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Comment (2) of Anonymous, on Behalf of Nuclear Energy Information Service, on Analysis of Socio-Economic Impacts Are Incomplete. No Analysis of Impacts of Early or Unexpected Closure Are Considered or Provided
	ML16091A112
Person / Time
Site:	LaSalle
Issue date:	03/29/2016
From:	; Nuclear Energy Information Service
To:	; Rules, Announcements, and Directives Branch
References
	81FR7378 00002, NRC-2014-0268
	Download: ML16091A112 (2)
	v • d • e

\~I Nuclear Energy Information Service Illinois' Nuclear Power Watchdog since 1981 Office and Mail: 3411 W. Oiversey Avenue, #16, Chicago, IL 60647-1245 (773)342-7650 www.neis.org neis@n~isJorg rc:'l

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~/11/Zo1? )~~I :.} ~1o1 14 if ,,yo- Initial Comments on the LaSalle NPP Ucense Ren~wai ,--*-

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Comment : Analysis of socio-economic impacts are incomplete. No analysis of impacts of early or unexpected closure are considered or provided.

The Exelon Safety Evaluation Report (SER) documents a significant tax impact for the presence of the LaSalle Nuclear Station, yet only addresses the positive impacts. No mention or analysis of negative impacts resulting from abrupt, planned, or unexpected early closure of LaSalle is presented. This is a significant omission, particularly in light of Exelon Corporation's threat of two years ago to close reactors in Illinois on economic grounds.

According to the Exelon SER LaSalle represents a sizeable portion of the County total tax base, It also accounts for large portions of the School District's adjusted property tax levy. These are not insignificant amounts. Their abrupt disappearance would wreak economic havoc on the affected governmental and essential service entities' ability to operate - just as Exelon's predecessor ComEd did to the community of Zion in 1997 when they unilaterally closed the Zion reactors ..

The SER either fails to recognize or mention at all some of the possible events that could result in such a closure situation:

o Unexpected major accident, resulting in immediate and presumably premature closure o NRC-ordered shut down o Exelon's unilateral decision to close the plant on economic or other grounds, as it did at Zion, resulting in an immediate loss of about 55% of Zion's tax base o Devaluation through sale, as occurred at the Clinton station, resulting in enormous loss of tax base o Eventual old-age, license expiration closure (the outcome most hoped for)

Exelon being a business will certainly make the calculations it made when it closed Zion, and decide if LaSalle should continue to operate.

In this omission the SER makes the same mistake the U.S. Government made when it invaded Iraq -it had no exit strategy. To simply assume that the only socio-economic effects of LaSalle's presence will be positive ones is simply irrational.

Recommendation: Planning for some kind ofeventua/ closure must be made long before it happens to minimize economic and service disruptions to the entities whose tax base will be affected. Debate about the license extension serves as a good reminder of this fact, and an opportunity to take action. We recommend that dependent governmental and taxing entities begin formal negotiations with Exelon to establish an escrowed "closure mitigation fund," based on some mutually agreeable assessment and payment structure, so that dependent entities will have some kind of temporary funds available to soften the economic blow of closure, and not radically disrupt essential services.

SUNSI Review Complete

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.CQmment: Inadequate attention* paid to* water availa!Jiiity of.the LaSalle NPP under potential futlite climate. disruption c;onditions. .

Historically, the LaSalle NPP has been one .of the IUinois reactor sites most sensitive to.water availability under.severe drought conditions*(e.g,, 1998; 2005;.2006). lt'.s siting on a portion of the Illinois river network that is shallo)Ner than other parts has brought the reactors c.lose to mandatory sbutdo\(l/n. to stay within EPA regulatory limits for thermal pollution during extreme droughts on tnore than oae occasion over the past two decades.

F_orecasts fot the fuJure of Illinois' climate over'the next few decades indicate it approaching that of current.,.

day West Texas. This Will have severe impacts on tne aqu~tic systems in the area; and on the'availabillty of water for intake a*nd discharge for Lc~Salle.

A more thorough re-examination of LaSalle's ability to safely oper~te, obtain-sufficient cooling water, and not thermally and radiologically d~.mage the local aquatic ecQ-system is in order in this* relin~ensing proceeding.

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