adequate to address the risks that climate change poses to plants(p. 41).
The report also states According to the NCA [National Climate Assessment], many of the climate conditions and impacts experienced in the United States today are unprecedented for thousands of years (p. 41). We need a full contemporary assessment of the severe climate threats that are evolving.
And it is not just the GAO making this plea to have climate change fully considered.
In the July 10, 2024 U.S. NRC Atomic Safety and Licensing Board ruling on Docket Nos. 50-238-SLR-2 and 50-339-SLR-2 in the matter of Virginia Electric and Power Company, the Chair of the ASLB, Michael M. Gibson filed a 23 page dissent when the board excluded consideration of climate change in this matter. Chair Gibson argues that it necessarily follows that a draft EIS must evaluate the environmental impacts of climate change on the plant itself, during the period of subsequent license renewal, because that is the subject of the proposed action.(p. 17 of Judge Gibson, Concurring in Part, and Dissenting in Part).
Noting that safety comes before licensing, I sincerely hope, for the well being of all, that you heed the statement from the Chair Gibson of the NRC Atomic Safety and Licensing Board, and amend the Draft SEIS so that it will encompass the severe accident risks of climate change regarding license extension for the two nuclear reactors on the shore of Lake Michigan.
Thank you for considering these comments.
Alfred Meyer, Board Member Physicians for Social Responsibility - Wisconsin
Federal Register Notice:
90FR16008 Comment Number:
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[External_Sender] Public Comment on Docket ID: NRC-2020-0277 Sent Date:
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6/2/2025 11:28:22 PM From:
Alfred Meyer Created By:
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