Don't Waste Michigan

August 22, 2005

Chief, Rules and Directives Branch

Division of Administrative Services

Office of Administration

Mailstop T-6D 59

U. S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Public Comments: Environmental Impact Statement re: Proposed 20 Year Extension of the Operating License for the Palisades Nuclear Power Plant [Docket No. 50-255; License No. DPR-20; Palisades owner is Consumers Energy/CMS; Palisades' operator is Nuclear Management Company, LLC]

Comments submitted by:

Gary Karch

251 Cass St., #714

Niles, MI 49120

A process that appears designed to intentionally disenfranchise a population with which it is supposed to promote dialogue can only be looked at with skepticism and must be considered a ruse and a sham. Although the model as presented for public comment regarding the request for a twenty year license extension for the Palisades Nuclear Plant in Van Buren County, Michigan, meets guidelines as established by the NRC, it provides little opportunity and draconian deadlines for true citizen participation to exist. Such restrictions may have been dismissed by communities in which other license renewals have been requested and approved, but I submit that Southwest Michigan holds itself to higher standards and wishes to challenge the industry paradigm and demand a more reasonable and humane response to this license renewal process than the flawed one that has been foisted upon us.

Current standards only allow for easy participation from persons living within the industry-designated ten mile radius emergency planning zone. Obviously radiation travels far greater distances than that, and even the extended 50 mile radius does not realistically encompass the distance a radiation release can travel. Meetings have been scheduled only in the South Haven area with limited publicity and at times that impede a working public's ability to attend. These dates and locations may be convenient for Palisades representatives and NRC staff but not to residents in the greater area affected by the plant's existence. For example, the next public meeting in which these and other comments submitted by today's deadline will be discussed is scheduled for the Friday before Labor Day. This insults the public, inhibits participation by interested citizens and denigrates the integrity of the process.

Materials pertinent to the license currently available only at the South Haven library should be made available in a majority of libraries located within the 50 mile radius. The whole process needs to be expanded to include public meetings and comment opportunities in all communities within the entire 50 mile radius who wish to request them. If the plant owners and managers have nothing to hide and take pride in their operation, then they should have no reservations about taking their meetings on the road and extending the process to a more reasoned pace. And if the NRC believes in the integrity of their process, they should likewise be up to this challenge. It is six years before the current license expires. There is no need to rush through the process. In fact, a more lengthy approach that is truly inclusive of citizen participation from affected communities should be encouraged.

Let us not forget that we are discussing the continued production for another 20 years of a lethal waste that requires extreme safety control measures. We are not talking about a tootsie roll factory here. The waste product is being stored on the shores of a body of water that constitutes one fifth of the earth's surface fresh water and which provides potable water to millions of people. Another twenty years of accumulated waste added to the already existing lineup of outdoor dry cask storage situated on unstable sand dunes is a major concern.

It has been recently confirmed by the National Academy of Science that there is no safe level of exposure to radiation and that even very low doses can cause cancer. I am therefore disturbed by nuclear industry corporate culture that has a ubiquitous record of dismissing legitimate concerns about radiation exposures. In the case of Three Mile Island, it has been found by more recent independent analysis of the 1979 accident that placement and frequency of monitoring devices were highly inadequate and unable to establish accurate data from which to establish radiation release patterns. For residents of Harrisburg and the surrounding area, that meant their reported symptoms of metallic taste, erythema, nausea, vomiting diarrhea, hair loss, deaths of pets and farm animals were attributed to stress brought on by the accident, not radiation releases from the accident. Apparently if no monitors were present in any given neighborhood and therefore no radiation data could be collected, then no radiation had been released. People were treated as though they had psychological problems, not legitimate symptoms of radiation exposure.

Exactly how will the citizens of Michigan be treated should a similar accident occur at Palisades? I simply refuse to accept my community being treated in such an insulting and degrading manner. I therefore ask that a complete map showing existing radiation detection locations for Palisades be provided and frank discussion on this monitoring methodology be initiated. I also ask that public health data regarding cancer rates in surrounding communities of the Palisades Nuclear Plant be included in the discussion, and participation by Michigan Department of Community Health epidemiologists be present at future hearings.

I also request that information reflecting the true financial taxpayer economic burden of the plant, including all anticipated guaranteed loans, tax incentives, and any other additional financial deals expected to be requested by plant owners that are contingent upon Palisades' continued operation, be provided at some point in the proceedings, or the means and process to obtain such data be provided. While I realize that this is not germane to the Environmental Impact Statement, disclosure of this information is vital to assessing Palisades' true financial worth to the community.

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Palisades nuclear reactor:

This aging, embrittled nuke needs to be shut down. The NRC re-licensed the aging nuclear reactor for another 20 years. That will be 60 years running, if it doesn't blow up first. The reactor was designed and built for 20 years. The NRC is rubber-stamping the re-licensing of nuclear reactors throughout the USA. Nuclear energy is not a solution to global warming. In the process of mining uranium, processing uranium, transporting nuclear fuel, building and running nuclear power plants, nuclear waste production, transportation, and dumping....tremendous amounts of fossil fuels are used, and the lake/river waters used to cool down nuclear reactions creates water heating, atmospheric heating and radioactive elemental releases into the environment.

A coaltion of environmental groups, including Don't Waste Michigan has filed a lawsuit in federal courts because the re-licensing did not take into account some very important issues.

The area surrounding Palisades is a cancer pocket. If you live in that area, and have cancer, know someone with cancer, or someone who has died from cancer, your testimony is especially crucial to the shut down. The goal of DWM is to shut it down before it melts down. Members of DWM have regularly attended meetings with the NRC with the purpose of bringing issues to light, getting testimony on the federal record, and to shut down unsafe nuclear reactors.

"Within the nuclear industry, it is well known that Palisades is the most likely to blow of all nuclear reactors in the United States....they don't necessarily cover things up, they just don't report them"

~former Palisades worker (who quit and moved to another state because of the way the Michigan nuclear industry runs things. He is still employed in the nuclear industry. His name is withheld at his request and to safeguard his worker status.

DWM members have brought it to the attention of the NRC and Homeland Security the need for more security surrounding and within nuclear reactors. Even without a terrorist attack, the mere operation of a nuclear reactor is a potential terrorist act, if a meltdown should occur.

Consumers Energy sold Palisades to Entergy, a mega-nuclear corporation with a bad track record. Consumers Energy buys power from Entergy to sell nuclear power to its customers. It has invested in wind power and is building natural gas plants also. DWM feels that a sustainable future can only be realized with safe, renewable energy systems, such as wind, water, and solar power.

There are so many issues that it is impossible to list them here.

The only nuclear reactors shut down instead of re-licensed were in the state of Maine where the people came out to protest. Since then, the NRC has changed their tactics. They operate as a rogue agency, cutting out public meetings and rubberstamping nuclear reactors without answering legitimate concerns the public brings forth.

Palisades (NIRS) website http://www.nirs.org/reactorwatch/licensing/palisades.htm

At a November 2004 meeting, the public was given time to speak.

When the South Haven mayor spoke out that the people of South Haven wanted the nuclear power plant, citizens rose in protest. "He does not speak for us! There is a cancer pocket here!"

In November, he was not re-elected, losing by 70%...

The people have spoken!

Get active and stop the terrible disaster that could happen if Palisades blows like Chernobyl....

60 years of a cracked reactor is too big a risk!!! It must go...and you can help.

Palisades issues:

Embrittlement

Global warming caused by nuclear energy

Cask problems (nuclear waste storage)

Nuclear accidents

The threat of terrorism

etc......public comments were truncated and edited in the EIS. by the NRC.

UPDATE 2007: The NRC rubberstamped the re-licensing of Palisades without allowing the public meetings as promised in winter/spring of 2007. The NRC never answered the questions put forth by DWM re: embrittlement, cask #4 (bad welds), nuclear waste buildup, rad waste spills, terrorism, and other issues.

UPDATE 2008: ENTERGY sold Palisades to ENEXUS, a subsidiary of itself. It is seeking the license transfer. So far problems have NOT been fixed: i.e. reactor head, snuffer valves, embrittlement etc. On August 5, there was an incident now under NRC investigation.

READ MORE ABOUT THE AUGUST 5th INCIDENT AND HOT SHUT DOWN.

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DWM member Kathryn Barnes reports on oil spill

NUCLEAR INFORMATION & RESOURCE SERVICE

SIERRA CLUB PUBLIC CITIZEN REDWOOD ALLIANCE

COMMITTEE TO BRIDGE THE GAP

Immediate Release: Nov. 10, 2004

Contacts: Diane D'Arrigo, NIRS (202) 841-8588 (cell)

Erica Hartman, Public Citizen (202) 454-5174

Dan Hirsch, CBG (831) 462-6136

Michael Welch, Redwood Alliance (707) 822-7884

5 Groups Sue Dept. of Transportation for New Rules that

Allow Nuclear Waste to Move Unregulated, Unmarked

Five public interest organizations filed suit in a Northern California federal district court against the US Department of Transportation (DOT) for its adoption of rules which reduce public protections by allowing more radioactivity to move on roads, rails, planes and waterways without regulatory control. The groups are Nuclear Information and Resource Service, Sierra Club, Public Citizen, Redwood Alliance and Committee to Bridge the Gap. The groups are calling for withdrawal of the portions of the rule that exempt and weaken nuclear transport controls and for full environmental impact review.

The regulations exempt various amounts of every radionuclide (all the radioactive forms of each element) from radioactive labeling, tracking, and control. They also allow some nuclear materials to be shipped without packaging. The groups will also challenge, in a separate case, the Nuclear Regulatory Commission (NRC) which simultaneously adopted the same regulations. A whole new category of exempt quantities has been adoptedallowing radioactive packages (called consignments) to be considered not radioactive in transport. The exempt concentration limits have changed, exempting higher concentrations for more than half of the hundreds of radionuclides listed.

"At a time of heightened concern about dirty bombs, the federal government should not increase the amount of nuclear material that can be transported without any labeling or tracking. This is the exact wrong time to let go of nuclear materials and wastes," stated Diane D'Arrigo, Radioactive Waste Project Director at Nuclear Information and Resource Service. "Watching for and detecting dirty bombs will be harder if more radioactive materials are shipped routinely without placards or manifests."

"Workers and the public will be exposed to radiation without their knowledge or consent. It is forced radiation exposure," charged Wenonah Hauter, director of Public Citizen's Critical Mass Energy and Environment Program.

Truck drivers, rail workers, loaders, emergency responders, even postal workers could be exposed routinely to more radioactivity than before without warning. Workers in the transport and shipping industries will get the highest doses but everyone who lives, works and travels along the routes could come into regular contact with unidentified nuclear waste. According to calculations in the DOT rule, truck drivers could get more radiation from hauling unmarked radioactive materials than one is allowed living next to a nuclear reactor or weapons site. DOT admits workers and the public will have more exposure to radioactivity but discounts the dangers of radiation, failing to consider the impacts on those more susceptible to radiation like children, the fetus, women and those with reduced immunity.

The transport rule fits into a larger picture of deregulating nuclear waste. Other federal agencies including the NRC, the Environmental Protection Agency (EPA) and the Departments of Energy and Defense (DOE, DOD) are in various stages of deregulating nuclear wastes and sites over which they have jurisdiction. If they proceed with deregulating nuclear wastes as now proposed, radioactive materials could go to municipal and industrial landfills, incinerators and scrap recycling centers. Workers at those sites would be regularly exposed to more man-made radiation. Changing the transport regulations makes taking unmarked nuclear loads to unregulated destinations possible once they are cleared by those other agencies.

"Removing existing requirements for labeling in transit will make it easier for other agencies to let nuclear wastes get out into commerce. The public will be exposed both during transport and then again from the products, buildings and roads made from nuclear contaminated materials," explained Dan Hirsch, President of the Committee to Bridge the Gap.

"That is the real motivation," said Dr. Judith Johnsrud of the Sierra Club, "to assist the nuclear industry in treating some nuclear waste as if not radioactive. This saves the nuclear generators money and pushes the economic and health burden onto unsuspecting transporters, recyclers, local governments, the public and the environment."

No meaningful justification for the exemptions is provided by either DOT or NRC for relaxing restrictions on nuclear materials transport. The exempt concentrations and amounts adopted are the same as those recommended by international nuclear advocacy organizations to allow nuclear waste to be cleared for commercial recycling.

"It is not a coincidence. This weakening of the nuclear transport laws is a deliberate attempt to bypass the American public's opposition to nuclear waste deregulation and release into everyday commerce. DOT and NRC are teaming up with the global nuclear industry to make nuclear power appear cheaper while putting transport workers, the public and environment at unnecessary radioactive risk." said Michael Welch of the Redwood Alliance.

For more information on Nuclear Information and Resource Service (NIRS), go to www.nirs.org.

On Palisades, a webpage at NIRS: very informative, highly recommended

For more information on Public Citizen, go to www.citizen.org.

For more information on Redwood Alliance, go to www.redwoodalliance.org.

For more information on Sierra Club, go to www.sierraclub.org.

A great anti-nike website: www.beyond nuclear.org

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PRESS RELEASE

For immediate use

Monday, May 5, 2008

Kevin Kamps, Beyond Nuclear (240)462-3216

Dave Kraft, NEIS (773)342-7650

<>“NUCLEAR RENAISSANCE” A FRAUD, SAFE-ENERGY GROUPS CHARGE

CHICAGO—The much ballyhooed “Nuclear Renaissance” is nothing more than a PR fraud foisted upon an unsuspecting and uninformed public, charge two safe-energy groups today.

<>Kevin Kamps, nuclear researcher for Beyond Nuclear (www.beyondnuclear.org) of Takoma Park, MD, and Dave Kraft, director of the Chicago-based Nuclear Energy Information Service – two organizations critical of nuclear power – maintain that the Nuclear Energy Institute (NEI – the trade group for the US nuclear power industry) has long been inflating the alleged benefits of nuclear power, while keeping the public in the dark about the downsides.

“We refuse to allow the NEI to come to Chicago to perpetuate its fake ‘Nuclear Renaissance’ without a public challenge of its bogus claims,” says Kamps. “This is no ‘renaissance.’ It’s a relapse.” Kamps asserts.

<>The NEI is in Chicago for its 3-day annual conference at the Fairmont Hotel. Exelon Chair John Rowe is chairman of the NEI. Exelon has 14 reactors in Illinois (11 operating), more than any other state.

“At a time when high energy costs and the prospect of catastrophic climate change call for radical changes in how we get our energy, we will not sit by quietly or patiently while PR hacks spew the falsehoods that nuclear power is either economical, or able to help solve the global warming problem,” says NEIS’ Kraft. “The people like the NEI who deliberately spread these falsehoods to make a short-term buck will find that there will be consequences from now on,” Kraft warned.

<>Reality has been very unkind to the Nuclear Renaissance, formally launched at an industry conference at the Palmer House, Chicago, in December 2001. From the heady days of Vice President Cheney’s 2001 call for 150 new reactors and NEI’s claims of reactors costing $1 billion/GW each, today’s headlines talk of maybe 8-10 reactors being built in the US by 2020; and Wall Street and utilities themselves talking about reactors costing $6-$12 billion each.

“Every cost prediction the NEI and the nuclear industry have made has been wrong. Yet, this industry keeps coming back to feed at the public trough,” Kamps points out. “The 2005 energy bill granted over $21 billion in actual and guaranteed subsidies for the nuclear industry, with an additional $30 billion possible in the next year. And even the Lieberman-Warner bill – touted as a bill to support and invest in clean energy sources to fight global warming and due for a vote in early June -- has as much as $500 billion in hidden benefits for the nuclear industry, even though the word nuclear appears no where in the bill,” Kamps notes. “This kind of fraud would make Al Capone blush.”

While nuclear industry predictions about costs have always been undervalued, its claims about its role in fighting global warming seem to trend in the opposite direction according to Kraft.

<>“If global warming is the ‘Titanic’ of all environmental issues, one threatening civilization, then the nuclear industry and NEI are selling seats to the life-boats, and leaky life-boats at that,” Kraft claims. “Nuclear power is simply too slow, too expensive, less carbon-effective and adds other equally dangerous risks compared to other viable choices that exist already to reduce atmospheric carbon. It must be rejected as a ‘solution’ or even a ‘helper’ in the fight against global warming,” Kraft asserts. “It is unconscionable that the NEI continues to perpetuate such a fraud on an ill-informed public.”

Both Kamps and Kraft are quick to point out that as dire as the energy and climate situation appear, viable cost- and environment-effective means already exist to deal with the two crises -- simultaneously.

<>“The nation simply must launch a Manhattan Project-style effort to move this nation away from increasingly expensive and environmentally damaging nuclear and fossil fuel power,” states Kamps.

“Fortunately, such a program has already been researched,” notes Kraft. “It is called, ‘Carbon Free – Nuclear Free by 2050: A Roadmap for US Energy Policy,’ developed by Dr. Arjun Makhijani of the Institute for Energy and Environmental Research (IEER; www.ieer.org ). His calculations show that this country can get off of BOTH fossil and nuclear fuels by mid-century, using technology already largely invented and available, and do so in a cost-effective manner. The economic and environmental benefits of Carbon Free – Nuclear Free are extraordinary, far surpassing those of nuclear power,” Kraft concludes.

<>Both agree that the real barriers to such an energy program are largely political, not technological.

“The influence of the NEI and nuclear industry over the Congress and the regulators at the Nuclear Regulatory Commission is enormous,” Kamps points out. “The tail wagging this dog needs to be swatted hard,” he says.

<>“An old saying notes that, ‘If we keep doing things the same way we’ve always done them, we’re likely to get a whole lot more of what we already got.’ If the NEI and its clients get their way, that means more nuclear waste, higher cost electricity, more nuclear proliferation, and more global warming, since the money used on the fake nuclear ‘renaissance’ would not get spent on more effective means of removing atmospheric carbon,” Kraft asserts.

“All of the candidates running for President are simply more-of-the-same fence sitters,” Kraft says. “Sen. Obama is tragically misguided in his belief that nuclear power needs to be ‘kept on the table’. In spite of the heavy campaign contributions to all the candidates from the nuclear industry people, they all need to break away from this dead-end industry, and launch a real sustainable energy future,” says Kraft

“One that doesn’t suffer from the continual paid PR exaggerations of the NEI,” Kamps concludes.

<>RESOURCES FOR REPORTERS

NUCLEAR COSTS AND TECHNOLOGY:

•

Paul Gunter, Beyond Nuclear, (301)270-2209 paul@beyondnuclear.org

•

David Lochbaum, nuclear engineer, Union of Concerned Scientists, dlochbaum@ucsusa.org

•

Michael Mariotte, Nuclear Information and Resource Service, (301)270-6477 nirsnet@nirs.org

•

“Nuclear Power Costs: High and Higher,” Dr. Arjun Makhijani, Science for Democratic Action, January, 2008. http://www.ieer.org/sdafiles/15-2.pdf

CARBON FREE – NUCLEAR FREE BY 2050: A Roadmap for US Energy Policy

•

Dr. Arjun Makhijani, Inst. for Energy and Environmental Research, (301)270-5500 arjun@ieer.org

•

(note: a summary newsletter and the entire book is downloadable for free in .pdf format at www.ieer.org)

SOME RECENT ”NUCLEAR RENAISSANCE” ARTICLES AND QUOTES:

•

“What Nuclear Renaissance?”, Christian Parenti, The Nation, May 12, 2008, 4 pages. http://www.thenation.com/doc/20080512/parenti/print

•

“Forget Nuclear,” Amory B. Lovins, Imran Sheikh, and Alex Markevich, April, 2008, 7 pages with footnotes. http://www.rmi.org/sitepages/pid467.php

•

“Insurmountable Risks: Can Nuclear Power Solve the Global Warming Problem?,” by Brice Smith, Science for Democratic Action, August, 2006. http://www.ieer.org/sdafiles/14-2.pdf

USEFUL QUOTES:

“Isn’t it time we forgot about nuclear power? Informed capitalists have. Politicians and pundits should too. After more than half a century of devoted effort and a half-trillion dollars of public subsidies, nuclear power still can’t make its way in the market.” – Amory Lovins, Rocky Mt. Institute, “Forget Nuclear.” April 2008. (see above)

<>“This much seems clear: a handful of firms might soak up huge federal subsidies and build one or two overpriced plants. While a new administration might tighten regulations, public safety will continue to be menaced by problems at new as well as older plants. But there will be no massive nuclear renaissance. Talk of such a renaissance, however, helps keep people distracted, their minds off the real project of developing wind, solar, geothermal and tidal kinetics to build a green power grid.” -- Christian Parenti The Nation, May 12, 2008

“It does not make economic sense.” --Warren Buffet, on explaining his decision to end plans to construct a nuclear reactor in Idaho, January, 2008.

-- end --

<<<<<<The MIDWEST"S YUCCA MOUNTAN>>>>>>..

The Canadian nuclear industry and government are proposing to bury all of Ontario's "low" and "intermediate" level radioactive wastes 1 kilometer (0.6 miles) from the Lake Huron shoreline at the Bruce Nuclear Complex, just 50 miles east across Lake Huron from Michigan. Ontario has a whopping 20 nuclear reactors (by comparison, Illinois is the U.S. state with the most reactors, with "just" 12 operating reactors; Michigan has "just" 4 still-operating reactors, and 1 permanently shutdown reactor).

That's a lot of radioactive waste targeted for burial on Canada's Lake Huron shoreline!

These so-called "low" and "intermediate" level radioactive wastes contain all of the same radioactive poisons as high-level radioactive waste, only in lesser concentrations. The long-lasting radioactive poisons in these wastes include cesium-137, strontium-90, plutonium-239, iodine-129, and nickel-59, to name but a few of the hundreds of radioactive poisons present in the waste. They have a hazardous persistence of about (or longer than) 300 years, 300 years, 240,000 years, 170 million years, and 800,000 years, to give you an idea how long they will remain dangerous to human and ecosystem health. Given the fact that Lake Huron is the drinking water supply for many millions of people downstream including in Michigan this plan is unacceptable, given the risk that a dump that close to the lake would leak over such long time periods.

Such a dump would also set a precedent for dumping radioactive wastes on the shorelines of the Great Lakes elsewhere. And at the Bruce Nuclear Complex in Canada, it could pave the way for all of Canada's high-level radioactive wastes to be dumped at Bruce as well.

This dump needs to be stopped in its tracks, and the Michigan environmental movement is just the group of folks to do it!

Group Statement to Canadian Nuclear Safety Commission:

September 22, 2006

From:

Kevin Kamps

Nuclear Waste Specialist

Radioactive Waste Project

Nuclear Information and Resource Service (NIRS)

6930 Carroll Avenue, Suite 340

Takoma Park, Maryland 20912-4423

Phone (301) 270-6477 extension 14

Fax (301) 270-4291

Kevin@nirs.org

www.nirs.org

on behalf of Lone Tree Council, West Michigan Environmental Action Council, Michigan Coalition on the Environment and Jewish Life (MI-COEJL), Coalition for a Nuclear-Free Great Lakes, Don't Waste Michigan, Citizens Resistance at Fermi Two (CRAFT), Nuclear-Free Great Lakes Campaign, Green Party of Michigan, Van Buren County Greens, Citizens for Alternatives to Chemical Contamination, Environmental Coalition on Nuclear Power, Environment Michigan, Voices for Earth Justice, and additional concerned citizens (see full contact information listed at the end of this submission)

To:

Canadian Nuclear Safety Commission

Attn: Michael Rinker, Environmental Assessment Specialist

Environmental Assessment and Protection Division

P.O. Box 1046, Station B

Ottawa, ON K1P 5S9

Phone: 1-800-668-5284 Fax: (613) 995-5086

E-mail: ceaainfo@cnsc-ccsn.gc.ca

Re: Comment on the Proposed Scoping Document (Environmental Assessment Guidelines) for Ontario Power Generation's Proposal for a Deep Geologic Repository for disposal of "low" and intermediate level radioactive wastes in Kincardine, Ontario, Canada

[Submitted via email to ceaainfo@cnsc-ccsn.gc.ca, as well as via Fax to (613) 995-5086]

Dear Mr. Rinker,

We are writing to express our concern about Ontario Power Generation's proposal for a deep underground radioactive waste dump at its Bruce nuclear site in Kincardine, Ontario, Canada only one kilometer (0.62 miles) from the shore of Lake Huron.

We are very disappointed that the staff of the Canadian Nuclear Safety Commission (CNSC) has failed to support an upgrade of the current environmental assessment from a Comprehensive Study to an independent Panel Review. There are three important reasons to do so. First, an independent review panel would ensure a fair hearing, keeping the process at arm's length from the CNSC, which is too close to the nuclear industry. Second, until now, radioactive waste has only been kept in temporary storage facilities, and this proposal would set an historic precedent for permanent deep underground disposal of radioactive waste in Canada and the Great Lakes Basin. Thirdly, because it is so long-lived and has the potential to affect human health and the environment for many generations to come, the public has always been very concerned about radioactive waste disposal, both in Canada, the United States, and in First Nations and Native American Nations throughout the Great Lakes Basin.

While I understand that CNSC staff has expanded the alternatives being considered, alternatives should include monitored, retrievable "interim" storage at the nuclear sites that generated the wastes in the first place, and "reduction at source" of radioactive waste through nuclear phase-out.

In terms of the study area for the assessment, the proposed dump has potential environmental impacts not just locally and regionally, but internationally as well. Because the radioactive wastes will remain toxic for hundreds of thousands of years, the dump is a threat not only to this generation, but to thousands of human generations into the future, and not only to the locality and the region around the Bruce nuclear complex, but also to downstream communities on the Great Lakes in Canada and the United States of America, as well as to First Nations and Native American communities. CNSC staff has rejected any possibility that the dump could have trans-boundary impacts. However, research and documents published by the International Joint Commission on Great Lakes Water Quality make it clear that Canadian nuclear facilities on the Great Lakes have had measurable trans-boundary effects, as have U.S. nuclear facilities. The study area should be expanded to include communities on the Lake Huron shoreline in both the U.S. and Canada, as well as extended to include communities downstream of Bruce that draw their drinking water from Lake Huron and points downstream.

The following important issues also need to be addressed:

-- the lack of Canadian federal policy on the long-term management of low and intermediate level radioactive waste;

-- inclusion of decommissioning waste in planning for the Bruce facility;

-- extension of the assessment time to one million years because of the long lifetime of some radioactive elements in low and intermediate level radioactive waste;

-- detailed examination of the safety of radioactive waste transportation from the Pickering and Darlington sites to the Bruce site;

-- alternatives to radioactive waste incineration;

-- municipalities on transportation routes should be consulted on the initiation of further decades of radioactive waste transportation through their communities; and

-- costing and economic analysis of the main proposal and all alternatives should be mandatory.

We would also like to tentatively reserve speaking slots for the submission of oral presentations at the Monday, October 23, 2006 CNSC hearing in Kincardine, Ontario, Canada regarding this matter, for representatives of our organizations that may be able to attend this hearing despite the very long travel distances that would be required to attend.

Whether as written or oral submissions, we will continue to communicate to the CNSC our deep concerns about, and objections to, the concentration of radioactive wastes from a score of nuclear reactors across Ontario, and the risk of catastrophic radioactive contamination to Lake Huron and points downstream, if these accumulated wastes begin to leak out from the proposed burial dump just 1 kilometer (0.6 miles) from the shoreline of Lake Huron. Our coalition of groups and individuals deeply troubled about this dangerous proposal continues to grow in Michigan, and we will share with CNSC and other Canadian, U.S., and First Nations decision-makers an updated list of organizations objecting to this radioactive waste dump in the heart of the Great Lakes by the time of the October 23rd CNSC hearing.

We would also like to express our endorsement of the comments submitted by Dave Martin, Energy Coordinator, Greenpeace Canada and S. (Ziggy) Kleinau, Coordinator, Citizens for Renewable Energy, to CNSC as a part of this proceeding.

We also request a copy of the revised scoping document, CMD 06-H22. Our postal and email addresses are given below, so that you can either mail a hard copy of this document, or email us an electronic version or Internet link. This document is not posted on the CNSC web site, which has unfortunately made our participation in this proceeding more difficult. We respectfully request that all documents pertaining to this proceeding be posted to CNSC's website, as well as provided directly to us either through the mail or email, to facilitate our participation in this proceeding.

Please also send us any information or application forms pertaining to intervener funding, for those of us who wish to intervene in this environmental assessment proceeding.

Please consider our concerns. Thank you.

Sincerely,

Kevin Kamps

Nuclear Waste Specialist

Nuclear Information and Resource Service

6930 Carroll Avenue, Suite 340

Takoma Park, Maryland 20912

Kevin@nirs.org

Phone (301) 270-6477 extension 14

Terry R. Miller, Chairman

Lone Tree Council

4649 David Ct

Bay City, MI 48706

terbar@charter.net

Thomas Leonard, Executive Director

West Michigan Environmental Action Council

1007 Lake Dr. SE

Grand Rapids, MI 49506

tleonard@wmeac.org

Sara Bernstein, Program Manager and Betsy Winkelman, Co-Chair

Michigan Coalition on the Environment and Jewish Life (MI-COEJL)

6735 Telegraph Road, #205

Bloomfield Hills, MI 48301

mi-coejl@jfmd.org

Bernstein@JFMD.org

Michael Keegan

Coalition for a Nuclear-Free Great Lakes

811 Harrison Street

Monroe, Michigan 48161

mkeeganj@comcast.net

Alice Hirt

Don't Waste Michigan

6677 Summitview Drive

Holland, Michigan 49423

alicehirt@charter.net

Keith Gunter

Citizens Resistance at Fermi Two (CRAFT) and Nuclear-Free Great Lakes Campaign

15784 Whitby Street

Livonia, Michigan 48154

keithtada@sbcglobal.net

Chuck Jordan

Vice Chair and State Central Committee Whip

Green Party of Michigan

Co-Chair

Van Buren County Greens

50521 34th Avenue

Bangor, Michigan 49013

jordanc@btc-bci.com

http://vbcgreens.org

Kathy Barnes

Don't Waste Michigan

Sherwood Chapter

PO Box 26

Sherwood, Michigan 49089

Kay Cumbow, Director

Citizens for Alternatives to Chemical Contamination

8735 Maple Grove Road

Lake, MI 48632-9511

kcumbow@greatlakes.net

Judith Johnsrud

Environmental Coalition on Nuclear Power

433 Orlando Avenue

State College, Pennsylvania 16803

johnsrud@uplink.net

Mike Shriberg, Ph.D.

Director

Environment Michigan

103 E. Liberty Street, Suite 202

Ann Arbor, MI 48104

734-662-9797

mshriberg@environmentmichigan.org

Patricia Gillis

Executive Director

Voices for Earth Justice

26672 Elm Street

Roseville, Michigan 48066

586-779-8015

Voices4earth@juno.com

(www.voices4earth.org)

Individuals:

Catherine Quigg

838 Harriet Lane

Barrington IL 60010

kaytq@yahoo.com

Pamela Rups

2705 Pine Ridge Rd.

Kalamazoo, MI 49008

pamela.rups@wmich.edu

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Radiation-Laced Groundwater Could Be More Widespread

than Entergy Nuclear Palisades Knows or Admits

Concerned Citizens Demand Compulsory Testing in Area and Lake Michigan

On Dec. 10 and 13, the Entergy Nuclear Palisades atomic power plant found concentrations of radioactive hydrogen, called tritium, in groundwater between the reactor and Lake Michigan that violate U.S. Environmental Protection Agency (EPA) Safe Drinking Water Act limits. Entergy Nuclear Palisades detected concentrations of 22,000 picoCuries per liter in the groundwater, above EPA’s 20,000 picoCurie per liter Safe Drinking Water Act limits.

However, technical expert Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research, reports that "[t]he scientific models used to evaluate the adverse health impacts of tritium have a number of serious weaknesses." Dr. Makhijani reports that "...tritium can cross the placental barrier. This tritium can then be incorporated into an embryo/fetus and irradiate rapidly dividing cells, thereby raising the risk of birth defects, early miscarriages, and other problems. Tritium therefore provides an important case study for examining how radiation protection standards need to be changed in light of risks to those who are not adult men." Dr. Makhijani, citing the vulnerability of embryos and fetuses to tritium’s radioactivity, is calling for Safe Drinking Water Act protections to be strengthened as much as 50 times, as has happened in the State of California; the State of Colorado and U.S. Department of Energy have agreed to protective levels for tritium in groundwater 40 times stronger than the EPA regulations in place at Palisades.

Statement of Kevin Kamps, Radioactive Waste Watchdog at Beyond Nuclear, and board member of Don’t Waste Michigan representing the Kalamazoo chapter, regarding Entergy Nuclear Palisades’ admitted radioactive contamination of groundwater and the necessity for extensive testing of the area’s groundwater, surface water, and drinking water supply, including Lake Michigan itself.

“Entergy Nuclear Palisades’ admitted detections are likely but the tip of a radioactive iceberg in the form of tritium contamination spreading throughout the groundwater below, perhaps even into Lake Michigan itself. Palisades’ admission merely confirms what we have long known – that this nuclear reactor is far from benign, but rather generates and releases harmful radioactivity into the environment. These leaks have undoubtedly worsened as this now forty year old reactor deteriorates and degrades with age.

In our view, it is criminal for Entergy Nuclear Palisades to trivialize, downplay, and explain away the potential health consequences of such tritium contamination in an attempt to deceive the unsuspecting public.

Area residents and visitors near Entergy’s Palisades atomic reactor – especially children, the most vulnerable of all – are at risk from drinking radioactively-contaminated well water or Lake Michigan water. The U.S. Nuclear Regulatory Commission (NRC), EPA, and the State of Michigan should do their job, and determine the health risks to the residents of Palisades Park resort community, CovertTownship, the City of South Haven, visitors to the Van Buren State Park, and other area residents.

As Dr. Arjun Makhijani at the Institute for Energy and Environmental Research has reported, tritium increases the risk not only of cancer, but also of non-cancerous diseases and maladies in pregnant women and the embryo/fetus, including ‘early miscarriages, malformations, and genetic defects. Risks can also be multi-generational given that a woman’s ova are produced while she is in her mother’s womb.’

Poisoned water has been leaking from the Palisades atomic reactor for who knows how long. Radiation has now been detected escaping as an underground radioactive plume, but the question must be asked, has it begun to contaminate Lake Michigan as well? Nearby residents, and visitors at the Van Buren State Park, may very well have unknowingly consumed, cooked in, and bathed with radioactively contaminated water, risking cancer and birth defects with repeated and prolonged exposure. Those swimming and fishing near Palisades, as at Van Buren State Park, may also be at increased risk due to radioactivity releases into the Lake Michigan environment.

Area residents and visitors should not be deceived nor satisfied by hollow claims from Entergy or NRC that exposure to tritium is harmless. This propaganda has already been debunked by the U.S. National Academy of Sciences, which has declared that there is no safe dose – no matter how small – of radiation.

Area residents and visitors to Van Buren State Park must demand their drinking water be independently and fully tested. Neither Entergy Nuclear nor the NRC can be trusted to protect human health against corporate greed. Currently, South Haven’s drinking water authority collects samples of Lake Michigan water from the City’s water intake system, but then hands them over to Entergy Nuclear for safety testing. This is a flagrant violation of basic chain of custody protocols designed to prevent fraud and falsification in scientific safety testing. Extensive on-site and off-site groundwater monitoring should be undertaken immediately. It must be conducted by legitimately independent and trustworthy third parties.

Entergy deceptively reported that the contaminated ‘well is located inside the owner controlled area and inside the protected area. This well is not a drinking water source.’ But they apparently have not even checked off-site groundwater, nor Lake Michigan. Of course, if they do not look for off-site contamination, they will not find it. And of course, all groundwater is potentially drinking water. The Van Buren State Park’s campground, immediately adjacent to Palisades nuclear reactor, uses well water for drinking. And the City of South Haven uses Lake Michigan as a drinking water supply, so leaking tritium entering Lake Michigan could flow from residents’ kitchen sink and bathroom taps as radioactively contaminated drinking, cooking, and shower water.

NRC has allowed Palisades’ now-closed sister atomic reactor, Big Rock up north in Charlevoix, to discharge 20,000 gallons of tritium contaminated water into Lake Michigan first via the soil, then via the groundwater, like a radioactive septic field. Given the proximity of area drinking water supply intakes in Lake Michigan, this outrage cannot be repeated at Palisades.”

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DWM Don't Waste Michigan

Dedicated to Environmental Quality and Integrity and Service to the Great Lakes Region, a Biodiverse Home of Fresh Water Resources

NEW!! FYI Resource and Information links page

Canada's Plans to Create a radioactive waste dump on Lake Huron: Go to the website

History of DWM: Don't Waste Michigan is a group of concerned citizens initially formed to stop Michigan from becoming a nuclear waste dumpsite. Dr. Mary Sinclair was key in the early development of the group.Because of the geological features of Michigan, i.e. its proximity to the Great Lakes, citizens throughout the state organized to stop the federal government from targeting Michigan. DWM organized town meetings and rallies in Lansing, the state capitol, to dissuade legislators from selling out the environment for federal money. The campaign was successful, not only in stopping Michigan from becoming a nuclear waste dumpsite, but in also educating the public. DWM continues to be active and to educate the public about nuclear waste and other issues. DWM joined with a coalition of groups to plan the Nuclear Free Great Lakes Action Camps from 1999 to 2001, and the conference in 2002. Member Alice Hirt struggled via the judicial system to stop radioactive waste from being transported through Michigan. The campaign was successful for a time, then the Judge under pressure, gave up jurisdiction and shipments began.

DWM members Corrine Carey and Kathryn Barnes journeyed in 2001 to the Nevada Test Site to join the Shoshone and others in prayer and protest over Yucca MT. and other nuclear issues, an account is in the photojournalism website about the Newe Sogobia. DWM also led protests at nuclear reactors about unsafe conditions to bring awareness to the attention of the media and the public. DWM members joined with NEIS in Chicago December 10th to protest the mega nuclear corporations meeting. DWM is currently part of the coalition to watchdog Palisades nuclear power plant near South Haven, Michigan and fought (unsuccessfully) to stop the re-licensing of the aging plant. DWM members attend public meetings to bring nuclear issues and concerns to the attention of the NRC.

Members attend Conferences and Forums periodically to learn and share and strategize with other environmental groups on nuclear issues.

Sign the petition for a Sustainable Energy Future

Minutes: Members signed petitions for greater nuclear safety (NEIS), for public meetings and EIS (Tri-Valley Cares) re:biodefense, and mailed cards to Gen.Sec. Annan of the UN for world peace. Discussion about a women's coalition to speak with Michigan's first woman governor on nuclear issues, joining in the clean water campaign, to renew contact with former DWM members, and about current concerns such as the adequacy/inadequacy of "no-fly zones" over nuclear reactors which border Michigan, and the situation of nuclear waste and DU transport through Michigan. Members felt national security can not insure against the threat of terrorism or accidents and it is only a matter of time before a catastrophe, especially since the beginning of the Iraq war.

What you can do:. Write to your representatives and stress the importance of shutting down aging and unsafe nuclear reactors, securing reactor sites from the threats of terrorism and accidents, tracking down loose nukes here in the US, and of supporting the implementation of safe, renewable energy technologies, i.e. wind, water, solar, and geothermal power...

Reuse

Reduce

Recycle

Live in Harmony with the earth...plant a garden, listen to the sounds of nature, learn about nature and interconnectedness....

www.care2.com Free email, webspace etc...environmentally friendly and secure.

www.greenpeace.org FYI lots of info, great interactive and educational stuff

Chem Trails info Video on Chem Trails

DWM members attended the Peace Conference in Grand Rapids, March 2005. Over 20 groups were represented, including the Women in Black, IGE, KNOW, Green Party, Greater Grand Rapids Food Systems, Peace Presence, Friends Committee, Holland Peacemakers, Tibet Michigan, and others. DWM members Corrine Carey and Kathryn Barnes spoke and gave a slide presentation about peace actions at the Nevada test site and other areas. The conference was a great success.

DWM members attended the BiNational Forum in Monroe, Michigan in 2007. Guest speakers included: Kevin Kamps of Beyond Nuclear, Professor Edwards Ph.D., President, Canadian Coalition for Nuclear Responsibility, Ziggy Kleinhaus of Citizens for Renewable Energy, David Gard, Energy Program Director, Michigan Environmental Council, Lansing, Alexis Raney, Director of Save the Wild U.P, Doris Allen, President of Voices for Earth Justice and Great Lakes songwriter and troubadour, Victor McManemy. The forum was a great success. It was educational and inspiring and free with refreshments and music, thanks to sponsors Harold Stokes and CACC and others.

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