Help Protect the Great Lakes Against Radioactive Risks! Please make environmental scoping comments, re: 80 years of proposed operations at the dangerously embrittled Point Beach nuclear power plant on Lake Michigan's Wisconsin shore, by the Wednesday, March 3 deadline at 10:59pm Central (11:59pm Eastern)!

NRC file photo of Point Beach Units 1 & 2 on the Lake Michigan shore at Two Rivers, WIDear Friends and Colleagues,

Help protect the irreplaceable Great Lakes (21% of Planet Earth's surface fresh water, and 84% of North America's!) against radioactive risks. On Wednesday, February 17th, the U.S. Nuclear Regulatory Commission (NRC) held a public comment meeting re: environmental scoping for NextEra Nuclear's (formerly Florida Power & Light) proposal to operate the two-reactor Point Beach nuclear power plant, in Two Rivers, Wisconsin, not for 40 years, not for 60 years (which most reactors in the U.S. have already gotten approved, including Point Beach, 15 years ago), but for a whopping, and highly risky 80 years. Thus far, only two nuclear power plants (comprising four atomic reactors) have gotten NRC rubber-stamps for 80 years of operations; but three more nuclear power plants (comprising six atomic reactors) have now applied for 80-year operational permits, including Point Beach Units 1 and 2 (see NRC's website documenting this, here.)

More than 100 concerned citizens and environmental group representatives -- from Wisconsin, other Great Lakes states, and across the country -- attended NRC's Feb. 17th call-in/webinar. 15 people gave excellent verbal comments critical of and opposed to 80 years of operations at Point Beach. The only person to speak in favor -- other than the industry-friendly NRC staffers -- was a Point Beach atomic reactor vice president.

Now we face a deadline at 10:59pm Central (11:59pm Eastern) on Wed., March 3rd, for the submission of written comments. Comments can be submitted online here: <https://www.regulations.gov/document/NRC-2020-0277-0001>

Comments can also be snail mailed to the following address, but must be postmarked by March 3rd or earlier: Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff.

Physicians for Social Responsibility-Wisconsin has done some very valuable, helpful write ups, providing tips that could help you prepare your own comments. See them posted online here: <https://psr-wisconsin.org/point-beach-eis>. I have also pasted PSR WI's write ups, down below in this email.

Beyond Nuclear has also prepared four sets of comments thus far (re: RPV embrittlement; Point Beach's very troubled past Operating Experience; renewables with storage as a viable alternative to 20 more years at Point Beach; and the high-level radioactive waste that would be generated, which should not be), and posted them online here: <http://www.beyondnuclear.org/relicensing/2021/2/17/beyond-nuclears-comments-opposed-to-80-years-of-operations-p.html>. Feel free to copy them verbatim and submit them as your own comments, or use them to help shape your own comments. As I complete additional sets of comments, I will continue to update the webpost immediately above, right up to the deadline, so check back there for additional comment ideas.

Thank you very much for taking action to protect the Great Lakes, by submitting comments in this proceeding by the deadline. Please spread the word!

For an Atomic Reactor-Free Lake Michigan and Great Lakes,

---Kevin Kamps, Beyond Nuclear radioactive waste specialist & Don't Waste Michigan board of directors member

A short background on Point Beach, and what is at stake:

Point Beach Unit 2, for one thing, has the single worst embrittled reactor pressure vessel (RPV) of any Pressurized Water Reactor (PWR) in the country. With decades of additional neutron radiation bombardment, the risk of a pressurized thermal shock (PTS) through-wall fracture, core meltdown, and catastrophic release of hazardous radioactivity, will only worsen. And decades of additional operations would mean many hundreds, even thousands, of additional metric tons of highly radioactive waste generated, for which we still have no safe, sound solution -- a further curse on all future generations. There would also be additional decades of "routine releases of radiation" into the environment, which are harmful to children and other living things. Point Beach even lacks cooling towers, which means all its waste heat is dumped into Lake Michigan. As two-thirds of the heat generated by splitting atoms at the 3,600 Megawatt-thermal nuclear power plant is waste, that has meant large-scale ecological impacts on the natural ecosystem of Lake Michigan for the past half-century, and now they want to keep on going for another three decades! All this to continue gouging Wisconsin ratepayers on their electric bills, when cheaper, safer, cleaner wind power, as but one example, is abundant and ready to go in the greater region, but for the lack of political will. Please read on below for how to make comments. Thanks to Hannah Mortensen, Executive Director of Physicians for Social Responsibility-Wisconsin, for the very valuable web posts below. Please spread the word, and thank you for anything you can do to help us protect the Great Lakes -- drinking water supply for 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Native American/First Nations! When it comes to radioactive risks on the Great Lakes, as Fairewinds Energy Education chief engineer Arnie Gundersen has warned, we all live "Downstream"! Fairewinds has also produced a short, humorous, but enlightening video about the risks of RPV embrittlement and PTS fracture, entitled "Nuclear Crack Down?" In 2014 to 2015, Arnie Gundersen served as the expert witness for an environmental coalition (Beyond Nuclear, Don't Waste Michigan, Michigan Safe Energy Future, and Nuclear Energy Information Service) which challenged RPV embrittlement and PTS fracture regulatory weakening at the Palisades atomic reactor in Southwest Michigan, also on the Lake Michigan shoreline. Terry J. Lodge, Toledo, OH-based attorney, served as that coalition's legal counsel.

Physicians for Social Responsibility-WI links and write ups:

• Written comments

  You can submit written comments online by March 3rd. Here are some tips for writing comments.

NRC provided slides for its February 17th call-in/webinar presentation here.

ABOUT

The U.S. Nuclear Regulatory Commission will conduct a scoping process to gather information necessary to prepare an environmental impact statement to evaluate the environmental impacts for the subsequent license renewal of the operating licenses for Point Beach Nuclear Plant, Unit Nos. 1 and 2 (Point Beach). The NRC is seeking public input on this action.

The application is available on the NRC’s website here and in the NRC’s publicly available Agency-wide Document Access and Management System (ADAMS). The ADAMS Accession Number is ML20329A292.

<https://psr-wisconsin.org/point-beach-eis>

Point Beach Nuclear Reactors - Environmental Impact Statement (EIS)

You can submit comments by March 3, 2021 at 10:59pm CT. You can submit online here or mail to Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff.

Download a PDF of tips for writing comments here >>

View our topic ideas and starter points for Point Beach EIS scoping comments here >>

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What is an EIS?

The environmental impact statement (EIS) is a government document that outlines the impact of a proposed project on its surrounding environment. In the United States, these statements are mandated by federal law for certain projects. Environmental impact statements are meant to inform the work and decisions of policymakers and community leaders. (source)

What is the connection with an EIS and the Point Beach license renewal application?

In accordance with 10 CFR 51.95(c), the Nuclear Regulatory Commission (NRC) must prepare an environmental impact statement with the renewal of an operation.

What is the purpose of public scoping in the EIS process?

The goal of scoping is to identify specific elements of the environment that might be affected if the renewal of the reactor licenses is carried out. The scoping process is a critical time to identify issues, determine points of contact, determine project schedules and provide recommendations to the agency. The overall goal is to define the scope of issues to be addressed in depth in the analyses that will be included in the EIS.

How do I get involved with the EIS process?

You can attend and speak at the public scoping meeting on February 17th from 2 - 4 pm Eastern Standard Time (EST), 1- 3 pm Central Standard Time (CST). Click here for more information and the link to join the meeting.

You can also submit comments by March 3, 2021 at 10:59pm CT. You can submit online here or mail to Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff.

What should I focus on during the public scoping meeting on February 17th from 2-4pm ET / 1-3pm CT and in the public scoping comments due March 3rd?

Download a PDF of tips for writing comments here >>

View our topic ideas and starter points for Point Beach EIS scoping comments here >>

Who writes and creates the EIS?

An EIS might have one or more authors. Federal agencies (this would include the Nuclear Regulatory Commission) typically outsource the writing of an EIS to third party contractors (including lawyers, scientists, engineers) with expertise in their preparation and in relation to the proposed project. As a result, the EIS varies in appearance, as well as length and number of supplemental attachments. (source)

Will there be another chance to get involved with this process?

Yes! Following the scoping process, the EIS will be drafted and then the draft will be released to the public. After the release, there will be a meeting and comment period in regards to the draft EIS during a 45-day period. The NRC predicts this will be in fall 2021, but be prepared for it to be delayed.

What is included in an EIS?

According to the American Bar Association, a typical federal EIS includes the following four sections:

• Section 1—Introduces the Proposed Action and its Purpose and Need

• Section 2—Describes the Affected Environment, provides a baseline for understanding the current environmental situation in relation to the Proposed Action.

• Section 3—Presents a Range of Alternatives to the Proposed Action—this is considered the “heart” of the EIS. There is always a No Action Alternative presented. Understanding how the environment would respond if no action were taken helps to evaluate the Proposed Action and Alternatives.

• Section 4—Analyzes the environmental impact of each of the Proposed Actions and Range of Alternatives. The analysis include:

  • Impacts to threatened or endangered species

  • Air and water quality impacts

  • Impacts to historical and cultural sites, particularly sites of significance for indigenous peoples

  • Social and economical impacts to local communities, including housing stock, businesses, property values, and considerations of aesthetics and noise expected

  • Cost and schedule analysis for all of the actions and alternatives presented

The EIS may include additional topics not required for every project, including financial plans, environmental mitigation plans, and plans for complying with any additional required federal, state, or local permits.

What is the proposed action with the Point Beach Nuclear Reactors?

The proposed action is the subsequent license renewal of the operating licenses for Point Beach Nuclear Plant, Unit Nos. 1 and 2.

What does no action alternative mean?

The National Environmental Policy Act (NEPA) requires agencies to always describe and analyze a “no action” alternative in an EIS. In simple terms, a no action alternative for an existing or ongoing federal project considers what would happen if the federal agency continued to operate and maintain the authorized project with no changes.

Agencies are obligated to evaluate a reasonable range of alternatives in enough detail so that a reader can compare and contrast the environmental effects of the various alternatives to the proposed action. The no action alternative analysis provides a benchmark to allow decision makers and the public to compare the levels of environmental effects of the alternatives. (source)