Kevin Kamps
To:
Chief, Rules and Directives Branch
Division of Administrative Services
Office of Administration
Mailstop T-6D 59
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001
Submitted electronically via: PalisadesEIS@nrc.gov
August 22, 2005
Public Comments re: 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'Comments on "Applicant's Environmental Report - Operating License Renewal Stage,
Palisades Nuclear Plant, Nuclear Management Company, March 2005" submitted by:
Michael J. Keegan, Chairperson, Coalition for a Nuclear Free Great Lakes
(CNFGL), Monroe, MI
Alice Hirt, Board Member, Don't Waste Michigan, Holland, MI
Dave Kraft, Director, Nuclear Energy Information Service, Evanston, IL
Keith Gunter, Co-Chair, Citizen's Resistance at Fermi Two (CRAFT), Livonia, MI
Kevin Kamps, Nuclear Waste Specialist, Nuclear Information and Resource Service,
Washington, D.C.
Henry W. Peters, director, Radiological Evaluation & Action Project, Great Lakes
(REAP, GL), Ewen MI
Our Public Comments:
Beyond Design Basis Aspects/Crisis of Embrittlement.
The embrittlement of the Palisades reactor pressure vessel and the unresolved
Pressurized Thermal Shock ("PTS") with ever increasing likelihood of the
failure of the reactor pressure vessel ("RPV") warrant special environmental
considerations. This type of accident is "Beyond Maximum Credible Accident"
scenarios, a beyond design basis -- and yet all too possible -- accident for the
reactor. Any EIS which is conducted must incorporate the outcome of such a
catastrophic accident. A 1982 NRC report (Calculation of Reactor Accident
Consequences or CRAC- 2) predicted that a meltdown and large-scale radiation
release from the Palisades reactor would cause 1,000 fatalities and 7,000
injuries in just the first year, 10,000 cancer deaths over time, $52.6 billion
in property damage (based on 1980 census, expressed in 1980 dollars, thus
significantly underestimating current and future impacts due to population
growth and inflation). The Palisades nuclear power station has been identified
as prone to early embrittlement of the reactor pressure vessel, which is a vital
safety component. The longer Palisades operates, the more embrittled its RPV
becomes, with decreasing safety margins in the event of the initiation of
emergency operation procedures, such as activation of the emergency core cooling
system. Moreover, there are rumored problems with the safety culture at the
plant which might inhibit candor in staff communications about
embrittlement-related problems in operations and procedures. Therefore, given
the public health and safety effects of a prospective additional twenty years of
operation, and given the present and prospective embrittlement trend of the RPV,
it is imperative to protect the interests of the public by denying such a 20
year license extension.
Excessive radioactive and toxic chemical contamination in local drinking water
due to emissions from Palisades nuclear power plant as part of its daily,
"routine" operations.
The radioactive and toxic chemical emissions from the Palisades nuclear power
plant into the waters of Lake Michigan contaminate the recently-installed
drinking water supply intake for the City of South Haven, built just offshore
from Van Buren State Park and just downstream from the Palisades reactor, due to
the direction of the flow of Lake Michigan's waters and the very close proximity
of the Palisades reactor to the South Haven drinking water supply intake.
U.S. National Oceanographic and Atmospheric Administration models confirm the
direction of water flow in Lake Michigan toward the intake.
The Palisades reactor has no place to store its overflowing irradiated nuclear
fuel inventory within NRC regulations.
Electricity is but the fleeting byproduct of the Palisades nuclear reactor. The
actual product is forever deadly radioactive waste. This cannot be excluded
from the EIS because if there is no license extension there will not be an
additional 20 years of high level nuclear waste generated by Palisades. The
indoor irradiated fuel storage pool reached capacity in 1993, thus necessitating
the utilization of a shoddy technology of outdoor dry cask storage pads at
Palisades. Both the older pad nearer Lake Michigan and the newer pad further
inland, are in violation of NRC earthquake regulations. 10 CFR §
72.212(b)(2)(i)(B) requires that: Cask storage pads and areas have been designed
to adequately support the static and dynamic loads of the stored casks,
considering potential amplification of earthquakes through soil-structure
interaction, and soil liquefaction potential or other soil instability due to
vibratory ground motion. . . .
According to expert, Dr. Ross Landsman, former U.S. Nuclear Regulatory
Commission Region III dry cask storage inspector, the older pad violates the
liquefaction portion of this regulation, and the newer pad violates the
amplification portion of the regulation. Neither the older nor newer dry cask
storage pads at the Palisades plant are in compliance with this cited
regulation. Nuclear Waste and Dry Cask storage cannot be omitted from EIS
considerations because they are a inevitable, adverse outcome of continued
operation of Palisades for an additional 20 years on top of the original 40 year
license.
Additionally, in 1993, Consumers Power (now Consumers Energy) assured a federal
district judge that if it encountered problems with loaded dry casks at
Palisades, it would simply reverse the loading procedure and return the
high-level radioactive waste to the storage pools. But the fourth cask loaded
at Palisades, in June 1994, was shortly thereafter admitted by Consumers Power
to be defective, having faulty welds. However, eleven years on, Consumers has
yet to unload the defective cask, because it cannot. Don't Waste Michigan,
which actively opposed the loading of the dry casks in the first case in 1993,
holds that Consumers perpetrated a fraud upon the court and the public, with the
complicate support of the NRC, and that Consumers has critically undermined its
credibility as to any pledges about the safety of dry cask storage. The
significance of this problem with cask #4 is considerable. For example, the
configuration of the 18 to 19 dry casks currently stored on the older pad
nearer Lake Michigan is such that the casks
furthest back cannot be moved or unloaded until all other casks in front of
them have been moved out of the way first. This configuration increases the
risks, making it very difficult to address emergencies involving certain casks
in the configuration in a timely manner.
Another issue that demands attention by NRC in its environmental impact
statement is the disconcerting proximity (just several hundred feet away,
according to maps appearing in the Environmental Report) of the Van Buren State
Park campground to the newer, more inland dry cask storage pad for high-level
radioactive wastes at Palisades. What are the radiation dose rates that families
camping at the State Park would suffer from those nearby dry casks? What are the
security and safety implications of having high-level radioactive waste stored
so close to a campground?
In its Environmental Impact Statement, NRC should also consider another
environmental impact concerning high-level radioactive waste ignored by
NMC/Consumers in its Environmental Report: the proposed shipment by barge of 125
or more rail-cask sized containers of irradiated nuclear fuel from Palisades to
the Port of Muskegon as part of the Yucca Mountain, Nevada nuclear waste dump
proposal. The U.S. Department of Energy describes and documents this proposal on
page J-83 of its Final Environmental Impact Statement for Yucca Mountain, in
table J-27 ("Barge shipments and ports"). 125 barge shipments may very well be
an underestimate, for DOE assumes only 10 year license extensions, whereas
NMC/Consumers is requesting a 20 year extension from NRC. Specifically, what if
a barge shipment goes down in the Lake, whether due to accident or attack? What
about the potential for a nuclear chain reaction inside the cask involving the
still fissile U-235, Pu-239, and other fissile radio nuclides present in the
waste? What about radioactive contamination of 20% of the world's surface fresh
water, the drinking water supply for 35 million people downstream?
Property Rights
Property rights of home owners on the shoreline and inland from Palisades have
been compromised by the "de facto" permanent high level waste site created.
This amounts to implementation of eminent domain without any compensation to
property owners. The constant threat of a nuclear accident or act of sabotage
has violated property owners' rights.
Additionally, any waste generated at Palisades after 2010 would be excess to the
capacity of the proposed national dump at Yucca Mountain, Nevada according to
U.S. Department of Energy projections in its Yucca Mountain Final Environmental
Impact Statement (Feb. 14, 2002), as revealed in Tables A-7 and A-8 on pages
A-15 and A-16 of Appendix A. In fact, the waste generated at Palisades from
1971 to 2010 may also be excess to Yucca, in that the proposed but highly
troubled and long delayed dump may never open. The State of Nevada maintains
that NRC's "Nuclear Waste Confidence Decision" is erroneous, in that it biases
NRC to favor approval of the Yucca Mountain dump license lest it, NRC, be
proven wrong in its assurance to the public that a high-level radioactive waste
geologic repository will open in the U.S. by 2025. Because so much uncertainty
surrounds the Yucca Mountain dump proposal, as well as other high-level
radioactive waste dump proposals (such as the Private Fuel Storage, LLC dump
targeted at the Skull Valley Goshute Indian Reservation in Utah), it is our
collective contention that waste generated at Palisades during the 20 year
license extension could very well be stored at Palisades indefinitely, a
scenario inadequately addressed by the applicant and NRC. Because the casks
cannot be transported, because the casks cannot be unloaded, what has been
created is a "de facto" permanent high level waste site.
Given that a severe radiation release from Palisades due to accident or attack
would significantly damage the economic base of western Michigan, not only
within the 50 mile zone around the
reactor, but even beyond it, due to crops and products that would have to be
destroyed, as well as the lingering stigma attached to western Michigan
agricultural products after such a release, a comprehensive Severe Accident
Mitigation Analysis must be performed, publicized and circulated for public
review and comment as a precondition to considering whether or not to grant a
license extension. The Severe Accident Mitigation Alternatives Analysis
presented in the Consumers/NMC "Environmental Report" is woefully inadequate,
ignoring as it does the full implications and significance of such risks as RPV
embrittlement, PTS, and the consequent potential of RPV rupture and catastrophic
radiation release.
Intensifying Sand Erosion and Avalanche Risk Compromise Integrity of Dry Storage
Pads and Casks
The more casks loaded on the storage pads at Palisades, the more risk of erosion
to the sand supporting the pads, given the large weight of the casks themselves
(VSC-24 casks weigh 132 tons each), weather related erosion of the sand dunes,
as well as the erosion that will occur due to more severe weather impacts from
the global climate crisis and climate de-stabilization. Arresting erosion at
both pads is important to safety and radiation containment over the long haul,
given the proximity of the waters of Lake Michigan. The State of Michigan and
the U.S. Army Corps of Engineers have designated the sand dunes upon which the
older pad is located -- so close to the waters of Lake Michigan -- as a
high-risk erosion zone. The Lake Michigan dunes are subject to "blow-outs"
where entire dunes are blown out during wind storms and lighting strikes. See
Nori, P. Sholtz, and M. Bretz (Department of Physics, The University of
Michigan), "Sound-Producing Sand Avalanches," Scientific American Vol. 277, No.
3 (September 1997). At Warren Dunes, some 35 miles south of Palisades, sand
blowouts have been estimated to travel as much as one-quarter mile per day,
exposing 5,000-year-old trees that have long since turned to charcoal. "Some
chilling facts about Dunes history," See:
//www.nwitimes.com/articles/2005/07/25/news/region/0256d4c429632
The Palisades dunes could, in a wind storm or lightning strike, shift, blow and
cover the dry cask storage area. This would in turn block the ventilation vents
on the dry casks, causing the irradiated fuel within to overheat beyond
technical specifications. As weather patterns intensify (as anticipated, due to
global warming) this potential for erosion will increase. Additionally, the
dunes and shoreline are geologically prone to sand avalanches. A sand avalanche
coupled with a seismic event could compromise the integrity of one or more
casks at Palisades. In fact, an earthquake at the older pad nearer the lake
could cause casks to fall into the waters of Lake Michigan. Not only could
radioactive contamination of Lake Michigan result, but, given the Uranium-235,
Plutonium-239, and other still-fissile radio nuclides present in the irradiated
nuclear fuel, the infiltrating water could cause a nuclear chain reaction in the
submerged cask itself, further endangering Palisades workers, emergency
responders, the public, and the Lake Michigan ecosystem, source of drinking
water - and so much more - to 35 million people downstream throughout the Great
Lakes Basin. NMC documents the potential for sand dune blow-outs at Palisades in
its Environmental Report, such as on Page B-6, where sand dune blow-outs are
described as comprising part of the overall Palisades nuclear power plant site.
NMC/Consumers also acknowledges sand dune blow-outs on Page 2-19 of its
Environmental Report: "Sand Dune Blow-out Communities (see Table 2.3-2,
Community 10) occur where wind action has resulted in dune destabilization." On
Table 2.3-2, the Environmental Report acknowledges that 4% of the Palisades site
comprises "Sand Dune Blow-Out Community." Of the remaining 13% of the Palisades
site comprised of Beach Grass Stabilized Dune Community, Beach Grass Stabilized
Flats, and Open Sand, one must wonder not if but when future sand dune blow-outs
will occur.
Non-Radiological Persistent Toxic Burdens to Area Water Sources.
The impact of 20 additional years of pollution by toxics disclosed but not
adequately controlled under requirements of the National Pollutant Discharge
Elimination System (NPDES) will directly affect water quality of nearby sources,
including Lake Michigan. In 2000, for example, Palisades was found to be in
"continuing noncompliance" for its apparent multiple misuses of Betz Clam-Trol
in Lake Michigan for the dispersion of mussels and clams affecting the reactor's
water intakes. See http://www.epa.gov/region5/water/weca/reports/mi4qtr01.txt
NPDES violations also contradict the spirit, intention and explicit
recommendation of the International Joint Commission (IJC). In its "Ninth
Biennial Report on Great Lakes Water Quality," the Commission's Recommendation
#16 (at p. 42) urges that "[g]overnments monitor toxic chemicals used in large
quantities at nuclear power plants, identify radioactive forms of the toxic
chemicals and analyze their impact on the Great Lakes ecosystem." Consumers
Energy and Nuclear Management Company admit, in Section 3.1.3.3 "Biofouling
Control" on Page 3-7 of their Environmental Report that NMC uses biocides such
as chlorination, bromination, and amine formulations. The IJC also called for
virtual elimination of toxic discharges into the Great Lakes, and identified
radio nuclides as persistent toxins that also needed to be virtually eliminated
from the Great Lakes. The IJC commissioned two reports, the first on the
radionuclide inventory in the Great Lakes, and the second on the
bio-accumulation of radio nuclides in Great Lakes biota. The third report in the
series, on radioactivity's impact on human health, was never completed. This
study on radiation's impact on human health in the Great Lakes Basin should be
completed prior to granting Palisades an additional 20 years of operations,
especially in light of the National Academy of Science Biological Effect of
Ionizing Radiation Panel's recent report (BEIR VII), which found that no amount
of radiation is too small to not have an adverse impact on human health.
Baseline health studies are necessary before NRC grants Palisades a license
extension, especially considering that the National Cancer Institute's report on
cancer near nuclear reactors, published in 1990, is now 15 years old. It does
not account for cancers occurring over the past 15 years, and is in addition
methodologically flawed. Independent base line health studies must be performed
before NRC grants Palisades a 20 year license extension.
Increased Degradation of Fuel Rods Excessively Utilized
To mitigate the prospect of increased embrittlement of the reactor pressure
vessel (RPV), the Palisades operator uses previously-irradiated fuel to create a
buffer next to the RPV wall. The second-use of irradiated fuel assemblies in
the reactor core tends to weaken and damage the cladding on the fuel rods,
making future waste handling, storage, transport, and ultimate disposal -
whether onsite at Palisades, in transport, or at future storage/dump sites -
problematic. It poses an elevated risk for the safety of Palisades workers and
the general public. Moreover, the U.S. Department of Energy ("DOE") depends on
the integrity of the fuel cladding as a means of preventing or minimizing the
risk of unanticipated fissioning in storage and transportation casks or other
units, as well as a means of delaying radiation releases from waste burial into
the groundwater at the proposed Yucca Mountain (Nevada) dumpsite.
Environmental Justice / Nuclear Racism
Palisades nuclear generating station is the source of environmental justice
violations. Located
within a predominantly African-American and low-income township, Palisades
provides woefully inadequate tax revenues to the host community, considering
the large adverse impacts and risks the reactor inflicts. Palisades'
African-American employees have traditionally been stuck in the dirtiest and
most dangerous jobs at the reactor, with little to no prospects for
promotion. Some of Palisades' African American employees have also experienced
death threats at the work place, including nooses hung in their lockers or in
public places to symbolize lynching, an apparent attempt to silence their public
statements for workplace justice.
Palisades' license extension application also has inadequately addressed the
adverse impacts that 20 additional years of operations and waste generation
would have on the traditional land uses, spiritual, cultural, and religious
practices, and treaty rights of various federally-recognized tribes in the
vicinity of the plant and beyond, as well as effects upon non-federally
recognized tribes governed by international law. Only three tribes were
contacted by the NRC by August 8th, 2005, and invited to participate in the
license extension proceedings, which effectively excluded a number of tribes
within the 50-mile zone around the reactor, as well as additional tribes beyond
the 50 mile zone which have historic and traditional ties to the Palisades site
and sites along the electric transmission line connected to Palisades. Despite
the Michigan State Historic Preservation Office's concern pertaining to possible
unreported archaeological properties present on, or with the vicinity of, the
Palisades site (see Page C-2, Cultural Resources Correspondence of the
Environmental Report), NMC and Consumers persist in opposing a survey of the
project area as unnecessary. But, if unreported Native American archaeological
sites are present at or near the Palisades nuclear power plant (which is very
possible, given the very close proximity of a large creek in Van Buren State
Park just to the north of the power plant, as well as the very close proximity
of Brandywine Creek just to the south of the power plant in Palisades Park -
rivers and creeks being common sites for encampments and villages amongst the
indigenous peoples of Michigan since time immemorial), then 20 additional years
of nuclear operations, radioactive waste generation, and daily radiation
emissions would have a significant and severe adverse impact on Native American
cultural and religious values at those sites, values which strive to protect
sacred areas from such degradation. The fact that NRC contacted only the
Nottawaseppi Huron Potawatomi, the Little Traverse Bay Band of Odawa Indians,
and the Match-E-Be-Nash-She-Wish Band of Potawatomi, but did not contact the
Pokagon Potawatomi (just 30 miles or so from the Palisades site), the Little
River Band of Odawa Indians, the Grand River Band of Ottawa Indians, the Saginaw
Chippewa Tribe, and the Grand Traverse Band of Ottawa and Chippewa Indians,
means that this Environmental Scoping proceeding should be suspended until all
stakeholder Native American tribes and bands are contacted and alerted to the
opportunity to not only comment on the Environmental Scoping, but to intervene
against the Palisades 20 year license extension. Given the sovereignty of these
tribes and bands, and the treaty rights that exist between them and the United
States federal government, the NRC has a government-to-government responsibility
to consult with these tribes and bands on such significant federal actions as
granting the Palisades reactor an additional 20 years of operations. An
archaeological survey must be conducted before NRC grants a 20 year license
extension to assure that Native American archaeological sites are not negatively
impacted by future Palisades reactor operations. Such impacts as harm to lake
sturgeon - sacred to some Great Lakes tribes - must also be evaluated. It is
interesting and telling that NMC's Environmental Report assigns no "importance"
to lake sturgeon (in Table 2.3-1, Page 2-47), despite its State of Michigan
Threatened Status, and its sacred status in the cultures and traditions of
various Great Lakes Native American Tribes, not to mention its importance to the
natural history of Lake Michigan as an ancient indigenous species in the
ecosystem. This is an indication that NMC/Consumers is not acknowledging or
addressing environmental justice impacts of 20 more years of operations at
Palisades on Native Americans.
Also, Palisades' license extension application inadequately addresses the
disproportionate adverse socioeconomic impacts of a catastrophic radiation
release, such as due to reactor core embrittlement leading to core rupture, to
the low-income Latin American agricultural workforce of the Palisades area.
Synergistic effects of such chronic and catastrophic radiation releases
combined with the toxic chemical exposures these low income Latin-American
agricultural workers already suffer on their jobs have not been evaluated.
Finally, there is an unacceptable lack of Spanish language emergency evacuation
instructions and notifications to serve the Spanish speaking Latino population
within 50 miles of the Palisades reactor, especially migrant agricultural
workers.
A potential flaw in the NMC/Consumers Environmental Report is its exclusion of
census block groups with greater than 50 percent of their area outside the 50-
and 20- mile radii from Palisades. Not including these groups in calculating
total population, minority or low-income estimates effectively excludes
significant minority and low-income populations in Grand Rapids and Battle
Creek, particularly African American and Latin American communities living in
these major urban centers.
In addition, it is odd that NMC/Consumers writes in the Environmental Report
(page 2-32) that "Berrien and Van Buren Counties host moderate numbers of
migrant workers," when 3,677 and 6,733 temporary farm laborers (many of them
Latino) were employed in Berrien and Van Buren Counties, respectively, according
to the U.S. Department of Agriculture in 2004. These numbers represent
populations as large as the county seats and even the biggest towns in these
counties. It is also not clear in the Environmental Report whether those numbers
include the families which very often accompany the migrant farm laborers, which
would boost the Latino population even higher.
It is ironic that NMC/Consumers acknowledges on Page 2-36 of the Environmental
Report that "Only one block group with a low-income population is located in Van
Buren County. This block group is located in the western portion of Covert
Township, which is a largely rural area." Why is it that the largely
African-American population of Covert Township is still low-income after 38
years of Palisades nuclear power plant's presence in the township? Wasn't the
presence of the reactor supposed to help its home town to thrive economically?
What are the environmental justice implications of such an ironic history?
The fact that "The amount of future property tax payments for Palisades...are
dependent on future market value of the plant" seems ripe for manipulation and
abuse - such as artificially lowering the market value of the plant in order to
lower future property tax payments -- by the politically and economically
powerful Palisades nuclear power plant on its host township, county, and region,
yet another environmental justice violation.
Chronic Emergency Unpreparedness Within the EPZ (Emergency Planning Zone).
Emergency responders in the 50 mile zone around the Palisades nuclear reactor
are inadequately trained and inadequately equipped to respond to a major
radioactivity release during an accident or attack at the plant. Even with its
modern fire trucks, Covert, Michigan does not have the staffing, equipment,
training nor preparedness for a major radiological emergency. Covert's best,
good as it is, is still no match for a Chernobyl-scale fire. The remainder of
the emergency
planning and even 50 mile zone is mostly occupied by rural, volunteer fire
departments, which have even less equipment and training with which to work.
Radiation monitors and radiation-protective gear are in short supply or unheard
of. Isolation wards for radioactively contaminated victims (so they don't harm
the doctors and nurses and other patients) are very rare, nearly non-existent at
most hospitals within 50 miles. A 1982 NRC report (Calculation of Reactor
Accident Consequences or CRAC- 2) predicted that a meltdown and large-scale
radiation release from the Palisades reactor would cause 1,000 fatalities and
7,000 injuries in just the first year, 10,000 cancer deaths over time, $52.6
billion in property damage (based on 1980 census, indexed to 1980 dollars, and
thus a significant underestimate of impacts given population growth and
inflation over the past 25 years). Clearly the community is ill equipped for
this risk of catastrophic radiation release which grows more likely the longer
the Palisades reactor operates.
Threats of Terrorist Attack and Sabotage at Palisades Nuclear Power Plant.
Located on the shoreline of Lake Michigan, the source of tourism, drinking
water, fish, recreation, and other economic value to tens of millions of people
downstream, Palisades represents a target for potentially catastrophic terrorist
attack or sabotage intended to release large amounts of radioactivity into the
Great Lakes basin. Palisades represents a radioactive bull's eye on the shore
of 20% of the planet's surface fresh water, the Great Lakes. The operating
reactor (containing many billions of curies of radioactivity) and high-level
waste storage pool (containing tens to hundreds of millions of curies) are
vulnerable to such attack, as are the outdoor dry storage casks, so highly
visible, stored in the open air, in plain sight.
Economic Impact Statement
As part of any NRC Environmental Impact Statement, there is need for an Economic
Impact Statement. This must include loss of "Opportunity Costs" such as tourism,
fishing, recreation, housing, other real estate, drinking water, etc. from
ongoing "routine" radiation releases into the waters, air and soil of the Lake
Michigan ecosystem, as well as the potential lost "opportunity costs"associated
with a major radiation release due to an accident or attack at the Palisades
reactor.
Baseline Public Health Study Regarding Rates of Cancer and other Diseases.
There is a current need for a baseline public health study to establish cancer
and other disease rates prior to consideration of the proposal for a 20 year
license extension. The NRC has relied on the National Cancer Institute (NCI)
Study of 1990 to address cancer rates near nuclear power plants. However, the
only data considered by the NCI was the county that reactor is located in, not
other downwind and downstream counties. Thus, that study is methodologically
flawed. It is also 15 years old, and thus does not include data on occurrences
of cancer over the past 15 years, rendering it outdated. In addition to studying
cancer, other diseases associated with radiation exposure must also be studied.
Aging of Component Parts
The aging of component parts must be taken into consideration and evaluated for
potential safety-significant failures over the course of a 20 year license
extension. Examples of such age-related failures at Palisades just in the recent
past include: failure of the Control Rod Drive Mechanism (see PNO-III-04-010
August 11, 2004); Relief Requests for Reactor Vessel Head Penetration problems
(NMS Request 10/4/04); Manual Reactor Trip / Main Condenser Vacuum (See Event #
41319); Emergency Declared on Primary Coolant System Integrity (See Event #
41681). Age-related failure of safety-significant systems could initiate the
sequence of events that leads to PTS that ruptures Palisades' dangerously
embrittled reactor vessel, causing catastrophic radiation releases into the
Great Lakes basin. Frighteningly, NMC repeats countless times in its
Environmental Report (as an excuse for not having to do any additional
environmental impact analysis on various issues) that "NMC does not plan to
undertake major refurbishment for Palisades license renewal." (As discussed in
Section 3.2, and elsewhere throughout the Environmental Report)
Potential of Renewable Energy, Energy Efficiency, and Energy Conservation to
Displace Palisades Nuclear Power Plant's Electricity Generation
In Section 7.0, "Alternatives to the Proposed Action," renewable energy sources
such as wind power and solar power, as well as alternatives to Palisades such as
energy efficiency and conservation, are given remarkably short shrift by
NMC/Consumers. In fact, polluting electricity sources such as fossil fuels are
given by NMC/Consumers as the only realistic alternatives to a 20 year license
extension at Palisades. This is self-serving, in that Consumers owns and
operates fossil fuel fired facilities. In fact, in 2002 nearly three-quarters of
Consumers electricity generation came from fossil fuel facilities. Such reports
as "Repowering the Midwest" by the Union of Concerned Scientists and
Environmental Law and Policy Center; a recent analysis by Amory Lovins at the
Rocky Mountain Institute published in the organization's summer 2005 newsletter
(see www.rmi.org); cutting edge research and development conducted by the
Midwest Renewable Energy Association; deployment by Mackinaw Power of modern,
large capacity wind turbines on the northern tip of Michigan's lower peninsula,
and plans to deploy more wind turbines on the Lake Michigan shoreline of west
Michigan; long-established Lake Michigan shoreline wind power operation by the
Traverse City, Michigan municipal power company; advances in solar electricity
by Solar Ovonics in Troy, Michigan (which manufactures solar electricity
generating roofing shingles, which could be installed unobtrusively over huge
surface areas atop families' homes); advances in solar power technology
documented by Steve Strong at Solar Design Associates; and a recent report
commissioned by the U.S. Public Interest Research Group ("Redirecting America's
Energy: The Economic and Consumer Benefits of Clean Energy Policies," Feb. 2005)
all clearly show that renewables, efficiency and conservation not only are ready
to go, reliable, safe, clean and affordable options for electricity generation
and savings, but also the source for tremendous job growth and cost savings.
Whereas NMC/Consumers may have a business agenda to ignore and downplay the
potential for such promising alternatives to polluting sources of electricity
such as fossil fuels and nuclear power, the NRC should fully examine such
alternatives in its environmental impact statement.
Climate Change Impacts on Palisades reactor operations during license extension
A number of times in its Environmental Report, NMC/Consumers mentions, and
affirms the now globally accepted fact that the collective activity of the human
race is in the process of altering the climate of the planet (Climate Change).
But the Nuclear Energy Institute, of which NMC/Consumers are members, actively
suggests that nuclear power may be a strategy to lower the impact of electrical
energy generation on this process. But it is also widely understood that
mitigation can only change processes in the future, beyond the coming decade or
two (and that is optimistic). The effects of past air emissions will govern the
changes in weather patterns now documented, and those in the 20 year license
extension period. The outlook globally is increasing severity in weather,
particularly storms, both in number and intensity and for the Great Lakes basin,
such impacts as increased frequency and severity of tornadoes, rain and
lightning storms, temperature extremes in summer and winter, etc.
NMC/Consumers fails to analyze the multiple impacts these accelerating changes
will have on reactor operations, as well as the ways that it will change the
type and magnitude of impact that the reactors have on their external
surroundings.
Analysis of Climate Change must include an analysis of increased potential for
Station Blackout by virtue of projected increased numbers and intensity of
tornados and other severe weather. Other factors of Climate Change impact are
discussed below with respect to inadequacy of NMC/Consumers Environmental
Report.
These factors may be seen as too complex to project and accurately analyze
twenty years in the future, however they are really no more complicated than the
complex interactions of NMC/Consumers' financial position, work force
capabilities and human factors, cumulative and synergistic events in aging
systems and multiple failure pathways that should be factored in the analysis of
whether component aging will be successfully managed to meet an ever moving
target called "current license basis."
Global warming could also alter the water levels and water temperatures in Lake
Michigan over the course of the 20 year license extension, impacting Palisades
nuclear reactor operations. Similarly, large-scale water diversion from Lake
Michigan or inland groundwater that feeds into the Great Lakes - proposed by
southwestern states, for example, to address their drinking water and other
needs in current drought conditions (perhaps also attributable to global
warming) and water bottling companies - could also impact water levels in Lake
Michigan over the next 20 years.
Endangered Species
NMC/Consumers Environmental Report identifies numerous federal and State of
Michigan endangered, threatened, candidate or species of special concern - such
as eastern box turtle, lake sturgeon, lake herring, creek chubsucker, Pitcher's
thistle, prairie warbler, prairie vole, eastern massasauga rattlesnake, spotted
turtle, Indiana bat, globe-fruited seedbox, scirpus-like rush, bald rush,
Carey's smartweed, and sedge that either already live at or near the Palisades
reactor, or very likely could in the future. 20 more years of reactor operations
threatens these already threatened, endangered, or candidate species, including
daily "routine" radiation releases and/or potential large-scale radiation
releases harmful impact on the threatened, endangered, or candidate genetics of
these species. In addition, the dunes upon which Palisades is built and operates
are recognized as Critical Dune Areas under Michigan's Natural Resources and
Environmental Protection Act, and are recognized by Covert Township as an
Environmentally Sensitive Area, and thus should be protected against 20 more
years of daily "routine" and potential large-scale accidental radioactive
contamination. Likewise, the Mesic southern forest on the south end of the
Palisades site is recognized as a prime example of this ecosystem type by the
Michigan National Features Inventory, and should be protected against ongoing
radioactive contamination for another two decades past 2011.
Findings of BEIR IIV Must Be Incorporated into EIS
The BEIR VII report has recently been published. The recent BEIR scientific
conclusion that there is no "safe" level of radiation - no matter how low the
exposure - requires reconsideration of the "legal" operation of Palisades at
all. The Palisades acknowledges routine "lawful" radiation releases. The new
scientific conclusion compels reconsideration of the feasibility of continuing
to allow Palisades to operate at all, especially given the related issues of
drinking water pollution via radiation.
Need For Independent / Verifiable Monitoring of Palisades
There is no independent verifiable monitoring of Palisades. The community of
Covert and surrounding communities are dependent upon the operators of Palisades
to provide notification of radiological releases. There is an implicit public
relations and financial incentive for the operators not to be forthcoming
regarding radiological events and accidents. Therefore these communities must
be equipped with independent verifiable radiological monitoring to protect
themselves.
Evacuation Issues - Reliance on Dated Census Data
Current Radiological Emergency Response Plan must be re-examined to incorporate
population trends and development projecting 20 years forward. Highway systems
including construction projects must be carefully planned. Transitory
populations of migrant workers must be considered. Bi-lingual notifications and
dissemination of information must be made not only available but as a condition
of operation.
Civil Liberties and Plant Security Issues / Community Security
In the post September 11, 2001 era of heighten concern about national security,
there exists a great potential for the violation of civil liberties of the
citizenry of the surrounding area. What will be the ramifications and
implications to the peoples of these environs when there are enhanced security
measures taken regarding Palisades. For example: walking along the beach;
recreational use of the Lake and adjacent parks; driving down the highway;
public protest and rights of assembly. Civil Liberties must be considered in
this EIS process.
Sabotage and Internal Dissent at Palisades Due to Nuclear Management Company
Whistle Blower Mistreatment
There are current legal actions being taken by whistle blowers at Palisades.
One such case has identified systematic abuse by Nuclear Management Company of a
Health Physicist worker who had reported what he believed to be various
violations of safety protocols to the U.S. Nuclear Regulatory Commission.
Plaintiff discussed over the telephone certain concerns of his about safety and
his fear of retaliation for bringing up safety concerns and by cooperating with
the Nuclear Regulatory Commission with Andrea Kock and Ryan Alexander of the
United States Nuclear Regulatory Commission. This resulted in the generation of
United States Nuclear Regulatory Commission Allegation Number RIII-03-A-0051.
This worker has been dismissed from employment. This culture of intimidation
sets the stage for internal dissent. When workers fear that they will be
dismissed for reporting safety concerns there is a serious problem with the
"Safety Culture" at Palisades with potential grave consequences. These concerns
must be addressed in the EIS process.
Need for Full Cost Accounting Principals regarding "No Action"of Re-license
Principles of Full Cost Accounting must be taken into consideration when
examining the No Action option (denial of re-licensing). Negative impacts on
public health, civil liberties curtailed, impact on realty, contamination of the
water and air, etc., etc.
Invasive Species Impact of: Zebra Mussels; Quagga Mussels; Alewife & Other Fish
Kills
What has been the impact of Zebra Mussels and Quagga Mussels on the Palisades
plant. How have these species been controlled at Palisades and how have the use
of toxics such as Betz Clam-Trol impacted the water quality on which the public
relies. What would be the consequences at Palisades if these toxics were not
used. What has the been the history and mitigation attempts regarding fish
kills at Palisades. What game fish have been impacted by the operation of the
Palisades. What has been the bio-accumulation and bio-concentration of
persistent toxics both radiological and non-radiological contamination in
recreational and commercial game fish.
Request for Sixty Day Extension on EIS Comment Period
There are a multitude of environmental concerns in addition to those raised
above that we will like to address but lacking adequate time to digest and
respond to voluminous NRC documents have been unable to do so. By letter dated
August 19, 2005 to Andrew L. Bates, Acting Secretary, Office of the Secretary
U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001. A request was
made for 60 day extension. Again, we respectfully request that NRC grant an
additional 60 days to the concerned citizens of Michigan, Indiana, and Illinois,
and the organizations, which represent them, in which to file scoping comments
on NRC's Environmental Review of the Palisades nuclear power plant 20-year
license extension proposal.
Thank you for your review of this document