Coalition comments opposing subsequent license extension at Point Beach, out to 80 years of operations

NRC file photo of Point Beach Nuclear Power Plant, Units 1 and 2, located on Wisconsin's Lake Michigan shorelineDear Friends and Colleagues,

Organizations and individuals are welcome to sign onto coalition comments to NRC, on its DSGEIS, Draft Supplemental Generic Environmental Impact Statement. Comments are due by Jan. 3, 2022, at 11:59pm Eastern Time.

See the coalition's five comments here.

To sign on an organization, please email kevin@beyondnuclear.org the following information:

Organization name, person's name, person's title if any, city, state.

To sign on as an individual, just send your name, city and state.

Sign on deadline is 5pm ET, Monday, Jan. 3, 2022.

Additional Background:

The first four comments are based on contentions submitted by Toledo, OH attorney Terry Lodge, on behalf of Physicians for Social Responsibility Wisonson, in the NRC Atomic Safety and Licensing Board licensing proceeding, on March 23, 2021. The contentions were based on expert witness reports provided by Arnie Gundersen, chief engineer at Fairewinds, Dr. Al Compaan of U. of Toledo, and Dr. Mark Cooper of Vermont Law School. See links to the contentions and expert witness reports (which will be attached to the coalition comments when they are submitted) here.

The first four comments are:

(1.) The NRC DEIS compounds NextEra’s Environmental Report error, in failing to consider a reasonable range of alternatives to the proposed action because of a failure to analyze thermal pollution mitigation as a means of reducing aquatic biota and migratory and year-round resident bird impingement, entrainment, and damage from thermal pollution, as required by NEPA and the NRC

(2.) Point Beach’s continued operation violates 10 CFR Part 50, Appendix A, Criterion 14 because the reactor coolant pressure boundary has not been tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture, and the aging management plan does not provide the requisite reasonable assurance.

(3.) The Point Beach Nuclear Plant Environmental Report, as well as the NRC DEIS, utterly fail to adequately evaluate the full potential for renewable energy sources, such as solar electric power (photovoltaics) to offset the loss of energy production from PBNP, and to make the requested license renewal action from 2030 to 2053 unnecessary.

(4.) Point Beach Nuclear Plant has an elevated risk of a turbine missile accident owing to the poor alignment of its major buildings and structures.

The fifth comment is based on "error of law" commentary provided by Beyond Nuclear Reactor Oversight Project Director Paul Gunter on Dec. 29, 2021 in this proceeding. See Gunter's comment, and additional information, linked and posted here.

The fifth comment is: Re: Misuse by Misinterpretation and Misrepresentation of 10 CFR 51.53(c)(3).

Thank you for considering signing on. Please spread the word.

Sincerely,

Kevin Kamps, Beyond Nuclear and Don't Waste Michigan