Wednesday

Feb172021

Beyond Nuclear's comments opposed to 80 years of operations proposed at Point Beach, WI

February 17, 2021

Point Beach Units 1 & 2, in Two Rivers, WI, on the Lake Michigan shoreline. NRC file photo.(Beyond Nuclear public comment #1)

Point Beach Unit 2 has the worst-embrittled reactor pressure vessel of any pressurized water reactor in the country.

NRC staff acknowledged this in writing in 2013. On April 18, 2013, NRC released a summary of the Palisades embrittlement webinar it had held on March 19th, 2013. This document has been referred to as: J. Geissner, Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant. It is available at ADAMS Accession No. ML13108A336. The slides from the NRC Public Webinar, Basis for NRC Requirements on Pressurized Thermal Shock, are available at ADAMS Accession No. ML13077A156. Specifically, on Page 2 of Enclosure 2 of the Summary (Page 5 of 15 on the PDF counter), at point #4, NRC staff list Point Beach 2 and Palisades (in Michigan) as the worst embrittled reactor pressure vessels in the country.

Decades of additional neutron radiation bombardment will only increase the risk of a pressurized thermal shock, through-wall fracture, core meltdown, and catastrophic release of hazardous radioactivity.

To give an idea of how catastrophic, in terms of casualties and property damage, consider the U.S. Nuclear Regulatory Commission's (NRC) own CRAC-II report. CRAC is short for Calculation of Reactor Accident Consequences. It is also known as "Technical Guidance for Siting Criteria Development," the 1982 Sandia (National Laboratory) Siting Study, NUREG/CR-2239, and/or SAND81-1549.

In the event of a core meltdown at Point Beach 2, CRAC-II predicted: 500 peak early fatalities (acute radiation poisoning deaths); 9,000 peak early (radiation) injuries; and 7,000 cancer deaths (latent cancer fatalities).

In terms of property damages, CRAC-II predicted $43.8 billion, expressed as Year 1982 dollar figures. When adjusted for inflation alone, this figure would now be $119 billion, in Year 2020 dollar figures.

And as Associated Press investigative journalist Jeff Donn reported in June 2011, in the aftermath of the beginning of the Fukushima Daiichi nuclear catastrophe in Japan, in his four-part series "Aging Nukes," populations have soared around U.S. nuclear power plants like Point Beach, so casualty figures would now be even worse than CRAC-II predicted nearly 40 years ago.

Donn also cited neutron radiation embrittled reactor pressure vessel pressurized thermal shock risk as the top example of NRC regulatory retreat in the past number of decades.

And as Fukushima has also shown, reactor meltdowns can proceed domino effect at multi-reactor sites. A meltdown at Unit 2 could lead to a meltdown at Unit 1, or vice versa, in which case those casualty and property damage figures above would have to be doubled.

The supplemental license extension, allowing 80 years of operations at Point Beach, should not be permitted, due to this increasing risk of pressurized thermal shock through-wall fracture of the highly embrittled reactor pressure vessel.

Sincerely,

Kevin Kamps

Beyond Nuclear, Radioactive Waste Specialist; Don't Waste Michigan, Board of Directors Member, representing the Lake Michigan Chapter; Citizens for Alternatives to Chemical Contamination, Advisory Board Member

Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912

kevin@beyondnuclear.org
www.beyondnuclear.org

Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.

[These comments were made verbally on Feb. 17, 2020, at NRC's webinar/call-in public comment session, and were also submitted to the agency electronically here.]

Update on February 18, 2021 by

admin

(Beyond Nuclear, public comment #2)

On slide #9 in its slideshow, NRC stated that Operating Experience (OE) is one of several bases for NRC's Safety Review of NextEra's proposal to operate Point Beach for 80 years.

Point Beach's OE leaves a lot to be desired. This century, the two reactors at Point Beach, in certain years, had a majority of the NRC's "red findings" -- the agency's highest safety violation designation, amongst the entire U.S. fleet of operating reactors -- then numbering 104 -- combined.

Similarly, at the very same time, WI's Kewaunee reactor -- a short distance from Point Beach (about the same distance as between the now infamous Fukushima Daiichi and Daini nuclear power plants in Japan) -- had a majority of the NRC's "yellow findings," the agency's second highest risk designation, more than the rest of the 103 operating reactors combined.

Kewaunee's permanent closure was announced in late 2012, and implemented in early 2013. In fact, Kewaunee's closure commenced a record-breaking number of atomic reactor shutdowns across the U.S. since.

Another such reactor that has closed for good, Fort Calhoun in Nebraska, was given a red finding in the aftermath of a climate change-induced natural disaster: historic flooding on the Missouri River in the spring and summer of 2011. Fort Calhoun never recovered, and was permanently shut down.

Given Point Beach's very bad OE, and the ever increasing risks of breakdown phase age-related degradation accidents and disasters, shouldn't Point Beach simply be shut down for good, and replaced with safer, cleaner, more secure, more affordable renewables sources, such as wind power and solar power, as well as efficiency and energy storage, such as batteries and compressed air energy storage? This is readily achievable, considering the decade or longer left on the two Point Beach reactors' 60-year operating licenses. A decade or longer is plenty of time to achieve such a just energy transition in WI. Especially so, when considering that WI hosts the cutting edge Midwest Renewable Energy Association.

The supplemental license extension, allowing 80 years of operations at Point Beach, should not be permitted, given its bad OE, and the additional degradation this likely inflicted on the aged reactors' safety-significant systems, structures, and components.

Sincerely,

Kevin Kamps

[These public comments were made verbally by Beyond Nuclear's radioactive waste specialist, Kevin Kamps, at NRC's call-in/webinar on Feb. 17, 2021. They were also be submitted electronically to the agency here.]

Update on February 18, 2021 by

admin

(Beyond Nuclear, public comment #3)

Wind power as an alternative to 80 years of extended operations at Point Beach nuclear power plant is readily achievable, and should be the preferred alternative. Both onshore and offshore wind power potential should be considered. It is ironic that NextEra (formerly Florida Power & Light) would not include wind power as a viable alternative in its Environmental Report (ER) and license application, considering that if you go to NextEra's website homepage, featured there is a beautiful, powerful photo of large-scale wind turbines filling a vast landscape. Such a visionary scenario is most doable in Wisconsin, both on-land and offshore, in Lake Michigan, and should be done, instead of allowing the dangerously age-degraded Point Beach reactors to continue operating for three more decades, or longer.

The only alternative sources of electricity considered in NextEra's ER are, inexplicably, solar backed up by natural gas, and small modular nuclear reactors. What about solar and wind backed up by batteries and compressed air energy storage? Why aren't such cleaner, safer, more secure, more affordable, just as or more reliable, and more realistic energy options considered?

It is not surprising that NextEra has done this though. In its home base of the Sunshine State, Florida Power & Light has -- contrary to its green-washing PR campaigns -- long neglected the tremendous potential for solar power (as well as wind power), instead preferring nuclear power, as well as the combustion of fossil fuels to generate electricity. The latter are most ironic, as burning fossil fuels contributes to climate chaos, global warming, melting ice caps, and rising sea levels. Florida is facing inundation in the decades ahead, making nuclear power plant operation on its coastlines, ever more dangerous and unrealistic. This is especially true at FP&L's own two-reactor Turkey Point nuclear power plant in southern Florida, which, ironically enough -- throwing caution to the wind (and waves) -- NRC has already rubber-stamped for 80 years of operations. Turkey Point already suffered a very near miss with a major catastrophe in 1992 during Hurricane Andrew. FP&L/NextEra, and NRC, have unwisely ignored that cautionary tale.

In addition to renewable sources of electricity being ready to affordably displace Point Beach, energy efficiency should be maximized. In fact, nega-watts, as dubbed by Amory Lovins of the Rocky Mountain Institute, are the cheapest kilowatt-hours to be had -- those that never had to be generated in the first place.

Dr. Arjun Makhijani of the Institute for Energy and Environmental Research concluded in his 2007 book Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy, that the U.S. economy -- the largest of any country on Earth -- could readily and affordably go nuclear power-free and fossil fuel-free, relying entirely on renewables and efficiency, within just a few decades, if only we chose to.

Since then, Dr. Makhijani has done multiple state-level analyses -- such as in Maryland, as but one example -- showing how to practically accomplish this carbon-free and nuclear-free energy economy. The same could readily be done in Wisconsin as well. After all, WI hosts the Midwest Renewable Energy Association, a national leader in its field, and its annual Fair.

Sincerely,

Kevin Kamps

[These comments were submitted to NRC electronically, here.]

Update on February 18, 2021 by

admin

(Beyond Nuclear, public comment #4)

Re: the high-level radioactive waste that would be generated at Point Beach nuclear power plant, if NRC rubber-stamps 80 years of operation at the two reactors:

Each reactor would generate at least 20 metric tons of irradiated nuclear fuel (highly radioactive waste) per year.

20 metric tons X 20 years (the extension on the already rubber-stamped 60-year license) = 400 metric tons per reactor.

400 metric tons X 2 reactors = 800 metric tons.

Thus, two decades of additional operations at Point Beach, on top of what NRC has already approved, would mean yet another 800 metric tons, or more, of additional high-level radioactive waste that would be generated, for which we still have no safe, sound solution, after 64 years of commercial/civilian nuclear power (and high-level radioactive waste generation) in this country. This additional 800 metric tons of irradiated nuclear fuel would represent a catastrophic risk in and of itself, to public health, safety, security, and the environment, and would be a curse on all future generations. High-level radioactive waste remains hazardous and deadly for more than a million years. 20 years of electricity generation at Point Beach is not worth the more than a million years of hazard associated with the high-level radioactive waste that would be generated. This is especially outrageous, when clean, safe, secure, affordable, and reliable renewables, such as wind and solar, combined with efficiency and storage, can readily displace Point Beach in terms of electricity supply.

Sincerely,

Kevin Kamps

[These comments were submitted electronically to NRC, here.]

Update on March 1, 2021 by

admin

(Beyond Nuclear, public comment #5)

If Point Beach is to be allowed to operate for not 60, but rather 80 years, then it is high time for cooling towers to be required to be installed.

Point Beach has no cooling towers. Unit 1 has operated since 1970. Unit 2 has operated since 1973. And that entire time, these atomic reactors have been dumping 2/3rds of the waste heat generated from the splitting of atoms, directly into Lake Michigan.

Unit 1 and Unit 2 are each rated at 1,800 Megawatts-thermal. This means that both units regularly discharge 1,200 MW-t of waste heat into Lake Michigan, for lack of cooling towers. This has gone on for more than half a century. Now Point Beach proposes continuing to do so not for 10 more years, but 30 more years.

These waste heat discharges cause a significant, negative environmental impact on the Lake Michigan environment and ecosystem. Not only are life forms sucked into the Point Beach nuclear power plant via cooling water inflow -- and thereby injured or killed -- but the waste heat discharge water flow increases the temperature of Lake Michigan out to a significant distance. The elevated temperature is disadvantageous to indigenous species of plants and animals, while advantageous to certain non-native/invasive species.

Please see the Beyond Nuclear report entitled Licensed to Kill: How the Nuclear Power Industry Destroys Endangered Marine Wildlife and Ocean Habitat to Save Money, for more information on the ecological impacts of atomic reactors that lack cooling towers. It is posted online here: <http://static1.1.sqspcdn.com/static/f/356082/3590840/1247621149403/ltk_full.pdf?token=CoXF%2BvQtuOods%2Fajf6xEV4dtO2M%3D>. While the report's title refers to "marine" and "ocean," the report also examines atomic reactor thermal waste water discharges into rivers, lakes, reservoirs, etc. The report's lessons learned are certainly applicable to Point Beach's negative thermal waste water discharge impacts on Lake Michigan's ecosystem.

The lack of cooling towers has led to atomic reactors not operating for 60, much less 80 years. The State of New York made clear to Indian Point's owner that if cooling towers were not installed, it would not allow Indian Point to operate for 60 years. The state retains authority over surface water quality, as re: the Hudson River, and asserted that authority at Indian Point. Indian Point's owner, Entergy, does not want to spend the $2.5 billion, or more, it would cost to install cooling towers. Thus, Indian Point Unit 2 shut for good in April 2020. Indian Point 3 will shut for good in April 2021.

Indian Point's two reactors were responsible for killing a billion fish and other aquatic life forms each and every year, for a half century. This represents a massive harm perpetrated on the Hudson River ecosystem by a nuclear power plant lacking cooling towers.

The lack of cooling towers at the Oyster Creek, New Jersey atomic reactor also led to permanent shut down, even before expiration of its NRC operating license. NRC rubber-stamped a 20-year extension at Oyster Creek, allowing it to operate for 60 years. However, the State of New Jersey, under the governorship of Chris Christie, agreed to only allow Oyster Creek to operate 50 years, but not 60 years, due to the lack of cooling towers. This "deal," to allow Oyster Creek to violate the Clean Water Act for 10 additional years, while still lacking cooling towers, was questionable. Oyster Creek should have been forced to close at the end of its 40-year initial license. But Gov. Christie agreed to allow Oyster Creek to continue violating the law, and harming Barnegat Bay, for another decade. In the end, though, Oyster Creek did close for good on Sept. 17, 2018, because its owner did not want to spend the money to build cooling towers, in order to continue operating for yet another decade into the future.

During its half century of operations, once every six weeks, the single reactor at Oyster Creek would draw in a volume of water equivalent to the entire volume of the narrow, shallow Barnegat Bay. Immense harm was done to Barnegat Bay's ecosystem by this half century of cooling water intake, and thermal waste water dumping, abuse.

If Point Beach is going to be allowed to operate for another three decades, on top of the five decades it has already operated, then cooling towers must be installed. Point Beach has already done immense harm to Lake Michigan's ecology. This cannot be allowed to continue for 30 more years, including during yet another 20-year license extension.

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #6)

If 800 metric tons, or more, of highly radioactive irradiated nuclear fuel (likely to be high burnup, to boot -- thermally hotter, more radioactive, and more brittle) is permitted to be generated at Point Beach Units 1 and 2 over yet another 20 years of operations (not the currently approved 60 years, but a total of 80 years at each reactor), this will exacerbate the challenges and risks of managing the high-level radioactive waste.

For example, in its Feb. 2002 Final Environmental Impact Statement for the proposed Yucca Mountain, Nevada high-level radioactive waste dump, the U.S. Department of Energy (DOE) proposed barging Point Beach's irradiated nuclear fuel, on the surface waters of Lake Michigan, down to the Port of Milwaukee. There, it would be transferred onto trains, for shipment out to Western Shoshone treaty land in Nevada, against the Indigenous Nation's will.

DOE predicted up to 217 casks of irradiated nuclear fuel, being barged from Point Beach to Milwaukee. (For documentation of this figure, and additional points below, see: <http://archives.nirs.us/factsheets/mibargefactsheet92804.pdf>. But in DOE's FEIS, it assumed only 50 years of operations at each of the Point Beach reactors. Ironically enough, that is right about how old the two reactors are at Point Beach. Unit 1 is a bit older than 50 years, and Point Beach 2 a couple years younger than 50.

So, for each and every year, from now on, that Point Beach operates, about 40 metric tons, or more, of additional irradiated nuclear fuel will be generated, more than DOE predicted when it assumed Point Beach would close for good at age 50.

This means that DOE's estimate of 215 barges of high-level radioactive waste on Lake Michigan, originating at Point Beach, could be a significant underestimate.

NRC has already approved 60 years of operations at Point Beach, 10 years longer than DOE assumed.

Now Point Beach has requested another 20 years of operations, for a grand total of 80 at Point Beach. NRC seems all too willilng to rubber-stamp that request, despite widespread public opposition.

Each barge shipment represents a roll of the die, that could come up snake eyes. Each barge shipment is a potential Floating Fukushima, a potential Mobile Chernobyl, a potential Dirty Bomb on the waves, traversing the surface waters of Lake Michigan. (Fukushima's 10th annual commemoration will be on 3/11/21; Chernobyl's 35th annual commemoration will be on 4/26/21; although Fukushima was a triple meltdown of reactors, and Chernobyl a reactor explosion and fire, irradiated nuclear fuel -- as would be barged from Point Beach on the surface waters of Lake Michigan -- is the same material that melted down at Fukushima, and exploded and burned at Chernobyl.)

If even a fraction of the contents of a single cask were to be released into Lake Michigan during such a barge ship, whether due to accident or attack, it would spell unprecedented radiological disaster for the Great Lakes downstream. The Great Lakes are the drinking water supply for 40 million people in 8 U.S. states (7 of them downstream of Point Beach and Milwaukee -- the only state not downstream is MN, which borders Lake Superior), 2 Canadian provinces, and a very large number of Indigenous Nations on both sides of the U.S./Canadian border. That only counts this generation. The Great Lakes will continue to serve as the drinking water supply, and so much more, for countless numbers of people, into the future.

A cask sinking to the bottom of Lake Michigan would present unprecedented emergency challenges. If the cask breaches, as due to the immense pressures at such depths, and/or due to damage caused during the accident or attack that led to the sinking in the first place, it will be very difficult to recover. Even older 24 Pressurized Water Reactor (PWR) irradiated nuclear fuel (INF) assembly shipping containers are very heavy, well over 100 tons. But current 37 PWR INF assembly shipping containers are around 50% more heavy. A very powerful ship-board crane would have to be brought in, set up, and activated, all assuming the cask's location on the bottom of Lake Michigan has been found, weather conditions (which could have caused the sinking in the first place) are amenable to such emergency operations, etc. The longer the cask or casks remain on the bottom of Lake Michigan, the more likely they will breach and begin to release their forever hazardous, deadly contents.

NRC's water submersion design criteria leave a lot to be desired. A cask that has undergone the puncture design criteria (a free fall from a mere 40-inch height, onto an 8-inch spike) must withstand submersion under 3 feet of water. Lake Michigan is much deeper than 3 feet, across most of its vast expanse.

An undamaged cask must withstand submersion under 200 meters (656 feet of water) for one hour. There are deeper depths in Lake Michigan, and the potential for a cask barge to stray (or be hijacked) to areas of such deeper depths is greater than zero. No matter how far under water the cask is or casks are submerged, it is very unlikely they could be recovered in just one hour's time. Chances are, it would take a very much longer period of time than that. And the longer a breached container remained on the bottom of Lake Michigan, the more of its forever hazardous, deadly contents it would release.

To make matters even worse, if a cask does breach, allowing radioactive poisons out, that means it is also allowing water in. Water is a neutron moderator. There is enough fissile material -- uranium-235, plutonium-239 -- in irradiated nuclear fuel to spark an inadvertent nuclear chain reaction, if a critical mass has formed in the course of the accident, in the presence of neutron moderating water. If such an inadvertent chain reaction were sparked in a cask, this would make harmful radiological releases into Lake Michigan even worse. But it would also make emergency response a potential suicide missions. Divers, or even emergency responders in submersibles, could not approach the chain reacting waste without risking potentially fatal exposures to gamma and neutron radiation emanating from the chain reaction, especially through the breached radiation shielding of the container.

And even if the cask were raised to the surface of Lake Michigan during recovery operations, if the waste inside were chain reacting, as it got closer and closer to the surface of the water, the gamma and neutron doses to emergency responders at the surface would increase, and could even risk lethal levels, depending on how close the responders were to the cask, how much and what kinds of radiation shielding they had, etc.

Yet another 20 year license extension at Point Beach would generate 800 metric tons, or more, of additional irradiated nuclear fuel. That INF would have to be transported away from Point Beach some day (or year, decade, century, etc.). If those shipments take place by barge, each one represents a potential for radiological catastrophe in Lake Michigan.

As Arnie Gundersen, chief engineer at Fairewinds Energy Education, pointed out in the aftermath of the 2011 Fukushima Daiichi nuclear catastrophe in Japan, the Great Lakes represent only 1/30,000th the water volume of the Pacific Ocean. If a Fukushima-scale radioactivity release were to happen on the Lake Michigan shore, the concentration of the hazard would be 30,000 times worse than Fukushima's radioactivity releases into the Pacific. See Arnie Gundersen's essay, "Downstream," posted online at this link: <https://www.fairewinds.org/demystify/downstream?rq=downstream>.

While an open Lake Michigan sinking along Wisconsin's shore between Point Beach and Milwaukee would be quite catastrophic enough, an accident or attack in the Port of Milwaukee itself could prove to be even worse. After all, such barge shipments would bring high-level radioactive waste into very close proximity to a densely contrated, very large urban population. Potential casualities (acute radiation poisoning deaths and injuries, latent cancer fatalities), as well as property damage, could prove even worse, and even more near term, than a sinking in a more remote, or rural, location.

To avoid such radioactive nightmare scenarios, why not just generate needed electricity in a safer way, that does not carry such high-risk, hazardous consequences as the potential for a barge of high-level radioactive waste sinking to the bottom of Lake Michigan? Renewables such as wind and/or solar, with battery and/or compressed air energy storage, combined with maximized energy efficiency, come to mind.

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #7)

Please consider these two articles, from mid-2012, published by Citizens Nuclear Information Center-Tokyo, re: reactor pressure vessel (RPV) neutron embrittlement and pressurized thermal shock risk at Japan's worst embrittled RPV, Genkai Unit 1:

<https://cnic.jp/english/?p=2653>

and

<https://cnic.jp/english/?p=2654>

They are entitled/dated: "Aging Nuclear Power Plants, focusing in particular on irradiation embrittlement of pressure vessels," NukeInfo Tokyo #148, publised May 11, 2012, and continued in NukeInfo Tokyo #149, published July 11, 2012; the pair of articles was updated March 11, 2015.

The author of both article installments is Hisamitsu Ino. CNIC Tokyo has published a biographical article about the author: <https://cnic.jp/english/newsletter/nit132/nit132articles/ww132.html>.

The gist of Hisamitsu Ino's articles is that predictions of embrittlement at Genkai Unit 1 proved to be significantly overly optimistic, non-conservative, when the predictions were finally, at long last, checked against actual physical data. The embrittlement was way worse than Japan's nuclear power industry and government safety regulators had predicted. The reality data-based validation of the overly optimistic hypothesis was long overdue, despite the high safety stakes involved.

After this revelation that embrittlement was actually much worse than had been predicted at Genkai Unit 1, the reactor was summarily shut down for good, post-Fukushima. The Japanese people would no longer sit idly by in the face of such risks. We should follow their inspiring and wise example, here in the U.S.

In the U.S., the NRC and nuclear power industry, as at Point Beach Unit 2, just keep making rosy predictions on paper, while scrupulously avoiding actual physical data that is quite close at hand -- capsules in RPVs that have never been harvested and analyzed; shut for good RPVs that could be "autopsied" (comprehensively and carefully examined and analyzed for physical data, such as extent of neutron embrittlement), etc. What is it that NRC and the U.S. nuclear industry don't want to know, don't want to find? There are still more than 60 Pressurized Water Reactors operating across the U.S., at various levels of vulnerability to neutron embrittlement of their RPVs, and hence pressurized thermal shock (PTS) through-wall fracture risk, which would lead to core meltdown, and potentially catastrophic releases of hazardous radiation, if containment(s) are damaged or destroyed, as happened at Fukushima, Japan beginning on 3/11/11, almost ten years ago now.

Palisades, MI and Point Beach Unit 2, WI, are -- according to NRC in April 2013 -- the worst embrittled RPVs in the U.S. This was acknowledged by NRC staff in the following document:

April 18, 2013: Giessner, J., U.S. Nuclear Regulatory Commission, letter to Entergy Nuclear Operations, Inc., "Summary of the March 19, 2013, Public Meeting Webinar Regarding Palisades Nuclear Plant," dated April 18, 2013 (ADAMS Accession No. ML13108A336).

Specifically, see Point #4 on Page 5 of 15 on the PDF counter. (This document is posted online here: <https://www.nrc.gov/docs/ML1310/ML13108A336.pdf>.)

We should learn from this cautionary tale in Japan, and pull all capsules in the U.S. that are long overdue, to check RPV embrittlement levels. Palisades in MI, for example, has a remaining capsule, the pull and analysis of which is very long overdue. Does Point Beach Unit 2 (and Point Beach Unit 1, for that matter) also hold capsules, the pulls and analysis of which are likely very long overdue?

In addition, there are retired (or "dead") PWR RPVs that could be "autopsied" -- comprehensively analyzed for critically needed embrittlement data. Indian Point Unit 3 is scheduled to shut down for good next month; Palisades MI is scheduled to shut down for good by May 31, 2022; Diablo Canyon Unit 1 is scheduled to shut down for good by 2024; Beaver Valley Unit 1 could also shut for good in the near future, if Energy Harbor (formerly, First Energy) attempts to secure bailouts at ratepayer and taxpayer expense continue to be met with such fierce resistance in PA, OH, and beyond. (See: <http://www.beyondnuclear.org/reactors-are-closing/>.)

These PWR RPVs are the other four of the top five most embrittled in the U.S., according to that 2013 NRC document cited above. Most to all of those permanent shut downs would occur prior to Point Beach Unit 2 entering its supplemental license extension period -- that is, 60 to 80 years of operations. Why wouldn't NRC require autopsies on these other highly embrittled RPVs, to apply lessons learned at Point Beach 2 prior to rubber-stamping this latest requested license extension? Science is based on actual physical data, not just theories and hypotheses. The latter are to be challenged and tested to verify their validity. That would be science-based nuclear safety regulation, vis-a-vis PTS risks.

In fact, Associated Press investigative journalist Jeff Donn cited repeated weakening of NRC PTS safety standards as his top example of NRC regulatory retreat, in the kick off article in his four-part post-Fukushima series entitled "Aging Nukes" (Part I: "US nuke regulators weaken safety rules"): <https://www.ap.org/press-releases/2012/aging-nukes-a-four-part-investigative-series-by-jeff-donn>

A year after the Fukushima Daiichi nuclear catastrophe began in Japan, the Japanese Parliament published a root cause report, the first such independent investigation in Japan's Post-WWII democratic history. The Japanese Parliament concluded that the root cause was not the earthquake, nor the tsunami, but rather collusion -- collusion between Tokyo Electric Power Company (and the rest of the nuclear power industry), government safety regulators, and elected officials.

There is just such collusion in spades at Point Beach, between NextEra, NRC, and pro-nuclear power government officials at all levels promoting the 80-year operational license. And thus Lake Michigan, and the rest of the Great Lakes, and all who reside on their shorelines, downwind and downstream, are being put in peril.

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #8)

This is a follow up on my public comment #2, re: OE (Operating Experience) at Point Beach.

I thank my colleagues at Nukewatch-Wisconsin for compiling the following Point Beach OE listing:

[Nukewatch

Kelly Lundeen and John LaForge, Co-directors

February 16, 2021

Wisconsin’s nuclear power reactors at Point Beach are located on Lake Michigan. They have suffered frequent unplanned shutdowns caused by accidents, resulting in official warnings, fines, and even criminal convictions. If a company wants to continue to create tons of high level radioactive waste, they need to prove that they will be doing something different so that none of these accidents will happen again.

As of 2008 three “RED” findings — the highest failure warning issued by the Nuclear Regulatory Commission (NRC) — had ever been made public.

At issue were safety procedures that were declared “inadequate” by NRC inspectors who said the failures existed “for many years and that the licensee had seven prior opportunities to identify these inadequacies.” The failures and inaction were of “high safety significance (a Red finding)” under NRC rules. NRC inspectors found that Point Beach’s owners continuously compromised the auxiliary [cooling] feed-water pumps between 2001 and 2007.

January 15, 2008

At Pont Beach’s Unit 1, an “Unusual Event” emergency was prompted by the complete loss of all offsite electric power to essential buses for more than 15 minutes, man-dating a notification of the Nuclear Regulatory Commission. A supply breaker opened “for unknown reasons,” was being investigated and preparations were made for a Unit 1 shutdown. ¾ NRC Event No. 43907, Jan. 15, 2008

December 8, 2006

At Point Beach, the Control Room Emergency Filtration System was declared inoperable. The Control Room Charcoal Filter Fan tripped during a surveillance test, an event or condition that could have prevented the filter’s performance during a contamination emergency or, in the NRC’s words, “could have prevented fulfillment of a safety function.” ¾ NRC Event No. 43040, Dec. 8, 2006

August 22, 2006

In an August 22, 2006 letter to Point Beach, the NRC charged that a senior reactor operator was discriminated against by the company’s management for identifying potential technical violations. The discrimination was an apparent violation of employee protection requirements. — NRC, “Point Beach Summary,” Inspection Procedure 95002,< nrc.gov/reactors/operating/ops-experience/degraded-cornerstone/pt-beach-summary.html>

December 16, 2005

Point Beach paid a $60,000 fine imposed Jan. 13, 2006 after two workers “deliberately provided NRC inspectors with inaccurate information” about the critique of an emergency preparedness drill at the Point Beach reactor in August 2002. The two were fired, and one was convicted in federal court of knowingly making false written statements to the NRC. ¾ NRC News, No. III-05-046, Dec. 19, 2005

December 13, 2005

A manual reactor trip shut down Point Beach Unit 1, due to loss of a condenser vacuum caused by failure of the running circulating water pump. Decay heat was being removed by “atmospheric dump valves.” The backup feed-water system was required. The operator, Florida Power & Light, said there are no known steam generator tube leak issues. ¾ Notification to NRC, Dec. 13, 2005

November 9, 2004

While operating at 100 percent power, Point Beach Unit 2 sprang a steam leak from a valve in the main steam flow transmitter. The leak of potentially contaminated steam forced an unplanned shutdown. The leak involved what is called “containment penetration” of the main steam line passing through the concrete containment building. Accordingly, operators declared a Technical Specification Condition “not met,” forcing operators to isolate the “affected penetration flow path with a completion time of 72 hours.” Operators were unable to meet the allowed completion time for this task. ¾ NRC Event No. 41212, Notification, Nov. 19, 2004

April 8, 2004

Point Beach paid a $60,000 fine imposed March 20, for last summer’s problems with the reactor’s backup cooling pumps. ¾ The Capital Times, March 20, 2004

February 11, 2004

The ongoing risk of a breakdown in Point Beach’s cooling feed-water pumps results in a NRC “RED” finding, the agency’s most severe safety failure warning. ¾ NRC News, Feb. 11, 2004

October 2002

A “RED” finding was issued by the NRC against Point Beach for problems with cold water circulation for cooling the reactor.

NRC News, Feb. 11, 2004

November 18, 1997

Point Beach Unit 2 was hastily shut down because of electrical problems. ¾ Milwaukee Jrnl Sntl, Nov. 18, 1997

August 12, 1997

The NRC recorded 21 violations at Point Beach in the 90-day period between Dec. 1996 and Feb. 1997. ¾ St. Paul Pioneer Press, Aug. 12, 1997

July 25, 1997

Reactor 2 at Point Beach was shutdown when a cooling water pump failed. ¾ Milwaukee Jrnl Sntl, Aug. 25, 1997

February 18, 1997

Reactor 1 at Point Beach was shut down when a cooling water pump defect required the pump’s replacement.

December 1996

Point Beach owner WEPCO was fined $325,000 for 16 safety violations and a 1996 explosion inside a loaded high-level waste cask. The NRC said WEPCO was “inattentive to their duties,” “starting up a power unit while one of its safety systems was inoperable,” and had failed to install “the required number of cooling pumps.” ¾ Milwaukee Jrnl Sntl, Aug. 12, 1997, and Dec. 5, 1996

May 28, 1996

At Point Beach, a potentially catastrophic explosion of hydrogen gas, “powerful enough to up-end the three-ton lid,” pushed aside a 6,390-pound cask lid while it was atop a storage cask filled with high-level waste. The lid was being robotically welded to the cask. ¾ Milwaukee Jrnl Sntl, June 8, 1995

March 30, 1995

A Point Beach reactor was shut down due to instrument failure in the emergency generator system used to circulate cooling water when regular power is cut off during emergencies. ¾ Wisconsin State Journal, March 30, 1995

____________

NUKEWATCH

740A Round L. Rd.

Luck, WI 54853

(715) 472-4185

www.nukewatchinfo].org

I have to point out the irony, at the Feb. 17, 2021 NRC call-in/webinar, of the NRC facilitator interrupting Kelly Lundeen of Nukewatch WI, because her verbal recitation of the listing of incidents at Point Beach, above, was taking too long. Whose fault is that? It is Point Beach's fault. And yet they want an 80 year operational permit. And NRC appears poised to rubber-stamp it. No questions asked. (Besides, NRC ended the meeting early, even before its announced ending time, so no public commenters should have been pressured to limit their remarks.)

And my colleague Mitchell Maricque informed me of the following Point Beach OE as well:

According to Wikipedia, "Due to steam generator tube degradation caused by intergranular stress corrosion cracking, Unit 1 was operated at approximately 75-80% of full power from December 1979 until October 1983, when replacement steam generators were installed. The Unit 2 steam generators were replaced in 1996-1997."

This is abysmal OE. Not only has it undermined public trust and confidence in the safe operation of Point Beach, but some of the incidents may have even degraded safety significant systems, structures, and components. Because of this abysmal OE, Point Beach should be denied 80 years of operations. It is too high risk. It is playing with fire. Only so many radioactive bullets can be dodged. Some day, luck may run out.

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, comment #9)

I am concerned about Point Beach's plan for management of radioactive steam generators. Seeking to operate for another 30 years, on top of the 50 years it already has, Point Beach could require one or more steam generator replacements in the future. This will add to an accumulation of radioactive steam generators on site. Once the nuclear power plant closes for good, there will be action taken to ship the radioactive steam generators off-site, as radioactive waste, for disposal at a dump. How will such shipments be done? Will they be barged on Lake Michigan?

A proposal to barge a grand total of 64 radioactive steam generators, from the Bruce Nuclear Generating Station in Kincardine, Ontario, Canada, on the surface waters of the Great Lakes, across the Atlantic Ocean, to Sweden, for "recycling," and return to sender radioactive waste shipments (the concentrated radioactive contamination of the steam generator tubes), a decade ago, led to a groundswell of public opposition that stretched from the Great Lakes to Europe. In the end, the shipments were stopped dead in their tracks. The Mohawks of Quebec nailed the final nail in the coffin lid on the proposed shipments, declaring they would not be allowed through their St. Lawrence River homelands.

During the course of our successful resistance struggle, to protect the Great Lakes against the risk of a drinking water emergency, if a radioactive steam generator released just a small fraction of its contents into a small volume waterway (such as the Detroit River), we learned of a secretive shipment of two radioactive steam generators, in November 2001, from Kewaunee atomic reactor in WI, near Point Beach, down Lake Michigan, through the Chicago waterways, down the Mississippi, to Memphis, for "processing." We did not find out about the shipment until a decade after it happened, thanks to U.S. Senator Russ Feingold, leading a Democratic U.S. Senate Great Lakes States delegation, demanding of NRC to release relevant documentation, in light of the Bruce Nuclear proposal.

Is Point Beach planning to barge radioactive steam generators, on Lake Michigan, through Chicago, down the Mississippi, to Memphis? Or on the Great Lakes, across the Atlantic, to Europe for "reprocessing"? Will there be return shipments, as there were to have been back to Bruce Nuclear? Will this barging be done in secret, like Kewaunee did in 2001?

Will NRC rubber-stamp such secretive radioactive waste barges on the Great Lakes, like it did -- literally overnight, in the dead of night -- with Kewaunee's shipments in 2001?

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #10)

I would like to share two links to creations of Fairewinds Energy Education. The first is a video, entitled "Nuclear Crack Down?", about reactor pressure vessel neutron embrittlement, and consequent pressurized thermal shock risk of through-wall fracture, core meltdown, and potential catastrophic radioactivity release. Here is the link: <https://www.fairewinds.org/nuclear-energy-education/nuclear-crack> The second is an essay, "Downstream," about the risks of a radioactive catastrophe on the Great Lakes shoreline, in light of the Fukushima Daiichi nuclear catastrophe in Japan, about to hit its ten year mark on 3/11/21, with no end in sight. Here is that link: <https://www.fairewinds.org/demystify/downstream?rq=downstream> Arnie Gundersen, Fairewinds Energy Education's chief engineer, served as an expert witness for the environmental coalition comprised of Beyond Nuclear-Don't Waste Michigan-Michigan Safe Energy Future-Nuclear Energy Information Service, when it challenged a reactor pressure vessel embrittlement license amendment at the Palisades atomic reactor, in Covert, MI, across Lake Michigan from Point Beach. Terry Lodge served as legal counsel. Despite our coalition's best efforts at Palisades in 2014-2015, NRC rubber-stamped Palisades' requested license amendment, another weakening of embrittlement safety standards, on top of so many that had come before. Many of those same groups had challenged Palisades' requested 20-year license extension (for a total of 60 years of operations), from 2005-2007. Again, NRC rejected our challenges, and rubber-stamped 60 years of embrittled operations at Palisades, PTS risks be damned. Now we are shocked that Point Beach Unit 2, a RPV about as embrittled if not more so, than Palisades, has applied to NRC for not 60 years of operations (which have already been permitted), but 80.

As I've mentioned in previous comments, AP investigative reporter Jeff Donn cited PTS safety regulatory retreat as his top example of a complicit NRC, captured by the industry it is supposed to regulate, in his post-Fukushima four-part series, "Aging Nukes."

In 2014-2015, as we battled Entergy, NRC staff, and the NRC Commissioners, over PTS risks at Palisades, I compiled an annotated bibliography timeline, which documents repeated regulatory weakening of PTS safety standards, over the course of many long decades. Here is the link to it, posted online: <http://www.beyondnuclear.org/safety/2014/10/30/beyond-nuclear-warns-nrc-against-weakening-rpv-embrittlement.html>.

At least Palisades has announced its closure, for good, by 5/31/22. Point Beach Unit 2, however, has applied for yet another 20-year license extension, meaning 30 more years of operations. This is tempting fate.

Given this very troubling history of NRC regulatory retreat on PTS safety standards -- in fact yet another weakening is underway or has already been approved, recently/presently -- and given the high stakes for the Great Lakes and all who call them home, I urge you in the strongest possible terms to reject Point Beach's application for 80 years of high-risk, embrittled operations.

Sincerely,

Kevin Kamps

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #11)

Re: Attachment D: Cultural Resources Consultations, in Point Beach's ER.

Point Beach's outreach to Indigenous Nations, as an attempt to protect Indigenous cultural properties, is woefully inadequate. While a very basic form letter was sent to a single person at 52 different Indigenous Nations, it put the burden on them for further consultation.

The form letter states: "Also, as part of the subsequent license renewal process, NRC may request a consultation with your tribe in accordance with Section 106 of the National Historic Preservation Act of 1966, as amended (Public Law 89-665; 54 U.S.C. 300101 et seq.), and implemented by the Advisory Council on Historic Preservation regulations (36 CFR 800)." (emphasis in original)

"...may request a consulation with your tribe..."?!

Many, to most, to all of those 52 named Indigenous Nations have treaties with the United States of America. Treaties are the highest law of the land, equal in stature to the U.S. Constitution itself. Sovereign nation to sovereign nation consultation is what is demanded, by law, and by basic respect.

The form letter also states "The ER addresses the potential to impact historic and cultural resources including tribal cultural resources on or near the PBN site."

But historic and cultural Indigenous resources on or near the Point Beach Nuclear site are not the only relevant issues. What about treaty rights to hunting and gathering territory? What about fishing rights in Lake Michigan, as well as inland surface waters? What about Indigenous Nations' burial sites and other sacred sites that are undoubtedly in the area, which has been inhabited by Indigenous Nations since time immemorial?

The top paragraph on the second page of the basic form letter reads:

"During the subsequent license renewal term, NEPB proposes to continue operating the units as currently operated and based on aging management studies does not expect that refurbishment, construction, ground disturbing activities, or physical changes will be needed. Protection of known cultural resources on the PBN site is managed by the Archaeological, Cultural, & Historic Resources section of the PBN procedures manual. NEPB does not anticipate operation of PBN to adversely affect the environment or any cultural or historic resources." (emphasis in original)

But the Archaeological, Cultural, & Historic Resources section of the PBN procedures manual was not provided, not in hardcopy form, nor even link to it. Again, the burden in on the Indigenous Nations to track down such documents.

And what about protection of unknown cultural resources, very likely located on the PBN site, perhaps even the footprint of current physical plant facilities, or on supposedly undisturbed land?

Point Beach has stated that no adverse effects on the environment, or any cultural or historic resources, are anticipated, re: 80 years of operation of a severely embrittled nuclear power plant -- the worst in the country -- that has had one of the very worst Operational Experiences in the U.S. nuclear power industry (such as, in a short space of time, multiple NRC "red findings" -- the very worst safety violation designation -- more than the 100+ other reactors across the country, combined!).

Impacts to cultural or historic or pre-historic Indigenous Nations' properties and resources do not just occur through construction projects, such as the building of new parking lots, or dry cask storage pads for ever mounting quantities of high-level radioactive waste dry storage casks, however.

Nuclear power plants "routinely" release radioactivity, with permission from NRC. These "routine" radioactivity releases are not harmless, however. As the National Academy of Science has affirmed, over and over for decades, any exposure to ionizing radioactivity carries a health risk to humans, and those risks accumulate over a lifetime of exposures.

And it's not just humans who are harmed. Other plant and animal species are also harmed, as Dr. Timothy Mousseau's large number of wildlife biology studies from Chernobyl and Fukushima have so clearly shown.

Many traditional Indigenous Nations place tremendous value and regard on other species, in addition to human beings. "We are all related," or "All of our relations" is the English translation of a traditional Indigneous phrase across many Nations, expressed in many different languages, recognizing this, as in prayers, ceremonies, and even daily life, such as while hunting, fishing, and gathering.

There is no mention whatsoever in Point Beach's basic form letter to the 52 Indigenous Nations about radioactivity or radiation and its often very long lasting hazards, depending on the radioisotope released. Again, the burden is placed on the lone individual written to by Point Beach at 52 Indigenous Nations, to do the research, to discover such impacts and their significance.

For more information on "routine" radioactivity releases from nuclear power plants, please see the linked Beyond Nuclear pamphlet at: <http://static1.1.sqspcdn.com/static/f/356082/26605366/1444852853757/BN_RoutineRadioactiveReleases_Oct2015.pdf?token=zwsUExAyfOttAa88dOgh7qJ3NkE%3D>.

Of course, as Beyond Nuclear has commented, the risk of a catastrophic radioactivity release at Point Beach is already significantly high, and increases with time. 80 years of operations at Point Beach, with its worst embrittled RPV (Reactor Pressure Vessel) in the U.S., represents sailing ever deeper into uncharted PTS (Pressurized Thermal Shock) risk territory. A catastrophic radioactivity release at Point Beach would have LARGE impacts on Indigenous Nations' interests on and near the site, and very likely far from the site, depending on wind direction, water flow, and food chain distribution networks. EXTRA LARGE, in fact, to borrow a phrase from Susan Schuurman with the Nuclear Issues Study Group in Albuquerque, NM, Beyond Nuclear's colleague in the fight against Consolidated Interim Storage Facilities for irradiated nuclear fuel in s.e. NM, also on lands significant to many Indigenous Nations, as well as the Latinx communities who live there now.

The basic form letter goes on, "Although construction of the existing PBN facility itself may have impacted any archaeological resources that may have been located within its footprint, much of the surrounding area remains largely undisturbed."

That description of past destruction due to lack of caring, concern, law, and regulation is very heartbreaking, and enraging. It can never be repeated again in the future, now that the United States supposedly recognizes that cultural genocide is not acceptable (a dubious proposition, given how Indigenous cultural resources and properties are still abused and even destroyed in this country -- take the Dakota Access Pipeline bulldozing Lakota sacred sites in the Dakotas in 2016, as but one example). But again, "routine" hazardous radiation releases, and the potential for catastrophic, large-scale hazardous radiation releases, also represent an EXTRA LARGE impact. This has gone on for 50 years already, and would go on for another 30 years, if NRC rubber-stamps Point Beach's license extension application.

The basic form letter goes on:

"A cultural resources survey of the property was not required prior to the construction of PBN, but five recorded surveys were conducted at various stages of expansion and licensing between 1993 through 2018. These surveys have covered approximately 972 acres of the of the 1,260-acre PBN property. There are no National Register of Historic Places (NRHP)-eligible cultural resources confirmed within the 1,260-acre PBN property. The June 2004 survey identified findings, which included 15 isolates and one prehistoric archaeological site. PBN has committed to avoiding previously identified sites within the 1,260-acre property."

It is sad and angering that "A cultural resources survey of the property was not required prior to the construction of PBN". This means that Indigenous Nations' cultural resources and properties, including burial sites and sacred sites, could well have been damaged or destroyed simply through the physical construction of the facility, let alone radioactive contamination since.

And what about Point Beach Nuclear committing to avoiding damage or destruction to unidentified sites on the property, in addition to identified sites?

Such damage or destruction can never be allowed to happen again, including on "much of the surrounding area [that] remains largely undisturbed." Of course, "routine"hazardous radioactivity release contamination is itself a significant disturbance, which Point Beach Nuclear entirely downplays and ignores in its basic form letter.

Again, re: the basic form letter's claim that:

"A cultural resources survey of the property was not required prior to the construction of PBN, but five recorded surveys were conducted at various stages of expansion and licensing between 1993 through 2018.These surveys have covered approximately 972 acres of the of the 1,260-acre PBN property. There are no National Register of Historic Places (NRHP)-eligible cultural resources confirmed within the 1,260-acre PBN property. The June 2004 survey identified findings, which included 15 isolates and one prehistoric archaeological site. PBN has committed to avoiding previously identified sites within the 1,260-acre property."

It is hard to understand how Point Beach Nuclear can state that "There are no National Register of Historic Places (NRHP)-eligible cultural resources confirmed within the 1,260-acre PBN property."

Given the June 2004 survey on Point Beach's own property, that identified 15 isolates and one prehistoric archaelogical site, as well as the nearly three-dozen Indigenous culture affiliated sites listed in Point Beach's own Table 2. Archaeological Sites Inventory Entries within a 6-Mile Radius of PBN, it is hard to understand how Point Beach can stand by the claim that there are likely no more Indigenous cultural resources or properties on its site. After all, it has admitted that nearly 300 acres have never even been surveyed, in the past 53 years of site physical disturbance and irradiation, with apparently no plans to do so for another 30+ years of operations. And Point Beach Nuclear already admitted it didn't even check for Indigenous properties and resources that may very well have been located under the physical footprint of its constructed facilities. Those, regretably, may already have been damaged or destroyed by Point Beach Nuclear, a half century or longer ago.

The basic form letter goes on:

"In preparation for the subsequent license renewal application, PBN conducted a literature review of the Wisconsin Historic Preservation Database to identify previously recorded sites within a 6-mile radius. The results of the 2020 literature review are presented in Table 2."

It is unclear how thorough the surveys in the six-mile radius of Point Beach, for Indigenous cultural properties and resources, have been. So very much may have been missed, if the surveys were not thorough nor comprehensive. Meaningful, respectful, legally and constitutionally mandated and required sovereign nation to sovereign nation consultation with the 52 Indigenous Nations identified -- and likely numerous others not yet identified by Point Beach Nuclear -- would almost certainly shed a lot more light.

In addition to federally recognized Indigenous Nations' governments, why were the traditional and spiritual leaders of these Indigenous Nations not consulted?

A final sign of disrespect comes at the end of the basic form letter, where Point Beach writes: "Your response is kindly requested within 45 days of receiving this letter."

The lone individual at each of the 52 Indigenous Nations written to probably has an overwhelming work burden on a good day. But these are not good days. A national pandemic emergency has gripped the entire country for over a year now. And Indigenous Nations are among the hardest hit communities of all, in our entire country, disproportionately so. 45 days is way too little time for meaningful consultation. Especially considering the context -- yet another 20-year license extension, on top of 60 already permitted, filed 10 years ahead of time. As well as the million year hazard that will be generated during that latest 20-year extension -- 800 metric tons, or more, of deadly, hazardous, highly radioactive waste, with nowhere to go, with no safe, sound solutions in sight.

In addition, Indigenous Nations likely have very limited resources to process such a letter from Point Beach Nuclear. And yet there is no offer of funding from Point Beach or NRC to help defray costs, or enable the work necessary to mount a meaningful sovereign nation to sovereign nation consultation.

I urge both Point Beach and NRC to do just that, engage in meaningful sovereign nation to sovereign nation consultations with each of the 52 already identified Indigenous Nations, and any not yet identified, in order to fulfill treaty right legal and constitutional obligations, as well as a sign of basic respect and common courtesy.

Sincerely,

Kevin Kamps

and Kay Drey, Beyond Nuclear, Board of Directors President (University City, Missouri)

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #12)

If Point Beach is allowed to operate an additional 20 years, on top of the 60 already permitted, for a grand total of 80, this will mean the generation of many additional hundreds of metric tons of high-level radioactive waste at Point Beach.

This could come back to haunt Wisconsin in the end.

Wisconsin was targeted, at two separate sites in the 1980s during the Nuclear Waste Policy Act's Eastern Site Search, for a national high-level radioactive waste dump. One site was the Wolf River Batholith. The second site was the Puritan Pluton. The Eastern Site Search for a permanent geologic repository was abandoned in 1986, a prelude to the "Screw Nevada" bill of 1987.

However, the State of Nevada, the Western Shoshone, and more than a thousand environmental groups, have successfully fended off the Yucca dump, for 34 years, and have no intention of ever yielding.

And in 2008, the U.S. Department of Energy released its Report on the Need for a Second Repository. It made clear that Wisconsin is still under consideration for a second permanent geologic repository. However, since Yucca is cancelled, perhaps it'll be targeted for the country's first national permanent geologic repository.

Wisconsin should stop generating high-level radioactive waste, unless it wants to move closer to the front of the line, for further consideration to became a -- perhaps the -- national high-level radioactive waste dump.

Kewaunee's closure in 2013 was a good step in the right direction. Now Point Beach should also be closed, as soon as possible. And of course no new atomic reactors should ever be built in Wisconsin. Point Beach's alternative to yet another 20 years of operations at Point Beach -- a small modular nuclear reactor to replace it -- is absurd. The high-level radioactive waste generated at even a small modular nuclear reactor would, like another 20 years of operations and high-level radioactive waste generation at Point Beach -- make Wisconsin an ever more likely target, yet again, for a national high-level radioactive waste dump.

Sincerely,

Kevin Kamps

and Kay Drey, Beyond Nuclear, Board of Directors President (University City, Missouri)

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear, public comment #13)

Re: alternatives analyses, Point Beach Nuclear's consideration of a small modular nuclear reactor as a replacement, instead of 80 years of operations of the current two age-degraded atomic reactors, is an economic absurdity. Consider the following scholars' examination of the fatally flawed economics of small modular nuclear reactors:

(1.) The Economic Failure of Nuclear Power and the Development of a Low Carbon Electricity Future: Why Small Modular Reactors are Part of the Problem, by Dr. Mark Cooper of Vermont Law School, May 2014. Posted online at: <https://www.nirs.org/wp-content/uploads/reactorwatch/newreactors/cooper-smrsaretheproblemnotthesolution.pdf>.

(2.) Numerous works by Dr. Arjun Makhijani of Institute for Energy and Environmental Research:

Light Water Designs of Small Modular Reactors: Facts and Analysis, September 2013. Posted online at: <https://ieer.org/resource/energy-issues/light-water-designs-of-small-modular-reactors-facts-and-analysis/>.

When Small Is Not Beautiful, Is It At Least Cheap?, April 2013. Posted online at: <https://ieer.org/news/small-modular-reactors/>.

Is There a Role for Small Modular Reactors? December 2012. Posted online at: <https://ieer.org/energy-systems/is-there-a-role-for-small-modular-reactors/>.

Small Modular Reactors, Fact Sheet -- No Solutions for the Cost, Safety, and Waste Problems of Nuclear Power. Posted online at: <https://ieer.org/resource/energy-issues/small-modular-reactors-solution/>.

(3.) Dr. Gordon Edwards, Canadian Nuclear Safety Commission, et al., Small Modular Nuclear Reactors: A Case of Wishful Thinking at Best, December 2019. Posted online at: <http://www.ccnr.org/SMNR_article_2019.pdf>.

This is but the tip of the iceberg of scholarship critical of the economics, and other aspects, of small modular nuclear reactors.

As we have commented previously in this proceeding, real alternatives to yet another 20 more years at the already dangerously age-degraded Point Beach nuclear power plant should be analyzed. These would include renewables like wind and/or solar, complemented with storage technologies like batteries and/or compressed air energy storage. (Point Beach's insistence to pair solar with natural gas back up as an alternatives analysis is misleading. Solar can be backed up with battery storage and/or compressed air energy and/or other green storage technologies, instead of polluting natural gas combustion.)

Another alternative is maximized energy efficiency. These alternatives are cleaner, safer, just as or more reliable, more secure, and more affordable than a radioactive catastrophe at an age-degraded Point Beach nuclear power plant past 60 years of operations, and the same re: a small modular nuclear reactor design, at increased risk of radioactive catastrophe due to its untested design. The break in phase, like the break down phase, is a period of increased reactor risks. Chernobyl and Three Mile Island Unit 2 were break in phase disasters at brand new reactors, for example.

Sincerely,

Kevin Kamps

and Kay Drey, Beyond Nuclear, Board of Directors President (University City, Missouri)

[These comments were submitted to the agency electronically here.]

Update on March 3, 2021 by

admin

(Beyond Nuclear's public comment #14)

We object to Point Beach Nuclear's reliance on, and assumption of, the proposed irradiated nuclear fuel Consolidated Interim Storage Facility (CISF) schemes, targeting the majority minority (Hispanic, Indigenous) State of New Mexico, as well as extreme West Texas, 0.37 miles from the border of New Mexico. Not only are Holtec's and Interim Storage Partners' CISF proposals major violations of Environmental Justice, they also violate the 2012 Blue Ribbon Commission on America's Nuclear Future Final Report's recommendation that CISFs must meet "consent-based siting." Non-consent to Holtec's and ISP's CISFs has been clearly and repeatedly expressed by: the All Pueblo Council of Governors; the Navajo Nation; New Mexico's governor, Michelle Lujan Grisham; the State Land Commissioner, Stephanie Garcia Richard; most of New Mexico's U.S. congressional delegation, including Deb Haaland, nominated by President Biden to become his Interior Secretary; many New Mexico state legislators; numerous New Mexican industry associations and small businesses; a large number of New Mexican environmental, environmental justice, and nuclear watchdog organizations; and a growing groundswell of New Mexico residents.

Likewise, Texas Governor Greg Abbott has clearly expressed his non-consent to both CISFs.

Similarly, we object to any reliance on, and assumption of, the Yucca Mountain highly radioactive waste dump-site scheme, targeting Western Shoshone land in Nevada. The Western Shoshone, the State of Nevada, its U.S. congressional delegation, and more than a thousand environmental groups in Nevada and across the country, as along Yucca-bound high-level radioactive waste/Mobile Chernobyl transport routes, have clearly expressed non-consent with the environmentally unjust Yucca dump scheme, which violates the U.S.-Western Shoshone "peace and friendship" Treaty of Ruby Valley of 1863, the highest law of the land, equal in stature to the U.S. Constitution itself.

Sincerely,

Kevin Kamps

and Kay Drey, Beyond Nuclear, Board of Directors President (University City, Missouri)

[These comments were submitted to the agency electronically here.]

admin | Comments Off |