ML081720201

Eric Joseph Epstein'S Comments on Behalf of Three Mile Island Alert, Inc. Draft Environmental Report for Susquehanna Nuclear Plant License Renewal Applications from PPL Susquehanna, LLC

ML081720201
Person / Time
Site:	Susquehanna
Issue date:	05/28/2008
From:	Epstein E Three Mile Island Alert
To:	Lund A NRC/NRR/ADRO/DLR
References
TAC MD3021, TAC MD3022
Download: ML081720201 (17)

Text

May 28. 2008 Louise Lund, Chief Renewal projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Eric Joseph Epstein's Comments on Behalf of Three Mile Island Alert, Inc.

Re: Draft Environmental Report for Susquehanna Nuclear Plant License Renewal Applications from PPL Susquehanna, LLC

Dear Ms. Lund:

Enclosed please find "Eric Joseph Epstein's Comments on Behalf of Three Mile Island Alert, Inc. Re: Draft Environmental Report for Susquehanna Nuclear Plant License Renewal Applications from PPL Susquehanna, LLC."

R spectfully sub ed, Er Jos h stein, Chairman Three ile I and Alert, Inc.

410o Hillsda e Road Harrisburg, PA 17112 ericepstein@comcast.net (717)-541-11ol 1

I. Background Three Mile Island Alert, Inc. ("TMIA" or "TMI-Alert") and Eric Epstein

("Epstein") began raising water use, water chemistry and aquatic challenges as well as interagency issues with the Nuclear Regulatory Commission's ("NRC")

dating back to . the Gomff ian's initial hearing convened in Berwick on November 15, 2006. Eric Epstein also identified the legitimate and peculiar interests of the Susquehanna River Basin Commission ("SRBC"), and introduced representatives from the NRC-NRR's, Division of License Renewal to members of the SRBC in attendance.

Beginning on June 5, 2007, PPL and NRC filed Responses in opposition to Mr. Epstein's concerns relating to water use, water chemistry and aquatic challenges. The Nuclear Regulatory Commission staff. alleged that Mr. Epstein's contention (T-I) is "outside of the scope" (1) and "not material" to this proceeding, and that there is not enough information (2) to establish a "genuine dispute." (NRC Staff, p. 8)

Epstein filings at the Susquehanna River Basin Commission and Nuclear Regulatory Commission relating to the relicensing and uprate of the Susquehanna Steam Electric Station ("SSES") sought to refine and define, clarify and coordinate, and address issues that continue to fall through regulatory gaps.

1 U.S. NRC Atomic Safety & Licensing Board Panel, Memorandum & Order, In the Matter of the PPL Susquehanna LLC, (Susquehanna Steam Electric Station, Units 1 and 2), Docket Nos. 50-387 and 50-388-OLA, ASLBP No. 07854-oi-BDoi, July 27, 2007: Judge G. Paul Bollwerk, II, Memorandum and Order.

III. Conclusion.

2 The NRC staff and PPL continue viewed the issues raised before the NRC as outside the cope of the NRC's uprate proceeding. Please refer to the NRC Staffs Brief in Opposition to Mr. Epstein'sAppeal of LBP--o7-lo (August 16, 2007), and PPL Susquehanna'sBrief in Opposition to Appeal of Eric Joseph Epstein. (August 16, 2007) 2

Almost two years after beginning this information quest, TMIA remains convinced, that a temporary stay of PPL Susquehanna's License Renewal Application ("LRA") is appropriate and will allow for resolution of all outstanding procedural and technical issues.

However, numerous water use, water safety, and interagency issues, as well as numerous procedural gaps in PPL's Application For Surface Water Withdrawal Request to Modify Application 19950301-EPU-0572, remain unresolved. The NRC and the Susquehanna River Basin Commission have allowed PPL to play a regulatory shell game.

TMIA and Mr. Epstein have sought to cure "irreparable harms" caused by an incomplete public record, the adverse precedent sets by not resolving the exiting procedural and technical omissions and thereby prevent identified and unidentified repercussions that may result from the Approval of PPL's Present License Renewal Application ("LRA").

All parties can agree that unintentionally destabilizing a sensitive and important aquatic asset is not in the public interest, and all sensible and proactive measures should be deployed to mitigate against this scenario. The "merits" of an exhaustive investigation are innumerable, and present no hardship to PPL Susquehanna.

This Case will inform future nuclear uprate and relicensing requests that will come before the Commission from the Peach Bottom Atomic Power Station, Three Mile Island, and the Susquehanna Steam Electric Station, as well as Early Site Permits and Letters of Interest for the construction of new nuclear power generation stations on the Susquehanna River. Even the NRC acknowledges the localized impact of the uprate request:

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To be sure, the EPU request will have implications in terms of increased water consumption, entrainment and impingement, and thermal and liquid effluent discharges, all of which are evaluated in the ER accompanying the PPL application that has not been the subject of Epstein's contentions. (3)

III. Outstanding Technical Issues PPL Susquehanna's requests before the NRC and the SRBC would extend the license of Susquehanna Unit 1 and 2 for an additional 20 years beyond the current expiration dates on July 17, 2022 and March 23, 2024. The Susquehanna nuclear power plant produces approximately 60 metric tons of high-level radioactive waste per year.

Susquehanna is one of 21 nuclear power plants where used reactor fuel pools have reached capacity, and is currently requesting permission to store an additional 1,200 tons of high-level nuclear waste along side of the Susquehanna River. (4)

Even more baffling are the regulatory moats that federal and state agencies erect to protect rigid and exclusive zones of interest that have been established without a collaborative framework. This type of regulatory behavior gives rise to undesired corporate behaviors such as "grandfathering" and "back fits," e.g., unapproved "uprates," passive deterioration of monitoring equipment, "immature" and inadequate scale model testing," time delays causing avoidable leaks, and waivers for monitoring wells.

3 "U.S. NRC Atomic Safety & Licensing Board Panel, Memorandum & Order, In the Matter of the PPL Susquehanna LLC," (Susquehanna Steam Electric Station, Units 1 and 2), Docket Nos. 50-387 and 50-388-OLA, ASLBP No. 07854-ol-BDol, July 27, 2007: Judge G. Paul Bollwerk, III, Chairman, p. 22.

4 Under current South Carolina law, PPL (as well as Exelon and FirstEnergy) will begin storing low-level radioactive waste onsite as of July 1, 2008 when Barnwell closes its facility to states outside of the Atlantic Compact.

Pennsylvania has no back-up site, and is member of the Appalachian Compact.

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The same Company which is requesting a surface water withdrawal "modification" (including a voluntary commitment to check the River Intake Structure) is the same Company that has been cavalier in addressing water-leakage and safety-related challenges at the SSES.

For example, although PPL was unable to provide well logs for TW-1 and TW-2, (5) the SRBC "grandfathered" TW-1 and TW-2. These wells are used to "supply sanitary water for the facility, to produce demineralized water, to maintain pumps seals, and for miscellaneous uses..." (6), and may (or may not) be included in the Company's tritium monitoring pogrom according to recent documents submitted to the NRC which indicate "quarterly sampling of four wells." (7) This is information the public has a Right-to-Know given the tritium leaks that have occurred at-numerous nuclear plants across the nation, and PPL's identification of "inadvertent releases of radioactive liquids" in December 1983, April, 1988, July, 1991, and February, 1995. The Company also reported 15 pollution incidents onsite from 198o through 1995." (GEIS, 2-23)

PPL Susquehanna has a recent history of requesting and receiving postponements and allowing those requests to atrophy. PPL was recently cited by the NRC after a lapsed safety-related incident occurred at the SSES. This avoidable violation demonstrates PPL's voluntary commitments are hollow:

5 SRBC & PPL Settlement, p. 3.

6 PPL Susquehanna, LLC, Susquehanna Steam Electric Station, Units 1 and 2; Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed License Amendment To Increase the Maximum Reactor Power Level, "Liquid Radioactive Waste and Offsite Doses [Federal Register:

August 21, 2007 (Volume 72, Number 161)] [Notices] [Page 46670-4668o].

7 Letter to the NRC, "Susquehanna Steam Electric Station Groundwater Protection - Data Collection Questionnaire," PLA 6086, Britt T. McKinney, Sr.

Vice President & Chief Nuclear Officer, July 20, 2o06.

The GEIS indicates that the sampling has been expanded to six wells.

(2.24) 5

PPL identified a jacket water flange leak during a diesel generator surveillance test on December 2, 2005, and entered this condition into the corrective action system. Although the leak was small and did not originally impact system operability and reliability, PPL rescheduled, delayed, and deferred repair work for this gasket connection until the degraded joint caused a leak of 12 gallons per hour during a March 28, 2007, surveillance test.

Due to the increased rate of jacket water coolant inventory loss, and the difficulty quantifying the leak rate, PPL shut down the engine and declared the "E' EDG inoperable. This caused a Technical Specification EDG to be unavailable and the station calculated risk to increase. (8)

(Boldface type added)

The NRC did not investigate site-specific aquatic challenges (9) at the SSES or relied on outdated data.

DEP confirmed that zebra mussel adults and juveniles have been found in Goodyear Lake, the first major impoundment on the Susquehanna River's main stem below Canadarago Lake in New York. Zebra mussels are an invasive species posing a serious ecological and economic threat to the water resources and water users downstream in the river and Chesapeake Bay. On June 19, 2007, zebra mussels were discovered in Cowanesque Lake, Tioga County.

8 NRC Inspection report 05000-387/2007003 and 05000388/2007003, "Post-Maintenance Testing," NRC Paul G. Krohn, Chief, Projects Branch 4, Division of Reactor Projects, July 24, 2007, pp. iii, 6-8)

"This finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and negatively affected the cornerstone's objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is related to the Problem Identification and Resolution cross cutting area (Corrective Action) because PPL did not take actions to correct the jacket water leak in a timely manner, commensurate with the issues safety significance. (P.i(d) (Section 1R19)

(Boldface type added) 9 PPL Susquehanna, LLC, Susquehanna Steam Electric, Units 1 and 2; Draft EIS and Finding of No Significant Impact Related to the Proposed License Amendment to Increase the Maximum Reactor Power Level, Federal Register:

August 21, 2007 (Volume 72, Number 161, pp. 46670-4668o.

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This marks the first time zebra mussels have been discovered in a the Susquehanna River watershed. (1o) Zebra mussels, like Asiatic clams, and other biological fouling, (11) can invade the SSES from the Susquehanna River.

According to the NRC, "the Asiatic clam is being controlled with an approved molluscicide in the spray pond, and any chlorine discharge is controlled by the NPDES permit." (12)

The NRC ignored the fact that zebra mussels were discovered at PPL's "fail-safe" water supply in Cowanesque Lake and noted: "There is no evidence zebra mussels have been found in anywhere in the vicinity of the SSES..." But the NRC acknowledges the "SRBC requirement that the SSES compensate consumptive water use during river low-flow conditions by sharing the costs of the Cowanesque Lake Reservoir, which provides river flow augmentation source."

Four of the issues Mr. Epstein raised at the SRBC remain unaddressed (Epstein Appeal, pp. 8 and 15; (c) (d) (e) (f), (g)), and were deemed "outside the scope" of the NRC's relicensing and uprate hearing process. Neither PPL, the EPA, the DEP or the NRC addressed health, safety and structural challenges caused by: micro fouling versus macro foiling; micro biologically influenced corrosion; biofilm's disease causing bacteria such as Legionella and listeria and the difficulty in eliminating established biofilms; oxidizing versus non-oxidizing 10 "In 2002, the first report of zebra mussel populations in the Chesapeake Bay Watershed were reported from Eaton Reservoir in the headwaters of the Chenango River, a major tributary to the Susquehanna River in New York. A short time later, zebra mussels also were found in Canadarago Lake, a lake further east in the Susquehanna main stem headwaters. Now, through DEP's Zebra Mussel Monitoring Network, reports were received that both zebra mussel adults and juveniles, called veligers, have made their way down to the Susquehanna main stem headwaters" (Pa DEP, Update, July 16, 2004) 11 Algae blooms recently "caused continuous clogging of multiple strainers of all pumps in TMI the intake structure; including: the two safety related DR pumps, all three safety related NR pumps, and all three non-safety related secondary river pumps." (NRC IR 05000289/2oo6oo4, p. 7) 12 NRC, "Memo and Order," July 27, 2007, p. 24, Footnote 20.

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biocides; chlorine versus bleach; alkaline versus non-alkaline environments; the possible decomposition into carcinogens; and, the eastward migration of Asiatic clams, zebra mussels and the anticipated arrival quagga mussels.

With the exception of a passing reference to the "annual survey" of zebra mussels, and the recognition that the "SESS has no procedure in place for treating Asiatic clams," both the NRC and SRBC have declined to deal with the issues Mr. Epstein raised relating to micro fouling, macro foiling, micro biologically influenced corrosion, biofilm disease, and the anticipated arrival of quagga mussels. ("U.S. NRC, Generic Environmental Impact Statement, Supplement 35: Regarding the Susquehanna Steam Electric Station, Unit 1 and 2," p. 2-31, April, 2008)

In regard to zebra mussels and Asiatic clams, the NRC supported Mr.

Epstein's contention, "Both species can cause biofouling of the power plant and other industrial water systems." (2-31, Lines 19-20)

PPL's introduction of a "new procedure" to analyze corroded and fouled intake pipes does not address the root cause of the biofouling or technical challenges afflicting the River intake flow meters. (Letter to Jerome S. Fields, PPL Susquehanna, from the Paula B. Ballaron, Director, SRBC, Regulatory Program, September 19, 2007, p. 3) Mr. Epstein furthered explained the peril linked to missing manifests that were simply "grandfathered" into compliance:

Although PPL was unable to provide well logs for TW-1 and TW-2, (SRBC & PPL Settlement, p. 3) the SRBC "grandfathered" TW-i and TW-2. These wells are used to "supply sanitary water for the facility, to produce demineralized water, to maintain pumps seals, and for miscellaneous uses..." (13) 13 PPL Susquehanna, LLC, Susquehanna Steam Electric Station, Units 1 and 2; Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed License Amendment To Increase the Maximum Reactor Power Level, "Liquid Radioactive Waste and Offsite Doses [Federal Register:

August 21, 2007 (Volume 72, Number 161)] [Notices] [Page 46670-46680].)

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Based on the US NRC's GEIS Supplement 35, "Regarding Susquehanna Steam Electric Station, Units 1 and 2 (April 2008)," the NRC has acknowledged the absence of water monitoring tools for Algae (periphyton and phytoplankton),

and benthic macro invertebrates. This monitoring ceased in 1994. (2-29 & 2-30)

The NRC acknowledged, "PPL does not sample private wells on nearby properties. The closest well is a domestic well near the southeast corner of the facility." (GEIS, "Water Quality," 2-24).

At issue is if there is a tangible impact to the community when a major industrial facility on the Susquehanna River is unable or unwilling to defeat water fouling, pipe corrosion, aquatic challenges and ineffectively meters increased water consumption. Any infection to the River's body, can infect the parts as well as the sum of the region's inhabitants. Central Pennsylvania is already under siege from regulations and mandates resulting from the deterioration of the Chesapeake Bay.

Mr. Epstein is asking the NRC to complete a full administrative record; rather than selectively evaluate, and then eliminate water use and water safety issues based on a perceived and nebulous concepts of "regulatory creep." (14) 14 Regulatory coordination gained momentum with the formation last month of an environmental law task force composed of federal, state, and local law enforcement and regulatory agencies to make sure business and individuals comply with air and water regulations. "Federal, state and local law enforcement and regulatory agencies have formed a task force to combat violations of federal and state environmental laws in Western Pennsylvania...

While members of the task force currently pursue violators, she said, integrating their efforts into a focused plan will produce more effective investigations and prosecutions.

"The 15-member task force includes the federal Environmental Protection Agency and the FBI, the Pennsylvania Department of Labor and the state police, the Allegheny County Health Department and the Pittsburgh Public Safety Department." (Pittsburgh Post Gazette, April 24, 2008) 9

Mr. Epstein recognizes that administrative agencies are created by statute, and their purview is limited to their express or inherent authority. Mr.

Epstein is not asking the NRC to go beyond their "charter."

However, the fragmentation of "regulatory oversight" or the segmentation of a large or cumulative project into smaller components in order to avoid designating the project a major federal action has been held to be unlawful. (15)

Mr. Epstein does not oppose the uprate or relicensing of the SSES, but has spent a great deal of personal resources "chasing down" answers to water use, water safety, and water chemistry questions as well as seeking clarification regarding interagency oversight and coordination.

Mr. Epstein simply wants to have the NRC answer questions he raised dating back to 2006.

PPL will face water chemistry, bio-fouling and aquatic challenges, and may impact PPL's equipment and operational abilities. These are the facts. Yet some unidentified agency is charged to provide oversight. Due to regulatory neurosis, area residents have been placed in environmental limbo.

15 City of Rochester v. United States Postal Serv., 541 F.2d 967, 972 (2d Cir.

1976) ("To permit noncomprehensive consideration of a project divisible into smaller parts, each of which taken alone does not have a significant impact but which taken as a whole has cumulative significant impact, would provide a clear loophole to NEPA."); Scientists' Inst. for Pub. Information, Inc. v. AEC, 156 U.S.

App. D.C. 395, 481 F.2d lo79, lo86 n.29, 1o86-89 (D.C.Cir. 1973) (statement required for overall project where individual actions are related logically or geographically). See generally W. Rodgers, Environmental Law BB 7.7, 7.9 14(1977) (discussing problems arising from scope and timing of environmental impact statements). The Supreme Court, however, has made clear that there is no affirmative obligation to regionalize a proposal under NEPA; a project of genuinely small scope of course would not be an impermissible segmentation. See Kleppe v. Sierra Club, 427 U.S. 390, 399-402, 96 S. Ct. 2718, 2725-2726, 49 L. Ed.

2d 576 (1976) (no obligation to prepare impact statement as to regional effects where no regional action proposed).

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IV. Socioeconomics Pennsylvania is the third oldest state in the nation, and its fastest growing population segment is octogenarians. An aging population base has unique and sensitized needs that were not factored, considered, or analyzed in the licensee's application or the NRC's GEIS. Moreover, by its own admission, PPL's plan to raise electric prices by at least 34.5% in the near future which will affect fixed-income and aging populations especially hard. (16)

"Rate shock" is not considered as a socioeconomic impact, but the GEIS assuringly noted, "There would also be no disproportionately high or adverse health or environmental impact ts as a result on minority and low-income populations in the region." (4-55)

An aging population base affects staffing, offsite support staffing, response times, emergency planning and social services. These human components are critical ingredients in the infrastructure of any large industrial complex. The ripple impact was not discussed in the GEIS. transportation and support services were limited to two paragraphs on 4-32. With a steadily aging population, where are the EMS and EMT technicians, and paramedic fire service providers going to come from, in state and a sector built on volunteerism?

In 2003, 16.2 million patients across the country arrived by ambulance for emergency department visits (14.2%). Or, about 31 ambulances arrived at an American emergency department every minute. Of ambulance-related visits, 39% were made by seniors, 68% were triaged as emergent or urgent, and 37% resulted in hospital-admission. (16) 16 Petition of PPL Electric Utilities Corporation for Approval of a Competitive Bridge Program, Pa PUC, Docket No: Pooo62227, 2006) 17 Data from the 2003 ED component of the National Hospital Ambulatory Medical Care Survey were used for the analysis. Data were provided by 405 participating EDs on 40,253 visits. Data from supplemental questionnaires to the hospital staff were used to describe volume and frequency of ambulance diversions.

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Who is going to taking an aging population to the ER?

The Bureau of Labor Statistics has calculated the average age and median years of tenure for persons in specific occupations in the United States. This data are useful for career planning, understanding turnover, and maintaining stability in volunteer recruitment. The average age of workers in this occupation was 34.3 years old in 1998, compared to 38.0 years for all occupations in this country. (18)

PPL and the NRC have failed to ask, let alone answer, who is going to transport and provide the emergency services for an economically distressed population in need of medical services?

While PPL and the NRC have spent large sums of money and countless hours examining the effect of aging of reactor components and an aging management review pursuant to lo C.F.R. §54.21(a) and lo C.F.R. § 54.21(c),

neither entity has examined the impact of relicensing on aging human beings who live within the shadow of the plant.

In Luzerne County, the population declined 1.8% between 2000 and 2003, and Columbia experienced a .9% increase. The U.S. Census Bureau reported that the average population of 65 years or older per county is 12.4%. However, the percent in Luzerne is 19.7% and in Columbia it is 15%. In Salem Township, host to the nuclear plant, the percentage of residents over 65 years of age is 19.6%.

Columbia and Luzerne Counties are two of six counties in the 29 county rate base "above the system average percentage of the poverty level." The data PPL uses is supplied by the Census Bureau and PA PUC's Bureau of Consumer Services, and indicate that 22.8% of the Luzerne County and 23% of the Columbia County populations qualify as "low-income households" eligible for energy assistance, i.e., living at or below the federal poverty levels.

18 The Occupational Outlook Handbook (2006-2007).

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People are not abstract hypotheticals that attorneys in DC can rework into a neat formula. Taken together, both counties are housing older Pennsylvanians less likely to be absorbed into a nuclear work force. These senior citizens are concurrently paying higher electric rates, and more in property taxes as a result of the operation of the Susquehanna Steam Electric Station.

The Company has not anticipated or planned to address the hardships it has created for the 65+ community: "PPL Electric has conducted no polling to gauge residential customers' awareness of rate caps and the impact that the removal of those caps would have on electric rates." (PPL EU, Pa PUC, Bridge to Competition, 2006).

The SSES area is an aging population with a significant portion of its residents living in poverty and facing "rate shock" and higher property taxes. If the Company can marshal the resources to seek approval for an uprate, relicensing and increase its rates, than it can find the time and resources to prepare an analysis to asses the impact of "rate shock" and property devaluations on the most vulnerable populations residing in its own backyard.

Failure to survey the impacts of relicensing on an aging community, is a stunning indictment on the NRC's inability to grasp that a good workforce and a solid community are interchangeable parts.

Deregulation shifted power plants back to the local tax rolls under the assumption that utilities would pay at least the same amount had they been subject to real estate taxes. However, after PPL collected over $2.86 billion in "stranded costs" for building ill-advised nuclear power plants, they claimed that their generating stations had depreciated overnight and were only worth a fraction of pre-deregulation estimates.

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PPL's tax analysis is flawed and lacks historical perspective. The Company failed to assess the impact of Revenue Neutral Reconciliations at the SSES on local citizens, residents, taxpayers, and homeowners. Both PPL and the NRC omitted PPL's total return in the last five years when factoring socioeconomic impacts and tax contributions. "PPL's total return has been 254 percent, more than three times the return of the S&P index." (19)

By limiting their historic snapshot from 2001-2005, PPL provides an incomplete fiscal picture of the impact their property devaluations and legal suits had on local taxing bodies. PPL has conveniently omitted the tax strain it has caused for residential consumers and senior citizens living on fixed incomes.

What's more, both PPI and the NRC failed to note that millions of dollars in regulated tax revenues are recovered by charging rate payers, i.e., $245 million (2007) and $265 (20o6). PPL and the NRC also did not factor the transition costs PPL sucks out of the same rate payer, i.e., $574 million (2007) and $884 (2006). (20)

The NRC repeated the same mistake as PPL and limited their tax analysis from 2002 -2005. The GEIS failed to note PPL's record profits, and provided no baseline to asses staffing trends at the SSES, e.g., retirements, attrition, "early out," full time v. part time, and "out sourcing."

However, the NRC accepted a staffing level figure at the SSES that is significantly below comparable per reactor employment levels at the Three Mile Island Nuclear Generating Station and the Peach Bottom Bottom Atomic Power Station.

19 James H. Miller, Chairman, President and CEO, April 4, 2008, "PPL Corporation 2007 Annual Report," Summary of Significant Accounting Polices, P. 4) 20 "PPL Corporation 2007 Annual Report," Summary of Significant Accounting Polices, p. 64.)

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The NRC attempted to address socioeconomic and tax related issues, but offered only cursory and superficial data. Relicensing a nuclear power plant should not impose economic hardships on the host community. PPL has successfully sued local taxing authorities, while at the same time increasing capacity and requesting a license extension.

Either the NRC must reexamine the economic impact of SSES on the community, or address how relicensing a nuclear power plant while shifting the tax burden and increasing rates on an aging community is compatible with the NRC's mission.

PPL agreed with TMIA relating to the import of economics on the relicensing -of the Susquehanna Electric Steam Station. In November 20o6, as part of its effort to promote relicensing of the SSES, PPL and the nuclear industry released, Economic Benefits of PPL Susquehanna Nuclear Power PlantAn Economic Impact Study by the Nuclear Energy Institute in Cooperation With PPL Corporation. Table 2-1. PPL Susquehanna Nuclear Power Plant specifically advertises and promotes the value of relicensing on local community, without evaluating any of the negative consequences.

PPL is now asking to extend the license of the Susquehanna Steam Electric Station under a new protocol which would adversely impact an aging population dependent on a fixed income levels. As a result of PPL's actions, this population that is being asked to absorb rising electric costs and property tax rates, in part due to the extended operation of the Susquehanna Steam Electric Station.

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V. Conclusion The NRC and PPL must confront unresolved water use, water safety, and interagency issues, even if they fall outside the conventional nuclear tool box.

Power generation, plant cooling, public safety are inherently connected. There is no separate imaginary fence between generation and safety.

Epstein and TMI-Alert have demonstrated that aging equipment coupled with water shortages, water chemistry or invasive aquatic species could create safety challenges at the Susquehanna Steam Electric Station over the life of the license extension.

The impact of relicensing on the local community is material and germane and the NRC should not sanction the relicensing of nuclear power plant that will result increased property taxes. The NRC must consider economic affects on a community since they are interrelated with the natural and physical effects of relicensing the SSES. (40 C.F.R. §158o.14, Met Ed V PANE, 460 U.S. 766, 722 (1983))

The public should be inoculated against artificial regulatory moats imposed by the SRBC, subjective safety definitions created by PPL, and "cut and paste" oversight produced by the NRC. (21)

There has to be a better way. With health insurance outpacing inflation, property taxes steadily increasing, and electric rates poised to spike, can consumers afford to live near a nuclear power plant that produces never ending rate hikes?

21 Essentially, DLR [the Division of Licensing Renewal] lacks a complete report quality assurance process to ensure documentation of the staffs aging management program review methodology and substantive support for staff conclusions. (NRC, Office of Inspector General-o7-A-15, September, 2007, p.11) 16

419f' UifllascW Road Ha~isburg1 PA 17112, ericepstein@ comcast.net I hereby certify that on May 28, 2008, "Eric Joseph Epstein's Comments on Behalf of Three Mile Island Alert, Inc. Re: Draft Environmental Report for Susquehanna Nuclear Plant License Renewal Applications from PPL Susquehanna, LLC" was sent via electronic mail and/or via United States Postal Service:

Office of the Secretary Office of the Commission U.S. Nuclear Regulatory Commission Appellate Adjudication 16th Floor US NRC Washington, DC 20555-0001 I One White Flint North 11555 Rockville Pike, Rockville, Maryland 20852 Attn: Rulemaking and Adjudications Staff Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff US NRC Office of the General Counsel Lawrence J. Chandler, Esquire Mail Stop Washington, DC 2055-0001 17