NUREG-1437 

 Supplement 27 

 

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants 

Supplement 27

Regarding 

Palisades Nuclear Plant 

Final Report 

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001
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 NUREG-1437

 Supplement 27 

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 27

Regarding 

Palisades Nuclear Plant

Final Report

Manuscript Completed: October 2006

Date Published: October 2006 

Division of License Renewal 

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

(a) Environmental effects are not detectable or are so minor that they will neither destabilize nor

noticeably alter any important attribute of the resource.

October 2006 iii NUREG-1437, Supplement 27

Abstract

The U.S. Nuclear Regulatory Commission (NRC) considered the environmental impacts of

renewing nuclear power plant operating licenses (OLs) for a 20-year period in its Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2, and codified the results in Part 51 of Title 10 of the Code of Federal

Regulations (10 CFR Part 51). In the GEIS (and its Addendum 1), the NRC staff identifies

92 environmental issues and reaches generic conclusions related to environmental impacts for

69 of these issues that apply to all plants or to plants with specific design or site characteristics. 

Additional plant-specific review is required for the remaining 23 issues. These plant-specific

reviews are to be included in a supplement to the GEIS.

This Supplemental Environmental Impact Statement (SEIS) has been prepared in response to |

an application submitted to the NRC by the Nuclear Management Company, LLC (NMC), to |

renew the OL for Palisades Nuclear Plant (Palisades) for an additional 20 years under 10 CFR

Part 54. This SEIS includes the NRC staff’s analysis that considers and weighs the |

environmental impacts of the proposed action, the environmental impacts of alternatives to the

proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It

also includes the NRC staff’s recommendation regarding the proposed action. |

Regarding the 69 issues for which the GEIS reached generic conclusions, neither NMC nor the

NRC staff has identified information that is both new and significant for any issue that applies to

Palisades. In addition, the NRC staff determined that information provided during the scoping

process did not call into question the conclusions in the GEIS. Therefore, the NRC staff

concludes that the impacts of renewing the Palisades OL would not be greater than the impacts

identified for these issues in the GEIS. For each of these issues, the NRC staff’s conclusion in

the GEIS is that the impact is of SMALL(a) significance (except for collective offsite radiological

impacts from the fuel cycle and high-level waste and spent fuel, which were not assigned a

single significance level). 

Regarding the remaining 23 issues, those that apply to Palisades are addressed in this SEIS. |

For each applicable issue, the NRC staff concludes that the significance of the potential

environmental impacts of renewal of the OL would be SMALL. The NRC staff determined that |

information provided during the public comment period did not identify any new issue with a |

significant environmental impact.

The NRC staff’s recommendation is that the Commission determine that the adverse |

environmental impacts of license renewal for Palisades are not so great that preserving the

option of license renewal for energy-planning decision makers would be unreasonable. This
Abstract

NUREG-1437, Supplement 27 iv October 2006

recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental

Report submitted by NMC; (3) consultation with Federal, State, and local agencies; (4) the NRC

| staff’s own independent review; and (5) the NRC staff’s consideration of public comments. 
October 2006 v NUREG-1437, Supplement 27

Contents

Abstract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv

Abbreviations/Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xxi

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.1 Report Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

1.2.1 Generic Environmental Impact Statement . . . . . . . . . . . . . . . . . . . . . . . 1-3

1.2.2 License Renewal Evaluation Process . . . . . . . . . . . . . . . . . . . . . . . . . . 1-5

1.3 The Proposed Federal Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7

1.4 The Purpose and Need for the Proposed Action . . . . . . . . . . . . . . . . . . . . . . . . 1-8

1.5 Compliance and Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9

1.6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-9

2.0 Description of Nuclear Power Plant and Site and Plant Interaction 

with the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1 Plant and Site Description and Proposed Plant Operation During the 

Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1.1 External Appearance and Setting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

2.1.2 Reactor Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2.1.3 Cooling and Auxiliary Water Systems . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

2.1.4 Radioactive Waste Management Systems and Effluent 

Control Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls . . . . . 2-10

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls . . . 2-12

2.1.4.3 Solid Waste Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13

2.1.5 Nonradioactive Waste Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14

2.1.6 Plant Operation and Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15

2.1.7 Power Transmission System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15
Contents

NUREG-1437, Supplement 27 vi October 2006

2.2 Plant Interaction with the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18

2.2.1 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-18

2.2.2 Water Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-19

2.2.3 Water Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-21

2.2.4 Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-24

| 2.2.5 Aquatic Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-26

2.2.6 Terrestrial Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-32

2.2.7 Radiological Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-48

2.2.8 Socioeconomic Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-49

2.2.8.1 Housing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-49

2.2.8.2 Public Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-51

2.2.8.3 Offsite Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-53

2.2.8.4 Visual Aesthetics and Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-54

2.2.8.5 Demography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-55

2.2.8.6 Economy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-56

2.2.9 Historic and Archaeological Resources . . . . . . . . . . . . . . . . . . . . . . . . . 2-59

2.2.9.1 Cultural Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-59

2.2.9.2 Historic and Archaeological Resources

at the Palisades Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-61

2.2.10 Related Federal Project Activities and Consultations . . . . . . . . . . . . . . . 2-62

2.3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-63

3.0 Environmental Impacts of Refurbishment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4

4.0 Environmental Impacts of Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.1 Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

4.2 Transmission Lines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12

4.2.1 Electromagnetic Fields – Acute Effects . . . . . . . . . . . . . . . . . . . . . . . . . 4-16

4.2.2 Electromagnetic Fields – Chronic Effects . . . . . . . . . . . . . . . . . . . . . . . . 4-17

4.3 Radiological Impacts of Normal Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18
Contents

October 2006 vii NUREG-1437, Supplement 27

4.4 Socioeconomic Impacts of Plant Operations During the License 

Renewal Period . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19

4.4.1 Housing Impacts During Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21

4.4.2 Public Services: Public Utility Impacts During Operations . . . . . . . . . . . 4-22

4.4.3 Offsite Land Use During Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-23

4.4.4 Public Services: Transportation Impacts During Operations . . . . . . . . . 4-25

4.4.5 Historic and Archaeological Resources . . . . . . . . . . . . . . . . . . . . . . . . . 4-25

4.4.6 Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-27

4.5 Groundwater Use and Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31

4.6 Threatened or Endangered Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-32

4.6.1 Aquatic Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-32

4.6.2 Terrestrial Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33

4.7 Evaluation of New and Potentially Significant Information on Impacts of 

Operations During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-35

4.8 Cumulative Impacts of Operations During the Renewal Term . . . . . . . . . . . . . . 4-35

4.8.1 Cumulative Impacts Resulting from Operation of the Plant 

Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-35

4.8.2 Cumulative Impacts Resulting from Continued Operation 

of the Transmission Lines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-37

4.8.3 Cumulative Radiological Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-38

4.8.4 Cumulative Socioeconomic Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-39

4.8.5 Cumulative Impacts on Groundwater Use and Quality . . . . . . . . . . . . . . 4-40

4.8.6 Conclusions Regarding Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . 4-41

4.9 Summary of Impacts of Operations During the Renewal Term . . . . . . . . . . . . . 4-42

4.10 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-42

5.0 Environmental Impacts of Postulated Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1 Postulated Plant Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1.1 Design-Basis Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.1.2 Severe Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5.2 Severe Accident Mitigation Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
Contents

NUREG-1437, Supplement 27 viii October 2006

5.2.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

5.2.2 Estimate of Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

5.2.3 Potential Plant Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-6

5.2.4 Evaluation of Risk Reduction and Costs of Improvements . . . . . . . . . . . 5-8

5.2.5 Cost-Benefit Comparison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-9

5.2.6 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-10

5.3 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11

6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste 

Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

6.1 The Uranium Fuel Cycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

6.2 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-9

7.0 Environmental Impacts of Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

7.1 Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

7.2 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-4

8.0 Environmental Impacts of Alternatives to License Renewal . . . . . . . . . . . . . . . . . . . . 8-1

8.1 No-Action Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1

8.2 Alternative Energy Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-6

8.2.1 Coal-Fired Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-8

8.2.1.1 Closed-Cycle Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . 8-9

8.2.1.2 Once-Through Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . 8-19

| 8.2.2 Natural-Gas-Fired Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-20

8.2.2.1 Closed-Cycle Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . 8-21

8.2.2.2 Once-Through Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . 8-31

8.2.3 Nuclear Power Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-32

8.2.3.1 Closed-Cycle Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . . 8-33

8.2.3.2 Once-Through Cooling System . . . . . . . . . . . . . . . . . . . . . . . . . 8-41

8.2.4 Purchased Electrical Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-42
Contents

October 2006 ix NUREG-1437, Supplement 27

8.2.5 Other Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-43

8.2.5.1 Oil-Fired Generation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-43

8.2.5.2 Wind Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-44

8.2.5.3 Solar Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-45

8.2.5.4 Hydropower . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-46

8.2.5.5 Geothermal Energy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-46

8.2.5.6 Wood Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-46

8.2.5.7 Municipal Solid Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-47

8.2.5.8 Other Biomass-Derived Fuels . . . . . . . . . . . . . . . . . . . . . . . . . 8-48

8.2.5.9 Fuel Cells . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-48 |

8.2.5.10 Delayed Retirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-49

8.2.5.11 Utility-Sponsored Conservation . . . . . . . . . . . . . . . . . . . . . . . . 8-49

8.2.6 Combination of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-50

8.3 Summary of Alternatives Considered . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-54

8.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-54

9.0 Summary and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1

9.1 Environmental Impacts of the Proposed Action – License Renewal . . . . . . . . . 9-4

9.1.1 Unavoidable Adverse Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-5

9.1.2 Irreversible or Irretrievable Resource Commitments . . . . . . . . . . . . . . . 9-6

9.1.3 Short-Term Use Versus Long-Term Productivity . . . . . . . . . . . . . . . . . . 9-6

9.2 Relative Significance of the Environmental Impacts of License Renewal 

and Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-6

9.3 NRC Staff Conclusions and Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . 9-7

9.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-9

Appendix A - Comments Received on the Environmental Review . . . . . . . . . . . . . . . . . . A-1

Appendix B - Contributors to the Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

Appendix C - Chronology of NRC Staff Environmental Review Correspondence

Related to the Nuclear Management Company, LCC, Application for

License Renewal of Palisades Nuclear Plant . . . . . . . . . . . . . . . . . . . . . . . . C-1
Contents

NUREG-1437, Supplement 27 x October 2006

Appendix D - Organizations Contacted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

Appendix E - Nuclear Management Company, LLC’s, Compliance Status and

Consultation Correspondence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

Appendix F - GEIS Environmental Issues Not Applicable to Palisades

Nuclear Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . F-1

Appendix G - NRC Staff Evaluation of Severe Accident Mitigation Alternatives (SAMAs) 

| for Palisades Nuclear Plant in Support of License Renewal 

Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-1
October 2006 xi NUREG-1437, Supplement 27

Figures

2-1 Location of Palisades, 50-mi Region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

2-2 Location of Palisades, 6-mi Region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3

2-3 Palisades Site Layout . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7

2-4 Transmission Lines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-16

4-1 Geographic Distribution of Minority Populations Within 50 mi of

Palisades Based on Census Block Group Data . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-29

4-2 Geographic Distribution of Low-Income Populations Within 50 mi of

Palisades Based on Census Block Group Data . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-30
NUREG-1437, Supplement 27 xii October 2006

Tables

2-1 State-Listed Aquatic Species Potentially Occurring in the Vicinity 

of Palisades and Associated Transmission Lines . . . . . . . . . . . . . . . . . . . . . . . . . 2-33

2-2 Federally Listed and State-Listed Terrestrial Species Potentially Occurring 

on or in the Vicinity of Palisades and Associated Transmission Lines . . . . . . . . . 2-37

| 2-3 Permanent Employee Residence Information for Palisades by County and City . 2-50

2-4 Housing Units and Housing Units Vacant (Available) by County During 

1990 and 2000 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-51

2-5 Major Public Water Supply Systems in Van Buren and Berrien Counties, 

2004 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-52

2-6 Land Use in Van Buren County, 2005 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-53

2-7 Population Growth in Van Buren and Berrien Counties, 1970 to 2020 . . . . . . . . . 2-55

| 2-8 Major Employment Facilities Within 10 mi of Palisades . . . . . . . . . . . . . . . . . . . . . 2-57

2-9 Contribution of Palisades to County Property Tax Revenues . . . . . . . . . . . . . . . . 2-58

3-1 Category 1 Issues for Refurbishment Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2

3-2 Category 2 Issues for Refurbishment Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3

4-1 Category 1 Issues Applicable to the Operation of the Palisades

Cooling System During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3

4-2 Category 1 Issues Applicable to the Palisades Transmission Lines During 

the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-13

4-3 Category 2 and Uncategorized Issues Applicable to the Palisades 

Transmission Lines During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16

4-4 Category 1 Issues Applicable to Radiological Impacts of Normal 

Operations During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-18

4-5 Category 1 Issues Applicable to Socioeconomics During the Renewal Term . . . . 4-19

4-6 Environmental Justice and GEIS Category 2 Issues Applicable to

Socioeconomics During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21

4-7 Category 1 Issue Applicable to Groundwater Use and Quality During the

Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-31

4-8 Category 2 Issue Applicable to Threatened or Endangered Species 

During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-32

5-1 Category 1 Issue Applicable to Postulated Accidents During the 

Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5-2 Category 2 Issue Applicable to Postulated Accidents During the 

Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4

| 5-3 Palisades Core Damage Frequency for Internal Events . . . . . . . . . . . . . . . . . . . . 5-7

| 5-4 Breakdown of Population Dose by Containment Release Mode . . . . . . . . . . . . . . 5-7
Tables

October 2006 xiii NUREG-1437, Supplement 27

6-1 Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste

Management During the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-2

7-1 Category 1 Issues Applicable to the Decommissioning of Palisades

Following the Renewal Term . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-2

8-1 Summary of Environmental Impacts of the No-Action Alternative . . . . . . . . . . . . . 8-3

8-2 Summary of Environmental Impacts of Coal-Fired Generation Using 

Closed-Cycle Cooling at an Alternate Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-10

8-3 Summary of Environmental Impacts of Coal-Fired Generation Using 

Once-Through Cooling at an Alternate Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-20

8-4 Summary of Environmental Impacts of Natural-Gas-Fired Generation 

Using Closed-Cycle Cooling at the Palisades Site and at an Alternate Site . . . . . 8-22

8-5 Summary of Environmental Impacts of Natural-Gas-Fired Generation 

Using Once-Through Cooling at an Alternate Site . . . . . . . . . . . . . . . . . . . . . . . . . 8-32

8-6 Summary of Environmental Impacts of New Nuclear Power Generation 

Using Closed-Cycle Cooling at the Palisades Site and at an Alternate Site . . . . . 8-34

8-7 Summary of Environmental Impacts of a New Nuclear Power Plant |

Using Once-Through Cooling at an Alternate Site . . . . . . . . . . . . . . . . . . . . . . . . . 8-42

8-8 Summary of Environmental Impacts of Combination of Alternatives at the 

Palisades Site and at an Alternate Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-51

9-1 Summary of Environmental Significance of License Renewal, the No-Action

Alternative, and Alternative Methods of Generation Using Closed-Cycle 

Cooling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-8

A-1 Individuals Providing Comments During Scoping Comment Period . . . . . . . . . . . A-3

A-2 Comments Received on the Draft SEIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-44 |

E-1 Consultation Correspondence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

E-2 Federal, State, Local, and Regional Licenses, Permits, Consultations, and

Other Approvals for the Palisades Nuclear Plant . . . . . . . . . . . . . . . . . . . . . . . . . . E-2

F-1 GEIS Environmental Issues Not Applicable to Palisades . . . . . . . . . . . . . . . . . . . F-1

G-1 Palisades Core Damage Frequency for Internal Events . . . . . . . . . . . . . . . . . . . . G-3

G-2 Breakdown of Population Dose by Containment Release Mode . . . . . . . . . . . . . . G-4

G-3 Palisades PSA Historical Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G-6

G-4 SAMA Cost-Benefit Screening Analysis for Palisades . . . . . . . . . . . . . . . . . . . . . . G-20
NUREG-1437, Supplement 27 xiv October 2006
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 xv NUREG-1437, Supplement 27

Executive Summary

By letter dated March 22, 2005, Nuclear Management Company, LLC (NMC), submitted an |

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating

license (OL) for Palisades Nuclear Plant (Palisades) for an additional 20-year period. If the OL

is renewed, State regulatory agencies and NMC will ultimately decide whether the plant will

continue to operate based on factors such as the need for power or other matters within the

State’s jurisdiction or the purview of the owners. If the OL is not renewed, then the plant must

be shut down at or before the expiration date of the current OL, which is March 24, 2011.

The NRC has implemented Section 102 of the National Environmental Policy Act (NEPA),

Title 42, Section 4321 of the United States Code (42 USC 4321) in Part 51 of Title 10 of the |

Code of Federal Regulations (10 CFR Part 51). In 10 CFR 51.20(b)(2), the Commission

requires preparation of an Environmental Impact Statement (EIS) or a supplement to an EIS for

renewal of a reactor OL. In addition, 10 CFR 51.95(c) states that the EIS prepared at the OL

renewal stage will be a supplement to the Generic Environmental Impact Statement for License

Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2.(a)

Upon acceptance of the NMC application, the NRC staff began the environmental review

process described in 10 CFR Part 51 by publishing a Notice of Intent to prepare an EIS and

conduct scoping. The NRC staff visited the Palisades site in July 2005 and held two public |

scoping meetings on July 28, 2005, in South Haven, Michigan. During the preparation of this |

Supplemental Environmental Impact Statement (SEIS) for Palisades, the NRC staff reviewed |

the NMC Environmental Report (ER) and compared it with the GEIS, consulted with other

agencies, conducted an independent review of the issues following the guidance set forth in

NUREG-1555, Supplement 1, Standard Review Plans for Environmental Reviews for Nuclear

Power Plants, Supplement 1: Operating License Renewal, and considered the public

comments received during the scoping process. The public comments received during the

scoping process that were considered to be within the scope of the environmental review are

provided in Appendix A, Part I, of this SEIS. |

The draft SEIS was published in February 2006. The NRC staff held two public meetings at |

Lake Michigan College, South Haven, Michigan, on April 5, 2006, to describe the preliminary |

results of the NRC environmental review, to answer questions, and to provide members of the

public with information to assist them in formulating comments on this SEIS. When the 75-day |

comment period ended, the NRC staff considered and dispositioned all of the comments |

received. These comments are addressed in Appendix A, Part II, of this SEIS. |

This SEIS includes the NRC staff’s analysis that considers and weighs the environmental |

effects of the proposed action, the environmental impacts of alternatives to the proposed action,
Executive Summary

NUREG-1437, Supplement 27 xvi October 2006

and mitigation measures for reducing or avoiding adverse effects. It also includes the NRC

| staff’s recommendation regarding the proposed action.

The Commission has adopted the following statement of purpose and need for license renewal

from the GEIS:

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of a current

nuclear power plant operating license to meet future system generating needs, as such

needs may be determined by State, utility, and, where authorized, Federal (other than NRC)

decision makers.

The evaluation criterion for the NRC staff’s environmental review, as defined in 10 CFR

51.950(c)(4) and the GEIS, is to determine

... whether or not the adverse environmental impacts of license renewal are so great that

preserving the option of license renewal for energy planning decision makers would be

unreasonable.

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that

there are factors, in addition to license renewal, that will ultimately determine whether an

existing nuclear power plant continues to operate beyond the period of the current OL.

NRC regulations [10 CFR 51.95(c)(2)] contain the following statement regarding the content of

SEISs prepared at the license renewal stage:

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of the

proposed action or of alternatives to the proposed action except insofar as such benefits

and costs are either essential for a determination regarding the inclusion of an alternative in

the range of alternatives considered or relevant to mitigation. In addition, the supplemental

environmental impact statement prepared at the license renewal stage need not discuss

other issues not related to the environmental effects of the proposed action and the

alternatives, or any aspect of the storage of spent fuel for the facility within the scope of the

generic determination in § 51.23(a) [“Temporary storage of spent fuel after cessation of

reactor operation–generic determination of no significant environmental impact”] and in

accordance with § 51.23(b).

The GEIS contains the results of a systematic evaluation of the consequences of renewing an

OL and operating a nuclear power plant for an additional 20 years. It evaluates

92 environmental issues using the NRC’s three-level standard of significance – SMALL,
Executive Summary

October 2006 xvii NUREG-1437, Supplement 27

MODERATE, or LARGE – developed using the Council on Environmental Quality guidelines. 

The following definitions of the three significance levels are set forth in footnotes to Table B-1 of

10 CFR Part 51, Subpart A, Appendix B:

SMALL – Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize,

important attributes of the resource.

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

For 69 of the 92 issues considered in the GEIS, the analysis in the GEIS reached the following

conclusions:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are not likely to be sufficiently beneficial to warrant implementation.

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and

significant information, the NRC staff relied on conclusions as amplified by supporting

information in the GEIS for issues designated as Category 1 in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B.

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues,

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis and must be addressed in a plantspecific supplement to the GEIS. Information on the chronic effects of electromagnetic fields

was not conclusive at the time the GEIS was prepared.
Executive Summary

NUREG-1437, Supplement 27 xviii October 2006

| This SEIS documents the NRC staff’s consideration of all 92 environmental issues identified in

the GEIS. The NRC staff considered the environmental impacts associated with alternatives to

license renewal and compared the environmental impacts of license renewal and the

alternatives. The alternatives to license renewal that were considered include the no-action

alternative (not renewing the OL for Palisades) and alternative methods of power generation. 

Based on projections made by the U.S. Department of Energy’s Energy Information

Administration, gas- and coal-fired generation appear to be the most likely power-generation

alternatives if the power from the plant is replaced. These alternatives are evaluated assuming

that the replacement power generation plant is located at either the Palisades site or some

other unspecified alternate location.

NMC and the NRC staff have established independent processes for identifying and evaluating

the significance of any new information on the environmental impacts of license renewal. 

Neither NMC nor the NRC staff has identified information that is both new and significant related

to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, the

| NRC staff did not identify, during the scoping process or during its review, any new issue

applicable to Palisades that had a significant environmental impact. Therefore, the NRC staff

relies upon the conclusions of the GEIS for all of the Category 1 issues that are applicable to

Palisades.

NMC’s license renewal application presents an analysis of the Category 2 issues. The NRC

staff has reviewed the NMC analysis for each issue and has conducted an independent review

of each issue plus environmental justice and chronic effects from electromagnetic fields. Nine

Category 2 issues are not applicable because they are related to plant design features or site

| characteristics not found at Palisades. Four Category 2 issues are not discussed in this SEIS

because they are specifically related to refurbishment. NMC has stated that its evaluation of

structures and components, as required by 10 CFR 54.21, did not identify any major plant

refurbishment activities or modifications as necessary to support the continued operation of

Palisades for the license renewal period. In addition, any replacement of components or

additional inspection activities are within the bounds of normal plant operation and are not

expected to affect the environment outside of the bounds of the plant operations evaluated in

the U.S. Atomic Energy Commission’s 1972 Final Environmental Statement Related to the

Operation of Palisades Nuclear Generating Plant, Consumers Power Company.

Eight Category 2 issues related to operational impacts and postulated accidents during the

renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are

| discussed in detail in this SEIS. Four of the Category 2 issues and environmental justice apply

to both refurbishment and to operation during the renewal term and are only discussed in this

| SEIS in relation to operation during the renewal term. For all eight of the Category 2 issues and

environmental justice, the NRC staff concludes that the potential environmental effects would be

of SMALL significance in the context of the standards set forth in the GEIS. In addition, the
Executive Summary

October 2006 xix NUREG-1437, Supplement 27

NRC staff determined that appropriate Federal health agencies have not reached a consensus

on the existence of chronic adverse effects from electromagnetic fields. Therefore, no further

evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the

NRC staff concurs with NMC’s identification of areas in which risk can be further reduced in a

cost-beneficial manner through the implementation of all or a subset of the identified, potentially

cost-beneficial SAMA. Given the potential for cost-beneficial risk reduction, the NRC staff

agrees that further evaluation of these SAMAs by NMC is warranted. However, none of the

potentially cost-beneficial SAMAs directly relate to adequately managing the effects of aging

during the period of extended operation. Therefore, they need not be implemented as part of

the license renewal pursuant to 10 CFR Part 54.

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of any other action undertaken by agencies or persons. For purposes of

this analysis, the overall conclusion of the NRC staff is that these impacts would not result in

significant cumulative impacts on potentially affected resources.

If the Palisades OL is not renewed and the plant ceases operation on or before the expiration of

its current OL, then the adverse impacts of likely alternatives will not be smaller than those

associated with continued operation of Palisades. The impacts may, in fact, be greater in some

areas.

The recommendation of the NRC staff is that the Commission determine that the adverse |

environmental impacts of license renewal for Palisades are not so great that preserving the

option of license renewal for energy-planning decision makers would be unreasonable. This |

recommendation is based on (1) the analysis and findings in the GEIS; (2) the ER submitted by

NMC; (3) consultation with other Federal, State, and local agencies; (4) the NRC staff’s own

independent review; and (5) the NRC staff’s consideration of public comments. |
NUREG-1437, Supplement 27 xx October 2006
October 2006 xxi NUREG-1437, Supplement 27

Abbreviations/Acronyms

° degree

:Ci microcurie(s)

:g microgram(s)

ac acre(s)

AC alternating current |

ACC averted cleanup and decontamination costs |

ACHP Advisory Council on Historic Preservation |

ADAMS Agencywide Documents Access and Management System

AEC U.S. Atomic Energy Commission

AEP American Electric Power

AFW auxiliary feedwater |

ALARA as low as reasonably achievable |

AOC averted offsite property damage costs |

AOE averted occupational exposure |

AOSC averted onsite costs |

APE area of potential effect |

APE averted public exposure |

AQCR Air Quality Control Region

BEIR Biological Effects of Ionizing Radiation |

Btu British thermal unit(s)

CDF core damage frequency |

CEOG Combustion Engineering Owners Group |

CEQ Council on Environmental Quality

CET containment event tree |

CFR Code of Federal Regulations

Ci curie(s)

cm3 cubic centimeter(s)

CO carbon monoxide

COE cost of enhancement |

CWS Circulating Water System

CZMA Coastal Zone Management Act

DAW dry active waste

DBA design-basis accident

DC direct current |

DDDIP direct drive diesel-driven injection pump |

DFO Department of Fisheries and Oceans Canada
Abbreviations/Acronyms

NUREG-1437, Supplement 27 xxii October 2006

| DFS dry fuel storage

DMR Discharge Monitoring Report

DOC U.S. Department of Commerce

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

DOL U.S. Department of Labor

DOT U.S. Department of Transportation

DSM Demand Side Management

EDG emergency diesel generator

EIA Energy Information Administration

EIS Environmental Impact Statement

ELF-EMF extremely low frequency-electromagnetic field

EPA U.S. Environmental Protection Agency

EPRI Electric Power Research Institute

ER Environmental Report

F Fahrenheit

FAA Federal Aviation Administration

FES Final Environmental Statement

FSAR Final Safety Analysis Report

ft foot (feet)

ft3 cubic foot (feet)

FWS U.S. Fish and Wildlife Service

gal gallon(s)

GEIS Generic Environmental Impact Statement for License Renewal of Nuclear Plants,

NUREG-1437

| GL Generic Letter

GLSC Great Lakes Science Center

GLSGN Great Lakes Sea Grant Network

gpd gallon(s) per day

gpm gallon(s) per minute

| GWd gigawatt day(s)

HEPA high-efficiency particulate air

HLW high-level waste

| HPI high-pressure injection

hr hour(s)

| HPSI high-pressure safety injection

| HVAC heating, ventilation, and air-conditioning
Abbreviations/Acronyms

October 2006 xxiii NUREG-1437, Supplement 27

Hz hertz

I-196 Interstate-196

IAEA International Atomic Energy Agency |

ICRP International Commission on Radiological Protection |

IDNR Indiana Department of Natural Resources

IEEE Institute of Electrical and Electronic Engineers

in. inch(es)

INEEL Idaho National Engineering and Environmental Laboratory

IPE Individual Plant Examination |

IPEEE Individual Plant Examination of External Events |

ISFSI independent spent fuel storage installation |

kV kilovolt(s)

kWe kilowatt(s) electrical

kWh kilowatt hour(s)

L liter(s)

lb pound(s)

LOCA loss of coolant accident |

LOOP loss of offsite power |

m meter(s)

m2 square meter(s)

mA milliampere(s)

MAAP Modular Accident Analysis Program |

MACCS2 Melcor Accident Consequence Code System 2 |

MDCH Michigan Department of Community Health

MDEQ Michigan Department of Environmental Quality

MDNR Michigan Department of Natural Resources

MEDC Michigan Economic Development Corporation

MEI maximally exposed individual

METC Michigan Electric Transmission Company, LLC

mg milligram(s)

MGy milliGray(s)

mi mile(s)

mi2 square mile(s)

mi3 cubic mile(s)

min minute(s)

MMACR modified maximum averted cost risk |

MNFI Michigan Natural Features Inventory
Abbreviations/Acronyms

NUREG-1437, Supplement 27 xxiv October 2006

mph mile(s) per hour

MRCC Midwestern Regional Climate Center

mrem millirem(s)

| MSIV main steam insolation valve

MSL mean sea level

| MTU metric ton(s)-uranium

MW megawatt(s)

MW(e) megawatt(s) electric

MW(t) megawatt(s) thermal

MWh megawatt hour(s)

| NAS National Academy of Sciences

NCES National Center for Educational Statistics

| NCI National Cancer Institute

| NCRP National Council on Radiation Protection and Measurements

NEPA National Environmental Policy Act

NREL National Renewable Energy Laboratory

NESC National Electric Safety Code

ng/J nanogram(s) per Joule

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMC Nuclear Management Company, LLC

NOAA National Oceanic and Atmospheric Administration

NOx nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NPS National Park Service

NRC U.S. Nuclear Regulatory Commission

ODCM Offsite Dose Calculation Manual

OL operating license

PCB polychlorinated biphenyl

PCS Primary Coolant System

PG&E PG&E Corporation

PM10 particulate matter with an aerodynamic diameter of 10 :m or less

PNL Pacific Northwest National Laboratory

| PSA Probabilistic Safety Assessment

PSD prevention of significant deterioration

psi pounds per square inch

| RAI request for additional information
Abbreviations/Acronyms

October 2006 xxv NUREG-1437, Supplement 27

RCP reactor coolant pump |

REMP radiological environmental monitoring program

ROI region of interest |

RPC replacement power cost |

RRW risk reduction worth |

s second(s)

SAMA severe accident mitigation alternative

SAR Safety Analysis Report

SBO station blackout |

SCR selective catalytic reduction

SECA Solid State Energy Conservation Alliance

SEIS Supplemental Environmental Impact Statement

SER Safety Evaluation Report

SGTR steam generator tube rupture |

SHPO State Historic Preservation Office(r) |

SIRWT safety injection and refueling water tank |

SO2 sulfur dioxide

SOx sulfur oxide(s)

spp. species |

STS STS Consultants, Inc.

SWPPP Storm Water Pollution Prevention Plan

SWS Service Water System

TEDE total effective dose equivalent

TLAA time-limited aging analysis

TRO total residual oxidant

TSS total suspended solids

TWh terawatt-hour(s)

U.S. United States

USC United States Code

USDA U.S. Department of Agriculture

USI unresolved safety issue |

UWSGI University of Wisconsin Sea Grant Institute

W watt(s)

yd yard(s)

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 1-1 NUREG-1437, Supplement 27

1.0 Introduction

Under the U.S. Nuclear Regulatory Commission’s (NRC’s) environmental protection regulations

in Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51), which implement the

National Environmental Policy Act of 1969 (NEPA), renewal of a nuclear power plant operating |

license (OL) requires the preparation of an Environmental Impact Statement (EIS). In preparing

the EIS, the NRC staff is required first to issue the statement in draft form for public comment,

and then issue a final statement after considering public comments on the draft. To support the

preparation of the EIS, the NRC staff has prepared a Generic Environmental Impact Statement

for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996,

1999).(a) The GEIS is intended to (1) provide an understanding of the types and severity of

environmental impacts that may occur as a result of license renewal of nuclear power plants

under 10 CFR Part 54; (2) identify and assess the impacts that are expected to be generic to

license renewal; and (3) support 10 CFR Part 51 to define the number and scope of issues that

must be addressed by the applicants in plant-by-plant renewal proceedings. Use of the GEIS

guides the preparation of complete plant-specific information in support of the OL renewal

process.

Nuclear Management Company, LLC (NMC), operates Palisades Nuclear Plant (Palisades) in |

southwestern Michigan under OL DPR-20, which was issued by the NRC. This OL will expire in

March 2011. On March 22, 2005, NMC submitted an application to the NRC to renew the

Palisades OL for an additional 20 years under 10 CFR Part 54. NMC is a licensee for the

purposes of its current OL and an applicant for the renewal of the OL. Pursuant to

10 CFR 54.23 and 51.53(c), NMC submitted an Environmental Report (ER) (NMC 2005a) in

which NMC analyzed the environmental impacts associated with the proposed license renewal

action, considered alternatives to the proposed action, and evaluated mitigation measures for

reducing adverse environmental impacts.

This report is the plant-specific supplement to the GEIS (the supplemental EIS (SEIS)) for the |

NMC license renewal application. This SEIS is a supplement to the GEIS because it relies, in |

part, on the findings of the GEIS. The NRC staff will also prepare a separate Safety Evaluation

Report in accordance with 10 CFR Part 54.
Introduction

NUREG-1437, Supplement 27 1-2 October 2006

1.1 Report Contents

The following sections of this introduction (1) describe the background for the preparation of this

| SEIS, including the development of the GEIS and the process used by the NRC staff to assess

the environmental impacts associated with license renewal; (2) describe the proposed Federal

action to renew the Palisades OL; (3) discuss the purpose and need for the proposed action;

and (4) present the status of NMC’s compliance with environmental quality standards and

requirements that have been imposed by Federal, State, regional, and local agencies that are

responsible for environmental protection.

| The ensuing chapters of this SEIS closely parallel the contents and organization of the GEIS. 

Chapter 2 describes the site, power plant, and interactions of the plant with the environment. 

Chapters 3 and 4, respectively, discuss the potential environmental impacts of plant

refurbishment and plant operation during the renewal term. Chapter 5 contains an evaluation of

potential environmental impacts of plant accidents and includes consideration of severe

accident mitigation alternatives. Chapter 6 discusses the uranium fuel cycle and solid waste

management. Chapter 7 discusses decommissioning, and Chapter 8 discusses alternatives to

license renewal. Finally, Chapter 9 summarizes the findings of the preceding chapters and

draws conclusions about the adverse impacts that cannot be avoided; the relationship between

short-term uses of man’s environment and the maintenance and enhancement of long-term

productivity; and the irreversible or irretrievable commitment of resources. Chapter 9 also

| presents the NRC staff’s recommendation with respect to the proposed license renewal action.

Additional information is included in appendixes. Appendix A contains public comments related

to the environmental review for license renewal and NRC staff responses to those comments. 

Appendixes B through G, respectively, list the following:

 C The preparers of the supplement,

 C The chronology of NRC staff’s environmental review correspondence related to this

| SEIS,

| C The organizations contacted during the development of this SEIS,

 C NMC’s compliance status in Table E-1 (this appendix also contains copies of

consultation correspondence prepared and sent during the evaluation process),

 C GEIS environmental issues that are not applicable to Palisades, and

 C Severe accident mitigation alternatives (SAMAs).
Introduction

October 2006 1-3 NUREG-1437, Supplement 27

1.2 Background

Use of the GEIS, which examines the possible environmental impacts that could occur as a

result of renewing individual nuclear power plant OLs under 10 CFR Part 54, and the

established license renewal evaluation process support the thorough evaluation of the impacts

of renewal of OLs.

1.2.1 Generic Environmental Impact Statement

The NRC initiated a generic assessment of the environmental impacts associated with the

license renewal term to improve the efficiency of the license renewal process by documenting

the assessment results and codifying the results in the Commission’s regulations. This

assessment is provided in the GEIS, which serves as the principal reference for all nuclear

power plant license renewal EISs.

The GEIS documents the results of the systematic approach that was taken to evaluate the

environmental consequences of renewing the licenses of individual nuclear power plants and

operating them for an additional 20 years. For each potential environmental issue, the GEIS

(1) describes the activity that affects the environment, (2) identifies the population or resource

that is affected, (3) assesses the nature and magnitude of the impact on the affected population

or resource, (4) characterizes the significance of the impact for both beneficial and adverse

impacts, (5) determines whether the results of the analysis apply to all plants, and (6) considers

whether additional mitigation measures would be warranted for impacts that would have the

same significance level for all plants.

The NRC’s standard of significance for impacts was established using the Council on

Environmental Quality (CEQ) terminology for “significantly” (40 CFR 1508.27, which requires

consideration of both “context” and “intensity”). Using the CEQ terminology, the NRC

established three significance levels – SMALL, MODERATE, and LARGE. The definitions of

the three significance levels are set forth in the footnotes to Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, as follows:

SMALL – Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize,

important attributes of the resource.

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.
Introduction

NUREG-1437, Supplement 27 1-4 October 2006

The GEIS assigns a significance level to each environmental issue, assuming that ongoing

mitigation measures would continue.

The GEIS includes a determination of whether the analysis of the environmental issue could be

applied to all plants and whether additional mitigation measures would be warranted. Issues

are assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1

issues are those that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

| required in this SEIS unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria of Category 1, and,

therefore, additional plant-specific review for these issues is required.

In the GEIS, the NRC staff assessed 92 environmental issues and determined that 69 qualified

as Category 1 issues, 21 qualified as Category 2 issues, and 2 issues were not categorized. 

The two uncategorized issues are environmental justice and chronic effects of electromagnetic

fields. Environmental justice was not evaluated on a generic basis and must be addressed in a

plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic

fields was not conclusive at the time the GEIS was prepared.

Of the 92 issues, 11 are related only to refurbishment, 6 are related only to decommissioning,

67 apply only to operation during the renewal term, and 8 apply to both refurbishment and

operation during the renewal term. A summary of the findings for all 92 issues in the GEIS is

codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B.
Introduction

October 2006 1-5 NUREG-1437, Supplement 27

1.2.2 License Renewal Evaluation Process

An applicant seeking to renew its OL is required to submit an ER as part of its application. The

license renewal evaluation process involves careful review of the applicant’s ER and assurance

that all new and potentially significant information not already addressed in or available during

the GEIS evaluation is identified, reviewed, and assessed to verify the environmental impacts of

the proposed license renewal.

In accordance with 10 CFR 51.53(c)(2) and (3), the ER submitted by the applicant must

 C Provide an analysis of the Category 2 issues in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, in accordance with 10 CFR 51.53(c)(3)(ii), and

 C Discuss actions to mitigate any adverse impacts associated with the proposed action

and environmental impacts of alternatives to the proposed action.

In accordance with 10 CFR 51.53(c)(2), the ER does not need to

 C Consider the economic benefits and costs of the proposed action and alternatives to the

proposed action except insofar as such benefits and costs are either (1) essential for

making a determination regarding the inclusion of an alternative in the range of

alternatives considered, or (2) relevant to mitigation;

 C Consider the need for power and other issues not related to the environmental effects of

the proposed action and the alternatives;

 C Discuss any aspect of the storage of spent fuel within the scope of the generic

determination in 10 CFR 51.23(a) in accordance with 10 CFR 51.23(b); and

 C Contain an analysis of any Category 1 issue unless there is significant new information

on a specific issue–this is pursuant to 10 CFR 51.23(c)(3)(iii) and (iv).

New and significant information is (1) information that identifies a significant environmental

issue not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, or (2) information that was not considered in the analyses summarized in the GEIS

and that leads to an impact finding that is different from the finding presented in the GEIS and

codified in 10 CFR Part 51.

In preparing to submit its application to renew the Palisades OL, NMC developed a process to

ensure that information not addressed in or available during the GEIS evaluation regarding the

environmental impacts of license renewal for Palisades would be properly reviewed before
Introduction

NUREG-1437, Supplement 27 1-6 October 2006

submitting the ER, and to ensure that such new and potentially significant information related to

renewal of the license for Palisades would be identified, reviewed, and assessed during the

period of NRC review. NMC reviewed the Category 1 issues that appear in Table B-1 of

10 CFR Part 51, Subpart A, Appendix B, to verify that the conclusions of the GEIS remained

valid with respect to Palisades. This review was performed by personnel from NMC and its

support organization who were familiar with NEPA issues and the scientific disciplines involved

in the preparation of a license renewal ER.

The NRC staff also has a process for identifying new and significant information. That process

is described in detail in Standard Review Plans for Environmental Reviews for Nuclear Power

Plants, Supplement 1: Operating License Renewal, NUREG-1555, Supplement 1 (NRC 2000). 

The search for new information includes (1) review of an applicant’s ER and the process for

discovering and evaluating the significance of new information; (2) review of records of public

comments; (3) review of environmental quality standards and regulations; (4) coordination with

Federal, State, and local environmental protection and resource agencies; and (5) review of the

technical literature. New information discovered by the staff is evaluated for significance using

the criteria set forth in the GEIS. For Category 1 issues, where new and significant information

is identified, reconsideration of the conclusions for those issues is limited to the assessment of

the relevant new and significant information; the scope of the assessment does not include

other facets of the issue that are not affected by the new information.

Chapters 3 through 7 discuss the environmental issues considered in the GEIS that are

applicable to Palisades. At the beginning of the discussion of each set of issues, a table

identifies the issues to be addressed and lists the sections in the GEIS where the issues are

discussed. Category 1 and Category 2 issues are listed in separate tables. For Category 1

issues for which there is no new and significant information, the table is followed by a set of

short paragraphs that state the GEIS conclusion codified in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, followed by the NRC staff’s analysis and conclusion. For Category 2

issues, in addition to the list of GEIS sections where the issue is discussed, the tables list the

| subparagraph of 10 CFR 51.53(c)(3)(ii) that describes the analysis required and the SEIS

| sections where the analysis is presented. The SEIS sections that discuss the Category 2

issues are presented immediately following the table.

The NRC prepares an independent analysis of the environmental impacts of license renewal

and compares these impacts with the environmental impacts of alternatives. The evaluation of

the NMC license renewal application began with publication of a Notice of Acceptance for

docketing and opportunity for a hearing in the Federal Register (Volume 70, page 33533

(70 FR 33533)) (NRC 2005a) on June 8, 2005. On June 27, 2005, the NRC staff published a

Notice of Intent to prepare an EIS and conduct scoping (70 FR 36967) (NRC 2005b). Two

public scoping meetings were held on July 28, 2005, in South Haven, Michigan. Comments

received during the scoping period were summarized in the Environmental Impact Statement

Scoping Process: Summary Report – Palisades Nuclear Plant, Van Buren County, Michigan
Introduction

October 2006 1-7 NUREG-1437, Supplement 27

(NRC 2005c). Comments that are applicable to this environmental review are presented in |

Part I of Appendix A. |

The NRC staff followed the review guidance contained in NUREG-1555, Supplement 1

(NRC 2000). The NRC staff and contractors retained to assist the NRC visited the Palisades

site on July 26 and 27, 2005, to gather information and to become familiar with the site and its

environs. The NRC staff also reviewed the comments received during scoping and consulted

with Federal, State, regional, and local agencies. A list of the organizations consulted is

provided in Appendix D. Other documents related to Palisades were reviewed and are

referenced in this SEIS. |

This SEIS presents the NRC staff’s analysis that considers and weighs the environmental |

impacts of the proposed renewal of the OL for Palisades, the environmental impacts of

alternatives to license renewal, and mitigation measures available for avoiding adverse

environmental impacts. Chapter 9, “Summary and Conclusions,” provides the NRC staff’s

recommendation to the Commission on whether or not the adverse environmental impacts of |

license renewal are so great that preserving the option of license renewal for energy-planning

decision makers would be unreasonable.

On February 23, 2006, the NRC published a Notice of Availability of the draft SEIS |

(71 FR 9383) (NRC 2006). A 75-day comment period began on the date of publication of the |

U.S. Environmental Protection Agency Notice of Filing of the draft SEIS to allow members of the

public to comment on the preliminary results of the NRC staff’s review. During this comment

period, two public meetings, an afternoon session and an evening session, were held on April 5, |

2006 at South Haven, Michigan. During these meetings, the NRC staff described the |

preliminary results of the NRC environmental review and answered questions related to it to |

provide members of the public with information to assist them in formulating their comments. |

The comment period for the Palisades draft SEIS ended on May 18, 2006. Comments made |

during the 75-day comment period, including those made at the two public meetings, are |

presented in Part II of Appendix A of this SEIS. The NRC’s responses to those comments are |

also provided. |

1.3 The Proposed Federal Action

The proposed Federal action is renewal of the OL for Palisades. Palisades is located in Covert

Township, Van Buren County, Michigan, on the southeastern shoreline of Lake Michigan. The

site is located 4.5 mi south of the South Haven city limits. Kalamazoo and Portage, Michigan,

and Elkhart and South Bend, Indiana, are located inland 30 to 50 mi from Palisades. Smaller

cities in the region include South Haven, Benton Harbor, and St. Joseph, Michigan. The site

location is approximately 75 mi northeast of downtown Chicago, Illinois.
Introduction

NUREG-1437, Supplement 27 1-8 October 2006

| The plant has a single pressurized light-water reactor. Combustion Engineering, Inc., designed

the Nuclear Steam Supply System, which includes the primary system (e.g., reactor vessel,

steam generators, pressurizer, and pumps), reactor auxiliary system components, nuclear and

certain process instrumentation, and the Reactor Protective System. Bechtel Corporation and

its affiliate, Bechtel Company, designed and supplied the balance of the plant equipment,

systems, and structures (NMC 2003).

The maximum authorized power level of the reactor is 2565 megawatts thermal (MW(t))

(NMC 2003). The current net summer capacity of Palisades is 786 megawatts electric (MW(e)),

| which is equivalent to the power needs of approximately 775,000 residences (NMC 2005a). 

Palisades uses a circulating water cooling system to conduct waste heat from the main

condenser to two mechanical draft cooling towers where heat is removed by evaporation. The

current OL for Palisades expires on March 24, 2011. By letter dated March 22, 2005, NMC

submitted an application to the NRC (NMC 2005b) to renew this OL for an additional 20 years of

operation (i.e., until March 24, 2031).

1.4 The Purpose and Need for the Proposed Action

Although a licensee must have a renewed license to operate a reactor beyond the term of the

existing OL, the possession of that license is just one of a number of conditions that must be

met for the licensee to continue plant operation during the term of the renewed license. Once

an OL is renewed, State regulatory agencies and the owners of the plant will ultimately decide

whether the plant will continue to operate based on factors such as the need for power or other

matters within the State’s jurisdiction or the purview of the owners.

Thus, for license renewal reviews, the NRC has adopted the following definition of purpose and

need (GEIS Section 1.3):

The purpose and need for the proposed action (renewal of an operating license)

is to provide an option that allows for power generation capability beyond the

term of a current nuclear power plant operating license to meet future system

generating needs, as such needs may be determined by State, utility, and where

authorized, Federal (other than NRC) decision makers.

This definition of purpose and need reflects the Commission’s recognition that, unless there are

findings in the safety review required by the Atomic Energy Act of 1954 or findings in the NEPA

environmental analysis that would lead the NRC to reject a license renewal application, the

NRC does not have a role in the energy-planning decisions of State regulators and utility

officials as to whether a particular nuclear power plant should continue to operate. From the

perspective of the licensee and the State regulatory authority, the purpose of renewing an OL is

to maintain the availability of the nuclear plant to meet system energy requirements beyond the

current term of the plant’s license.
Introduction

October 2006 1-9 NUREG-1437, Supplement 27

1.5 Compliance and Consultations

NMC is required to hold certain Federal, State, and local environmental permits, as well as meet

relevant Federal and State statutory requirements. In its ER (NMC 2005a), NMC provided a list

of the authorizations from Federal, State, and local authorities for current operations as well as

environmental approvals and consultations associated with license renewal for Palisades. |

Authorizations and consultations relevant to the proposed OL renewal action are included in

Appendix E.

The NRC staff has reviewed the list and consulted with the appropriate Federal, State, and local

agencies to identify any compliance or permit issues or significant environmental issues of

concern to the reviewing agencies. These agencies did not identify any new and significant

environmental issues. The ER (NMC 2005a) states that NMC is in compliance with applicable

environmental standards and requirements for Palisades. The NRC staff has not identified any

environmental issues that are both new and significant.

1.6 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

40 CFR Part 1508. Code of Federal Regulations, Title 40, Protection of Environment,

Part 1508, “Terminology and Index.”

Atomic Energy Act of 1954 (AEA). 42 USC 2011, et seq.

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321, et seq.

Nuclear Management Company, LLC (NMC). 2003. Final Safety Analysis Report (FSAR)

– Palisades Nuclear Plant. Rev. 24, Covert, Michigan (October 2003).

Nuclear Management Company, LLC (NMC). 2005a. Applicant’s Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Power Plant. Docket No. 50-255, Covert,

Michigan (March 2005).

Nuclear Management Company (NMC). 2005b. Palisades Nuclear Plant. Application for

Renewed Operating License. Covert, Michigan (March 22, 2005).
Introduction

NUREG-1437, Supplement 27 1-10 October 2006

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Main Report, Supplement 1: Operating License Renewal. 

NUREG-1555, Supplement 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005a. “Notice of Acceptance for Docketing of

the Application and Notice of Opportunity for Hearing Regarding Renewal of Facility Operating

License No. DPR-20 for an Additional 20-Year Period.” Federal Register, Vol. 70, No. 109,

pp. 33533–33535, Washington, D.C. (June 8, 2005).

U.S. Nuclear Regulatory Commission (NRC). 2005b. “Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process.” Federal Register, Vol. 70,

No. 122, pp. 36967–36968, Washington, D.C. (June 27, 2005).

U.S. Nuclear Regulatory Commission (NRC). 2005c. Environmental Impact Statement Scoping

Process: Summary Report – Palisades Nuclear Plant, Van Buren County, Michigan. 

| Washington, D.C. (December 14, 2005).

| U.S. Nuclear Regulatory Commission (NRC). 2006. “Nuclear Management Company, LLC;

| Palisades Nuclear Plant; Notice of Availability of the Draft Supplement 27 to the Generic

| Environmental Impact Statement, and Public Meeting for the License Renewal of Palisades

| Nuclear Plant.” Federal Register, Vol. 71, No. 36, pp. 9383–9384, Washington, D.C. 

| (February 23, 2006).
October 2006 2-1 NUREG-1437, Supplement 27

2.0 Description of Nuclear Power Plant and Site

and Plant Interaction with the Environment

Palisades Nuclear Plant (Palisades) is owned by Consumers Energy Company (Consumers

Energy), a subsidiary of CMS Energy Corporation. Nuclear Management Company, LLC

(NMC), operates Palisades on behalf of Consumers Energy. With respect to the Palisades |

operating license (OL), Consumers Energy is the owner licensee, and NMC is the licensed

operator of the facility (NMC 2005a). Palisades is located in Covert Township, Van Buren

County, Michigan, on the southeastern shoreline of Lake Michigan. The plant consists of a

pressurized light-water reactor that produces steam that turns turbines to generate electricity. 

The Palisades facilities and infrastructure include the power block area, two independent spent

fuel storage installations for dry storage, mechanical draft cooling towers, main parking lot, main

access road, switchyard (Palisades Substation), and power transmission facilities and corridors,

which extend eastward from the power block to the eastern site boundary at the Blue Star

Memorial Highway. Other development on the site consists of waste storage and support

facilities, including a radioactive waste storage building, an interim steam generator storage

building for storage of old steam generators that were replaced in the early 1990s, a

warehouse, an outage/training facility, and spent fuel services building. The plant and its

environment are described in Section 2.1, and the plant’s interaction with the environment is

presented in Section 2.2.

2.1 Plant and Site Description and Proposed Plant Operation

During the Renewal Term

Palisades is located on approximately 432 ac of land, and is bordered by Lake Michigan on the

west and the Blue Star Memorial Highway and adjacent Interstate-196 (I-196) on the east in

Covert Township, Van Buren County, Michigan. The nearest town is South Haven, Michigan,

which is approximately 4.5 mi north of the plant, and has a population of about 5000 people. 

The major towns within a 50-mi radius of the plant are Kalamazoo and Portage, Michigan, and

Elkhart, Mishawaka, and South Bend, Indiana. Figures 2-1 and 2-2 show the site location and

features within 50 mi and 6 mi, respectively (NMC 2005a).

Based on 2000 U.S. Census Bureau data, approximately 1.3 million people live within 50 mi of

the site (NMC 2005a). The population density of 293 persons/mi2

 is considered a high

population area based on the criteria described in the Generic Environmental Impact Statement 
Plant and the Environment 

NUREG-1437, Supplement 27 2-2 October 2006

Figure 2-1. Location of Palisades, 50-mi Region
Plant and the Environment

October 2006 2-3 NUREG-1437, Supplement 27

Figure 2-2. Location of Palisades, 6-mi Region
Plant and the Environment 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

NUREG-1437, Supplement 27 2-4 October 2006

for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996,

1999).(a)

NMC employs a permanent workforce of approximately 530 employees and 110 contractors. 

The reactor is refueled on an 18-month refueling cycle. During refueling outages, site

employment increases by approximately 380 workers assigned for temporary (30 to 40 days)

duty (NMC 2005a). Upon the initiation of the renewed OL, the permanent workforce is expected

to increase by approximately 60 employees to perform the license renewal surveillance, online

monitoring, inspections, testing, trending, and record keeping activities (NMC 2005a). 

2.1.1 External Appearance and Setting

Palisades property includes approximately 1 mi of lake frontage and extends about 1 mi

eastward from Lake Michigan. The local terrain consists of a gentle upward sloping beach at an

elevation of about 580 ft above mean sea level (MSL) that rises sharply into sand dunes at an

elevation of approximately 780 ft MSL and then drops off abruptly to about 610 ft MSL at the

eastern site boundary. The area surrounding the plant property is largely rural, characterized by

agriculture and heavily wooded, rugged sand dunes along the lakeshore (NMC 2005a). As

indicated in Figure 2-2, there are few urban areas and little industrial development within the

6-mi radius of the plant. The only major industrial facility in the immediate vicinity of the site is

| the Covert Generating Station, on the east side of I-196. The Covert Generating Station, owned

| and operated independently of Palisades, consists of three natural-gas-fired combined-cycle

electric generating units. It generates 1100 MW of electricity when all three units are operating. 

The electricity from the plant is connected to the grid at the Palisades Substation. 

The developed area on the Palisades site, which includes power production and support

facilities, roads, parking lots, and the transmission line rights-of way up to the site boundary, is

approximately 80 ac. No residences exist on the site. The main access to the site is the Blue

Star Memorial Highway. 

Numerous public recreational areas and summer vacation properties exist within 50 mi of the

Palisades site. The area is particularly popular with tourists during the summer months. There

are no Federal facilities, but State-owned facilities include eight parks, two recreational areas,

seven game areas, one fish and wildlife area, and seven wilderness and natural areas

(NMC 2005a). There are also a large number (more than 200) of municipal and privately owned

parks and recreational areas. The site is bordered by Van Buren State Park on the north and a

privately owned residential and lakefront recreational community, Palisades Park and Country

| Club, on the south. The 400-ac Van Buren State Park has a 1-mi shoreline on Lake Michigan

and contains campgrounds and picnic and beach facilities. Two of the State Parks in the region
Plant and the Environment

October 2006 2-5 NUREG-1437, Supplement 27

are linear walking and riding trails. The Van Buren Trail State Park is a dirt and gravel multiuse

trail between South Haven and Hartford, Michigan. The Kal-Haven Trail State Park is a 34-mi

crushed limestone path between South Haven and Kalamazoo, Michigan. Both trails are

located on abandoned railroad paths (NMC 2005a). Many of the State-owned and private

recreational areas within 50 mi of the site offer facilities for camping, picnicking, boating,

hunting, fishing, swimming, hiking, horseback riding, and winter sports (NMC 2005a).

The 432-ac Palisades site is owned by Consumers Energy. Consumers Energy has granted |

easements to the Michigan Electric Transmission Company, LLC (METC), which owns the

transmission lines leaving the Palisades Substation on the site. The immediate plant area is

fenced, with a locked gate under the control of plant personnel. Access to the site is controlled

both from the land and the lake. 

2.1.2 Reactor Systems

The Nuclear Steam Supply System for Palisades is a pressurized water reactor consisting of a

reactor Primary Coolant System (PCS) and associated auxiliary systems (NMC 2003b). The

PCS design features two closed loops in which reactor coolant is circulated, each of which

includes two primary coolant pumps and a steam generator. The reactor coolant, demineralized

water to which chemicals are added to control corrosion and moderate the nuclear reaction,

circulates under high pressure through the reactor vessel and the tube side of the two steam

generators in these closed loops. Heat from the reactor is transferred to conditioned,

demineralized water in the shell side of the steam generators to produce high-pressure steam

that is routed through the steam turbine, condensed back to water in the main condenser, and

pumped back to the steam generators, thus comprising an isolated secondary cooling loop (i.e.,

the secondary system) (NMC 2003b). The steam turbine is a tandem-compound unit and is

connected directly to the generator. The maximum calculated capacity of the turbine generator

is 865 megawatts-electric (MW(e)) gross. Heat transfer from the main condenser is

accomplished by a third cooling loop, the Circulating Water System (CWS).

The nuclear fuel is low-enriched uranium dioxide with enrichments below 5 percent by weight

(NMC 2005a). The fuel is contained in long fuel rods that are assembled into fuel bundles

consisting of 225 rods in 15 × 15 arrays. The collection of fuel bundles with associated

instrument tubes, control rods, and structural elements make up the reactor core. The nuclear

energy contained in the fuel is converted to thermal energy through fissioning of the uranium

atoms in the fuel, and the thermal energy is transferred to the circulating water in the primary

cooling system as described above.

The reactor, steam generators, and related systems are enclosed in a Containment Building

that is designed to prevent leakage of radioactivity to the environment in the improbable event of

a rupture of the reactor coolant piping. The Containment Building is a reinforced concrete
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NUREG-1437, Supplement 27 2-6 October 2006

cylinder with a slab base and an arching dome. A 0.25-in. welded steel liner is attached to the

inside face of the concrete shell to ensure a high degree of leak-tightness. In addition, the

3.5-ft-thick concrete walls serve as a radiation shield for both normal and accident conditions.

The Containment Building is ventilated to maintain pressure and temperatures within acceptable

limits. The containment ventilation system also can purge the containment prior to entry. 

Exhaust from the ventilation system is monitored for radioactivity before being released to the

plant vent, which is located just above the top of the containment outside wall. High-efficiency

particulate air (HEPA) filters are used when needed to filter the air before releasing it.

In addition to the Containment Building, the major structures within the power block on the

Palisades site include the Turbine Building, which houses the turbines, the electrical generator,

condenser, feedwater heaters, and feedwater and condensate pumps; the Auxiliary Building

and the attached Radioactive Waste Building, which contain the spent fuel pool, radioactive

waste management equipment, heating and ventilation system components, the emergency

diesel generators, switchgear, laboratories, offices, and the control room; the Condensate and

Makeup Demineralizer Building, which houses the equipment and facilities used to treat the

makeup water for the CWS; the Cooling Tower Pump House; and the Intake Structure, which

houses the service water and fire protection pumps. 

As shown in Figure 2-3, the other prominent structures outside of the power block area on the

Palisades side include two independent spent fuel storage installations for dry storage, cooling

towers, the Palisades Substation (the switchyard), power transmission lines extending from the

| Palisades Substation to the eastern site boundary, a warehouse building, a meteorological

tower, and various storage areas, roads, and parking lots.

2.1.3 Cooling and Auxiliary Water Systems

Palisades relies on two sources of water: raw water from Lake Michigan and potable water from

| the South Haven Municipal Water Authority (Consumers Energy 2003a; NMC 2003b). The

water from Lake Michigan is used primarily for waste heat removal in the plant’s Service Water

System (SWS) and CWS. The withdrawal rate is approximately 98,000 gpm during normal full

power operation. Of this flow, evaporative loss due to evaporation from the two CWS cooling

towers may range as high as 12,000 gpm during the summer, while the remaining 86,000 gpm

| is returned to Lake Michigan (Consumers Energy 2003a; NMC 2003b).

The water for the SWS and CWS is withdrawn from Lake Michigan via pipeline from a

submerged intake crib structure located 3300 ft offshore in water about 35 ft deep (Consumers

| Energy and NMC 2001). The crib structure is a box measuring 57 ft wide, 57 ft long, and 13 ft

high. Two-thirds of its top surface consist of steel plates, and one-third is comprised of bar
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October 2006 2-7 NUREG-1437, Supplement 27

Figure 2-3. Palisades Site Layout
Plant and the Environment 

NUREG-1437, Supplement 27 2-8 October 2006

racks. Water enters the crib through the bar racks and on each of the crib’s four sides, which

are constructed of 2-in. vertical steel bars spaced at 10-in. intervals (Consumers Energy and

NMC 2001). 

Originally, the crib was designed for a once-through cooling-water flow rate of approximately

400,000 gpm. However, subsequent conversion to a closed-cycle cooling system reduced

intake flow to approximately 98,000 gpm, resulting in low approach velocities of approximately 

0.1 foot per second at the face of the structure (Consumers Energy and NMC 2001). Water

flows from the intake crib through an 11-ft-diameter pipe to the onshore intake structure where it

passes through trash racks constructed of steeply sloped bars to prevent entry of coarse debris. 

Debris accumulated on the trash racks is removed by a mechanical rake or scoop (AEC 1972). 

The water then flows through vertical 0.375-in. mesh traveling screens for removal of finer

debris (Consumers Energy and NMC 2001). The traveling screens are cleaned by rotating and

backwashing the screens as needed (in automatic or manual operation) and sluicing the debris

to a collection basket (AEC 1972; Consumers Energy and NMC 2001). The accumulated debris

is disposed of in accordance with the Palisades National Pollutant Discharge Elimination

System (NPDES) permit (MDEQ 2004). 

Three 8000-gpm service water pumps, one of which is normally on standby, are located in the

onshore intake structure and provide water to the SWS (NMC 2003b). The purpose of the

service water is to remove waste heat from the nuclear plant and steam plant auxiliary systems. 

After flowing through coolers, heat exchangers, and other plant components, this service water

is discharged to the makeup basin, which is open to the suction basins for the CWS

| cooling-tower pumps (NMC 2003b). A small fraction of water in the SWS is used as feedwater

for production of demineralized water for use in the primary and secondary cooling loops. 

The CWS removes waste heat from the main condenser by recirculating water from the hot side

of the condenser through the facility’s two mechanical draft cooling towers (NMC 2003b). In

these towers, cooling takes place through evaporation. Water circulation in this system is

accomplished by two 164,000-gpm pumps located in the cooling-tower pump building. 

Evaporation in the cooling towers ranges from 4500 gpm in winter to 6000 gpm in summer for

each of the two towers. 

Evaporation and other losses (e.g., cooling-tower blowdown) from the CWS are replaced by

makeup water withdrawn from the onshore intake structure by two 40,000-gpm dilution water

pumps. Makeup water surplus is directed to the makeup basin where it combines with the SWS

cooling water. Excess cooling water in the makeup basin flows over weirs to the mixing basin

for discharge to the lake. 

The cool lake water provided by the dilution water pumps increases the generation efficiency of

the plant and reduces the temperature of the water discharged to the lake (NMC 2003b). 

Cooling water mixes with low-volume waste sources, which meet the criteria described in
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October 2006 2-9 NUREG-1437, Supplement 27

Section 2.2.3, from plant operations in the mixing basin and flows through openings in the outer

wall of the mixing basin to Lake Michigan via Outfall 001, which is the shoreline discharge

structure (NMC 2003b). The outfall is a pile structure that widens from 37 ft at the mixing basin

outlet wall to 100 ft at its terminus, 108 ft from the outlet wall (AEC 1972). The discharge

(monitoring point 001A) is monitored for both radiological and nonradiological parameters in

accordance with the NPDES permit (MDEQ 2004). Associated limits include a maximum

allowable discharge flow of 135.2 million gpd, a daily maximum heat addition limit of

2.1 × 109

 Btu/hr, and limits for release of total residual oxidants (TROs) used for biofouling

control (MDEQ 2004).

2.1.4 Radioactive Waste Management Systems and Effluent Control Systems

Radioactive wastes resulting from plant operations are classified as liquid, gaseous, and solid

wastes. Palisades uses liquid, gaseous, and solid radioactive waste management systems to

collect and process these wastes before they are released to the environment or shipped to

offsite commercial waste processing or disposal facilities. The waste disposal system meets

the design objectives and release limits as set forth in Title 10 of the Code of Federal

Regulations, Part 20 (10 CFR Part 20) and Part 50 (10 CFR Part 50), Appendix I (“Numerical

Guide for Design Objectives and Limiting Conditions for Operation to Meet the Criterion ‘As Low

As is Reasonably Achievable’ for Radiological Material in Light-Water-Cooled Nuclear Power

Reactor Effluents”), and controls the processing, disposal, and release of radioactive liquid,

gaseous, and solid wastes. Section 3.8.1.1 “Regulatory Requirements” of the GEIS (NRC |

1996) provides a summary of the regulatory requirements and specific numerical dose limits. |

Unless otherwise noted, the description of the radioactive waste management systems and |

effluent control systems for liquid, gaseous, and solid wastes presented here (Sections 2.1.4.1,

2.1.4.2, and 2.1.4.3, respectively) is based on information provided in the Palisades Final Safety

Analysis Report (FSAR; NMC 2003b) and as confirmed during the U.S. Nuclear Regulatory

Commission (NRC) staff site visit on July 26 and July 27, 2005.

The waste disposal system collects and processes all potentially radioactive reactor plant

wastes for removal from the plant site within limitations established by applicable governmental

regulations. In addition, the system is capable of liquid waste segregation and reuse. All

planned releases of liquid and gaseous effluents may be either batch or continuous. Before a

batch may be released, the tank is sampled and the sample analyzed in the laboratory. A gas

release is made only if the release can be made without exceeding Federal standards, and lack

of reserve holdup capacity requires such a release. Radiation monitors are provided to maintain

surveillance over the release operation, and a permanent record of activity released is provided

by radiochemical analysis of known quantities of waste (NMC 2003b).

Radioactive fission products build up within the fuel as a consequence of the fission process. 

These fission products are contained in the sealed fuel rods; however, as a result of fuel
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NUREG-1437, Supplement 27 2-10 October 2006

cladding failure and corrosion, small quantities escape from the fuel rods and contaminate the

reactor coolant. Neutron activation of the primary coolant system is also responsible for coolant

contamination. Nonfuel solid wastes result from treating and separating radionuclides from

gases and liquids and from removing contaminated material from various reactor areas. Solid

wastes also consist of reactor components, equipment, and tools removed from service as well

as contaminated protective clothing, paper, rags, and other trash generated from plant

operations during design modification and during routine maintenance activities. The solid

waste disposal system is designed to package solid wastes for removal to offsite treatment or

disposal facilities. Some solid waste is temporarily stored onsite.

Fuel assemblies that have exhausted a certain percentage of their fuel and that are removed

from the reactor core for disposal are called spent fuel. Palisades currently operates on an

18-month refueling cycle. Spent fuel is temporarily stored onsite in a spent fuel pool and in two

dry-storage areas.

The Offsite Dose Calculation Manual (ODCM) for Palisades (NMC 2004a), which is included

in the Palisades Annual Radioactive Effluent Release and Waste Disposal Reports

(e.g., NMC 2005b), describes the methods and parameters used for calculating radioactivity

concentrations in the environment and the estimated potential offsite doses associated with

liquid and gaseous effluents from the plant. The ODCM also specifies controls for release of

liquid and gaseous effluents from Palisades to ensure compliance with NRC regulations.

2.1.4.1 Liquid Waste Processing Systems and Effluent Controls

A small fraction of the water circulating in the primary coolant system is routinely withdrawn by

the chemical and volume control system within the plant, processed, and then reinjected into

the primary coolant system to control the composition and volume of the primary coolant. The

processing equipment removes any radionuclides that either escape from the fuel rods or are

produced in the coolant due to activation with neutrons to prevent their buildup in the primary

coolant. 

Any leaks from piping, valves, pump seals, and storage tanks throughout the plant are routinely

collected via catch basins, building drains, or sumps. At times equipment changes, repairs, or

cleanup operations also generate liquids that contain small concentrations of radioactive

elements. All such liquids, including those generated by the chemical and volume control

system, are handled by the Liquid Radioactive Waste System. They are collected, monitored,

and processed by a combination of mechanisms, including holdup (permitting radioactive

decay), filtration, demineralization, and ion-exchange treatment (removal of insoluble

particulates and soluble contaminants), degassing (removal of dissolved gases), and

evaporation (volume reduction). After processing, most of the liquids are recycled back into the

primary coolant system or other liquid systems within the plant and reused. The wet residues or

certain concentrates are solidified and sent offsite for disposal (see Section 2.1.4.3). Liquid
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(a) The fission and activation products do not include tritium activity (which is given separately), activity of |

dissolved and entrained gases (which is generally below levels of detection), and gross alpha

radioactivity (which is negligibly small).

October 2006 2-11 NUREG-1437, Supplement 27

streams that are not needed in the plant and meet the release criteria established in 10 CFR

Part 50, Appendix I, are discharged to Lake Michigan after dilution with CWS discharge. This

flow is via low-velocity surface discharge at the shoreline. The releases to the lake are in

batches and are strictly monitored to make sure that the release criteria are met. Any liquids

that do not meet the criteria are reprocessed until they meet the criteria, or they are sent offsite

for disposal after appropriate solidification and packaging.

Some of the radionuclides in the recycled primary coolant are noble gases dissolved in the

water. These radionuclides are degassed during the processing of the bleed-off stream by the

chemical and volume control system and sent to the gaseous radioactive waste processing

system for further processing (see Section 2.1.4.2). 

Prior to 1989, another source of liquid waste was the laundry facility that was used to clean

contaminated clothing. Although the equipment used for laundry is still in place, the facility is no

longer being used. Laundry is sent offsite to be cleaned by a contractor, and clean laundry is

returned to the site. 

During the 5-year period from 2000 through 2004, an average of four liquid batch releases |

occurred annually from Palisades. During this 5-year period, there were no unplanned or

uncontrolled liquid releases to the environment. Liquid effluents were reported in the Palisades

Annual Radioactive Effluent Release and Waste Disposal Reports for the years 2000 through

2004 (NMC 2001a, 2002, 2003a, 2004b, 2005b). Over this period, liquid effluents containing |

fission and activation products(a) and tritium were released into Lake Michigan. An annual

average of 1.18 × 10-3 Ci of fission and activation products and 202 Ci of tritium were

discharged with an average diluted concentration of 8.78 × 10-15 Ci/L for fission and activation

products and 1.58 × 10-9 Ci/L for tritium (NMC 2001a, 2002, 2003a, 2004b, 2005b). The |

maximum amount released in any one year during the 5-year period was 2.12 × 10-3 Ci for

fission and activation products and 342 Ci for tritium. The releases and the average diluted

concentrations were well below NRC regulatory limits. In 2005 (the most recent year for which |

data were available), the radioactive materials released to Lake Michigan in liquid effluents were |

0.01 Ci of fission and activation products and 305 Ci of tritium (NMC 2006a). Nine liquid batch |

releases occurred in 2005; none of them were unplanned or uncontrolled. The average diluted |

concentration of fission and activation products in liquid effluents released in 2005 was |

7.27 × 10-14 Ci/L; the average diluted concentration of tritium was 2.13 × 10-9 Ci/L. NMC does |

not anticipate any significant increases in liquid waste released annually during the renewal

period. See Section 2.2.7 for a discussion of the theoretical doses to the maximally exposed

individual (MEI) as a result of these releases.
Plant and the Environment 

NUREG-1437, Supplement 27 2-12 October 2006

| Since the March 22, 2005, application for the license renewal of Palisades, NMC has modified

| its liquid radioactive waste processing system. The system that NMC installed in December

| 2005 relies on cleaning of the contaminated liquid streams through a process known as ion

exchange. In this method, specially formulated resins are used to capture the contaminants

| from the liquid streams; streams can be recycled through the resin bed to further reduce

| contaminant levels if samples are above regulatory standards. Once saturated, the resins are

removed from the system and are treated as solid waste. New resins are placed in the system

and the cycle is repeated. 

| The equipment NMC has installed is commonly used in other nuclear power plants in the

United States, including the Donald C. Cook Nuclear Plant in Michigan and Nine Mile Point in

| New York. On the basis of experience in those plants and analyses conducted by NMC staff, it

| is expected that the amount of radioactive material released in liquid effluent may increase

| slightly. However, Palisades will continue to comply with all regulatory standards and will

maintain the existing ODCM release limits and set points.

2.1.4.2 Gaseous Waste Processing Systems and Effluent Controls

During plant operations, gaseous wastes originate from degassing reactor coolant discharged to

the chemical and volume control system, displacement of cover gases as liquids accumulate in

various tanks, miscellaneous equipment vents and relief valves, and sampling operations and

automatic gas analysis for hydrogen and oxygen in cover gases.

The Gaseous Radioactive Waste System in Palisades is designed to maintain gaseous

| effluents within limits specified in 10 CFR Part 20, 40 CFR Part 190, and to the ALARA (as low

| as reasonably achievable) requirement of 10 CFR Part 50, Appendix I. Section 3.8.1.1 of the

| GEIS (NRC 1996) provides a summary of these regulatory requirements and specific numerical

| dose limits. The Gaseous Radioactive Waste System is divided into two sections: (1) the gas

collection header, which collects low-activity gases from liquids that have been previously

degassed and/or vented in other waste handling steps, and (2) the waste gas processing

system, which collects gases from potentially high-activity sources. Gases collected by the gas

collection header are passed through a HEPA filter to the suction side of the main vent exhaust

fans, diluted by ventilation exhaust air, and discharged through a ventilation stack to the

atmosphere. 

The waste gas processing system collects all potentially high-activity gaseous waste. The

waste gas surge tank collects and absorbs surges from the demineralizer vents, quench tank

vent, primary system drain tank vent, volume control tank vent, vacuum degassifier vent,

equipment drain tank, and evaporator vents. The same tank also collects vent gas from relief

valves on various waste collection tanks. The waste gas surge tank discharges to one of three

compressors that compress the gas for storage and decay in one or more of six waste decay
Plant and the Environment

October 2006 2-13 NUREG-1437, Supplement 27

tanks. If the activities are less than or equal to 1 × 10-5 :Ci/cm3 (xenon-133), the waste gas

surge tank can be discharged through a HEPA filter directly to the ventilation stack.

Gases collected in decay tanks are held in the tanks until the radioactivity is low enough for

them to be discharged to the atmosphere. Gaseous effluents entering the plant’s ventilation

stack are continuously monitored and flow-controlled so that the previously established limits

are not exceeded. The discharge is then immediately diluted by mixing airflow from one of the

two continuously operating ventilation fans that transport 75,000 ft3

/min of air up the stack. If at

any time a high radiation condition is detected, the flow of radioactive gases through the stack is

stopped and the control room operators are alerted of the condition. 

Gaseous effluents for the years 2000 through 2004 were reported in the Palisades Annual |

Radioactive Effluent Release and Waste Disposal Reports (NMC 2001a, 2002, 2003a, 2004b, |

2005b). During this 5-year period, there were no unplanned or uncontrolled gaseous releases

to the environment; Palisades did, however, release measurable concentrations of fission and

activation gases, radioiodine, particulate radioactivity, and tritium in gaseous effluents to the

atmosphere. The average annual effluent releases over this 5-year period were 28.9 Ci of

fission and activation gases, 1.93 × 10-3 Ci of iodine-131, 2.65 × 10-4 Ci of particulates, and

37.7 Ci of tritium. The maximum amount released in any one year during this 5-year period was

65 Ci for fission and activation gases, 3.49 × 10-3 Ci for iodine-131, 9.62 × 10-4 for particulates,

and 99.2 Ci for tritium. In 2005 (the most recent year for which data were available), there were |

also no unplanned or uncontrolled gaseous releases to the environment. The radioactive |

materials released to the atmosphere in gaseous effluents were 43.8 Ci of fission and activation |

gases, 1.30 × 10-3 of iodine-131, 3.11 × 10-5 of particulates, and 108 Ci of tritium (NMC 2006a). |

NMC does not anticipate any significant increases in the radioactive gaseous releases during

the renewal period. As discussed in Section 2.2.7, the estimated doses to the MEI as a result of

these releases is a small fraction of applicable dose limits.

2.1.4.3 Solid Waste Processing

Solid wastes from Palisades include filter sludge, spent resin, radioactive tools and equipment,

and miscellaneous trash from plant operations and laboratory, maintenance, and cleanup

operations. The solid wastes are collected, processed, and temporarily stored onsite before

being shipped offsite for disposal or further processing and disposal by an authorized third

party. Radiation levels of shipped containers are maintained within the standards set forth by

the NRC and the U.S. Department of Transportation (DOT) (NMC 2003b).

The Solid Radioactive Waste System consists of those systems and components that are used

to process and package wet and dry solid waste so that the waste is suitable for transport and

disposal. The system is not used for spent fuel storage and shipment. The spent fuel from the

plant is currently stored in the spent fuel storage pool and two dry storage areas onsite.
Plant and the Environment 

NUREG-1437, Supplement 27 2-14 October 2006

High-activity reactor wastes other than the spent fuel are stored in the fuel storage pool to allow

radioactive decay, then packaged and transferred in approved shipping containers for offsite

burial. Maintenance waste, such as contaminated clothing and tools, is packed in suitable

DOT-approved containers and may be stored prior to shipment. Process waste, such as filter

sludges and spent resins, is collected in tanks, processed, and stored prior to shipment.

Dry active waste (DAW), generated as a result of operation and maintenance activities, is

collected throughout the radiologically controlled areas of the facility. Typical DAW includes air

filters, cleaning rags, protective tape, paper and plastic coverings, discarded contaminated

clothing, tools, equipment parts, and solid laboratory wastes. Most DAW has relatively low

radioactive content and may be handled manually. The DAW is normally stored in various work

areas and then moved to the process area.

Liquid radwaste concentrates (evaporator bottoms) are volume reduced to a dry powder, mixed

with a binding agent, and discharged directly into a burial container. Wet solid radioactive

waste results from the processing of spent demineralizer resins (both bead and powdered) and

spent filter material from the equipment drain, floor drain subsystems, and water cleanup

systems. The wet waste is solidified, dried, or dewatered for acceptability for a disposal site. If

storage is required for any of these types of waste, the containers of waste may be temporarily

stored onsite.

Transportation and disposal of solid radioactive wastes are performed in accordance with the

applicable requirements of 10 CFR Part 71 and 10 CFR Part 61, respectively. No releases to

the environment occur from solid radioactive wastes generated at Palisades. During the period

2000 through 2004, Palisades made an average of 16 shipments of solid radioactive waste

each year, with an average volume for spent resins, filter sludges, evaporator bottoms,

contaminated equipment, and other sources of 1561 ft3

, and an average activity of 1740 Ci

| (NMC 2001a, 2002, 2003a, 2004b, 2005b; 2005e). The maximum volume of waste shipped

offsite in any one year during this 5-year period was 2285 ft3 in 2001. In terms of activity, the

| maximum amount shipped in any one year was 8554 Ci in 2000. In 2005 (the most recent year

for which data were available), approximately 3630 ft3 | of solid waste containing 347 Ci of

| radioactivity was shipped offsite (NMC 2006a). The modification to the liquid waste processing

| system at Palisades completed in December 2005 (see Section 2.1.4.1) is not expected to

significantly change the generation of solid waste and offsite shipments of such waste from the

plant.

2.1.5 Nonradioactive Waste Systems

The principal nonradioactive effluents from Palisades consist of chemical and biocide wastes,

lubrication oil waste, resin regeneration waste, FreonTM filters, and sanitary waste. Palisades

stopped using chlorinated solvents and oils several years ago. The chemistry laboratory may

generate small quantities of expired chemicals. Other wastes could include laboratory packs
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October 2006 2-15 NUREG-1437, Supplement 27

and mercury switches. Spent batteries and discarded fluorescent lights are recycled. Sanitary

waste is sent to three onsite septic tanks. The tanks are sampled twice a year and emptied |

quarterly. Thus far, no radioactive contamination has been detected in the tanks. Depending

on the usage and the number of workers onsite during outages, they may be emptied more

frequently. The sewage removed from the tanks is taken to a local sewage treatment plant and

treated there, along with regular city sewage. 

2.1.6 Plant Operation and Maintenance

Routine maintenance performed on plant systems and components is necessary for the safe

and reliable operation of a nuclear power plant. Maintenance activities conducted at Palisades

include inspection, testing, and surveillance to maintain the current licensing basis of the plant

and to ensure compliance with environmental and safety requirements. Certain activities can be

performed while the reactor is operating. Others require that the plant be shut down. Long-term

outages are scheduled for refueling and for certain types of repairs or maintenance, such as the

replacement of a major component. Palisades is refueled on an 18-month schedule.

As part of the License Renewal Application (Application), NMC conducted an aging management review to manage the impacts of aging on systems, structures, and components in

accordance with 10 CFR Part 54. Appendix A of the Application provides the information to be

submitted in a FSAR Supplement as required by 10 CFR 54.21(d) for Palisades. The

Application contains the technical information required by 10 CFR Part 54. Section 4 of the

Application documents the evaluations of time-limited aging analyses (TLAAs) for the period of

extended operation. Appendix B of the Application provides descriptions of the programs and

activities that will manage the impacts of aging for the period of extended operation. These

summary descriptions of aging management program activities and TLAAs will be incorporated

into the FSAR for Palisades following the issuance of the renewed OL. NMC expects to

conduct the activities related to the management of aging impacts during plant operation or

normal refueling and other outages, but does not plan any outages specifically for the purpose

of refurbishment.

2.1.7 Power Transmission System

Transmission corridors considered in scope for license renewal are those constructed

specifically to connect the facility to the transmission system (10 CFR 51.53(c)(3)(ii)(H)). The

Final Environmental Statement (FES) for Palisades (AEC 1972) described two transmission

lines that connected Palisades with the transmission system. Both lines were constructed in

1969 and have steel lattice support structures anchored to concrete footings (AEC 1972). The

initial 0.6-mi long Palisades-Cook 345-kV transmission line (referred to as the Palisades-West

Olive line in the FES (AEC 1972)) connects to the American Electric Power (AEP) system, while

the 40-mi-long Palisades-Argenta 345-kV transmission line connects to the METC system and 
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NUREG-1437, Supplement 27 2-16 October 2006

the Michigan Power Pool (NMC 2005a). The Palisades-Argenta line extends eastward to the

Argenta Substation near Plainwell, north of Kalamazoo (Figure 2-4). Both transmission lines

have been owned by the METC since 2002, while Consumers Energy owns the land on which

the transmission lines are located (NMC 2005a).

The Palisades Substation, which operates at 345-kV, is the interconnection between Palisades

and the power grid system. The applicant’s ER (NMC 2005a) describes changes in the way

that Palisades is connected to the transmission system that have been made since the FES was

published. Currently seven 345-kV circuits on four double-circuit, steel lattice support structure

transmission lines extend from the Palisades Substation (Figure 2-3): Palisades-Cook #1 and

#2 (Circuits 310B and 310A); Palisades-Argenta #1 and #2 (Circuits 309A and 309B);

Palisades-Vergennes and Roosevelt-Palisades (Circuits 306A and 306B); and Palisades-Covert

Plant (Circuit 306J) (NMC 2005a). However, only the 0.6-mi-long Palisades-Cook line and the

40-mi-long Palisades-Argenta line are considered in scope for license renewal.

Both transmission lines associated with Palisades were constructed in accordance with the

National Electrical Safety Code (NESC) (IEEE 2002) and industry guidance in effect at that

time. The transmission facilities are maintained to ensure continued compliance with current

standards.

Figure 2-4. Transmission Lines
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October 2006 2-17 NUREG-1437, Supplement 27

The 0.6-mi-long Palisades-Cook transmission line occurs on land similar to that of the Palisades

site. Its construction involved the clearing of a 150-ft-wide right-of-way totaling 10.9 ac over

sand dunes (AEC 1972). The Palisades-Argenta transmission line right-of-way is 1320 ft wide

for the first 4.5 mi, 350 ft wide for the next 34 mi, and 471 ft wide for the final 1.5 mi, totaling

2250 ac. This line occurs mostly on flat to gently rolling terrain crossing land used primarily for

agriculture, with scattered orchards and residential and commercial properties (AEC 1972).

In general, the corridors are in remote, sparsely populated areas. Where the Palisades-Argenta

line crosses agricultural lands, the land typically continues to be used for agricultural purposes. 

Both transmission lines cross Blue Star Memorial Highway and I-196, which occur just east of

Palisades. The Palisades-Argenta line also crosses a number of other State and

U.S. highways. The transmission lines are near the Van Buren State Park, and the

Palisades-Argenta transmission line crosses the Kal-Haven and Van Buren State Trails

(NMC 2005a). The Palisades-Argenta line crosses the Kalamazoo River and several other

streams (see Section 2.2.5), while the 0.6-mi-long Palisades-Cook line does not cross any

streams or rivers.

The METC recognizes that transmission line rights-of-way provide ancillary compatible uses,

including agriculture, wildlife habitat, recreation, and aesthetics. The METC practices a

vegetation-management program that utilizes physical, chemical, and biological treatments to

promote stable, diverse, low-growing plant communities in a way that promotes wildlife habitat

and/or maintains current usage of the rights-of-way and reduces environmental impacts.

Semiannual visual helicopter patrols and biennial infrared inspections of the transmission lines

are conducted to check for anomalies in the conductors, insulators, and support structures, as

well as for encroachments into the rights-of-way (e.g., trees, buildings, or other obstructions)

(NMC 2005a). Walking inspections are also conducted about every 2 years to assess the

condition of trees and other vegetation. Contractors conduct vegetation maintenance about

every 4 years in accordance with METC-approved maintenance plans. Right-of-way

maintenance involves both selective cutting and herbicide application. Herbicide use during

right-of-way maintenance is restricted to treatment of tree species, with a basal application

applied to individual stems or root crowns. Such applications are normally made at 5- to 6-year

intervals (METC 2001). Only those herbicides approved by the U.S. Environmental Protection

Agency (EPA) are used. They are applied by a licensed contractor in accordance with label

instructions (NMC 2005a). Danger trees are generally removed whenever identified, except at

critical areas where they are trimmed (METC 2001).

Border and wire zone vegetation management is employed for right-of-way maintenance. The

wire zone (the area beneath the conductors) is managed to promote a mix of herbaceous

plants, whereas the border area is managed to promote low-growing shrubs and other

compatible vegetation. Low-growing trees and shrubs that do not interfere with the function of
Plant and the Environment 

NUREG-1437, Supplement 27 2-18 October 2006

the transmission lines are left undisturbed. Trees that have the potential to interfere with the

transmission lines, including danger trees that are outside of the 150-ft-wide right-of-way, are

removed (NMC 2005a). Special consideration is given to areas where threatened and

| endangered species could occur and maintenance activities are planned. Practices to mitigate

adverse impacts on these species are reviewed and approved by the METC before

maintenance activities are conducted (NMC 2005a).

2.2 Plant Interaction with the Environment

Sections 2.2.1 through 2.2.8 provide general descriptions of the environment near Palisades as

background information. They also provide detailed descriptions where needed to support the

analysis of potential environmental impacts of refurbishment and operation during the renewal

term, as discussed in Chapters 3 and 4. Section 2.2.9 describes the historic and archaeological

| resources in the area, and Section 2.2.10 describes other Federal project activities that might

| impact license renewal.

2.2.1 Land Use

The Palisades site is located in Covert Township, Van Buren County, Michigan, on the

southeastern shoreline of Lake Michigan, about 4.5 mi from South Haven, Michigan. The

Palisades site is approximately 432 ac and extends approximately 1 mi inland between Lake

Michigan and the Blue Star Memorial Highway and adjacent I-196. The nearest population

center is the township of Covert, which is approximately 2.5 mi southeast of the Palisades site. 

Van Buren State Park is located immediately to the north of the Palisades site, and Van Buren

Trail State Park is located northeast of the site.

The Palisades site lies on the southwest flank of the Michigan Basin within the Central Lowland

physiographic province (NMC 2003b). Covert Ridge, a glacial moraine, bounds the area to the

east of the site. The ridge serves as a drainage divide; the water table gradient is nearly flat

with a slow westward flow toward the lake. The western part of the site is covered by large,

coalescing sand dunes more than 200 ft high, while the eastern portion is characterized by

scattered lower dunes with broad intervening basins, some of which contain shallow ponds. 

The dunes are relatively stable topographic features with occasional blowout caused by wind

action. The majority of the land area is heavily wooded, with occasional wetlands.

The plant facilities are located about 2500 ft from both the northern and southern boundaries of

the site. A number of buildings and other permanent structures occupy approximately 80 ac of

the Palisades site. These include the power generation and administration area (20 ac),

transmission corridors and switchyard (30 ac), warehouse area (7 ac), cooling towers (4 ac),

and other supporting buildings and waste storage (7 ac) (DeCamp 2005).
Plant and the Environment

October 2006 2-19 NUREG-1437, Supplement 27

A fence, with a locked gate under the control of plant security personnel, surrounds the

protected plant area, and the site boundary is posted (NMC 2005a). As a result of events on |

September 11, 2001, NMC implemented actions to limit and/or monitor the entire beach area

along the lakefront portion of the site. These actions include vehicle barriers and no trespassing

signs at the north and south site boundaries. The U.S. Coast Guard has established a security

zone extending along the lakeshore frontage of the site 1000 yds out into Lake Michigan,

effectively prohibiting access without prior authorization (NMC 2005a).

In addition, Section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA)

(Section 1456(c)(3)(A) of Title 16 to the United States Code, (16 USC 1456(c)(3)(A))) requires

that applicants for Federal licenses certify that the proposed coastal zone activity is consistent

with the enforceable policies of the State’s coastal management program (NRC 2004). A copy

of the certification is also to be provided to the State. The State is to notify the Federal agency

whether the State concurs with or objects to the applicant’s certification. This notification is to

occur within 6 months of the State’s receipt of the certification. Palisades is within Michigan’s

coastal zone for purposes of the Act. Following submission of the NMC certification of

consistency, the Michigan Department of Environmental Quality (MDEQ) determined that

renewal of the OL for Palisades would be consistent with the Michigan Coastal Management |

Program (NMC 2005a; Attachment D).

2.2.2 Water Use

Palisades lies on the southeastern shore of Lake Michigan, the only Great Lake that lies entirely

within the boundaries of the United States. Lake Michigan is the second largest of the Great

Lakes by volume at 1.3 × 1015 gal and third largest by area at 22,300 mi2

. It drains an area of

45,600 mi2

 (Fuller, Shear, and Witting 1995). Major tributaries of Lake Michigan include the

Fox-Wolf, Grand, St. Joseph, Menominee, and Kalamazoo Rivers. Lake Michigan is joined to |

Lake Huron at the Straits of Mackinac; thus, the two basins are hydrologically connected.

The northern part of the Lake Michigan watershed is forested and sparsely populated, except

for the Fox River Valley, which drains into Green Bay. The southern part of Lake Michigan is

among the most urbanized areas in the Great Lakes region, containing both the Milwaukee and

Chicago metropolitan areas.

Lake Michigan provides safe drinking water for 10 million people, wildlife habitat, food

production and processing, active sport and sustenance fisheries, and other valuable |

commercial and recreational activities (EPA 2000). However, threats to the ecosystem of the

lake and its basin persist.

As described in Section 2.1.3, water usage at Palisades includes Lake Michigan water by the

SWS and the CWS. In addition, the facility receives municipal water from the South Haven
Plant and the Environment 

(a) Personal communication from R. Packard, South Haven Michigan Water Filtration Plant, to J. Quinn,

Argonne National Laboratory, Argonne, Illinois. Subject: “Municipal Water System.” (September 16,

2005).

(b) Personal communication from W. Chooi, District Engineer, Michigan Department of Environmental

Quality, to J. Quinn, Argonne National Laboratory, Argonne, Illinois. Subject: “Lake Michigan Water

Intake at Covert.” (September 16, 2005).

NUREG-1437, Supplement 27 2-20 October 2006

Municipal Water Authority. Average water use by the Palisades Domestic Water Distribution

| System is approximately 18,000 gpd (Consumers Energy 2003a). This system provides

| Palisades with water for potable, sanitary, emergency shower, eyewash station, and other uses. 

Average daily plant usage represents 1.1 percent of the South Haven Municipal Water

Authority’s average daily demand and 0.45 percent of its permitted capacity (NMC 2005a). 

NMC does not expect any significant change in water usage during the license renewal term. 

The South Haven Water Authority has an excess capacity of 0.77 million gpd.

A water intake was constructed in 2002 offshore from Van Buren State Park, approximately 1 mi

north of the Palisades facility. The purpose of this intake is to provide water to the

| Covert Generating Station, a 1170-MW, combined-cycle, natural-gas-fired power plant that

shares a transmission line with Palisades (Mulcahy 2002). The Covert plant is located about

1 mi east of Palisades (Figure 2-2). Water usage from the Covert plant has been approximately

8 million gpd (Prein & Newhof 2004). The intake is designed as infiltration beds, comprised of

slotted pipe on the lake bottom, and surrounded by gravel and sand that allow infiltration while

keeping lake sand out of the pipes (Prein & Newhof 2004). Each infiltration bed has a capacity

of 10 million gpd (Prein & Newhof 2004), and the system may be expanded.(a) 

From the inception of the water intake structure as a source of water for the gas plant’s cooling

needs, planners realized its potential as a possible future supply point for municipal water

(PG&E 2001; City of South Haven 2005; Mulcahy 2002). 

South Haven’s water needs are anticipated to outgrow its capacity (City of South Haven 2005). 

South Haven’s water system has been operating at 80 to 90 percent of its capacity, and

additional development is anticipated, according to a water filtration plant representative.(a) The

district engineer for the MDEQ estimates that in 3 to 5 years, a water treatment plant will be

completed, relying on the intake for use in an expanded municipal water system.(b) The water

| treatment plant would be built on land provided by the Covert Generating Station (City of

South Haven 2005).(b) As with the existing South Haven water supply system, sampling and

monitoring of an additional intake and treatment plant would be regulated by the State of

Michigan.

Most of the domestic water is disposed of as sanitary wastewater, which is collected by the

Palisades septic system. This system collects the raw sanitary wastewater in holding tanks

| where solids settle out of the wastewater. Effluent from the tanks flows to three sanitary drain
Plant and the Environment

October 2006 2-21 NUREG-1437, Supplement 27

fields, one located between the north cooling tower and the power block, one located east of

Warehouse No. 2, and one located north of the Outage Building (Figure 2-3). Wastewater is

treated and disposed of by infiltration at the drain fields; solids are periodically removed from the

holding tanks and disposed of at a licensed wastewater treatment facility by a commercial

vendor (Consumers Energy 1998).

Palisades has three operating groundwater wells to supply water for grounds maintenance and

other miscellaneous uses. Their combined pumping capacity is 24 gpm.

2.2.3 Water Quality

The water quality of Lake Michigan has been degraded by industrial, municipal, agricultural,

navigational, and recreational water users for more than 150 years. Water quality is diminished

near urban areas, mostly due to sewer overflows, direct storm water runoff, and industrial

discharges. Sources of pollutants throughout the basin include atmospheric deposition, release

from contaminated groundwater and sediments, point source discharges, and nonpoint source

runoff.

The health of aquatic organisms is continually affected by the presence of toxic pollutants 

(e.g., mercury and polychlorinated biphenyls (PCBs)). Fish consumption advisories and beach |

closings adversely affect the beneficial uses of the lake. Non-native species continue to disrupt

native plant and animal communities. Purple loosestrife (Lythrum salicaria) is still largely

uncontrolled despite numerous eradication attempts (EPA 2000). Algal species abundance and

type can vary greatly within the lake and can be altered by excessive predation by uncontrolled

exotic species and competition with nonindigenous algae (EPA 2000). Increased salinity and

other environmental changes may also support adaptation of non-native species.

The United States and Canada, in consultation with State and Provincial governments, are

working to “restore and maintain the chemical, physical, and biological integrity of the water of |

the Great Lakes Basin Ecosystem” under the provisions of the Great Lakes Water Quality

Agreement, signed in 1972 and amended in 1987 (EPA 2000).

As part of this effort, the Lake Michigan Technical Committee developed a Lake Michigan

Lakewide Management Plan (EPA 2000) that describes the current state of lake habitats

(e.g., open waters, wetlands, and tributary streams), identifies areas of concern, and

recommends future steps that should be taken to protect and restore Lake Michigan

ecosystems. These recommendations range from controls on ballast water to remediation of

contaminated sediment sites, to implementation of Total Maximum Daily Load strategies for

tributary streams. The Lake Michigan Lakewide Management Plan lists a number of areas in

which improvements have been made (e.g., reduction of point-source pollutants entering the

basin and protection and restoration of wetlands) but notes other areas still needing
Plant and the Environment 

NUREG-1437, Supplement 27 2-22 October 2006

| improvement (e.g., deposition of toxic air pollutants in the watershed and non-point-source

pollutants).

Consumers Energy Company’s Palisades Nuclear Plant is authorized to discharge water to

Lake Michigan under an NPDES permit administered by the MDEQ. As described in the current

NPDES permit (MDEQ 2004), Palisades has one outfall, Outfall 001, and three monitoring

points: 001A, 001D, and 001F. 

At monitoring point 001A, the discharge is a combination of noncontact cooling water,

cooling-tower blowdown, and the miscellaneous treated low-volume wastewaters from

monitoring points 001D and 001F, which may include steam generator blowdown,

demineralization backwash, regeneration waste, reverse osmosis filter backwash, turbine sump

drainage, floor drainage, laboratory waste, and radwaste wastewater. Water from the three

monitoring points discharges to Lake Michigan through five pipes at Outfall 001. The NPDES

permit for Palisades (MDEQ 2004) describes the limits for discharges at monitoring point 001A. 

The daily limit for TRO is 38 :g/L for continuous discharge (greater than 160 min/day) and

200 :g/L for intermittent discharge (less than or equal to 160 min/day). During bromine use, the

discharge must be less than or equal to 120 min/day, and the TRO daily limit is 50 :g/L. The

heat addition limit is 2.1 × 109

 Btu/hr. The pH should range between 6.5 and 9.0. Flow and

| TRO discharge time are to be recorded daily, and outfall observations are to be made five times

| per week.

Monitoring point 001D is radwaste wastewater, up to 0.1 million gpd. The flow and total

suspended solids (TSS) are monitored at this point, with a grab sample for TSS analysis for

each batch of wastewater. TSS limits are 30 mg/L monthly and 100 mg/L daily. As discussed

in Section 2.1.4.1, this radwaste wastewater must meet criteria prior to discharge at monitoring

point 001D. Monitoring point 001F is turbine sump water, also up to 0.1 million gpd. The flow

and oil and grease content are monitored, with two grab samples per month for oil and grease

analysis. Oil and grease limits are 15 mg/L monthly and 20 mg/L daily. Discharges from

monitoring points 001D and 001F are monitored prior to discharge to the mixing basin, where

the discharge comingles with other wastewater. 

Palisades applies treatments to control microbiological organisms and the zebra mussel

(Dreissena polymorpha) in the SWS and CWS. NMC uses approved biocides in these systems

to control biofouling problems in accordance with use and discharge requirements, including

provisions of the NPDES permit and special MDEQ approvals required for discharge of water

treatment additives (MDEQ 2004). NMC currently is permitted by MDEQ to use chlorination,

bromination, and application of a quaternary amine formulation for biofouling control

| (MDEQ 2004; Consumers Energy 2003a). Compliance with NPDES permit limits for discharge

of these biocides and associated residuals is confirmed by monitoring.
Plant and the Environment

October 2006 2-23 NUREG-1437, Supplement 27

Discharge Monitoring Reports (DMRs) include daily data on TRO discharge time, oxidants, flow, |

pH, visual inspection, and dechlorination agent, all at monitoring point 001A. Oxidants are |

noted as “not used” on many monthly reports. Betz Clam-Trol treatments are no longer required |

to be reported in DMRs for Palisades, but monitoring during Clam-Trol treatments is performed |

in accordance with the NPDES permit. Temperature data collection at monitoring point 001A is |

conducted in accordance with the NPDES permit. The actual temperature data are not logged |

on the DMRs, but rather the Btu/hr data are presented, as a function of temperature and flow

data. The permitted maximum for heat addition is 2.1 × 109

 Btu/hr (MDEQ 2004).

Several violations of NPDES permitting requirements have been issued by the MDEQ in the last

5 years. One was a minor oily sheen and discharge to Lake Michigan on April 6, 2001. The

sheen was within 2 to 5 ft of the lakeshore and was remediated with an oil boom. Another was

a septic lift station pump failure on February 12, 2002, during which about 300 gal of liquid

sewage (no solids) overflowed into storm drains, which drained onto beach sands (Consumers

Energy 2002). According to a notification submitted to the MDEQ, the incident did not cause

adverse impact to the environment or the public (Consumers Energy 2002).

EPA Region 5 manages a Web site of quarterly listings of facilities in noncompliance

(EPA 2005a). In the second quarter of 2001, violations such as “report overdue” and |

“compliance schedule overdue” are posted for the Palisades plant, and “incomplete/deficient

report” is listed for each compliance parameter. In subsequent quarters, “continuing

noncompliance” notices are listed for the compliance parameters. The initial violations stem

from a delinquent annual review of the Storm Water Pollution Prevention Plan (SWPPP)

(NMC 2001b). The MDEQ (2005c) has documented that the noncompliance notices in the |

online database are erroneous, and the facility is in compliance.

Seven field surveys conducted from August 2000 to June 2003 provide information on the

thermal characteristics of the cooling water discharged to Lake Michigan and the resulting

thermal plume in the lake. The surveys include temperature measurements while the plant was

operating at near-maximum power levels at a discharge flow rate of 92,500 gpm. Results of the

surveys indicate that the thermal plume is much smaller than it was when Palisades had its

initial once-through cooling system and that the plume is generally at the surface. The area of

the plume (the 3°F isotherm) ranged seasonally from 40 to 286 ac at the lake surface and from

0 to 19 ac at a depth of 3 ft. The 3°F isotherm was seldom noted to extend at or below a depth

of 5 ft. The temperature of the plant cooling-water discharge during the surveys ranged from

77 to 98°F, corresponding to approximately 25 to 34°F above the ambient lake temperature in

all seasons except winter. During the winter survey, conducted March 19, 2001, the ambient

lake temperature was 34°F, the discharge temperature was approximately 78°F, or 44°F above

ambient, and the plume area at the surface was approximately 76 ac. According to the NPDES

permit, Palisades must make gradual changes to thermal inputs to the lake to avoid fish

mortality due to cold shock during the winter months (MDEQ 2004).
Plant and the Environment 

NUREG-1437, Supplement 27 2-24 October 2006

The applicant monitors the septic sludge twice per year. A 1-L dip sample is taken at each

sampling event, and it is analyzed through a gamma scan. Septic waste is hauled to the Benton

| Harbor-St. Joseph Wastewater Plant. Septic field effluent is not monitored. 

| The Palisades SWPPP notes that the septic system has the potential to overflow and reach

| storm water outflow SW-4 by way of a catch basin (Consumers Energy 2003b). To prevent this,

an alarm system, structural curb, and backup pump have been installed. The SWPPP also

notes that storm water outflow SW-6, which discharges to monitoring point 001A, includes floor

drains in the Turbine Building. Therefore, the building has sediment bags or socks to collect

debris and sediment, and an oil boom is installed across the mixing basin. 

2.2.4 Air Quality

The Palisades site is located in the Moist Continental Climate zone, characterized by the

dominance of tropical air masses in summer and polar air masses in winter and by the presence

of deciduous forest that covers the Great Lakes region of the United States and Canada. 

Seasonal changes between summer and winter are very large, with an average seasonal

temperature change of 46°F. Daily temperatures also change often. Abundant precipitation

falls throughout the year but increases in the spring and summer seasons due to invading

tropical air masses. Cold winters are caused by polar and arctic air masses moving south. 

Local precipitation occurs throughout the year, with a typical increase in rainfall in summer. 

Meteorological records for southwestern Michigan (i.e., the South Haven area) are generally

representative of the Palisades site. The data from this area indicate that the lowest

precipitation amounts for the year generally last for about a month or two, typically in February. 

Mean or normal monthly temperatures for southwestern Michigan range from 13.4 to 35.3°F in

January to 65.5 to 77.6°F in July and August (MRCC 2005). The mean annual precipitation for

the region is 35.8 in. Normal monthly precipitation ranges from 1.7 to 2.5 in. in the dry season

(January to March) to 3.6 to 4.1 in. in the wet season (July to September) (NOAA 2002).

Onsite meteorological conditions at Palisades are monitored at three levels: 10, 30, and 100 m

from the main meteorological tower. The tower winds (speed and direction) and temperature

are measured at two levels, 10 and 30 m, including horizontal wind direction variations. 

Atmospheric stability is calculated from temperature differences taken from readings between

the 30- and 10-m levels. Hourly data from readings recorded from both levels and annual

summaries, including wind roses, can be found in the Palisades meteorological monitoring

| semiannual report (Consumers Energy 2005a). Winds during the winter season tend to be

stronger, with mean winds at the 100-m level exceeding 9 mph, and are predominately out of

the southwest. During the summer, winds are more often from the southwest and are from the

north-northwest more than 20 percent of the time; in the fall, they are from the southeast to

| south-southeast about 19 percent of the time (Consumers Energy 2005a).
Plant and the Environment

(a) Tornado wind speeds for the F-0 to F-4 categories are in the following ranges: F-0: 40 to 72 mph; 

F-1: 73 to 110 mph; F-2: 113 to 157 mph; F-3: 158 to 206 mph; and F-4: 207 to 260 mph |

(Fujita 1987).

October 2006 2-25 NUREG-1437, Supplement 27

Over the past 55 years, severe thunderstorms with winds exceeding 58 mph or with resulting

property damage occurred on average about once per year (NOAA 2005). During the period

from the middle of March to the middle of November, the daily occurrence of thunderstorms and

high winds is less than once every 2 months, with a total of 103 thunderstorm and wind damage

reports filed for Van Buren County from January 1, 1950, to May 31, 2005. Through the last half

of the last century to the present, 1950 to 2005, a total of 16 tornadoes touched down in Van

Buren County (NOAA 2005). The majority of these (13 strikes) produced slight or moderate

property damage, less than $25,000 and less than $250,000, respectively. These storm events

were categorized in the low-to-moderate intensity range of the Fujita Tornado Scale, that is, F-0,

F-1, and F-2 category tornados.(a) Three F-3 tornado strikes, two that occurred on March 3,

1956, and one on May 13, 1980, caused a total of 21 injures and produced major property

damage totaling approximately $2.5 million for each storm (NOAA 2005). On the basis of

statistics for the 30 years from 1954 through 1983 (NRC 2005a), the probability of a tornado |

striking a point in a 1 degree latitude-longitude square at the site is expected to be about 7 to 8

× 10-4 per year. 

Wind resources are expressed in terms of wind power classes, ranging from Class 1 to Class 7

(PNL 1986). Each class represents a range of mean wind power density or approximate mean |

wind speed at specified heights above the ground. The wind energy resource for most of the

Lake Michigan shoreline region in the State of Michigan, including Van Buren County, has good

wind power potential. The annual average wind power for this part of the State is rated Class 3 |

(PNL 1986). Areas designated Class 3 or greater are suitable for most wind energy |

applications, whereas Class 2 areas are marginal, and Class 1 areas are generally not wind

power suitable.

Air quality in a given area is a function of the air pollutant emissions (type of pollutant; rate,

frequency, and duration; and exit conditions and location of release), atmospheric conditions

(climate and meteorology), the area itself (size of airshed and topography of the area), and the

pollutants transported from outside the area. Air quality within a 31-mi radius of Palisades is

generally considered good, with the exception of areas within 16 mi of designated ozone

nonattainment areas (EPA 2005b). Localized sources of emissions include man-made sources

of commercial, residential, and transportation-related emissions. Natural sources of windblown

dust contribute to temporary increases in air pollution. 

The MDEQ is responsible for air quality in six Air Quality Control Regions (AQCRs) within the

State of Michigan. Palisades is located in Van Buren County, Michigan, and is within AQCR 82
Plant and the Environment 

NUREG-1437, Supplement 27 2-26 October 2006

located in the southwestern corner of the State. AQCR 82 includes two other counties, Berrien

and Cass, just south of Van Buren. This region, with the exception of the 8-hour ozone

standard, is designated as being in attainment or unclassifiable for all criteria pollutants (40 CFR

| 81.333). The AQCR 82 is designated as the Kalamazoo-Battle Creek 8-hour nonattainment

| area for ozone (Clean Air Act Amendments of 1990, Title 1, Part D, Subpart 1). No Prevention

of Significant Deterioration Class I areas are located within 62 mi of Palisades.

Two emergency diesel generators serve the Palisades plant. The two small generators are

| identical and are rated at a nominal capacity of approximately 2500 kilowatts electric (kW(e)). 

The diesels are used for emergency backup power and provide a standby source of electric

power for equipment required for mitigation of the consequences of an accident, for safe

shutdown, and for maintenance of the station in a safe condition under postulated event and

| accident scenarios (NMC 2005d). The diesel generators are tested once a month for 1-, 2-, 3-,

and 4-hour test burn durations. Maintenance tests for each generator (e.g., to replace pumps

and test for leaks) last 24 hours and are run as needed. Twenty-four hour endurance runs are

performed on a staggered test schedule, once every 18 months.

Under the air pollution rules and regulations of the MDEQ, Part 2, R 336.1212, insignificant

activities exemptions, emergency diesel generators meeting certain operating criteria are

exempt from State operating permit requirements. The rules define emergency power

generating units as stationary internal combustion engines that operate as a mechanical or

electrical power source only when the usual supply of power is unavailable. These sources are

provided a permit exemption if their annual emissions are less than significance levels as

defined in R 336.1119. This would apply to operations during emergency situations, routine

maintenance, and routine exercising (e.g., test firing the engine for 1 hour a week to ensure

reliability). Since all of the emergency diesel generators at Palisades operate for a small

number of test hours per year, emissions from these sources are not regulated under

Michigan’s Permit Operating Program. In addition to the emergency diesel generators,

Palisades has three No. 2 diesel oil-fired boilers that are used for evaporator heating, plant

space heating, and feedwater purification. Two units are rated at 6.8 MW/hr and the third at

7.4 MW/hr. All three units are permitted to operate under Michigan’s Air Pollution Control Rule

336.1210(1) (MDEQ 2003).

There are no mandatory Federal Class 1 areas within 100 mi of the Palisades site in which

| visibility is an important value, as designated in 40 CFR Part 81.

2.2.5 Aquatic Resources

Palisades is located on the southeastern shoreline of Lake Michigan, which is the source and

receiving body for the plant’s cooling system. The 40-mi-long Palisades-Argenta 345-kV

transmission line associated with Palisades crosses several streams, including the South

Branch of the Black River, Extension Drain, Veley Drain (a Clear Lake tributary), Pine Creek
Plant and the Environment

October 2006 2-27 NUREG-1437, Supplement 27

(a tributary to the Kalamazoo River), and the Kalamazoo River (NMC 2005a). No streams are

crossed by the 0.6-mi-long Palisades-Cook transmission line. Transmission line right-of-way

maintenance activities in the vicinity of stream and river crossings include procedures to

minimize erosion and shoreline disturbance while encouraging vegetative cover. In addition,

aerial application of herbicides is restricted from riparian areas (NRC 1978).

Water depths in the southeastern portion of Lake Michigan are up to 10 ft within 500 ft of the

shore and up to 50 ft at 1 mi offshore. Lake substrates range from coarse and very coarse sand

in the surf zone, medium sand at the 5-ft-depth zone, and fine sand in deeper waters (NMC

2005a). Open-lake temperatures range from 35°F in January and February to about 75°F in

mid August. Temperatures near the Palisades intake range from a monthly minimum of about

34°F in January to a monthly maximum of about 70°F in August, with a daily minimum and

maximum of about 33°F and 80°F, respectively (NMC 2005a). In the Palisades area, the lake is

thermally stratified in summer but is generally isothermic in early winter and early spring. 

Inshore waters may be substantially warmer than offshore waters in early winter, while being

colder in early spring. These conditions limit mixing of inshore and offshore waters during these

periods. Intermittent ice cover extends 1 to 2 mi offshore during winter (NMC 2005a; AEC

1972).

Lake Michigan is used for a variety of purposes, including navigation, recreation, tourism, and

conservation. The major changes and modifications that have had the greatest impact on

aquatic resources of Lake Michigan include (1) industrial, urban, and residential developments

on the lakefront; (2) water quality impairment from industrial, municipal, agricultural,

navigational, and recreational water uses; (3) overfishing; and (4) invasion of exotic species

(EPA 2004). Overall, the status of Lake Michigan habitats, including open water, wetlands,

coastal shore, and tributaries, is considered “mixed” to “deteriorating” (EPA 2004). Dams,

agricultural and urban development activities, drainage and filling of wetlands, and invasive

species have adversely affected the aquatic resources of the tributary streams to Lake Michigan

(e.g., the Kalamazoo River) (Wesley 2005).

Contamination is emerging as an important concern in fish in Lake Michigan and its tributary

streams (EPA 2004). Some fish cannot be sold commercially because of high levels of PCBs,

mercury, or other substances (Fuller, Shear, and Witting 1995). The State of Michigan has

published advisories governing the consumption of fish from these water bodies. Within the

southeastern portion of Lake Michigan, there are advisories for brown trout (Salmo trutta), lake

trout (Salvelinus namaycush), rainbow trout (Oncorhynchus mykiss), chinook salmon

(O. tshawytscha), coho salmon (O. kisutch), common carp (Cyprinus carpio), channel catfish

(Ictalurus punctatus), rainbow smelt (Osmerus mordax), lake sturgeon (Acipenser fulvescens),

walleye (Sander vitreus), lake whitefish (Coregonus clupeaformis), and yellow perch (Perca

flavescens). PCB advisories have also been issued for common carp, northern pike (Esox
Plant and the Environment 

NUREG-1437, Supplement 27 2-28 October 2006

lucius), and white sucker (Catostomus commersoni) in the Black River, and for all fish species

for some portions of the Kalamazoo River (MDCH 2003).

Despite the modifications and multiple competing uses of Lake Michigan, the overall fish

community is fairly diverse. Almost 100 species of fish occur in Lake Michigan (UWSGI 2001a). 

| Lake Michigan supports commercial, recreational, and tribal fishing. Commercial and tribal

production totals more than 14.6 million lb of fish annually (EPA 2004). Lake whitefish is the

| primary commercial species, while both lake whitefish and lake trout comprise the tribal

fisheries (Stein et al. 2003). Some commercial fishing also targets bloater (Coregonus hoyi)

and rainbow smelt (Madenjian et al. 2004). Sport fishing within the southeastern portion of Lake

Michigan is for lake trout, rainbow trout or steelhead (the migratory form of rainbow trout), brown

trout, coho salmon, chinook salmon, northern pike, smallmouth bass (Micropterus dolomieu),

various sunfish (e.g., bluegill (Lepomis macrochirus), pumpkinseed (L. gibbosus), and rock bass

(Ambloplites rupestris)), yellow perch, and walleye (MDNR 2005d; IDNR 2005). Important

forage species in Lake Michigan include alewife (Alosa pseudoharengus), bloater, rainbow

smelt, and deepwater sculpin (Myoxocephalus thompsoni) (Madenjian et al. 2002, 2005).

Top-level predators in Lake Michigan are dominated by the introduced trout and salmon, while

the native burbot (Lota lota) and lake trout (the original top predators in the lake)

(Madenjian et al. 2004) are recovering. The lake trout is recovering mostly through stocking

rather than natural reproduction. About 2.4 million yearling lake trout are stocked annually into

Lake Michigan (Bronte and Schuette 2002). Reasons that self-sustaining populations of lake

trout have yet to be reestablished in Lake Michigan may include loss of suitable spawning

habitat, environmental contamination, predation on larval lake trout by alewife, thiamine

deficiency from a diet of alewife, and a loss of genetically distinct strains (EPA 2004). About

70 percent of the Great Lakes trout and salmon fishery is dependent upon fish stocking 

(MDNR 2004).

Forty fish species were collected during preoperational and early years of operation at

Palisades. The dominant species included alewife (the major component of the catch), rainbow

smelt, yellow perch (the most numerous game species), spottail shiner (Notropis hudsonius, the

most abundant minnow species), slimy sculpin (Cottus cognatus, which inhabits the rip-rap

around the intake crib), trout-perch (Percopsis omiscomaycus), longnose dace (Rhinichthys

cataractae), longnose sucker (Catostomus catostomus), and white sucker (NMC 2005a;

NRC 1978; AEC 1972). Coho and chinook salmon, steelhead, and lake and brown trout were

also collected during preoperational studies (NMC 2005a).

At least 160 species have been introduced into the Great Lakes since the early 1800s through

the canal system interconnection with the Atlantic Ocean (e.g., sea lamprey (Petromyzon

marinus), alewife, and white perch (Morone americana)), ship ballast (e.g., Asiatic clam

(Corbicula fluminea), zebra mussel (Dreissena polymorpha), spiny water flea (Bythotrephes

cederstroemi), and round goby (Neogobius melanostomus)), or as intentionally introduced
Plant and the Environment

October 2006 2-29 NUREG-1437, Supplement 27

species (e.g., common carp, rainbow smelt, and various salmonids) (EPA 2004; Peeters 1998). 

The non-native salmonids that were introduced to the Great Lakes between 1870 and 1960

include Atlantic species (Atlantic salmon (Salmo salar) and brown trout); Pacific species

(chinook salmon, coho salmon, rainbow trout, kokanee (Oncorhynchus nerka), chum salmon

(O. keta), cutthroat trout (O. clarkii), masu salmon (O. masou), and pink salmon

(O. gorbuscha)); and Arctic species (Arctic charr (Salvelinus alpinus)) (Crawford 2001).

Since the mid-1970s, salmonid stocking in Lake Michigan has included the brook trout, brown

trout, lake trout, rainbow trout/steelhead, chinook salmon, coho salmon, and splake (hybrid

between lake trout and brook trout). Nearly 14.5 million trout and salmon are stocked annually

in Lake Michigan. Atlantic salmon have not been stocked in the lake since 1989 (Bronte and

Schuette 2002). Currently, the only major objective for salmonid stocking is the development

and maintenance of recreational fisheries (Crawford 2001). The stocking of salmonids may

have resulted in the introduction of some non-native fish diseases and parasites to the Great

Lakes and caused genetic alteration of native salmonids through hybridization and introgression

and/or through declines in the abundance of native salmonids. Also, stocked salmonids may

present a direct threat to native and non-native forage fish and invertebrates, while placing

competitive pressure upon native fish species for food and habitat resources (Crawford 2001).

The native fish species of Lake Michigan have been affected by introduced aquatic species,

most notably the sea lamprey and alewife. Both species have adversely affected native fish

species, including commercially and/or recreationally important species such as the cisco

(Coregonus artedi), lake whitefish, burbot, and lake trout (Madenjian et al. 2002). Combined

with overfishing, the introduction of the sea lamprey led to the extirpation of the longjaw cisco

(C. alpanae), deepwater cisco (C. johannae), and blackfin cisco (C. nigripinnis) from

Lake Michigan (Fuller and Nico 2000). Sea lamprey abundance remains higher than desired in

Lake Michigan. This limits rehabilitation efforts for lake trout, despite the stocking program

previously mentioned (Stein et al. 2003). Other impediments to sustainable reproduction of lake

trout in Lake Michigan relate to the following: (1) the lakewide population is too low,

(2) spawning aggregations are too diffuse and in inappropriate locations, and (3) there is poor

survival of early life stages (Bronte et al. 2003).

The alewife was first reported from Lake Michigan in 1949, and by 1967 it made up about

85 percent of the fish biomass of the lake (Peeters 1998). Its increase was aided by the

decrease in its main predators (lake trout and burbot) caused by the sea lamprey. The

population explosion of alewives led to the decline of native planktivorous fishes such as the

emerald shiner (Notropis atherinoides), lake whitefish, cisco, and a number of coregonine

species (Peeters 1998; Fuller and Nico 2000). The alewife is the most important prey species

for salmonids in Lake Michigan. The alewife’s estimated lakewide biomass decreased from

42,876 metric tons in 2003 to 13,721 metric tons in 2004 (Madenjian et al. 2005). Currently,

there is no commercial fishery for alewives in Lake Michigan (Madenjian et al. 2004). 
Plant and the Environment 

NUREG-1437, Supplement 27 2-30 October 2006

Alewives are easily stressed, and during peak population levels, stress can result in large

die-offs in the spring. They are affected by both osmotic stress associated with life in

freshwater and exposure to fluctuating water temperatures when they move to inshore waters

(e.g., exposure to colder waters during an upwelling event can cause the fish to die;

UWSGI 2002). Susceptibility to cold is related to inadequate fat reserves

(Eshenroder et al. 1995). In spring, alewives are also in a weakened condition because of a

lack of forage in the winter and by stress related to spawning (UWSGI 2001b). Adult alewives

feed little, if at all, during their spawning migration (DFO 2004). Large numbers of spawning

alewives can occur in nearshore waters as a result of strong year classes produced in the prior

3 or more years. Fish that become weak or die during rapid temperature change can be blown

into windrows close to shore or can wash onto beaches (UWSGI 2002). Adult mortality

following spawning may be as high as 40 to 60 percent (DFO 2004). Therefore, potentially

large numbers of both moribund and dead alewives can be found in inshore waters during the

spawning season. The alewife spawning season generally occurs from late May to early

August, peaking in June and July, in the southeastern portion of the lake (Jude 1995).

The white perch preys on eggs of walleye and other species (including its own), zooplankton,

macroinvertebrates, and minnows. It may compete with yellow perch, emerald shiner, and

spottail shiner for food resources (Fuller 2003).

The round goby first appeared in southern Lake Michigan in 1994 (Fuller and Benson 2003). It

feeds on the eggs and young of other bottom-dwelling fish species, zebra mussels, snails,

soft-shelled crayfish, aquatic insects, and zooplankton. The round goby inhabits a wide variety

of habitats but prefers rock, cobble, or rip-rap (Manz 1998). This is the type of habitat found

around the Palisades intake. The round goby has a long spawning season (it may spawn up to

six times during the breeding season) and aggressively defends its spawning area. It displaces

native sculpins and darters and impacts recreationally important centrarchids (sunfish and bass)

and lake trout (GLSC 2003; Marsden and Chotkowski 1995; Manz 1998; Ray and Corkum

1997). However, to date, no lakewide changes in the abundance of any Lake Michigan species

have been ascribed to the round goby invasion (Madenjian et al. 2002). 

The ruffe (Gymnocephalus cernuus), native to Europe and Asia, was introduced to the Great

Lakes in ship ballast. This species also has the potential to disrupt fish community structure

within the lake through competition or modification of plankton and macroinvertebrate

populations (Jude 1995). 

The plankton community of Lake Michigan may be changing as a result of the presence of

contaminants and nutrients in the water and sediment as well as the presence of exotic species

such as the zebra mussel and spiny water flea (EPA 2004). Phytoplankton abundance and

production in nearshore areas have decreased since 1970, probably due to a reduction in

phosphorus loading (Madenjian et al. 2002). Phytoplankton in southeastern Lake Michigan is

dominated by diatoms, while green algae and blue-green algae were not found to be abundant
Plant and the Environment

October 2006 2-31 NUREG-1437, Supplement 27

near Palisades (AEC 1972; NRC 1978). Periphyton (attached algae) and rooted aquatic plant

growth is limited in the Palisades area because of shifting sandy-gravel substrates (NRC 1978;

NMC 2005a). The water intake structure and other underwater components provide artificial

habitats for periphyton.

The zooplankton community in Lake Michigan near Palisades is abundant and fairly diverse. 

Copepods and cladocerans dominated the zooplankton community near Palisades (NRC 1978). 

Predation by the spiny water flea has caused a significant decline in three offshore

Daphnia spp. that are a prey source for young-of-year fish (Lehman 1991). The spiny water flea

population grows rapidly, partly due to its parthenogenic asexual reproduction. Its rapid

population growth allows it to monopolize the zooplankton food supply, which can be

detrimental to fishes such as the bloater (GLSGN 1991).

The benthic macroinvertebrate community near Palisades was dominated by Diporeia spp.

(formerly known as Pontoporeia spp., an amphipod), chironomids (midges), aquatic worms, and

fingernail clams (NRC 1978; NMC 2005a). Nearshore benthic macroinvertebrate communities

have been altered dramatically since the 1960s because of a reduction in phosphorus and other

nutrient loads and the establishment of the zebra mussel (Madenjian et al. 2002).

The zebra mussel was first discovered in Lake Michigan in 1988. Its impacts fall into three main

categories: (1) biofouling, (2) filter feeding, and (3) nutrient dynamics (Garton 2002). The zebra

mussel has impacted aquatic communities by consuming zooplankton and phytoplankton

(fundamentally altering the foodchain) and by displacing native mussels (Garton 2002;

Madenjian et al. 2002). Zebra mussels have eliminated native mussels from some areas of the

Great Lakes and can exclude gastropods (snails) and net-spinning caddisflies from hard

substrates through competition for food and space (Stewart et al. 1998a). However, they

consistently cause increases in the total macroinvertebrate biomass and densities of

hydrozoans, flatworms, and amphipods on hard benthic substrates because their shells

enhance surface area, substrate heterogeneity, and accumulation of benthic organic matter

(Horvath et al. 1999; Stewart et al. 1998a).

It is suspected that the lakewide population decline of Diporeia spp. is linked to the introduction

of the zebra mussel, which has severely limited the food available to Diporeia spp. (EPA 2004). 

Declines of Diporeia spp. might be the cause of decline in the abundance of lake whitefish and

slimy sculpin (Madenjian et al. 2004; Stein et al. 2003) and decline in alewife condition

(Madenjian et al. 2002). Reduced biomass of phytoplankton, zooplankton, and Diporeia spp.

caused by zebra mussels may adversely affect rainbow smelt and young salmonids, which in

turn would affect predators of these fishes. However, freshwater drum (Aplodinotus grunniens),

rock bass, yellow perch, and other benthivorous fish species consume large numbers of

gammarid amphipods, crayfish, zebra mussels, and other benthic macroinvertebrates that have

increased in abundance (Stewart et al. 1998a,b). |
Plant and the Environment 

NUREG-1437, Supplement 27 2-32 October 2006

The zebra mussel is cold-tolerant and is considered a potential serious biofouling problem at

power plants. Zebra mussels can accumulate on the inside of intake tunnels; intake cribs; and

screenhouse walls, floors, and trash racks. Large piles of zebra mussels that slough off from

other areas can accumulate on screenhouse floors in areas of low flow and against

out-of-service traveling screens. Approved biocides are used, in accordance with NPDES

| permit requirements (MDEQ 2004), to control zebra mussels (Consumers Energy 2003a;

| NMC 2005a).

The amphipod Echinogammarus ischnus and the quagga mussel (Dreissena bugensis), a

species similar to the zebra mussel, have recently been reported in Lake Michigan. Both

species will likely contribute to further food-web modifications in the lake. The quagga mussel

may further decrease the abundance of Diporeia spp. in offshore areas, while E. ischnus may

become an important food item for many fish species (Nalepa et al. 2001).

No Federally listed threatened, endangered, proposed, or candidate aquatic species occur in

Lake Michigan in the vicinity of Palisades. In addition, no Federally listed aquatic species are

listed for Allegan, Kalamazoo, and Van Buren Counties within which the Palisades-Argenta

transmission line occurs (FWS 2005a; MNFI 2005a,b). Also, no designated critical habitat for

aquatic species occurs in the site vicinity. State-listed aquatic species that have the potential to

occur in the vicinity of Palisades and its associated transmission lines are presented in

Table 2-1.

2.2.6 Terrestrial Resources

The Palisades site is located in the glacial plain of Lake Michigan, where sand dunes up to

200 ft high occur in a band along the lakeshore, and generally flat to gently rolling glacial

features occur eastward (NMC 2005a). Forests dominated by American beech (Fagus

grandifolia), sugar maple (Acer saccharum), and eastern hemlock (Tsuga canadensis) made up

much of the original vegetation of the region (MNFI 2005c); however, timber harvest, sand

mining, and drainage of wetlands have greatly altered the landscape (NMC 2005c). Most of the

land in the region is now devoted to agriculture, including blueberry farming on poorly drained

sites and orchards and vineyards on better drained soils (NMC 2005a).

The entire Palisades site is protected under the CZMA and Michigan’s Coastal Zone

Management Program (MDEQ 2005a). About 80,000 ac of Lake Michigan sand dunes in

Michigan, including those within the Palisades site, are classified and protected as Critical Dune

Areas under authority of Michigan’s Natural Resources and Environmental Protection Act,

Part 353 (MDEQ 2005b). Development activities in designated critical dune areas, including

those on the site, require an environmental impact assessment and permit from MDEQ

(MDEQ 2005b).
Plant and the Environment

October 2006 2-33 NUREG-1437, Supplement 27

Table 2-1. State-Listed Aquatic Species Potentially Occurring in the Vicinity of Palisades

and Associated Transmission Lines

Scientific

Name

Common

Name

Michigan

Status(a) County(a) Habitat

Plants

Lemna valdiviana pale duckweed X K, V Ponds, marshes

Insects

Stenelmis

douglasensis

Douglas

stenelmis riffle

beetle

SC K On wood in lakes, streams,

and rivers

Mussels and Snails

Alasmidonta viridis slippershell

mussel

SC A Small to medium lakes; small

tributaries to large rivers

Cyclonaias

tuberculata

purple

wartyback

SC A Moderate gradient of medium to

large rivers

Funtigens nickliniana watercress snail SC K Ponds, small lakes, small

streams

Fish

Acipenser fulvescens lake sturgeon T A Large rivers and shallow water of

large lakes

Lepisosteus oculatus spotted gar SC A, K Nearshore areas of medium to

large lakes; medium to large

rivers

Coregonus artedi lake herring T A, K Nearshore areas of medium to

large lakes; large rivers

Hiodon tergisus mooneye T A Nearshore areas of medium to

large lakes; large rivers

Erimyzon oblongus creek

chubsucker

E A, K Low-gradient creeks

Notropis anogenus pugnose shiner SC K, V Small to medium lakes; small

tributaries to medium rivers

Notropis texanus weed shiner X A, K Sand-bottomed creeks; sloughs

and large rivers

(a) A = Allegan County, E = endangered, K = Kalamazoo County, SC = special concern, 

T = threatened, V = Van Buren County, X = probably extirpated.

Sources: Brown 1976; Carman 2002a,b; Consumers Energy and NMC 2001; Cummings and Mayer 1992; Eagle |

et al. 2005; FWS 2003; MNFI 2005a,b; Page and Burr 1991; NatureServe 2005; Scott and Crossman 1973; Smith |

1979.
Plant and the Environment 

NUREG-1437, Supplement 27 2-34 October 2006

Developed or maintained areas occupy about 80 ac of the 432-ac Palisades site. Most

(about 68 percent) of the undeveloped portions of the Palisades site are dominated by forest. 

The most extensive forest community type is a red oak (Quercus rubra), sassafras (Sassafras

albidium), sugar maple, and American beech association. This forest is typical of many

rear-dune areas along the Lake Michigan shoreline and appears to have a well-balanced,

all-age structure (NMC 2005a). A portion of this community near the southern site boundary is

recognized as important habitat by the Michigan Natural Features Inventory (MNFI) (Higman

and Goff 1991; Goff 1992). Most of the remaining forest on the site is a second-growth

community dominated by red oak, white ash (Fraxinus americana), sassafras, and sugar maple.

Early successional plant communities on the Palisades site include old-field and upland

scrub-shrub, which occupy portions of transmission line rights-of-way, abandoned railroad bed,

disturbed sites around buildings, forest openings, borders of forested areas, and dune blowouts

(NMC 2005a). These communities occupy about 10 percent of the site.

Portions of steep dunes and flats at the base of dunes that are on or adjacent to developed

areas have been stabilized with plantings of beach grass (Ammophila breviligulata) and dune

grass (Calamovilfa longifolia) or are stabilized by natural colonization of these species

(NMC 2005a). These areas occupy about 10 percent of the site. Sand dune blowouts

(4 percent of the site) occur where wind action has disturbed established vegetation and

resulted in dune destabilization. About 3 percent of the site is open sand (beach and other

unvegetated flat areas).

Wetland communities occupy a total of about 9 ac (2 percent of the site area) but are generally

small and widely scattered (NMC 2005a). The largest wetland on site is located just north of the

Palisades Substation and is a seasonally inundated wetland dominated by black gum (Nyssa

sylvatica), willow (Salix spp.), and reedgrass (Calamogrostis spp.). Similar small wetlands

occur in the transmission right-of-way on the eastern border of the site, and a small forested

wetland dominated by black gum is located north of the Outage Building sanitary waste

drainfield.

Approximately 5 ac of vegetation (1 percent of the site) on dune ridges adjacent to and

southeast of the cooling towers have been affected by condensate plumes and drift

(NMC 2005a). Drift from operation of the two mechanical draft cooling towers has resulted in

the replacement of the original mature trees with an early succession dense scrub-shrub

community. Some standing dead trees remain from the original forest. Rochow (1978a)

described the sequence of vegetation change in drift-impacted areas at Palisades. Three to

four months after cooling tower start-up, white pines began to show signs of chemically induced

injury in areas up to 295 ft from the towers. Deciduous trees began showing visible signs of

injury during the second summer of operation. High deposition rates of sulfate were considered

| responsible for this damage (Rochow 1978a,b). Severe icing of vegetation in the winter of 1976
Plant and the Environment

October 2006 2-35 NUREG-1437, Supplement 27

to 1977 resulted in extensive damage of trees, and by the third summer of operations, the forest

canopy had been nearly eliminated in the most severely impacted areas.

Site surveys have documented a variety of terrestrial vertebrates on the site, including

4 amphibian, 3 reptile, 113 bird, and 14 mammal species. Amphibians include northern leopard

frog (Rana pipiens), spring peeper (Pseudacris crucifer), American toad (Bufo americanus), and

red-backed salamander (Plethodon cinereus). Reptiles on the site include the eastern box turtle

(Terrapene carolina), eastern hognose snake (Heterodon platyrhinos), and blue racer (Coluber

constrictor). Birds on the site include killdeer (Charadrius vociferus), ring-billed gull (Larus

delawarensis), northern flicker (Colaptes auratus), blue jay (Cyanocitta cristata), black-capped

chickadee (Poecile atricapillus), gray catbird (Dumetella carolinensis), American robin (Turdus

migratorius), red-winged blackbird (Agelaius phoeniceus), American goldfinch (Carduelis tristis),

and eastern towhee (Pipilo erythrophthalmus). Mammals on the site include white-tailed deer

(Odocoileus virginianus), eastern cottontail (Sylvilagus floridanus), raccoon (Procyon lotor), red

fox (Vulpes vulpes), white-footed mouse (Peromyscus leucopus), eastern chipmunk (Tamias

striatus), and thirteen-lined ground squirrel (Spermophilus tridecemlineatus).

The landscape crossed by the Palisades-Cook transmission line and the western portion of the

Palisades-Argenta line is similar to that of the Palisades site; however, the eastern portion of the

Palisades-Argenta transmission line in Van Buren County crosses an area with moderate to

steep slopes and scattered kettle depressions that are poorly drained (NMC 2005a). Most of

the original vegetation of this portion of the project area was forest dominated by American

beech, sugar maple, and white oak (Quercus alba). However, swamp hardwoods, tamarack

(Larix laricina), wetland shrubs, and bogs occurred in kettle depressions, and wet prairie and

emergent marsh were found in other poorly drained sites (MNFI 2005c; NMC 2005a). Most of

the area is now used for agriculture. In Kalamazoo County, the Palisades-Argenta line

traverses a glacial outwash plain with flat to gently sloping terrain. Prior to settlement, tallgrass

prairies, oak savannas, wet prairies, marshes, and extensive wet meadows were present |

(MNFI 2005c; NMC 2005a). Most uplands and large areas of wetland in this region have been

converted to agriculture. Although prairie fens remain common in the region, tallgrass prairie,

wet prairie, and oak savanna are now quite rare (NMC 2005a).

Approximately 38 percent of the land within transmission line rights-of-way associated with

Palisades is classified as active agricultural land (NMC 2005a). Approximately 28 percent and

25 percent of the rights-of-way are forest (mostly hardwoods) and rangeland (mostly shrubland),

respectively, and about 7 percent of the area traversed consists of urban and developed areas

such as roadways.

The percent of area within Palisades rights-of-way occupied by wetland communities was

estimated by the applicant as 2 percent (primarily scrub-shrub) by using State land-use data but

as 18 percent by using the U.S. Fish and Wildlife Service (FWS) National Wetland Inventory
Plant and the Environment 

NUREG-1437, Supplement 27 2-36 October 2006

(NMC 2005a). Nearly all of these wetlands are seasonally or temporarily flooded palustrine

emergent and, to a lesser extent, seasonally flooded palustrine scrub-shrub habitat. Wetlands

within the corridors are generally associated with unnamed streams in the Brandywine Creek,

South Branch Black River, Paw Paw River, and Kalamazoo River watersheds.

Areas of natural vegetation traversed by the lines are maintained to ensure compatibility with

the line by using a vegetation-management protocol that involves periodic selective removal of

woody vegetation to promote and maintain herbaceous plant communities beneath the

conductors and low-growing shrubs and other compatible vegetation in the border zones. 

Vegetation maintenance beyond the border zone is limited to selective removal of trees that

could come into contact with the line (NMC 2005a). Right-of-way maintenance activities are on

an approximate 4- to 6-year schedule; although mowing is occasionally used for vegetation

maintenance, selective application of registered herbicides is the preferred method of

vegetation control. Compatible land uses (e.g., cropland, pastureland) are allowed to continue

on the right-of-way. No access road exists along the right-of-way, and access is gained on foot

and with the use of all-terrain vehicles.

Federally listed and State-listed, proposed, or candidate terrestrial species found in Allegan,

Kalamazoo, and Van Buren Counties and, therefore, possibly present on the Palisades site or

the transmission line rights-of-way associated with Palisades are included in Table 2-2. No

designated critical habitat occurs on the Palisades site or vicinity, or on the associated

transmission line rights-of-way.

The NRC contacted the FWS and requested information on Federally listed and proposed

threatened and endangered species, candidate species, and critical habitat on and near the

Palisades site (NRC 2005b). In its response, the FWS stated that four Federally listed species

and one Federal candidate for listing could occur in the project area (FWS 2005c). These

include the Pitcher’s thistle (Cirsium pitcheri; threatened), Karner blue butterfly (Lycaeides 

melissa samuelis; endangered), Mitchell’s satyr butterfly (Neonympha mitchelli mitchelli;

endangered), Indiana bat (Myotis sodalis; endangered), and eastern massasauga rattlesnake

(Sistrurus catenatus catenatus; candidate).

Pitcher’s thistle is the only Federally listed species known to exist on the Palisades site

(NMC 2005a). It occurs on the site in open habitats on the dunes, including dune blowouts. 

The species is a perennial, herbaceous plant that is endemic to the nonforested dunes of the

western Great Lakes and requires active dune processes to maintain early successional habitat

(FWS 2005c). In Michigan, Pitcher’s thistle is most common in the dunes of the northern and

northeastern shores of Lake Michigan and exists in scattered populations along the perimeter of

southeastern Lake Michigan (MNFI 2005c).
Plant and the Environment

October 2006 2-37 NUREG-1437, Supplement 27

Table 2-2. Federally Listed and State-Listed Terrestrial Species Potentially Occurring

on or in the Vicinity of Palisades and Associated Transmission Lines

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Plants

Agalinis gattingeri Gattinger’s gerardia – E Sandy, rocky, or clayey slopes;

open woods; barrens;

Kalamazoo County

Aristida

tuberculosa

beach three-awned

grass

– T Sandy barrens; Van Buren

County

Aristolochia

serpentaria

Virginia snakeroot – T Southern floodplain forests, rich

dry-mesic forests; Van Buren

County

Aster sericeus western silvery aster – T Prairies, dry banks, fields;

Kalamazoo County

Astragalus

canadensis

Canadian milk-vetch – T Oak barrens, moist openings,

wet ground, sandy lake shores;

Kalamazoo County

Baptisia

leucophaea

cream wild indigo – E Openings of dry to dry-mesic

forest; Kalamazoo County

Bartonia

paniculata

panicled screw-stem – T Coastal plain marsh; Allegan

and Van Buren Counties

Berula erecta cut-leaved

water-parsnip

– T Cold spring-fed drainages;

recorded within 1 mi of

Palisades-Argenta line (1940s);

Allegan, Kalamazoo, and Van

Buren Counties

Besseya bullii kitten-tails – T Oak savanna remnants on

steep hillsides; Kalamazoo and

Van Buren Counties

Calamagrostis

stricta

narrow-leaved

reedgrass

– T Streams, marshes, fens,

mudflats; Kalamazoo County

Carex

albolutescens

greenish-white sedge – T Intermittent wetlands, lake

margins, wet prairies; Allegan

and Kalamazoo Counties

Carex lupuliformis false hop sedge – T Deciduous and mixed swamps

in southern Michigan;

Kalamazoo County
Plant and the Environment 

NUREG-1437, Supplement 27 2-38 October 2006

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Carex platyphylla broad-leaved sedge – T Mesic forests formed on dunes;

Van Buren County

Carex oligocarpa eastern few-fruited

sedge

– T Rich deciduous woods;

Kalamazoo County

Carex seorsa sedge – T Swamps and buttonbush

depressions; recorded (1985)

within 1 mi of Palisades site;

Kalamazoo and Van Buren

Counties

Carex straminea straw sedge – E Low ground, marshes, and

swamps; Kalamazoo County

Castanea dentata American chestnut – E Upland forest; Kalamazoo

County

Cirsium pitcheri

|

Pitcher’s thistle T T Great Lakes shorelines and

sand dunes; found in dune

blowouts and other open dune

habitats on the site; more than

100 individual plants found

onsite in July 2005 in the

northwestern portion of the site

near Van Buren State Park

| (NMC 2006c); Allegan and Van

Buren Counties

Coreopsis

palmata

prairie coreopsis – T Mesic prairies along railroad

rights-of-way; Kalamazoo and

Van Buren Counties

Corydalis flavula yellow fumewort – T Oak savannas and floodplain

forests; Kalamazoo County

Cypripedium

candidum

white lady-slipper – T Alkaline wetlands; Kalamazoo

and Van Buren Counties

Diarrhena

americana

beak grass – T Floodplain forests; Kalamazoo

County

Draba reptans creeping

whitlow-grass

– T Oak savanna and prairie;

Kalamazoo County
Plant and the Environment

October 2006 2-39 NUREG-1437, Supplement 27

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Dryopteris celsa log fern – T Acidic, humus-rich soils in

hardwood swamps and

floodplain forests; Kalamazoo

and Van Buren Counties

Echinodorus

tenellus

dwarf burhead – E Intermittent, seasonally

inundated wetlands within oak

barrens; Allegan County

Eleocharis

compressa

flattened spike-rush – T Limestone pavement and

grassland; Kalamazoo County

Eleocharis

microcarpa

small-fruited

spike-rush

– E Intermittent, seasonal wetlands;

Allegan County

Eleocharis

tricostata

three-ribbed

spike-rush

– T Wetlands with a fluctuating

water table; Allegan County

Eryngium

yuccifolium

rattlesnake-master – T Sedge and grass-dominated

portions of prairie fens;

Kalamazoo and Van Buren

Counties

Eupatorium

sessilifolium

upland boneset – T Slopes of oak savannas;

Kalamazoo County

Euphorbia

commutata

tinted spurge – T Sandy areas of riparian hillsides

and open woods; Allegan

County

Filipendula rubra queen-of-the-prairie – T Prairie fen; Kalamazoo County

Fuirena squarrosa umbrella-grass – T Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

Kalamazoo and Van Buren

Counties

Galearis

spectabilis

showy orchis – T Rich deciduous woods, often

near temporary spring ponds;

Kalamazoo and Van Buren

Counties

Gentiana flavida white gentian – E Dry or moist prairies and oak

woodlands; Kalamazoo County
Plant and the Environment 

NUREG-1437, Supplement 27 2-40 October 2006

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Gentiana

puberulenta

downy gentian – E Edges of coastal plain marshes

in oak barrens; Allegan County

Gentianella

quinquefolia

stiff gentian – T Wet meadows; Kalamazoo

County

Geum triflorum prairie-smoke – T Lower slopes of dry sand

prairie; Allegan County

Gillenia trifoliata Bowman’s root – T Oak barrens; Kalamazoo

County

Helianthus mollis downy sunflower – T Prairie remnants and oak

barrens; Kalamazoo County

Hydrastis

canadensis

goldenseal – T Southern hardwood forests and

moist ravines and portions of

riparian forests; Allegan,

Kalamazoo, and Van Buren

Counties

Isoetes

engelmannii

Appalachian quillwort – E Intermittent wetlands; Allegan

County

Isotria verticillata whorled pogonia – T Successional oak and red

maple forest; Kalamazoo and

Van Buren Counties

Juncus

brachycarpus

short-fruited rush – T Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

Allegan County

Juncus scirpoides scirpus-like rush – T Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

recorded within 1 mi of

Palisades-Argenta line (1983);

Allegan, Kalamazoo, and Van

Buren Counties

Juncus vaseyi Vasey’s rush – T Wet prairies, moist sandy

barrens, and open marshy flats

or swales; Allegan County
Plant and the Environment

October 2006 2-41 NUREG-1437, Supplement 27

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Lechea pulchella Leggett’s pinweed – T Seasonally inundated

intermittent wetlands; Allegan

and Kalamazoo Counties

Linum virginianum Virginia flax – T Open oak forests, upland

woods, and lakeside and

riparian forests; Kalamazoo and

Van Buren Counties

Ludwigia

sphaerocarpa

globe-fruited seedbox – T Muddy shores of lakes,

marshes, and streams; Allegan

and Van Buren Counties

Lygodium

palmatum

climbing fern – E Moist thickets and woods;

Kalamazoo County

Morus rubra red mulberry – T Southern floodplain forest;

Kalamazoo County

Muhlenbergia

richardsonis

mat muhly – T Limestone pavement

communities; Kalamazoo

County

Nelumbo lutea American lotus – T Marshes and large rivers;

Kalamazoo County

Panax

quinquefolius

ginseng – T Rich shaded forests; Allegan,

Kalamazoo, and Van Buren

Counties

Panicum leibergii Leiberg’s panic-grass – T Dry prairies and open areas in

savannas; Kalamazoo and Van

Buren Counties

Panicum

longifolium

long-leaved

panic-grass

– T Seasonally flooded wetlands in

shallow depressions; Allegan

County

Panicum

verrucosum

warty panic-grass – T Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

Van Buren County

Platanthera ciliaris orange or yellow

fringed orchid

– T Acid swamps; Allegan,

Kalamazoo, and Van Buren

Counties
Plant and the Environment 

NUREG-1437, Supplement 27 2-42 October 2006

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Poa paludigena bog bluegrass – T Bogs, swamps, and wet woods;

Kalamazoo County

Polygonum careyi Carey’s smartweed – T Coastal plain marshes and

intermittent wetlands; Allegan

and Van Buren Counties

Populus

heterophylla

swamp or black

cottonwood

– E Swamp forest; Kalamazoo

County

Potamogeton

bicupulatus

waterthread

pondweed

– T Coastal plain marshes and

intermittent wetlands; Allegan

and Van Buren Counties

Psilocarya

scirpoides

bald-rush – T Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

Allegan, Kalamazoo, and

Van Buren Counties

Rhynchospora

globularis

globe beak-rush – E Coastal plain marshes, sandy

lake edges, dune swales,

seepages, and sandy marshes;

Allegan County

Sabatia angularis rose-pink – T Moist sandy shores,

depressions in dunes, marshy

ground and edges of lakes;

Kalamazoo and Van Buren

Counties

Schoenoplectus

hallii

Hall’s bulrush – T Intermittent wetlands within oak

barrens; Allegan County

Scleria pauciflora few-flowered nut-rush – E Sandy edges of intermittent

wetlands; Van Buren County

Scleria reticularis netted nut-rush – T Seasonally flooded wetlands in

glacial lakeplain landscapes;

Allegan and Van Buren

Counties

Silene stellata starry campion – T Dry, open woodlands on sandy

soils; Kalamazoo County

Silphium

integrifolium

rosinweed – T Mesic prairie; Kalamazoo and

Van Buren Counties
Plant and the Environment

October 2006 2-43 NUREG-1437, Supplement 27

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Silphium

laciniatum

compass-plant – T Mesic prairies; Kalamazoo

County

Silphium

perfoliatum

cup-plant – T Openings in floodplain forests;

Kalamazoo County

Sisyrinchium

atlanticum

Atlantic

blue-eyed-grass

– T Moist sandy shores; Allegan

County

Solidago

missouriensis

Missouri goldenrod – T Dry sand prairie; Kalamazoo

County

Spiranthes ovalis lesser ladies’-tresses – T Open, sandy soil, old roads,

and open fields; Kalamazoo

County

Stellaria

crassifolia

fleshy stitchwort – T Cold springs and seeps along

rivers; Kalamazoo County

Trichostema

dichotomum

bastard pennyroyal – T Oak savannas; Allegan,

Kalamazoo, and Van Buren

Counties

Trillium sessile toadshade – T Floodplains and mesic forests;

recorded within 1 mi of

Palisades-Argenta line (1981);

Kalamazoo and Van Buren

Counties

Triphora

trianthophora

three-birds orchid – T Rich oak-hickory forests;

Allegan, Kalamazoo, and

Van Buren Counties

Valerianella

chenopodiifolia

goosefoot corn-salad – T Wet sites in forested

floodplains; Kalamazoo County

Viola pedatifida prairie birdfoot violet – T Mesic prairie; Kalamazoo

County

Utricularia

subulata

zigzag bladderwort – T Damp sand at the margins of

interdunal wetlands; Allegan

County

Zizania aquatica

var. aquatica

wild-rice – T Rivers, streams, lakes, and

ponds; Kalamazoo County
Plant and the Environment 

NUREG-1437, Supplement 27 2-44 October 2006

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Insects

Erynnis persius

persius

Persius duskywing – T Oak savannas and pine barrens

(Shepard et al. 2005); Allegan

and Kalamazoo Counties

Hesperia ottoe Ottoe skipper – T Remnant dry sand prairies and

open oak barrens with native

warm season grasses; Allegan

County

Incisalia irus frosted elfin – T Oak savannas and pine barrens

(Shepard et al. 2005); Allegan

and Kalamazoo Counties

Lepyronia gibbosa great plains

spittlebug

– T Prairies; Van Buren County

Lycaeides melissa

samuelis

Karner blue butterfly E T Oak or oak-pine savanna,

openings, old fields, and rightsof-way surrounded by

close-canopied oak forest; 

Allegan County

Neonympha

mitchellii mitchellii

Mitchell’s satyr

butterfly

E E Calcareous wetlands;

Kalamazoo and Van Buren

Counties

Nicrophorus

americanus

American burying

beetle

E E Wide variety of habitats with

significant humus and topsoil

suitable for burying of carrion

(FWS 1989); Kalamazoo

County, last observation 1961;

no recent State sightings

(MDNR 2005a).

Speyeria idalia regal fritillary – E Tall-grass prairie, meadows,

marshes, and pastures

(Shepard et al. 2005);

Kalamazoo County
Plant and the Environment

October 2006 2-45 NUREG-1437, Supplement 27

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Amphibians

Ambystoma

opacum

marbled salamander – T Sandy, upland deciduous

forests most of the year;

lowland forest in the fall to

breed (MDNR 2005b); Allegan

and Van Buren Counties

Reptiles

Clemmys guttata spotted turtle – T Shallow wetlands; recorded

within 1 mi of PalisadesArgenta line (2002); Allegan,

Kalamazoo, and Van Buren

Counties

Clonophis

kirtlandii

Kirtland’s snake – E Damp meadows, vacant lots,

and open swampy woodlands

(MDNR 2005c); Kalamazoo and

Van Buren Counties

Sistrurus

catenatus

catenatus

eastern massasauga

rattlesnake

C – Wetlands, including bogs, fens,

shrub swamps, wet meadows,

marshes, moist grasslands, wet

prairies, and floodplain forests;

recorded within 1 mi of

Palisades-Argenta line (1995);

Allegan, Kalamazoo, and Van

Buren Counties

Birds

Buteo lineatus red-shouldered hawk – T Mature, forested floodplains

and upland forest; Allegan

County

Dendroica discolor prairie warbler – E Upland scrub-shrub; recorded

within 1 mi of PalisadesArgenta line (1997); Allegan

and Van Buren Counties
Plant and the Environment 

NUREG-1437, Supplement 27 2-46 October 2006

Table 2-2. (contd)

Scientific Name Common Name

Federal

Status(a)

Michigan

Status(a)

Habitat and Location in

Project Area(b)

Lanius

ludovicianus

migrans

migrant loggerhead

shrike

– E Grasslands and open,

agricultural areas characterized

by short vegetation and

scattered trees, shrubs, or

hedgerows; Allegan County

Rallus elegans king rail – E Freshwater marshes; Allegan

and Van Buren Counties

Mammals

Cryptotis parva least shrew – T Grassy, weedy, or brushy

fields; Allegan, Kalamazoo, and

Van Buren Counties

Microtus

ochrogaster

prairie vole – E Open prairie and savanna;

recorded on Palisades site

(1978); Kalamazoo and Van

Buren Counties

Myotis sodalis Indiana bat E E Riparian, bottomland, and

upland forest habitats; Allegan,

Kalamazoo, and Van Buren

| Counties (FWS 2005b)

(a) C = candidate for listing; E = listed as endangered, T = listed as threatened, – = no listing.

(b) Habitat information from MNFI 2005b,c or NMC 2005a unless otherwise noted. Location 

on Palisades site or near transmission lines from NMC 2005a. County occurrence from 

MNFI 2005d unless otherwise noted.

The Pitcher’s thistle has been found in dune blowouts and in semistabilized, but dynamic, full-

| sun dune habitats throughout the Palisades site (NMC 2006c). The species’ distribution on the

site can change over time in response to changes in habitat suitability and the location of seed

sources offsite. From the early 1980s until the late 1990s, the Pitcher’s thistle was found onsite

in suitable habitat near the cooling towers. No Pitcher’s thistle were found near the cooling

towers during the NRC staff’s site audit in July 2005. A survey on July 28, 2005, found no

Pitcher’s thistle in suitable habitat south or north of Palisades site; however, a population

comprised of 113 individuals (9 mature plants and 104 first-year plants) were found in the beach

| grass stabilized dune community and flats located on the northern end of the site adjacent to

| Van Buren State Park (NMC 2006c).

| On the basis of county distributions published in FWS (2005b), the Karner blue butterfly occurs

in Allegan County and the Mitchell’s satyr butterfly occurs in Kalamazoo and Van Buren
Plant and the Environment

October 2006 2-47 NUREG-1437, Supplement 27

Counties. However, Czarnecki (FWS 2005c) stated that the Karner blue butterfly may occur

near the Argenta-E. Elkhart transmission line in eastern Van Buren County, and the Mitchell’s

satyr butterfly may be found near the Palisades-Cook transmission line in Berrien County. It

should be noted that neither the Argenta-E. Elkhart transmission line nor the portion of the

Palisades-Cook transmission line in Berrien County were part of the original licensing of the

plant and, therefore, are not considered in this SEIS. Neither species was observed during field |

surveys of the Palisades site and transmission line corridors conducted in 1979 (Asplundh

1979) and 1991 (Higman and Goff 1991; Goff 1992).

The Karner blue butterfly is dependent on its only known larval food plant, wild lupine

(Lupinus perennis), grasses, and a variety of nectar plants (FWS 2005a). These plants and the |

butterfly’s habitat occur in areas of sandy soil in oak and oak-pine savanna habitat, as well as

other locations such as highway and transmission line rights-of-way, especially those

surrounded by close-canopied oak forest (FWS 2005c; MNFI 2005b). The Mitchell’s satyr

butterfly is closely affiliated with wetlands that are dominated by sedges, especially Carex

stricta, with scattered deciduous or coniferous trees such as tamarack and red cedar

(Juniperus virginiana) (FWS 2005c; MNFI 2005b).

There is a possibility that the Indiana bat occurs within suitable habitat on or near the Palisades

site or transmission lines associated with the plant (FWS 2005c). The summer range of this

species includes the southern half of Michigan and most of the western coastal counties of the

Lower Peninsula. Although the MNFI does not have records of occurrence in the three counties

in the project area (MNFI 2005d), the FWS lists the Indiana bat as occurring in all three of the

counties associated with the proposed action (FWS 2005b). Suitable habitat for the Indiana bat |

consists of riparian, bottomland, and upland forest habitats with trees that have crevices or

exfoliating bark that can be used as roosting sites.

The eastern massasauga rattlesnake is known from Allegan, Kalamazoo, and Van Buren

Counties and could occur on the Palisades site and within the rights-of-way of its associated

transmission lines (FWS 2005b,c). Four records of eastern massasauga occur within 1 mi of |

the Palisades-Argenta transmission line within Van Buren County. Across the species’ range,

Michigan has the most recent recordings, and the State may represent the massasauga’s last

stronghold (MNFI 2005b). Recent sightings have been clustered in several portions of the

Lower Peninsula, including Allegan and Kalamazoo Counties of the project area (MNFI 2005b). 

Eastern massasauga habitat includes a variety of wetland habitats, including bogs, fens, shrub

swamps, wet meadows, marshes, moist grasslands, wet prairies, and floodplain forests

(MNFI 2005b). In southern Michigan, populations are typically associated with open wetlands,

particularly prairie fens. In the summer, snakes migrate from wetlands to drier, upland sites that

include forest openings, old fields, agricultural lands, and prairies. Preferred sites have the

following characteristics: (1) open, sunny areas intermixed with shaded areas, presumably for
Plant and the Environment 

NUREG-1437, Supplement 27 2-48 October 2006

thermoregulation; (2) a water table near the surface for hibernation; and (3) variable elevations

between adjoining lowland and upland habitats (MNFI 2005b).

2.2.7 Radiological Impacts

NMC has conducted a radiological environmental monitoring program (REMP) around the

Palisades site since 1971. Through this program, radiological impacts on workers, the public,

and the environment are monitored, documented, and compared with the appropriate

standards. The objectives of the REMP are the following:

 C Identify and measure radiation and radioactivity in the plant environs for the calculation

of potential dose to the population.

 C Verify the effectiveness of in-plant measures used for controlling the release of

radioactive materials.

 C Provide reasonable assurance that the predicted doses, based on effluent data, have

not been substantially underestimated and are consistent with applicable standards.

 C Comply with regulatory requirements and plant technical specifications and provide

records to document compliance.

| Each year, radiological releases are summarized in the Palisades Annual Radioactive Effluent

| Release and Waste Disposal Report (e.g., NMC 2005b). The limits for all radiological releases

are specified in the ODCM (NMC 2004a), and these limits are designed to meet Federal

standards and requirements. The primary radiological standards applicable to Palisades are

| contained in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 50, Appendix I. Section

| 3.8.1.1 “Regulatory Requirements” of the GEIS (NRC 1996) also provides a summary and

| specific numerical dose limits associated with these standards and requirements. The REMP

includes monitoring of the waterborne environment (groundwater, surface water, and

sediments), ingestion pathways (milk, fish, and vegetation), direct radiation (gamma dose on

thermoluminescent dosimeter locations), and atmospheric environment (airborne radioiodine,

| particulates, gross beta, and gamma). The results of the REMP are summarized in the

| Palisades Annual Radiological Environmental Operating Reports (e.g., NMC 2005c and 2006b). 

| The REMP data indicate that the operation of Palisades has minimal impact on the

| environment, and most isotopic activity measured in the environmental media around Palisades

| is at environmental background levels (NMC 2006b).

| NMC performs an annual assessment of radiation dose to the general public from radioactive

| effluents. Dose estimates are calculated on the basis of actual liquid and gaseous effluent

| release data. Calculations are performed by using the plant effluent release data, onsite

meteorological data, and appropriate pathways identified in the ODCM (NMC 2004a).
Plant and the Environment

October 2006 2-49 NUREG-1437, Supplement 27

The EPA’s 40 CFR Part 190 is the most limiting generic requirement regarding allowable |

radiation dose to a member of the public. This regulation limits annual dose to a member of the |

public to 25 mrem total effective dose equivalent (TEDE) per year from the entire nuclear fuel |

cycle including power reactors. For the 5-year period 2000 through 2004, the annual TEDE |

calculated each year for the MEI by NMC was well within the annual limit of 25 mrem for |

members of the public as specified in the ODCM (TEDE is the sum total of the external dose

and the sum of the weighted internal dose) (NMC 2001a, 2002, 2003a, 2004b, 2005b). Over |

this 5-year period, the maximum annual TEDE for the MEI was estimated to be 7.53 × 10-3

mrem with an annual average TEDE of 3.73 × 10-3 mrem (NMC 2001a, 2002, 2003a, 2004b, |

2005b). These doses represent approximately 0.03 percent and 0.015 percent of the 25-mrem

limit, respectively. In 2005, the TEDE for the MEI was calculated to be 7.36 ×10-3 mrem (NMC |

2006a). The TEDE estimates include exposure from liquid and gaseous effluents and direct |

radiation. These results confirm that Palisades is operating in compliance with 10 CFR Part 50,

Appendix I, 10 CFR Part 20, and 40 CFR Part 190.

A modification to the Liquid Radioactive Waste System was completed in December 2005, as |

discussed in Section 2.1.4.1. However, the TEDEs are still expected to remain much lower than |

the applicable standards. 

2.2.8 Socioeconomic Factors

The NRC staff reviewed the NMC ER (NMC 2005a) and information obtained from county, city,

school district, and local economic development staff. The following sections describe the

housing market, community infrastructure, population, and economy in the region surrounding

the Palisades site.

2.2.8.1 Housing

The majority of plant employees live in Van Buren County (44 percent) and in Berrien County

(33 percent), and most of the remaining employees are located in Ottawa, Allegan, and

Kalamazoo Counties (Table 2-3). Given the residential location of Palisades employees, the

most significant impacts of plant operations are likely to occur in Van Buren and Berrien

Counties. The analysis in this SEIS focuses on the impacts of Palisades operations in these |

two counties.

NMC refuels Palisades every 18 months. During refueling, approximately an additional

380 workers are employed for a 30- to 40-day period (NMC 2005a). The majority of these

workers reside in the same communities as the permanent employees at the plant

(NMC 2005b).
Plant and the Environment 

NUREG-1437, Supplement 27 2-50 October 2006

Table 2-3. Permanent Employee Residence Information 

| for Palisades by County and City

County and City(a)

Number of

Employees Percent of Total

VAN BUREN COUNTY

South Haven 156 30

Bangor 14 3

Grand Junction 13 2

Paw Paw 12 2

Hartford 8 2

Others 30 6

Total Van Buren County 233 44

BERRIEN COUNTY

St. Joseph 73 14

Coloma 24 5

Benton Harbor 23 4

Stevensville 21 4

Watervliet 14 3

Others 17 3

Total Berrien County 172 33

Other counties 119 23

| Grand total 524 100(b)

(a) Addresses are for both unincorporated (counties) and incorporated (cities

and towns) areas.

| (b) Total may not equal 100% because of rounding.

Source: NMC 2004c.

The number of housing units and housing vacancies in Van Buren and Berrien Counties are

shown in Table 2-4. In Van Buren County, the total number of housing units grew at an annual

rate of 0.7 percent over the period 1990 to 2000, while the number of occupied units grew at an

average annual rate of 0.9 percent over the same period. With an annual average population

growth rate of almost 1 percent during this period, there was a slight decline in the annual rate

of growth in the number of vacant units. In Berrien County, total and occupied housing over the

period 1990 to 2000 grew at an average annual rate of approximately 0.5 percent, exceeding

the growth rate in population during this period, leading to a 1.5 percent annual growth in vacant

housing units.
Plant and the Environment

October 2006 2-51 NUREG-1437, Supplement 27

Table 2-4. Housing Units and Housing Units Vacant (Available) by County 

During 1990 and 2000

1990 2000

Percentage

Change 1990 to 2000

VAN BUREN COUNTY

Housing units 31530 33975 7.8

Occupied units 25402 27982 10.2

Vacant units 6128 5993 -2.2

BERRIEN COUNTY

Housing units 69532 73445 5.6

Occupied units 61025 63569 4.2

Vacant units 8507 9876 16.1

Source: U.S. Census Bureau 2000b.

2.2.8.2 Public Services

Water Supply

Water supplies in Van Buren and Berrien Counties come from both surface and groundwater

sources, although surface water (especially Lake Michigan) is the main source (NMC 2005a). 

While Lake Michigan water meets the water quality standards set by the State, water from the

lake is under localized threat of degradation from surface runoff, construction, and industrial

activity.

Currently, Van Buren County has 28 water suppliers, although these suppliers currently only

provide 28 percent of capacity and water supply (NMC 2005a). Residents in Van Buren County

not served by municipal systems receive water from individual onsite wells or through wells

accessed by small private providers. In Berrien County, 50 suppliers provide 57 percent of

water supplies, with the majority of capacity and water supply in the county provided by

municipal systems located in St. Joseph, Benton Harbor, Niles, and Lake Charter. Access to

water by using individual onsite wells or through private supply systems is less important as a

source of water supply in Berrien County. Table 2-5 shows the largest water supply systems in

both counties.

According to estimates, excess water capacity in both Van Buren and Berrien Counties is high,

and existing water suppliers would be able to satisfy new residential, commercial, and industrial

demands (NMC 2005a).
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NUREG-1437, Supplement 27 2-52 October 2006

Table 2-5. Major Public Water Supply Systems in Van Buren and Berrien 

| Counties, 2004

Water System Source

Average Daily Use

(million gpd)

Maximum Capacity

(million gpd)

VAN BUREN COUNTY

South Haven Surface water 1.7 4

Lawton Groundwater 1.3 3.9

Mattawan Groundwater 0.8 1.6

BERRIEN COUNTY

Benton Harbor Surface water 4.9 12

St. Joseph Surface water 5.2 16

Niles Groundwater 1.7 9.5

Lake Charter Township Surface water 1.6 5

Buchanan Groundwater 0.5 2.2

Source: NMC 2005a.

South Haven Municipal Water Authority provides potable water to Palisades at an average daily

| rate of 18,000 gpd (Section 2.2.2). Fire protection services for the plant are provided by the

| Covert Township Fire Department and the South Haven Fire Department.

Education

Palisades is located in the Covert Public School District, which has a current enrollment of

739 students (Standard and Poor’s 2005). Fifty-four teachers are currently employed in the

district (MEDC 2005), and current expenditures are $6222 per student (Standard and

Poor’s 2005). Enrollment has declined slightly in recent years, together with expenditures

per student, while the number of teachers in the district has remained stable over the same

period (MEDC 2005; Standard and Poor’s 2005; greatschools.net 2005).

Including the Covert Public School District, there are 12 public school districts in Van Buren

County, with a current total enrollment of 17,696 students (Standard and Poor’s 2005). Average

expenditure per student in the public school districts in the county is $5013, compared with

$8653 for Michigan as a whole in 2002 (Standard and Poor’s 2005). There were an additional

six private schools in the county in 2004 with a total enrollment of 550 students (NCES 2005).

Berrien County has 15 public school districts, which had a total enrollment of 27,012 students in

2002. Average expenditure per student in the county was $4841. There are also
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October 2006 2-53 NUREG-1437, Supplement 27

30 private/parochial schools with a current total enrollment of 4030 students, and two public |

school academies (Berrien County 2005).

Transportation

Access to Palisades is via Blue Star Memorial Highway, approximately 1 mi east of the plant. 

Blue Star Memorial Highway runs parallel to I-196 and US 31. Most employees traveling from

Benton Harbor and St. Joseph from the south, and South Haven to the north use these roads.

Moderate increases in traffic have occurred on many of the roads in the vicinity of the plant; in

particular, I-196, which has seen large increases in commercial traffic. Four segments of I-196

for which traffic counts are available, were assessed in the NMC ER (NMC 2005a). These

segments are located both north and south of the plant. Traffic conditions on this stretch of

roadway vary between medium density, stable flow, to high-capacity traffic where congestion is

likely. Blue Star Memorial Highway also experiences relatively high daily traffic flow

(NMC 2005a). |

2.2.8.3 Offsite Land Use

Land use in Van Buren County (623 mi2

) is primarily agricultural (47 percent of total land area)

and residential (44 percent), with a smaller land area occupied by industrial (2 percent) and

commercial (2 percent) land uses (Table 2-6). Berrien County (583 mi2

) is also rural in |

character, with approximately 84 percent of the land area used for agriculture or classified as

unused. About 9 percent of county land is residential and 3 percent is devoted to

manufacturing, commercial, and sand and gravel mining activities (NMC 2003b). Fruit

production, particularly berries, apples, and cherries, and food processing are an important part

of the agricultural economy in both counties. Tourism also provides a significant source of 

Table 2-6. Land Use in Van Buren County, 2005(a)

Land Use Percent of Total

Residential 44

Commercial 2

Industrial 2

Agriculture 47

Other 5

Total 5

(a) Interview with K. Getman and M. Thomas, Michigan

Economic Development Corporation (July 2005).
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(a) Interview with K. Getman and M. Thomas, Michigan Economic Development Corporation (July 2005).

NUREG-1437, Supplement 27 2-54 October 2006

employment and income in both counties. The Lake Michigan lakefront, parks, and recreational

areas are strong attractions for summer and fall visitors and seasonal residents, even though

less than 4 percent of the land is devoted to public and semipublic uses in both counties.

Although Van Buren County’s population has grown relatively slowly over the past 30 years, it

has experienced moderate residential, industrial, and commercial growth during that period. 

Residential development has moved away from the urban cores, notably the Kalamazoo area

(NMC 2005a), and through the development of lakefront locations for summer and retirement

homes, notably in the South Haven area. As a result of these developments, both the

Lake Michigan lakefront and prime farmland in the county are confronting growth pressure. In

an attempt to manage new development, the county has developed an overall land-use

decision-making strategy that encourages the implementation of a “smart growth” methodology

by municipalities within the county. To conform with the strategy, each municipality has

attempted to create development and planning tools that are compatible with local

infrastructure, encourage clustering of new mixed use developments to foster the preservation

of open space, farmland, natural beauty, and critical environmental areas.(a)

2.2.8.4 Visual Aesthetics and Noise

Palisades is located on the southeastern shoreline of Lake Michigan. The Lake Michigan

shoreline in Van Buren County serves as a strong draw to summer tourists and seasonal

residents who enjoy the recreational and environmental attractions of the area.

The Palisades site covers 432 ac of beach and high-wooded sand dunes. Plant buildings

| include a rectangular turbine building (94 ft high); a cylindrical, domed-top reactor containment

| building (92 ft high); a rectangular auxiliary building (108 ft high); and two cooling towers 

| (65 ft high). All of the plant’s structures and the reactor dome are equal to or below the height

of the surrounding sand dunes. While the plant is readily visible from Lake Michigan and the

shoreline, the distance from the north and south property lines, and the property’s dominating

sand dunes and trees obscure buildings from view of adjacent properties and I-196. The

transmission lines can be seen from both the interstate highway and Blue Star Memorial

Highway.

Noise measurements are not available for the Palisades site. However, noise generated by

Palisades operations is mitigated at the site boundary because the plant is located

approximately 2500 ft from the northern and southern boundaries of the site and is surrounded

by sand dunes and vegetation, and most equipment is located within the plant buildings. In
Plant and the Environment

October 2006 2-55 NUREG-1437, Supplement 27

addition, I-196 encloses the eastern portion of the site and reduces the conspicuousness of any

noise generated by Palisades operations. 

2.2.8.5 Demography

In 2000, 118,667 people were living within 20-mi of Palisades, for a density of 238 persons/mi2

. 

This density translates to Category 4 (least sparse), using the GEIS measure of sparseness

(NMC 2005a). At the same time, there were 1,287,558 persons living within 50 mi of the plant,

for a density of 283 persons/mi2

. The NRC sparseness and proximity matrix assigns a Category

4 rating (high density) for this measure as well. There are currently no mandatory growth

controls that would limit housing development in this area (NMC 2005a).

Table 2-7 shows population trends for the two counties where the majority of Palisades

employees live. Annual average growth rates in Van Buren County show moderate growth

during the 1970s, followed by slight increases during the 1980s and 1990s. The annual

average growth rate in Michigan over this period was 0.4 percent. 

Growth is forecasted to continue at moderate levels over the period 2000 to 2020. In Berrien

County, relatively slow growth in population in the 1970s was followed by declining population in

the 1980s and slight increases in the 1990s. Population is forecasted to decline in both

decades between 2000 and 2020.

Table 2-7. Population Growth in Van Buren and Berrien Counties, 1970 to 2020

Van Buren County Berrien County

Year Population

Annual Growth

Percent(a) Population

Annual Growth

Percent

1970 56,173 –(b) 163,875 –

1980 66,814 1.7 171,276 0.5

1990 70,060 0.5 161,378 -0.6

2000 76,263 0.9 162,453 0.1

2010 87,100 1.3 160,800 -0.1

2020 95,800 1.0 158,900 -0.1

(a) Annual percent growth rate is calculated over the previous decade.

(b) – indicates no data available.

Sources: NMC 2005a; U.S. Census Bureau 2000a.
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NUREG-1437, Supplement 27 2-56 October 2006

Transient Population

The transient population in the vicinity of Palisades consists primarily of tourists visiting South

Haven, St. Joseph, Benton Harbor, and various recreational facilities (NMC 2005a). It is

estimated that peak visitation levels reach almost 10,000 associated with campgrounds and

beaches in the area (NMC 2005a). People visiting summer homes and attendance at local

colleges in the area also represent a substantial source of transient population in the area. 

Migrant Farm Labor

| Seasonal and migrant workers are employed during the summer and fall months in many of the

| counties in the area surrounding the plant. In 2002, there were 4696 hired farm workers in

| Berrien County and 7527 in Van Buren County (USDA 2002). Of these workers, 3677 (78%) in

| Berrien County and 6733 (89%) in Van Buren County were temporary, having worked less than

| 150 days in the year.

2.2.8.6 Economy

Employment and Income

| Total employment in Van Buren County was 23,982 in 2002 (U.S. Census Bureau 2000b; USDA

| 2002). Agriculture is the most important sector in Van Buren County, with 7537 people

| employed (31% of the total employed; the county is one of the most important in the state in the

| production of fruit and vegetables (NMC 2005a)). Service industries are also an important part

| of the economy of the county, with 28 percent of total employment (6635 people). The largest

employer in the county is Consumers Energy, with 484 employees (Table 2-8). Manufacturing

| also plays an important part in the local economy, with 21 percent of local employment

(4934 people); a number of manufacturing firms have a large local labor force, including

| Double J Moulding and Pullman Industries. Wholesale and retail trade employs 12 percent

(2974 people) of the county workforce.

| Of the 65,340 employed in Van Buren County in 2002, almost 45 percent of employment

(29,214 people) is in the various service sectors (U.S. Census Bureau 2000b). Manufacturing

| has a relatively small share of county employment (22 percent), with 14,435 people employed.

| Wholesale and retail trade has more than 15 percent of the county workforce, with 9836 people.

Personal income in Berrien County was $2.0 billion in 2002 (in 2004 dollars), with a per capita

income of $25,514 (2004 dollars) (DOC 2002). In Berrien County, total personal income was

$4.7 billion, with a per capita income of $29,081.
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October 2006 2-57 NUREG-1437, Supplement 27

Table 2-8. Major Employment Facilities Within 10 mi |

of Palisades

Firm Number of Employees

Consumers Energy 484

Double J Moulding 240

Pullman Industries 240

Wal-Mart 230

South Haven Community Hospital 160

De Grandchamp Blueberry Farms 154

Wyckoff Chemical 140

South Haven Public Schools 126

Bangor Industries 110

Source: MEDC 2005.

Unemployment

Unemployment in Van Buren County was moderately high at 7.2 percent in December 2004. 

The rate for Michigan as a whole for the same month was 7.1 percent. In Berrien County, the

rate for December 2004 was lower, at 4.2 percent (DOL 2004).

Taxes

Palisades pays property taxes to Covert School District, Covert Township, Van Buren

Intermediate School District, Van Buren County, the District Library, South Haven Community |

Hospital District, and Lake Michigan College, and it contributes to the Michigan State Education |

fund. Because Palisades is located in Covert Township, the township collects sufficient tax |

revenues from the plant to cover local expenditures and forwards the balance to the other

jurisdictions. Revenues are used to fund local and county emergency management programs,

public safety, local public schools, local government operations, local road maintenance, and

the local library system.

The plant is a significant source of tax revenue for local and county government. In 2004, |

56 percent (about $1 million in 2004 dollars) of tax revenues raised by Covert Township came |

from Palisades property taxes, and 29 percent ($2.7 million) of revenues raised by Covert

School District came from the plant (Table 2-9). Roughly 4 percent (about $0.8 million in 2004

dollars) of Van Buren County tax revenues in 2004 came from Palisades. |
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NUREG-1437, Supplement 27 2-58 October 2006

| Table 2-9. Contribution of Palisades to County Property Tax Revenues

Year

Total Covert School

District Property 

Tax Revenues

(millions $ 2004)

Property Tax Paid to Covert

School District for

Palisades (millions $ 2004)

Percent of Total

Property Taxes

COVERT SCHOOL DISTRICT

2002 7.4 2.8 37

2003 8.7 2.7 31

2004 9.2 2.7 29

Year

Total Covert Township

Property Tax Revenues

(millions $ 2004)

Property Tax Paid to Covert

Township for Palisades

(millions $ 2004)

Percent of Total

Property Taxes

COVERT TOWNSHIP

2002 1.6 0.9 58

2003 1.5 0.9 60

2004 1.6 0.9 56

Year

Total Van Buren County

Property Tax Revenues

(millions $ 2004)

Property Tax Paid to Van

Buren County for Palisades

(millions $ 2004)

Percent of Total

Property Taxes

VAN BUREN COUNTY

2002 17.6 0.9 5

2003 18.7 0.9 5

2004 19.7 0.8 4

Year

Total Van Buren

Intermediate School

District Property Tax

Revenues

(millions $ 2004)

Property Tax Paid to

Van Buren Intermediate

School District for

Palisades (millions $ 2004)

Percent of Total

Property Taxes

VAN BUREN INTERMEDIATE SCHOOL DISTRICT

2002 26.3 0.9 3

2003 26.9 0.8 3

2004 28.4 0.8 3

Source: VerBermones 2005.
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October 2006 2-59 NUREG-1437, Supplement 27

Utility restructuring legislation has been in place in Michigan since 2000. However, the

long-term impact of the restructuring of the electric power industry in the State and its impact on

Palisades are not yet known. Any changes in assessed valuation of plant property and

equipment that may potentially occur could affect property tax payments to the township,

county, and local school districts. However, any impacts on tax revenues as a result of

restructuring would not occur as a direct result of license renewal.

2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological

resources at the Palisades site and in the surrounding area.

2.2.9.1 Cultural Background

Evidence of human occupation within the region is found in archaeological sites dated

according to the following chronological sequence that reflects cultural change through time: 

Paleo-Indian Period (10000 BC to 8000 BC); Archaic Period (8000 BC to 1000 BC); Woodland |

Period (1000 BC to AD 1050); and Upper Mississippian Period (1050 to 1600). The

Paleo-Indian Period marks the beginning of human occupation within the region. These were

highly mobile bands of hunters and gatherers, with a heavy reliance on late Pleistocene animals

for food, clothing, and shelter. Archaeological sites tend to be found in upland areas along

ancient lakebeds and may consist of a single projectile point or other stone tool of a style

characteristic of the period (Mason 1981). 

During the Archaic Period, human populations adapted to the postglacial environment by

adopting a more sedentary way of life based upon hunting, fishing, and gathering, and a heavy

dependence upon waterways for travel, transport, and settlement (Funk 1978; Quimby 1960). 

Archaeological sites from this period are larger, more numerous, and richer in occupation debris

than previous periods, reflecting larger, denser populations and a more abundant and reliable

subsistence base. New types of raw material were used for tool production as the techniques of

pecking, grinding, and polishing stone gained importance (Mason 1981). 

In the Woodland Period, earthenware pottery appears in archaeological sites. Burials are

characteristically earthen mounds and contain an abundance of grave offerings. The

beginnings of undisputed plant domestication and agriculture also mark this period

(Mason 1981). Widespread exchange networks existed and there is evidence of a dramatic

increase in the frequency and scale of warfare (Fitting 1978; Mason 1981). The Upper

Mississippian Period in southwestern Michigan is characterized by mostly Late Woodland

cultural traits with the addition of shell- and grit-tempered cord-marked and plain ceramics

(Brose 1978).
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NUREG-1437, Supplement 27 2-60 October 2006

The historic period begins in the late 1600s with the arrival of French explorers, missionaries,

and fur traders. Fort Miami (in present-day St. Joseph) and Fort St. Joseph (in present-day

Niles) were the first European settlements in the area. Native American groups that inhabited

the area during the historic period were predominantly the Potawatomi, Mascouten, Miami, and

Ottawa. During the early historic period, their villages were situated on the edge of forested

land, adjacent to prairies and convenient to streams and the lakeside; temporary winter camps

were established in sheltered areas. By the beginning of the nineteenth century, the

Potawatomi had established 11 known villages in southern Michigan. Most were near the

shorelines of Lake Michigan and Lake Erie, generally along the streams that flow into their

waters (Clifton 1978; Goddard 1978; Callender 1978; Feest and Feest 1978).

After 1783, the official beginning of the American period, Indian lands were rapidly absorbed by

| expanding American settlements; by 1821, most of these lands were ceded by treaty or

purchase (Feest and Feest 1978). In the 1830s, lumbering was an important regional industry

and drew many settlers (Brennan 2004). One of the earliest settlements in the Palisades area

was Paulville, a logging town established in 1857, and several logging operations were

established in the area between 1866 and 1880. While the 1840s and 1850s was a period of

agricultural settlement of much of southern lower Michigan (Great Lakes Research 2000), the

dune formations present at the Palisades site rendered this area unsuitable for agriculture. As

late as 1927, only six structures were located in the Palisades vicinity and they were south of

| the site along Brandywine Creek (Weir et al.1980). 

Five historic properties within Van Buren County are listed on the National Register of Historic

Places (NRHP; NPS 2005a); there are no National Historic Landmarks listed for the county

(NPS 2005b). Properties listed on the NRHP that are closest to the Palisades site (Liberty Hyde

Bailey Birthplace in South Haven and the Navigation Structures at South Haven Harbor) are

located approximately 6 mi to the north. In addition, one property in Allegan County (the James

Noble Sherwood House in Plainwell) is located approximately 0.5 mi from the PalisadesArgenta transmission line right-of-way (NPS 2005a). The Michigan State Historic Preservation

Office’s (SHPO’s) inventory of historic properties for Van Buren County lists 29 properties. 

Those nearest the Palisades site are Ward School, Hartman School, and Haven Peaches

Informational Designation, all in South Haven, and the First Congregational Church in Covert

(State of Michigan 2005). 

The Southwest Michigan Underwater Preserve stretches along the Lake Michigan shoreline

from just north of Holland to just north of the Indiana border, including the 1-mi stretch of the

lakeshore that lies within the Palisades site boundaries. Seventeen sites are documented in

and near the preserve that include shipwrecks, geologic features, and historic structures: most

lie offshore from South Haven. The closest to the Palisades site is the shipwreck site of the City

of Greenbay, which sank in 1887. It lies at a depth of 10 ft (Michigan Underwater Preserve

Council 2004), approximately 0.5 mi north of the Palisades site.
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October 2006 2-61 NUREG-1437, Supplement 27

At least seven previous archaeological surveys came within 1 mi of the Palisades site and

transmission line rights-of-way. These surveys resulted in the recordation of 15 archaeological

sites within 1 mi of the Palisades site and transmission line rights-of-way. These 15 sites

consist of prehistoric lithic scatters and camp sites, one dating to the Archaic Period; isolated

prehistoric artifacts, including two Paleo-Indian Period fluted points; one prehistoric village site,

Pell Village; two prehistoric sites of undetermined function; and one historic trading post site. 

One of the prehistoric sites of unknown type, 20-VA-28, is located about 0.3 mi south of the

Palisades site and the other, 20-VA-4, is recorded just outside the Palisades site’s eastern

boundary (Weir et al. 1980).

2.2.9.2 Historic and Archaeological Resources at the Palisades Site

The Palisades site encompasses approximately 432 ac of land, including about 1 mi of

Lake Michigan shoreline. The site consists primarily of sand dunes, mostly forested, that

extend from the shoreline inland approximately 1 mi. Approximately 80 ac of the site are |

developed or maintained. The developed or maintained areas include power production and

support facilities, roads, and related infrastructure. Most of these facilities are located along the

main and north access roads. Also within this area are the power corridor from the main station |

transformer to the Palisades Substation and transmission rights-of-way from the substation

extending offsite. Service and circulating water are withdrawn from Lake Michigan via pipeline

from a submerged intake crib structure located 3300 ft offshore (NMC 2005a; Consumers |

Energy 2005b). In addition to the land disturbance caused by these developments, more than 4 |

ac of additional land in the northern portion of the Palisades site have been disturbed by former

use of the land for sand quarrying operations. Intact archaeological sites could be present

within the remaining undeveloped areas as well as in soils below the depth of ground

disturbance in most areas of the site. As discussed in Section 2.2.9.1, Native American villages |

are known to have been situated within physiographic settings similar to portions of the

Palisades site: on the shorelines of Lake Michigan and on the edge of forested land, adjacent

to prairies and convenient to streams and the lakeside. 

A file search conducted on July 27, 2005, at the Michigan SHPO indicates that one cultural

resources assessment (Weir et al. 1980) was undertaken at the Palisades site but that no

archaeological field surveys have been conducted either at the Palisades site or for original

transmission line construction or maintenance. The cultural resource assessment, which was

undertaken in 1979, concluded that without accurate knowledge of the cultural resources

present at the Palisades site, it must be assumed that power plant construction has the potential

to adversely impact significant resources that may exist on the plant site. The report

recommends that an intensive survey be undertaken of the undisturbed portions of the site. 

In addition to the assessment report on file at the Michigan SHPO, Consumers Energy files

contain a second report that documents a brief cultural resource field visit to the Palisades site
Plant and the Environment 

NUREG-1437, Supplement 27 2-62 October 2006

by archaeologists in 1982. The purpose of the field visit was to determine the likelihood of the

existence of archaeological sites at the locations of three proposed facilities: a drainage pond,

a parking lot, and a warehouse (CAI 1982). The report concluded that the likelihood of

encountering archaeological sites at the three locations was minimal because of the generally

steep terrain and distance from the Lake Michigan shore.

Agency consultation undertaken by the U.S. Atomic Energy Commission (AEC) in 1972 for

issuance of an OL for Palisades operation generated comment letters from the U.S. Department

of the Interior and from the Michigan State Liaison Officer for Historic Preservation (AEC 1972). 

The Department of the Interior letter states that it does not appear that the existing plant should

directly affect any site eligible for registration as a National Historic Landmark (DOI 1972). The

Michigan State Liaison Officer’s letter concludes that as far as could be determined at that time,

Palisades would not adversely affect known historical or archaeological resources of the State

| of Michigan (MDNR 1972).

Consumers Energy and NMC corresponded with the Michigan SHPO in early 2005 regarding

| the current license permit renewal application (Consumers Energy and NMC 2005). The

Consumers Energy and NMC letter to the SHPO states that NMC, Consumers, and the

Palisades Environmental Review Team conclude the operation of Palisades through the license

renewal term will not have an adverse effect on any historic or cultural property in the region

and, therefore, a survey of the project area is not necessary. Their conclusion was based upon

the small extent of potential land-disturbing activities, the absence of known historic properties

in the vicinity of Palisades, and the existence of adequate environmental controls to ensure

| protection of cultural resources. A response letter from the SHPO dated March 14, 2005,

| concurred with these conclusions (Michigan SHPO 2005). The NRC staff forwarded a copy of

| the draft SEIS to the Michigan SHPO for review and comment. In a letter dated June 19, 2006,

| the Michigan SHPO stated that no historic properties are affected in the project area (Michigan

| SHPO 2006).

| Correspondence between the Michigan SHPO and the NRC, dated June 30, 2005, and

| June 19, 2006, are provided in Appendix E.

| Government-to-government consultation with appropriate Federally recognized Native American

Tribes has been initiated. Copies of the consultation letters are provided in Appendix E. To

date, no known sites of significance to Native Americans have been identified at Palisades.

2.2.10 Related Federal Project Activities and Consultations

The NRC staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the OL for Palisades. Any such activities could result in cumulative environmental

impacts and the possible need for the Federal agency to become a cooperating agency for

| preparation of the SEIS.
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October 2006 2-63 NUREG-1437, Supplement 27

The NRC staff has determined that there are no Federal project activities that would make it

desirable for another Federal agency to become a cooperating agency for preparing this SEIS. |

There are no known Federal facilities or land or Native American land within 50 mi of Palisades. 

The D.C. Cook Nuclear Plant, owned by the Indiana and Michigan Power Company, is located

approximately 28 mi south-southwest of Palisades. 

The NRC is required under Section 102(c) of the National Environmental Policy Act of 1969 as

amended (NEPA) to consult with and obtain the comments of any Federal agency that has

jurisdiction by law or special expertise with respect to any environmental impact involved. The

NRC consulted with the FWS; the consultation is described in Sections 2.2.6 and 4.6, and

correspondence is included in Appendix E.

2.3 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for

Protection Against Radiation.”

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of

Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental |

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” |

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing

Requirements for Land Disposal of Radioactive Waste.”

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and

Transportation of Radioactive Material.”

40 CFR Part 81. Code of Federal Regulations, Title 40, Energy, Part 81, “Designation of Areas

for Air Quality Planning Purposes.” 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

“Environmental Radiation Protection Standards for Nuclear Power Operations.”

Asplundh Environmental Services and S & R Environmental Consulting (Asplundh). 1979. 

Terrestrial Ecological Survey for the Palisades Site. Report for Consumers Power Company,

Jackson, Michigan. (December 1979). |
Plant and the Environment 

NUREG-1437, Supplement 27 2-64 October 2006

Berrien County. 2005. “Berrien County Department of Economic Development.” Available

URL: http://www.berriencounty.org/econdev/top10emp.shtml (Accessed July 2005). 

Brennan, J. 2004. “Michigan Historical Markers: Van Buren County/Courthouse.”

Available URL: http://www.michmarkers.com/startup.asp?startpage=S0006.htm

(Accessed June 22, 2005).

Bronte, C.R., and P.A. Schuette. 2002. Summary of Trout and Salmon Stocking in Lake

Michigan 1976–2001. Great Lakes Fishery Commission, Lake Michigan Committee Meeting,

| Duluth, Minnesota. (March 21–22, 2002). 

Bronte, C.R., J. Jonas, M.E. Holey, R.L. Eshenroder, M.L. Toneys, P. McKee, B. Breidert,

R.M. Claramunt, M.P. Ebener, C.C. Krueger, G. Wright, and R. Hess. 2003. “Possible

Impediments to Lake Trout Restoration in Lake Michigan.” Great Lakes Fishery Commission,

Ann Arbor, Michigan. Available URL: http://www.glfc.org/lakecom/lmc/ltrestore.pdf

(Accessed January 12, 2004).

Brose, D.S. 1978. “Late Prehistory of the Upper Great Lakes Area.” In Northeast, Bruce G.

Trigger, ed., pp. 569–582. Handbook of North American Indians, Vol. 15, W.C. Sturtevant,

general ed., Smithsonian Institution, Washington, D.C.

Brown, H.P. 1976. Aquatic Dryopoid Beetles (Coleoptera) of the United States. Water

Pollution Control Research Series 18050 ELD04/72. U.S. Environmental Protection Agency,

Cincinnati, Ohio (September 1976).

Callender, C. 1978. “Miami.” In Northeast, Bruce G. Trigger, ed., pp. 681–689. Handbook of

North American Indians, Vol. 15, W.C. Sturtevant, general ed., Smithsonian Institution,

Washington, D.C.

Carman, S.M. 2002a. “Special Animal Abstract for Alasmidonta viridis (Slippershell Mussel).” 

Michigan Natural Features Inventory, Lansing, Michigan. Available URL: 

http://web4.msue.msu.edu/mnfi/abstracts/aquatics/Alasmidonta_viridis.pdf

(Accessed July 15, 2005).

Carman, S.M. 2002b. “Special Animal Abstract for Lepisosteus oculatus (Spotted Gar).” 

Michigan Natural Features Inventory, Lansing, Michigan. Available URL: 

http://web4.msue.msu.edu/mnfi/abstracts/aquatics/Lepisosteus_oculatus.pdf (Accessed July 15,

2005).

|

City of South Haven. 2005. “Water Supply Information.” August 3. Available URL: 

http://www.south-haven.com/csh%20folder/csh/Pages/Communications/News%20Blurbs/

SH%20Trib%20article%2008-03-05.pdf (Accessed September 15, 2005). 
Plant and the Environment

October 2006 2-65 NUREG-1437, Supplement 27

Clean Air Act (CAA) Amendments of 1990. 42 USC 7401, et seq. |

Clifton, J.A. 1978. “Potawatomi.” In Northeast, Bruce G. Trigger, ed., pp. 725–742. Handbook |

of North American Indians, Vol. 15, W.C. Sturtevant, general ed., Smithsonian Institution, |

Washington, D.C. |

Coastal Zone Management Act of 1972 (CZMA). 16 USC 1451, et. seq.

Commonwealth Associates, Inc. (CAI). 1982. Letter report from W.E. Rutter, Archaeologist,

Commonwealth Associates, Inc., to G.A. Dawson, Consumers Power Company, Jackson, |

Michigan. Letter No. 62-0392-000. No subject. (August 27, 1982). |

Consumers Energy Company (Consumers Energy). 1998. Waste Water Disposal System

Report. Jackson, Michigan. (February 1998). |

Consumers Energy Company (Consumers Energy). 2002. Letter from J. Crawford, Consumers

Energy Company, Jackson, Michigan, to D. O’Donnell, Michigan Department of Environmental |

Quality. Subject: “Submittal of Release Notification Form R4616.” 

(February 13, 2002). 

Consumers Energy Company (Consumers Energy). 2003a. Letter and attached application |

from J.A. Crawford, Consumers Energy Company, Jackson, Michigan, to G. Danneffel,

Michigan Department of Environmental Quality, Kalamazoo, Michigan. Subject: “Consumers

Energy Company, Palisades Nuclear Plant NPDES Permit No. MI0001457 Permit Application

Renewal.” (April 3, 2003).

Consumers Energy Company (Consumers Energy). 2003b. Spill Prevention, Control and

Countermeasures/Pollution Incident Prevention Plan (SW3P), Rev. 2. Jackson, Michigan. |

(May 12, 2003). 

Consumers Energy Company (Consumers Energy). 2005a. Palisades Meteorological |

Monitoring Semiannual Data Report, July 1, 2004 – December 31, 2004 and 2004 Annual

Summary. Environmental and Laboratory Services Department, Jackson, Michigan. |

(March 3, 2005).

Consumers Energy Company (Consumers Energy). 2005b. Notes from Dawson, G., and R. |

Comstock, Consumers Energy Company, Jackson, Michigan. Subject: “Notes Regarding |

Developed Acreage Estimates for the Palisades Nuclear Plant Site.” (August 31, 2005). |

Consumers Energy Company and Nuclear Management Company, LLC (Consumers Energy

and NMC). 2001. Palisades Nuclear Plant Biological Assessment of the 1999 Cooling Water
Plant and the Environment 

NUREG-1437, Supplement 27 2-66 October 2006

Flow Increase at the Palisades Plant, near South Haven, Michigan. Consumers Energy

| Company, Jackson, Michigan, and Nuclear Management Company, LLC, Covert, Michigan. 

(May 2001).

Consumers Energy Company and Nuclear Management Company, LLC (Consumers Energy

and NMC). 2005. Letter from D.J. Malone and S.T. Wawro, Consumers Energy Company and

Nuclear Management Company, LLC, to M. MacFarlane-Faes, Environmental Review

Coordinator, Michigan State Historic Preservation Office. Subject: “Palisades Nuclear Plant –

License Renewal Environmental Review.” (February 11, 2005). 

Crawford, S.S. 2001. “Salmonine Introductions to the Laurentian Great Lakes: An Historical

Review and Evaluation of Ecological Effects. Executive Summary.” Canadian Special

Publication of Fisheries and Aquatic Sciences. Available URL: http://www.uoguelph.ca/

| ~scrawfor/research/research_greatlakes/research_greatlakes_fisheries/research_greatlakes_

| fisheries_issues/research_greatlakes_fisheries_issues_salmon_monograph.shtml

(Accessed February 24, 2004).

Cummings, K.S., and C.A. Mayer. 1992. “Field Guide to Freshwater Mussels of the Midwest.”

Illinois Natural History Survey Manual 5. Illinois Natural History Survey, Champaign, Illinois. 

Available URL: http://www.inhs.uiuc.edu/cbd/collections/mollusk/fieldguide.html (Accessed April

27, 2004).

|

DeCamp, G.C. 2005. “Palisades Nuclear Plant License Renewal Environmental Review: 

Estimated Onsite Developed or Maintained Acreage.” Constellation Nuclear Services, 

| Aiken, South Carolina. (July 27, 2005).

Department of Fisheries and Oceans Canada (DFO). 2004. “The Alewife.” Ottawa, Ontario,

Canada. Available URL: http://www.dfo-mpo.gc.ca/zone/underwater_sousmarin/gasparea/alewife-gaspareau_e.htm (Accessed July 14, 2004).

Eagle, A.C., E.M. Hay-Chmielewski, K. Cleveland, A. Derosier, M. Herbert, and R. Rustem, eds. 

2005. “Michigan’s Wildlife Action Plan.” Michigan Department of Natural Resources, Lansing,

Michigan. Available URL: http://www.michigan.gov/dnr/0,1607,7-153-10370_30909-120235--

00.html (Accessed July 18, 2005).

Eshenroder, R.L., M.E. Holey, T.K. Gorenflo, and R.D. Clark, Jr. 1995. “Fish-Community

Objectives for Lake Michigan.” Great Lakes Fishery Commission Spec. Pub. 95-3. Available

URL: http://www.glfc.org/pubs/SpecialPubs/Sp95_3.pdf (Accessed January 25, 2004).

Feest, J.E., and C.F. Feest. 1978. “Ottawa.” In Northeast, Bruce G. Trigger, ed., pp. 772–786. 

Handbook of North American Indians, Vol. 15, W.C. Sturtevant, general ed., Smithsonian

Institution, Washington, D.C.
Plant and the Environment

October 2006 2-67 NUREG-1437, Supplement 27

Fitting, J.E. 1978. “Regional Cultural Development, 3000 B.C. to A.D. 1000.” In Northeast,

Bruce G. Trigger, ed., pp. 44–57. Handbook of North American Indians, Vol. 15,

W.C. Sturtevant, general ed., Smithsonian Institution, Washington, D.C.

Fuller, K., H. Shear, and J. Witting, eds. 1995. “The Great Lakes: An Environmental Atlas and

Resource Book.” 3rd Ed. Government of Canada and U.S. Environmental Protection Agency. 

Available URL: http://www.epa.gov/glnpo/atlas/index.html (Accessed February 25, 2004).

Fuller, P. 2003. Morone americana (Gmelin 1789). U.S. Geological Survey (USGS), Center for

Aquatic Resource Studies, Gainesville, Florida. Available URL: http://nas.er.usgs.gov/

queries/SpFactSheet.asp?speciesID=777 (Accessed February 25, 2004).

Fuller, P., and A. Benson. 2003. Neogobius melanostomus (Pallas 1814). U.S. Geological

Survey (USGS), Center for Aquatic Resource Studies, Gainesville, Florida. Available URL: 

http://nas.er.usgs.gov/queries/SpFactSheet.asp?speciesID=713 (Accessed February 23, 2004).

Fuller, P., and L. Nico. 2000. Petromyzon marinus (Linnaeus 1758). U.S. Geological Survey

(USGS), Center for Aquatic Resource Studies, Gainesville, Florida. Available URL: 

http://nas.er.usgs.gov/queries/SpFactSheet.asp?speciesID=836 (Accessed February 23, 2004).

Fujita, T.T. 1987. U.S. Tornadoes Part 1 70-Year Statistics. Satellite and Mesometeorology

Research Project (SMRP). Research Paper Number 218. University of Chicago, Chicago,

Illinois.

Funk, R. E. 1978. “Post-Pleistocene Adaptations.” In Northeast, Bruce G. Trigger, ed.,

pp. 16–27. Handbook of North American Indians, Vol. 15, W.C. Sturtevant, general ed.,

Smithsonian Institution, Washington, D.C.

Garton, D.W. 2002. “Ecological Consequences of Zebra Mussels in North American Lakes.” 

Lakeline (Spring 2002).

Goddard, I. 1978. “Mascouten.” In Northeast, Bruce G. Trigger, ed., pp. 668–672. Handbook

of North American Indians, Vol. 15, W.C. Sturtevant, general ed., Smithsonian Institution,

Washington, D.C.

Goff, F.G. 1992. Supplement #1 to: Ecological Assessment of the Palisades Plant Site and

Ecological Enhancement Plan. Vital Resources Consulting, Report to Consumers Power

Company (May 20, 1992).
Plant and the Environment 

NUREG-1437, Supplement 27 2-68 October 2006

Great Lakes Research, Inc. 2000. Cultural Resource Inventory Survey: City of South

Haven/Covert Generating Co. Project, Van Buren State Park, South Haven Township, Van

Buren County, Michigan. Report No. 98–661. Indianapolis, Indiana.

Great Lakes Science Center (GLSC). 2003. “Great Lakes Issues – Round Goby.” 

U.S. Geological Survey (USGS), Great Lakes Science Center, Ann Arbor, Michigan. 

Available URL: http://www.glsc.usgs.gov/research/greatlakesissues.asp?ID=3 

(Accessed February 24, 2004).

Great Lakes Sea Grant Network (GLSGN). 1991. “Spiny-Tailed Bythotrephes in the

Great Lakes.” Illinois-Indiana, Michigan, Minnesota, New York, Ohio, and Wisconsin Sea Grant

College Programs. Available URL: http://sgnis.org/publicat/mi-spiny.htm

(Accessed February 25, 2004).

Greatschools.net. 2005. “Covert Public Schools.” Available URL: http://www/greatschools.net/

modperl/browse_district/331/mi/ (Accessed July 2005).

Higman, P.J., and F.G. Goff. 1991. Ecological Assessment of the Palisades Plant Site and

Ecological Enhancement Plan. Vital Resources Consulting, Report to Consumers Power

| Company, Jackson, Michigan. (November 1991).

Horvath, T.G., K.M. Martin, and G.A. Lamberti. 1999. “Effect of Zebra Mussels, Dreissena

polymorpha, on Macroinvertebrates in a Lake-outlet Stream.” American Midland Naturalist,

Vol. 142, pp. 340–347.

Institute of Electrical and Electronics Engineers, Inc. (IEEE). 2002. National Electric Safety

Code.

Indiana Department of Natural Resources (IDNR). 2005. “Fishing Northwest Indiana’s Lake

Michigan Shoreline and Tributaries.” Indiana Department of Natural Resources, Indianapolis,

Indiana. Available URL: http://www.in.gov/dnr/fishwild/fish/lkmich/lmfish.pdf (Accessed

November 14, 2005).

Jude, D.J. 1995. Impact on Aquatic Organisms of Increased Heat Input to the Thermal

Discharge of the Donald C. Cook Nuclear Plant, Southwestern Michigan. Center for Great

| Lakes and Aquatic Sciences, University of Michigan, Ann Arbor, Michigan. (December 1995).

Lehman, J.T. 1991. “Causes and Consequences of Cladoceran Dynamics in Lake Michigan: 

Implications of Species Invasion by Bythotrephes.” Journal of Great Lakes Research, Vol. 17,

pp. 437–445.
Plant and the Environment

October 2006 2-69 NUREG-1437, Supplement 27

Madenjian, C.P., G.L. Fahnenstiel, T.H. Johengen, T.F. Nalepa, H.A. Vanderploeg,

G.W. Fleischer, P.J. Schneeberger, D.M. Benjamin, E.B. Smith, J.R. Bence, E.S. Rutherford,

D.S. Lavis, D.M. Robertson, D.J. Jude, and M.P. Ebener. 2002. “Dynamics of the Lake

Michigan Food Web, 1970–2000.” Canadian Journal of Fisheries and Aquatic Sciences,

Vol. 59, pp. 736–753.

Madenjian, C.P., T.J. Desorcie, and J.D. Holuszko. 2004. Status and Trends of Prey

Populations in Lake Michigan, 2003. Great Lakes Fishery Commission, Lake Michigan

Committee Meeting, Ypsilanti, Michigan. (March 24, 2004). |

Madenjian, C.P., D.B. Bunnell, T.J. Desorcie, J.D. Holuszko, and J.V. Adams. 2005. Status

and Trends of Prey Populations in Lake Michigan, 2004. Great Lakes Fishery Commission,

Lake Michigan Committee Meeting, Ypsilanti, Michigan (March 22, 2005).

Manz, C.H. 1998. “The Round Goby: An Example of the ‘Perfect’ Invader?” Illinois Natural

History Survey Reports Nov–Dec 1998. Available URL: http://www.inhs.uiuc.edu/chf/pub/

surveyreports/nov-dec98/goby.html (Accessed February 24, 2004).

Marsden, J.E., and M.A. Chotkowski. 1995. “The Round Goby Invades Lake Michigan.” Illinois

Natural History Survey Reports Nov–Dec 1995. Available URL: http://www.inhs.uiuc.edu/chf/

pub/surveyreports/nov-dec95/gobies.html (Accessed February 24, 2004).

Mason, R.J. 1981. Great Lakes Archaeology. Academic Press, New York, New York. |

Michigan Department of Community Health (MDCH). 2003. “2003 Michigan Family Fish

Consumption Guide.” Michigan Department of Community Health, Lansing, Michigan. 

Available URL: http://www.michigan.gov/documents/FishAdvisory03_67354_7.pdf

(Accessed April 27, 2004). 

Michigan Department of Environmental Quality (MDEQ). 2003. “Renewable Operating Permit.” 

RO Permit No. 200200005. Air Quality Division. (February 4, 2003).

Michigan Department of Environmental Quality (MDEQ). 2004. “Authorization to Discharge

Under the National Pollutant Discharge Elimination System.” Permit No. MI0001457. Surface

Water Quality Division. (September 23, 2004). 

Michigan Department of Environmental Quality (MDEQ). 2005a. “Coastal Zone Boundary

Maps.” Lansing, Michigan. Available URL: http://www.michigan.gov/deq/0,1607,7-135-

3313_3677_3696-90802--,00.html (Accessed July 13, 2005). 
Plant and the Environment 

NUREG-1437, Supplement 27 2-70 October 2006

Michigan Department of Environmental Quality (MDEQ). 2005b. “The Sand Dunes Program.” 

Lansing, Michigan. Available URL: http://www.michigan.gov/deq/0,1607,7-135-3311_4114_

4236-9832--,00.html (Accessed July 13, 2005).

Michigan Department of Environmental Quality (MDEQ). 2005c. Letter from M.J. Tironi,

Kalamazoo District Office, Water Bureau, Michigan Department of Environmental Quality, to

| E. Dehn, Environmental Coordinator, Consumers Energy Company, Jackson, Michigan. 

Subject: “National Pollutant Discharge Elimination System.” (November 9, 2005). 

| Michigan Department of Natural Resources (MDNR). 1972. Letter from S.A. Milstein, Michigan

| Department of Natural Resources, to Mary Jane Oestmann, U.S. Atomic Energy Commission. 

| No subject. (May 19, 1972). (See p. A-141 of AEC 1972).

Michigan Department of Natural Resources (MDNR). 2004. “Overview of Michigan’s Fish

Hatchery System.” Ann Arbor, Michigan. Available URL: http://www.michigan.gov/dnr/

0,1607,7-153-10364_28277---,00.html (Accessed February 26, 2004).

Michigan Department of Natural Resources (MDNR). 2005a. “American Burying Beetle

(Nicrophorus americanus Olivier).” Lansing, Michigan. Available URL: 

http://www.michigan.gov/dnr/0,1607,7-153-10370_12145_ 12204-32983--,00.html 

(Accessed July 11, 2005).

Michigan Department of Natural Resources (MDNR). 2005b. “Marbled Salamander

(Ambystoma opacum).” Lansing, Michigan. Available URL: 

http://www.michigan.gov/dnr/0,1607, 7-153-10370_12145_12201-33012 12201-33012-,00.html

(Accessed July 11, 2005).

Michigan Department of Natural Resources (MDNR). 2005c. “Kirtland’s Snake (Clonophis

kirtlandii).” Lansing, Michigan. Available URL: http://www.michigan.gov/dnr/0,1607,7-153-

10370_12145_12201-60850--,00.html (Accessed July 11, 2005).

Michigan Department of Natural Resources (MDNR). 2005d. “2005 Michigan Fishing Guide.” 

Lansing, Michigan. Available URL: http://www.michigan.gov/documents/2005Fishing_Guide_

119644_7 (Accessed November 14, 2005).

Michigan Economic Development Corporation (MEDC). 2005. “Van Buren County – Economy.” 

Available URL: http://medc.michigan.org/miinfo/places/VanBurenCounty/

?section=economy (Accessed July 2005). 

Michigan Electric Transmission Company (METC). 2001. Covert-to-Palisades Substation

| 345 kV Line Route Environmental Impact Statement. Ann Arbor, Michigan. 

| (December 5, 2001).
Plant and the Environment

October 2006 2-71 NUREG-1437, Supplement 27

Michigan Natural Features Inventory (MNFI). 2005a. “Michigan’s Special Animals.” Lansing,

Michigan. Available URL: http://web4.msue.msu.edu/mnfi/data/specialanimals.cfm 

(Accessed July 21, 2005).

Michigan Natural Features Inventory (MNFI). 2005b. “Michigan’s Special Plants.” 

Lansing, Michigan. Available URL: http://web4.msue.msu.edu/mnfi/data/specialplants.cfm

(Accessed July 21, 2005).

Michigan Natural Features Inventory (MNFI). 2005c. “Vegetation Circa 1800 Maps.” 

Lansing, Michigan. Available URL: http://web4.msue.msu.edu/ mnfi/data/veg1800.cfm

(Accessed July 8, 2005).

Michigan Natural Features Inventory (MNFI). 2005d. “Michigan County Element Lists –

March 2001.” Lansing, Michigan. Available URL: http://web4.msue.msu.edu/mnfi/data/

County_lists_2001.pdf (Accessed July 1, 2005).

Michigan State Historic Preservation Office (Michigan SHPO). 2005. Letter from B.D. Conway,

Michigan State Historic Preservation Officer, Lansing, Michigan, to J. Holthaus, Environmental |

Project Manager, Palisades Nuclear Plant, Covert, Michigan. Subject: “ER-05-249 Palisades

Nuclear Power Plant, License Renewal, Covert Township, Van Buren County (NRC).” 

(March 14, 2005).

Michigan State Historic Preservation Office (Michigan SHPO). 2006. Letter from M.M. Faes, |

Michigan State Historic Preservation Officer, Lansing, Michigan, to B. Pham, U.S. Nuclear |

Regulatory Commission, Washington, D.C. Subject: “ER-05-249 Palisades Nuclear Power |

Plant License Renewal, Covert Township, Van Buren County (NRC).” (June 19, 2006). |

Michigan Underwater Preserve Council, Inc. 2004. A Diver’s Guide to Michigan Underwater

Preserves, 2004–2005. J.R. Underhill Communications, Kalamazoo, Michigan.

Midwestern Regional Climate Center (MRCC). 2005. Available URL: http://sisyphus.sws.

uiuc.edu/overview/overview.htm (Accessed July 20, 2005).

Mulcahy, M. 2002. “Covert Operation: Bog Power Plant a Big Employer for Trades.” The

Building Tradesman. June 21. Available URL: http://www.detroitbuildingtrades.org/newspapr/

june212002.html (Accessed September 15, 2005).

Nalepa, T.F., D.W. Schloesser, S.A. Pothoven, D.W. Hondorp, D.L. Fanslow, M.L. Tuchman,

and G.W. Fleischer. 2001. “First Finding of the Amphipod Echinogammarus ischnus and the

Mussel Dreissena bugensis in Lake Michigan.” Journal of Great Lakes Research, Vol. 27, 

pp. 384–391. 
Plant and the Environment 

NUREG-1437, Supplement 27 2-72 October 2006

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321, et seq.

National Center for Educational Statistics (NCES). 2005. “Private School Information.” 

Available URL: http://nces.ed.gov/surveys/pss/privateschoolsearch/ (Accessed July 2005). 

National Oceanic and Atmospheric Administration (NOAA). 2002. “Divisional Normals and

Standard Deviations of Temperature, Precipitation, and Heating and Cooling Degree Days

1971–2000 (and previous normals periods),” Climatology of the United States, No. 85,

Secs. 1 and 2: Temperature and Precipitation, National Oceanic and Atmospheric

Administration, National Environmental Satellite Data and Information Service, National Climate

Data Center, Asheville, North Carolina (June 15, 2002). 

National Oceanic and Atmospheric Administration (NOAA). 2005. Storm Events Database

Search. Available URL: http://www4.ncdc.noaa.gov/cgi-win/wwcgi.dll?wwevent~storms 

(Accessed September 8, 2005). 

National Park Service (NPS). 2005a. “National Register Information System, Van Buren

County and Allegan County.” Available URL: http://www.nr.nps.gov/ (Accessed June 9, 2005).

National Park Service (NPS). 2005b. “Lists of National Historic Landmarks by State.” Available

URL: http://www.cr.nps.gov/nhl/designations/ listsofNHLs.htm (Accessed June 10, 2005).

|

NatureServe. 2005. “NatureServe Explorer: An Online Encyclopedia of Life.” Version 4.5. 

NatureServe, Arlington, Virginia. Available URL: http://www.natureserve.org/explorer

(Accessed July 15, 2005).

Nuclear Management Company, LLC (NMC). 2001a. Palisades Nuclear Plant 2000 Annual

Radioactive Effluent Release and Waste Disposal Report, January 2000 – December 2000.

| Docket No. 50-255. Covert, Michigan. (March 29, 2001).

Nuclear Management Company, LLC (NMC). 2001b. Letter from L. A. Lahti, Nuclear

| Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission,

| Washington, D.C. Subject: “Docket 50–255, License DPR-20, Palisades Plant National

Pollutant Discharge Elimination System Permit Violation Report, May 1, 2001, through

October 31, 2001.” (November 26, 2001). 

Nuclear Management Company, LLC (NMC). 2002. Palisades Nuclear Plant 2001 Annual

Radioactive Effluent Release and Waste Disposal Report, January 2001 – December 2001.

| Docket No. 50-255. Covert, Michigan. (March 26, 2002).
Plant and the Environment

October 2006 2-73 NUREG-1437, Supplement 27

Nuclear Management Company, LLC (NMC). 2003a. Palisades Nuclear Plant 2002 Annual

Radioactive Effluent Release and Waste Disposal Report, January 2002 – December 2002.

Docket No. 50-255. Covert, Michigan. (March 24, 2003). |

Nuclear Management Company, LLC (NMC). 2003b. Final Safety Analysis Report (FSAR) –

Palisades Nuclear Plant, Rev. 24. Covert, Michigan. (October 2003). |

Nuclear Management Company, LLC (NMC). 2004a. Palisades Nuclear Plant Offsite Dose

Calculation Manual. Rev. 19. Covert, Michigan. (January 2004.) |

Nuclear Management Company, LLC (NMC). 2004b. Palisades Nuclear Plant 2003 Annual

Radioactive Effluent Release and Waste Disposal Report, January 2003 – December 2003.

Docket No. 50-255. Covert, Michigan. (March 25, 2004). |

Nuclear Management Company, LLC (NMC). 2004c. Palisades Employees by County. Covert,

Michigan. (September 14, 2004). |

Nuclear Management Company, LLC (NMC). 2005a. Applicant’s Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255,

Covert, Michigan. (March 2005). |

Nuclear Management Company, LLC (NMC). 2005b. Palisades Nuclear Plant 2004 Annual

Radioactive Effluent Release and Waste Disposal Report, January 2004 – December 2004.

Docket No. 50-255. Covert, Michigan. (March 29, 2005). |

Nuclear Management Company, LLC (NMC). 2005c. Palisades Nuclear Plant 2004

Radiological Environmental Operating Report. Docket No. 50-255. Covert, Michigan. |

(May 12, 2005).

Nuclear Management Company, LLC (NMC). 2005d. Palisades Nuclear Plant License

Application for Renewed Operating License. Covert, Michigan. (March 22, 2005). |

Nuclear Management Company, LLC (NMC). 2005e. Letter from J. Holthaus, Environmental

Project Manager, Nuclear Management Company, LLC, Covert, Michigan, to R. Schaaf, Senior

Project Manager, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission,

Washington, D.C. Subject: “Palisades Nuclear Plant, Response to Supplemental Questions

Concerning Radioactive Solid Waste Management.” (October 18, 2005). 

Nuclear Management Company, LLC (NMC). 2006a. Palisades Nuclear Plant 2005 Annual |

Radioactive Effluent Release and Waste Disposal Report, January 2005 S December 2005. |

Docket No. 50-255. Covert, Michigan. (March 29, 2006). |
Plant and the Environment 

NUREG-1437, Supplement 27 2-74 October 2006

| Nuclear Management Company, LLC (NMC). 2006b. Palisades Nuclear Plant 2005

| Radiological Environmental Operating Report. Docket No. 50-255. Covert, Michigan. 

| (May 10, 2006).

| Nuclear Management Company, LLC (NMC). 2006c. Email from J. Holthaus, Environmental

| Project Manager, Nuclear Management Company, LLC, Covert, Michigan, to B. Pham, Project

| Manager, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission,

| Washington, D.C. Subject: “Status of the Federally listed Pitcher’s Thistle (Cirsium pitcheri) on

| the Palisades Nuclear Plant Site.” (September 5, 2006). 

| Pacific Northwest Laboratory (PNL). 1986. Wind Energy Resource Atlas of the United States. 

| DOE/CH 10093-4, Solar Energy Research Institute, Golden, Colorado. (October 1986).

Page, L.M., and B.M. Burr. 1991. A Field Guide to Freshwater Fishes. Houghton Mifflin

Company, Boston, Massachusetts.

Peeters, P. 1998. “Into Lake Michigan’s Waters. Exotic Fish Took Hold by Many Routes.” 

Wisconsin Natural Resources Magazine, June/July, 1998. Available URL: 

http://www.wnrmag.com/stories/1998/jun98/mich.htm (Accessed February 24, 2004).

PG&E Corporation (PG&E). 2001. “PG&E National Energy Group Begins Construction of

Michigan Power Plant.” Available URL: http://www.pgecorp.com/news/press_releases/

Release_Archive2001/080601press_release.shtml (Accessed September 15, 2005). 

Prein & Newhof. 2004. “Covert’s Intake & Pump Station Work Hard Underground.” In View. 

Spring 2004. Available URL: http://www.preinnewhof.com/contact/inview/spring_2004.pdf

(Accessed September 15, 2005). 

Quimby, G.I. 1960. Indian Life in the Upper Great Lakes. The University of Chicago Press,

Chicago, Illinois.

Ray, W.J., and L.D. Corkum. 1997. “Predation of Zebra Mussels by Round Gobies, Neogobius

melanostomus.” Environmental Biology of Fishes, Vol. 50, pp. 267–273. 

Rochow, J.J. 1978a. “Compositional, Structural, and Chemical Changes to Forest Vegetation

from Fresh Water Wet Cooling Tower Drift.” Proceedings of Cooling Tower Environment – 1978

Symposium. College Park, Maryland.

Rochow, J.J. 1978b. “Mechanical and Vegetational Impact of Chemical Drift from Mechanical

Draft Cooling Towers.” Environmental Science and Technology, Vol. 12, pp. 1379–1383.
Plant and the Environment

October 2006 2-75 NUREG-1437, Supplement 27

Scott, W.B., and E.J. Crossman. 1973. Freshwater Fishes of Canada. Bulletin 184. Fisheries

Research Board of Canada, Ottawa.

Shepherd, M.D., D.M. Vaughan, and S.H. Black. 2005. “Red List of Pollinator Insects of North

America.” Portland, Oregon: The Xerces Society for Invertebrate Conservation. Available

URL: http://www.xerces.org/Pollinator_Red_List/index.htm (Accessed July 11, 2005).

Smith, P.W. 1979. The Fishes of Illinois. University of Illinois Press, Urbana, Illinois.

Standard and Poors. 2005. “School Evaluation Services.” Available URL: http://www.ses.

standardandpoors.com/ (Accessed July 2005).

State of Michigan. 2005. “Historic Sites Online.” Available URL: http://www.mcgi.state.mi.

us/hso/ (Accessed June 10, 2005).

Stein, R.A., M.E. Gaden, and C.I. Goddard. 2003. “Protecting and Restoring the Great Lakes

Fishery.” Great Lakes Fishery Commission, Ann Arbor, Michigan. Available URL: 

http://www.senate.gov/!epw/108th/Stein_082503.pdf (Accessed December 18, 2003).

Stewart, T.W., J.G. Miner, and R.L. Lowe. 1998a. “Quantifying Mechanisms for Zebra Mussel

Effects on Benthic Macroinvertebrates: Organic Matter Production and Shell-Generated

Habitat.” Journal of the North American Benthological Society, Vol. 17, pp. 81–95.

Stewart, T.W., J.G. Miner, and R.L. Lowe. 1998b. “Macroinvertebrate Communities on Hard

Substrates in Western Lake Erie: Structuring Effects of Dreissena.” Journal of Great Lakes

Research, Vol. 24, pp. 868–879.

|

University of Wisconsin Sea Grant Institute (UWSGI). 2001a. “Fish of Lake Michigan.” 

Madison, Wisconsin. Available URL: http://www.seagrant.wisc.edu/greatlakesfish/

LakeMichFishIndex.html (Accessed April 28, 2004).

University of Wisconsin Sea Grant Institute (UWSGI). 2001b. “Alewife Watch 2001.” 

Madison, Wisconsin. Available URL: http://www.seagrant.wisc.edu/outreach/fisheries/Alewife/

alewife.html (Accessed July 14, 2004).

University of Wisconsin Sea Grant Institute (UWSGI). 2002. “Why Are the Alewives Dying?” 

Madison, Wisconsin. Available URL: http://www.seagrant.wisc.edu/greatlakesfish/

alewifenews.html (Accessed July 14, 2004).

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to the

Operation of Palisades Nuclear Generating Plant, Consumers Power Company. Docket No. 50-
Plant and the Environment 

NUREG-1437, Supplement 27 2-76 October 2006

255. U.S. Atomic Energy Commission, Directorate of Licensing, Washington, D.C. 

(June 1972).

U.S. Census Bureau. 2000a. “American Fact Finder.” U.S. Census Bureau, Washington, D.C. 

Available URL: http://factfinder.census.gov/ (Accessed July 2005). 

U.S. Census Bureau. 2000b. “County Business Patterns.” U.S. Census Bureau,

Washington, D.C. Available URL: http://www.census.gov/epcd/cbp/view/cbpview.html

(Accessed July 2005).

U.S. Department of Agriculture (USDA). 2002. Census of Agriculture – County Data. 2002. 

National Agricultural Statistics Service, Washington, D.C. Available URL: http://www.nass.

usda.gov/census/census02/volume1/mi/st26_2_007_007.pdf.

U.S. Department of Commerce (DOC). 2002. “Local Area Personal Income.” Bureau of

Economic Analysis. Available URL: http://www.bea.doc.gov/bea/regional/reis/ (Accessed

July 2005).

U.S. Department of the Interior (DOI). 1972. Letter from Deputy Assistant Secretary of the

Interior to L. Manning Muntzing, U.S. Atomic Energy Commission. No subject. (April 7, 1972). 

U.S. Department of Labor (DOL). 2004. “Local Area Unemployment Statistics.” Bureau of

Labor Statistics. Available URL: ftp://ftp.bls.gov/pub/time.series/la/ (Accessed July 2005). 

U.S. Environmental Protection Agency (EPA). 2000. “Lake Michigan Lake Wide Management

Plan (LaMP) 2000.” Available URL: http://www.epa.gov/glnpo/lakemich/ (Accessed

February 25, 2004). 

U.S. Environmental Protection Agency (EPA). 2004. “Lake Michigan Lakewide Management

Plan (LaMP) 2004.” U.S. Environmental Protection Agency, Chicago, Illinois. Available URL: 

http://www.epa.gov/glnpo/lakemich/2004update/index.html (Accessed July 22, 2005).

U.S. Environmental Protection Agency (EPA). 2005a. “Quarterly Non-Compliance Reports,

Region 5.” Available URL: http://www.epa.gov/region5/water/weca/reports (Accessed

September 23, 2005). 

U.S. Environmental Protection Agency (EPA). 2005b. “Michigan 8-hour Ozone Nonattainment

Areas.” Green Book. Available URL: http://www.epa.gov/oar/oaqps/greenbk/mi8.html

(Accessed July 29, 2005).
Plant and the Environment

October 2006 2-77 NUREG-1437, Supplement 27

U.S. Fish and Wildlife Service (FWS). 1989. “Endangered and Threatened Wildlife and Plants;

Determination of Endangered Status for the American Burying Beetle.” Federal Register,

Vol. 54, pp. 29652–29655 (July 13, 1989).

U.S. Fish and Wildlife Service (FWS). 2003. “Freshwater Mussels (Threatened, Endangered,

Proposed, and Candidate) Available Information.” U.S. Fish and Wildlife Service, Region 3. 

Available URL: http://midwest.fws.gov/Endangered/clams/index.html (Accessed April 29, 2004).

U.S. Fish and Wildlife Service (FWS). 2005a. Letter from C.A. Czarnecki, U.S. Fish and

Wildlife Service, East Lansing, Michigan, to J. Holthaus, Nuclear Management Company, LLC,

Covert, Michigan. Subject: “Endangered Species List Request, Proposed Palisades Nuclear

Plant (Palisades) License Renewal Project, Allegan, Berrien, Kalamazoo, and Van Buren

Counties, Michigan.” (March 17, 2005).

U.S. Fish and Wildlife Service (FWS). 2005b. “County Distribution of Michigan’s FederallyListed Threatened, Endangered, Proposed, and Candidate Species.” U.S. Fish and Wildlife

Service, Region 3. Available URL: http://www.fws.gov/midwest/endangered/lists/michigancty.html (Accessed July 6, 2005).

U.S. Fish and Wildlife Service (FWS). 2005c. Letter from C. Czarnecki, U.S. Fish and Wildlife

Service, East Lansing, Michigan, to P.T. Kuo, U.S. Nuclear Regulatory Commission, Rockville,

Maryland. Subject: “Endangered Species List Request, Proposed Palisades Nuclear Plant

(Palisades) License Renewal Project, Allegan, Berrien, Kalamazoo, and Van Buren Counties,

Michigan.” (July 29, 2005).

U.S. Nuclear Regulatory Commission (NRC). 1978. Final Addendum to the Final

Environmental Statement Related to Operation of Palisades Nuclear Generating Plant

Consumers Power Company. Docket No. 50-255. NUREG-0343. U.S. Nuclear Regulatory

Commission, Office of Nuclear Reactor Regulation, Washington, D.C. (February 1978).

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. “Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues.” Appendix D to

NRR Office Instruction LIC-203, Rev. 1, Washington, D.C. (May 24, 2004). |
Plant and the Environment 

NUREG-1437, Supplement 27 2-78 October 2006

U.S. Nuclear Regulatory Commission (NRC). 2005a. Tornado Climatology of the Contiguous

United States. NUREG/CR 4461, Rev. 1, PNNL-15112, Washington, D.C. (April 2005). 

U.S. Nuclear Regulatory Commission (NRC) 2005b. Letter from P.T. Kuo, U.S. Nuclear

Regulatory Commission, Rockville, Maryland, to C. Czarnecki, U.S. Fish and Wildlife Service,

East Lansing, Michigan. Subject: “Request for List of Protected Species Within the Area Under

Evaluation for the Palisades Nuclear Plant License Renewal.” (June 30, 2005).

Weir, D.J., C.S. Demeter, and C.E. Larsen. 1980. Cultural Resource Management Assessment

Study of Eight Candidate Power Plant Sites. Commonwealth Associates, Inc., Report No. 2098. 

(January 1980).

VerBermones, D. 2005. “Taxes Paid on Palisades Nuclear Plant.” Consumers Energy 

(July 26, 2005).

Wesley, J.K. 2005. “Draft Kalamazoo River Assessment.” Michigan Department of Natural

Resources, Fisheries Division, Ann Arbor, Michigan. February. Available URL: 

http://michigan.gov/documents/KalamazooRA_text_tables_117809_7.pdf

(Accessed July 21, 2005).
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 3-1 NUREG-1437, Supplement 27

3.0 Environmental Impacts of Refurbishment

Environmental issues associated with refurbishment activities are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS includes a determination of whether the

analysis of the environmental issues could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required in this Supplemental Environmental Impact Statement (SEIS) unless new and |

significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and,

therefore, additional plant-specific review of these issues is required.

License renewal actions may require refurbishment activities for the extended plant life. These

actions may have an impact on the environment that requires evaluation, depending on the type

of action and the plant-specific design. Environmental issues associated with refurbishment

that were determined to be Category 1 issues are listed in Table 3-1.

Environmental issues related to refurbishment considered in the GEIS for which these

conclusions could not be reached for all plants, or for specific classes of plants, are Category 2

issues. These are listed in Table 3-2.
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 27 3-2 October 2006

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SURFACE-WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Impacts of refurbishment on surface-water quality 3.4.1

Impacts of refurbishment on surface-water use 3.4.1

AQUATIC ECOLOGY (FOR ALL PLANTS)

Refurbishment 3.5

GROUNDWATER USE AND QUALITY

Impacts of refurbishment on groundwater use and quality 3.4.2

LAND USE

Onsite land use 3.2

HUMAN HEALTH

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4;

3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

Category 1 and Category 2 issues related to refurbishment that are not applicable to the

Palisades Nuclear Plant (Palisades) because they are related to plant design features or site

characteristics not found at Palisades are listed in Appendix F.

The potential environmental impacts of refurbishment actions would be identified, and the

analysis would be summarized within this section, if such actions were planned. Nuclear

| Management Company, LLC (NMC), indicated that it has performed an evaluation of structures

| and components pursuant to Section 54.21 of Title 10 of the Code of Federal Regulations

(10 CFR 54.21) to identify activities that are necessary to continue operation of Palisades during

the requested 20-year period of extended operation. These activities include replacement of

certain components as well as new inspection activities and are described in the Environmental

| Report (ER) (NMC 2005).
Environmental Impacts of Refurbishment

October 2006 3-3 NUREG-1437, Supplement 27

Table 3-2. Category 2 Issues for Refurbishment Evaluation

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1

GEIS

Sections

10 CFR 51.53

(c)(3)(ii)

Subparagraph

TERRESTRIAL RESOURCES

Refurbishment impacts 3.6 E

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 3.9 E

AIR QUALITY

Air quality during refurbishment (nonattainment and

maintenance areas)

3.3 F

SOCIOECONOMICS

Housing impacts 3.7.2 I

Public services: public utilities 3.7.4.5 I

Public services: education (refurbishment) 3.7.4.1 I

Offsite land use (refurbishment) 3.7.5 I

Public services, transportation 3.7.4.2 J

Historic and archaeological resources 3.7.7 K

ENVIRONMENTAL JUSTICE

Environmental justice Not

addressed(a)

Not 

addressed(a)

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to

10 CFR Part 51 were prepared. If an applicant plans to undertake refurbishment activities for license renewal,

environmental justice must be addressed in the applicant’s environmental report and the U.S. Nuclear

Regulatory Commission staff’s environmental impact statement.

However, NMC stated that the replacement of these components and the additional inspection

activities are within the bounds of normal plant component replacement and inspections;

therefore, they are not expected to affect the environment outside the bounds of plant operations as evaluated in the Final Environmental Statement for Palisades (AEC 1972). In addition,

NMC’s evaluation of structures and components as required by 10 CFR 54.21 did not identify

any major plant refurbishment activities or modifications necessary to support the continued

operation of Palisades beyond the end of the existing operating license. Therefore,

refurbishment is not considered in this SEIS. |
Environmental Impacts of Refurbishment

NUREG-1437, Supplement 27 3-4 October 2006

3.1 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

Nuclear Management Company, LLC (NMC). 2005. Applicant's Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255, Covert,

Michigan (March 2005).

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to the

Operation of Palisades Nuclear Generating Plant, Consumers Power Company. Docket No. 50-

255. Directorate of Licensing. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 4-1 NUREG-1437, Supplement 27

4.0 Environmental Impacts of Operation

Environmental issues associated with operation of a nuclear power plant during the renewal

term are discussed in the Generic Environmental Impact Statement for License Renewal of

Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS

includes a determination of whether the analysis of the environmental issues could be applied to

all plants and whether additional mitigation measures would be warranted. Issues are then

assigned a Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues

are those that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, OR LARGE) has been assigned to

the impacts (except for collective off-site radiological impacts from the fuel cycle and

from high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and

therefore, additional plant-specific review of these issues is required.

This chapter addresses the issues related to operation during the renewal term that are listed in

Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51), |

Subpart A, Appendix B, and are applicable to the Palisades Nuclear Plant (Palisades). 

Section 4.1 addresses issues applicable to the Palisades cooling system. Section 4.2

addresses issues related to transmission lines and onsite land use. Section 4.3 addresses the

radiological impacts of normal operation, and Section 4.4 addresses issues related to the

socioeconomic impacts of normal operation during the renewal term. Section 4.5 addresses

issues related to groundwater use and quality, while Section 4.6 discusses the impacts of

renewal-term operations on threatened and endangered species. Section 4.7 addresses
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-2 October 2006

potential new information that was raised during the scoping period, and Section 4.8 discusses

cumulative impacts. The results of the evaluation of environmental issues related to operation

during the renewal term are summarized in Section 4.9. Finally, Section 4.10 lists the

references for Chapter 4. Category 1 and Category 2 issues that are not applicable to

Palisades because they are related to plant design features or site characteristics not found at

Palisades are listed in Appendix F.

4.1 Cooling System

Category 1 issues in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B that are applicable to

the Palisades cooling system operation during the renewal term are listed in Table 4-1. Nuclear

| Management Company, LLC (NMC), stated in its Environmental Report (ER) (NMC 2005a) that

it is not aware of any new and significant information associated with the license renewal and

| continued operation of Palisades. The U.S. Nuclear Regulatory Commission (NRC) staff has

not identified any new and significant information during its independent review of the NMC ER

| (NMC 2005a), the site visit, the scoping process, the evaluation of other available information

| and public comments on the draft SEIS. Therefore, the NRC staff concludes that there would

be no impacts related to these issues beyond those discussed in the GEIS. For all of the

| issues, the NRC staff concluded in the GEIS that the impacts would be SMALL, and additional

plant-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1,

for each of these issues follows:

 C Altered current patterns at intake and discharge structures. Based on information in the

GEIS, the Commission found that

Altered current patterns have not been found to be a problem at operating

nuclear power plants and are not expected to be a problem during the license

renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of altered current patterns at intake and discharge

structures during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

October 2006 4-3 NUREG-1437, Supplement 27

Table 4-1. Category 1 Issues Applicable to the Operation of the Palisades Cooling System

During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SURFACE-WATER QUALITY, HYDROLOGY, AND USE

Altered current patterns at intake and discharge structures 4.2.1.2.1

Altered thermal stratification of lakes 4.2.1.2.2

Temperature effects on sediment transport capacity 4.2.1.2.3

Scouring caused by discharged cooling water 4.2.1.2.3

Eutrophication 4.2.1.2.3

Discharge of chlorine or other biocides 4.2.1.2.4

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4

Discharge of other metals in wastewater 4.2.1.2.4

AQUATIC ECOLOGY

Accumulation of contaminants in sediments or biota 4.2.1.2.4

Entrainment of phytoplankton and zooplankton 4.2.2.1.1

Cold shock 4.2.2.1.5

Thermal plume barrier to migrating fish 4.2.2.1.6

Distribution of aquatic organisms 4.2.2.1.6

Premature emergence of aquatic insects 4.2.2.1.7

Gas supersaturation (gas bubble disease) 4.2.2.1.8

Low dissolved oxygen in the discharge 4.2.2.1.9

Losses from predation, parasitism, and disease among organisms

exposed to sublethal stresses

4.2.2.1.10

Stimulation of nuisance organisms 4.2.2.1.11

AQUATIC ECOLOGY (PLANTS WITH COOLING-TOWER-BASED HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early life stages 4.3.3

Impingement of fish and shellfish 4.3.3

Heat shock 4.3.3

TERRESTRIAL RESOURCES

Cooling-tower impacts on crops and ornamental vegetation 4.3.4

Cooling-tower impacts on native plants 4.3.5.1

Bird collisions with cooling towers 4.3.5.2

HUMAN HEALTH

Microbiological organisms (occupational health) 4.3.6

Noise 4.3.7
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-4 October 2006

 C Altered thermal stratification of lakes. Based on information in the GEIS, the

Commission found that

Generally, lake stratification has not been found to be a problem at operating

nuclear power plants and is not expected to be a problem during the license

renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

| programs, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of altered thermal

stratification of lakes during the renewal term beyond those discussed in the GEIS.

 C Temperature effects on sediment transport capacity. Based on information in the GEIS,

the Commission found that

These effects have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of temperature effects on sediment transport

capacity during the renewal term beyond those discussed in the GEIS.

 C Scouring caused by discharged cooling water. Based on information in the GEIS, the

Commission found that

Scouring has not been found to be a problem at most operating nuclear power

plants and has caused only localized effects at a few plants. It is not expected to

be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

| programs, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of scouring

caused by discharged cooling water during the renewal term beyond those discussed in the

GEIS.
Environmental Impacts of Operation

October 2006 4-5 NUREG-1437, Supplement 27

 C Eutrophication. Based on information in the GEIS, the Commission found that

Eutrophication has not been found to be a problem at operating nuclear power

plants and is not expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

programs, and its evaluation of other available information (including plant monitoring data |

and technical reports) and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of eutrophication during the renewal term beyond

those discussed in the GEIS.

 C Discharge of chlorine or other biocides. Based on information in the GEIS, the

Commission found that

Effects are not a concern among regulatory and resource agencies, and are not

expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information (including the National Pollutant Discharge Elimination System |

(NPDES) permit for Palisades and discussion with the Michigan Department of

Environmental Quality (MDEQ) compliance office) and public comments on the draft SEIS. |

Therefore, the NRC staff concludes that there would be no impacts of discharge of chlorine

or other biocides during the renewal term beyond those discussed in the GEIS.

 C Discharge of sanitary wastes and minor chemical spills. Based on information in the

GEIS, the Commission found that

Effects are readily controlled through the NPDES permit, and periodic

modifications, if needed, and are not expected to be a problem during the license

renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information (including the NPDES permit for Palisades and discussion with the |

MDEQ compliance office) and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of discharges of sanitary wastes and minor

chemical spills during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-6 October 2006

 C Discharge of other metals in wastewater. Based on information in the GEIS, the

Commission found that

These discharges have not been found to be a problem at operating nuclear

power plants with cooling-tower-based heat dissipation systems and have been

satisfactorily mitigated at other plants. They are not expected to be a problem

during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information (including the NPDES permit for Palisades and discussion with the

| MDEQ compliance office) and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of discharges of other metals in wastewater

during the renewal term beyond those discussed in the GEIS.

 C Accumulation of contaminants in sediments or biota. Based on information in the GEIS,

the Commission found that

Accumulation of contaminants has been a concern at a few nuclear power plants

but has been satisfactorily mitigated by replacing copper alloy condenser tubes

with those of another metal. It is not expected to be a problem during the license

renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of available

| information and public comments on the draft SEIS. Therefore, the NRC staff concludes

that there would be no impacts of accumulation of contaminants in sediments or biota during

the renewal term beyond those discussed in the GEIS.

 C Entrainment of phytoplankton and zooplankton. Based on information in the GEIS, the

Commission found that

Entrainment of phytoplankton and zooplankton has not been found to be a

problem at operating nuclear power plants and is not expected to be a problem

during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

| programs, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of entrainment of

phytoplankton and zooplankton during the renewal term beyond those discussed in the

GEIS.
Environmental Impacts of Operation

October 2006 4-7 NUREG-1437, Supplement 27

 C Cold shock. Based on information in the GEIS, the Commission found that

Cold shock has been satisfactorily mitigated at operating nuclear plants with

once-through cooling systems, has not endangered fish populations or been

found to be a problem at operating nuclear power plants with cooling towers or

cooling ponds, and is not expected to be a problem during the license renewal

term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of cold shock during the renewal term beyond

those discussed in the GEIS.

 C Thermal plume barrier to migrating fish. Based on information in the GEIS, the

Commission found that

Thermal plumes have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of thermal plume barriers on migrating fish during

the renewal term beyond those discussed in the GEIS.

 C Distribution of aquatic organisms. Based on information in the GEIS, the Commission

found that

Thermal discharge may have localized effects but is not expected to affect the

larger geographical distribution of aquatic organisms.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

programs, and its evaluation of other available information and public comments on the draft |

SEIS. Therefore, the NRC staff concludes that there would be no impacts on distribution of |

aquatic organisms during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-8 October 2006

 C Premature emergence of aquatic insects. Based on information in the GEIS, the

Commission found that

Premature emergence has been found to be a localized effect at some operating

nuclear power plants but has not been a problem and is not expected to be a

problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of premature emergence of aquatic insects during

the renewal term beyond those discussed in the GEIS.

 C Gas supersaturation (gas bubble disease). Based on information in the GEIS, the

Commission found that

Gas supersaturation was a concern at a small number of operating nuclear

power plants with once-through cooling systems but has been satisfactorily

mitigated. It has not been found to be a problem at operating nuclear power

plants with cooling towers or cooling ponds and is not expected to be a problem

during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of gas supersaturation during the renewal term

beyond those discussed in the GEIS.

 C Low dissolved oxygen in the discharge. Based on information in the GEIS, the

Commission found that

Low dissolved oxygen has been a concern at one nuclear power plant with a

once-through cooling system but has been effectively mitigated. It has not been

found to be a problem at operating nuclear power plants with cooling towers or

cooling ponds and is not expected to be a problem during the license renewal

term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, the review of monitoring

| programs, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of low dissolved

oxygen during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

October 2006 4-9 NUREG-1437, Supplement 27

 C Losses from predation, parasitism, and disease among organisms exposed to sublethal

stresses. Based on information in the GEIS, the Commission found that

These types of losses have not been found to be a problem at operating nuclear

power plants and are not expected to be a problem during the license renewal

term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of losses from predation, parasitism, and disease

among organisms exposed to sublethal stresses during the renewal term beyond those

discussed in the GEIS.

 C Stimulation of nuisance organisms. Based on information in the GEIS, the Commission

found that

Stimulation of nuisance organisms has been satisfactorily mitigated at the single

nuclear power plant with a once-through cooling system where previously it was

a problem. It has not been found to be a problem at operating nuclear power

plants with cooling towers or cooling ponds and is not expected to be a problem

during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of stimulation of nuisance organisms during the

renewal term beyond those discussed in the GEIS.

 C Entrainment of fish and shellfish in early life stages (cooling-tower-based heat

dissipation). Based on information in the GEIS, the Commission found that

Entrainment of fish has not been found to be a problem at operating nuclear

power plants with this type of cooling system and is not expected to be a problem

during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of entrainment of fish and shellfish in early life
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-10 October 2006

stages for cooling-tower-based systems during the renewal term beyond those discussed in

the GEIS.

 C Impingement of fish and shellfish (cooling-tower-based heat dissipation). Based on

information in the GEIS, the Commission found that

The impingement has not been found to be a problem at operating nuclear power

plants with this type of cooling system and is not expected to be a problem during

the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of impingement of fish and shellfish for coolingtower-based systems during the renewal term beyond those discussed in the GEIS.

 C Heat shock (cooling-tower-based heat dissipation). Based on information in the GEIS,

the Commission found that

Heat shock has not been found to be a problem at operating nuclear power

plants with this type of cooling system and is not expected to be a problem during

the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of heat shock for cooling-tower-based systems

during the renewal term beyond those discussed in the GEIS.

 C Cooling-tower impacts on crops and ornamental vegetation. Based on information in the

GEIS, the Commission found that

Impacts from salt drift, icing, fogging, or increased humidity associated with

cooling-tower operation have not been found to be a problem at operating

nuclear power plants and are not expected to be a problem during the renewal

term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no cooling-tower impacts on crops and ornamental vegetation

during the renewal term beyond those discussed in the GEIS.
Environmental Impacts of Operation

October 2006 4-11 NUREG-1437, Supplement 27

 C Cooling-tower impacts on native plants. Based on information in the GEIS, the

Commission found that

Impacts from salt drift, icing, fogging, or increased humidity associated with

cooling-tower operation have not been found to be a problem at operating

nuclear power plants and are not expected to be a problem during the license

renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no cooling-tower impacts on native vegetation during the

renewal term beyond those discussed in the GEIS.

 C Bird collisions with cooling towers. Based on information in the GEIS, the Commission

found that

These collisions have not been found to be a problem at operating nuclear power

plants and are not expected to be a problem during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of bird collisions with cooling towers during the

renewal term beyond those discussed in the GEIS.

 C Microbiological organisms (occupational health). Based on information in the GEIS, the

Commission found that

Occupational health impacts are expected to be controlled by continued

application of accepted industrial hygiene practices to minimize worker

exposures.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of microbiological organisms during the renewal

term beyond those discussed in the GEIS.
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NUREG-1437, Supplement 27 4-12 October 2006

 C Noise. Based on information in the GEIS, the Commission found that

Noise has not been found to be a problem at operating plants and is not

expected to be a problem at any plant during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of noise during the renewal term beyond those

discussed in the GEIS.

No Category 2 issues related to cooling system operation during the renewal term are

applicable to Palisades.

4.2 Transmission Lines

The Final Environmental Statement (FES) for Palisades (AEC 1972) describes two transmission

lines that connect Palisades with the transmission system. The transmission lines, as well as

their ownership and responsibilities for their maintenance, are described in Section 2.1.7 of this

Supplemental Environmental Impact Statement (SEIS). The 0.6-mi-long Palisades-Cook

345-kV transmission line connects to the American Electric Power (AEP) system, while the

40-mi-long Palisades-Argenta 345-kV transmission line connects to the Michigan Electric

| Transmission Company, LLC (METC), system and the Michigan Power Pool (NMC 2005a).

The Palisades-Cook transmission line is situated on land similar to that of the Palisades site. Its

construction involved the clearing of a 150-ft-wide right-of-way totaling 10.9 ac over sand dunes

(AEC 1972). The Palisades-Argenta transmission line right-of-way is 1320 ft wide for the first

4.5 mi, 350 ft wide for the next 34 mi, and 471 ft wide for the final 1.5 mi, totaling 2250 ac. This

line crosses mostly flat to gently rolling terrain used primarily for agriculture (AEC 1972).

Vegetation control along Palisades transmission lines is accomplished through the use of

herbicides, mowing, and cutting, or pruning of tall-growing tree species that are considered

danger trees. Danger trees are typically outside the cleared right-of-way but could cause a line

outage from windfall of healthy or diseased trees. Procedures are in place to ensure that

vegetation management along rights-of-way is carried out in a manner to protect local water

bodies and aquatic organisms that could be adversely impacted from herbicide application in

the immediate vicinity of stream and river crossings. Herbicides that are used comply with

Federal and State regulations and are applied by licensed applicators.

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

Palisades transmission lines are listed in Table 4-2. NMC stated in its ER that it is not aware of

any new and significant information associated with the renewal of the Palisades operating
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October 2006 4-13 NUREG-1437, Supplement 27

license (OL) (NMC 2005a). The NRC staff has not identified any new and significant

information during its independent review of the NMC ER, the site visit, the scoping process, |

and its evaluation of other available information and public comments on the draft SEIS. |

Therefore, the NRC staff concludes that there would be no impacts related to these issues

beyond those discussed in the GEIS (NRC 1999). For all of those issues, the NRC staff

concluded in the GEIS that the impacts would be SMALL, and additional plant-specific |

mitigation measures are not likely to be sufficiently beneficial to be warranted.

Table 4-2. Category 1 Issues Applicable to the Palisades Transmission Lines During

the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

TERRESTRIAL RESOURCES

Power line right-of-way management (cutting and herbicide application) 4.5.6.1

Bird collisions with power lines 4.5.6.2

Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops,

honeybees, wildlife, livestock)

4.5.6.3

Floodplains and wetlands on power line right-of-way 4.5.7

AIR QUALITY

Air quality effects of transmission lines 4.5.2

LAND USE

Onsite land use 4.5.3

Power line right-of-way 4.5.3

A brief description of the NRC staff’s review and GEIS conclusions, as codified in Table B-1, for

each of these issues follows:

 C Power line right-of-way management (cutting and herbicide application). Based on

information in the GEIS, the Commission found that

The impacts of right-of-way maintenance on wildlife are expected to be of small

significance at all sites.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, consultation with the U.S. Fish

and Wildlife Service (FWS) and the Michigan Department of Natural Resources (MDNR), |

and its evaluation of other available information and public comments on the draft SEIS. |
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-14 October 2006

Therefore, the NRC staff concludes that there would be no impacts of power line right-ofway maintenance during the renewal term beyond those discussed in the GEIS.

 C Bird collisions with power lines. Based on information in the GEIS, the Commission

found that

Impacts are expected to be of SMALL significance at all sites.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, consultation with the FWS and

| MDNR, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of bird collisions

with power lines during the renewal term beyond those discussed in the GEIS.

 C Impacts of electromagnetic fields on flora and fauna (plants, agricultural crops,

honeybees, wildlife, livestock). Based on information in the GEIS, the Commission

found that

No significant impacts of electromagnetic fields on terrestrial flora and fauna

have been identified. Such effects are not expected to be a problem during the

license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of electromagnetic fields on flora and fauna during

the renewal term beyond those discussed in the GEIS.

 C Floodplains and wetlands on power line rights-of-way. Based on information in the

GEIS, the Commission found that

Periodic vegetation control is necessary in forested wetlands underneath power

lines and can be achieved with minimal damage to the wetland. No significant

impact is expected at any nuclear power plant during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, consultation with the FWS and

| MDNR, and its evaluation of other available information and public comments on the draft

| SEIS. Therefore, the NRC staff concludes that there would be no impacts of power line

rights-of-way on floodplains and wetlands during the renewal term beyond those discussed

in the GEIS.
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October 2006 4-15 NUREG-1437, Supplement 27

 C Air quality effects of transmission lines. Based on the information in the GEIS, the

Commission found that

Production of ozone and oxides of nitrogen is insignificant and does not

contribute measurably to ambient levels of these gases.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no air quality impacts of transmission lines during the renewal

term beyond those discussed in the GEIS.

 C Onsite land use. Based on the information in the GEIS, the Commission found that

Projected onsite land use changes required during ... the renewal period would

be a small fraction of any nuclear power plant site and would involve land that is

controlled by the applicant.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no onsite land-use impacts during the renewal term beyond

those discussed in the GEIS.

 C Power line rights-of-way. Based on information in the GEIS, the Commission found that |

Ongoing use of power line rights-of-way would continue with no change in

restrictions. The effects of these restrictions are of small significance.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of power line rights-of-way on land use during the

renewal term beyond those discussed in the GEIS.

There is one Category 2 issue related to transmission lines, and another issue related to

transmission lines is being treated as a Category 2 issue. These issues are listed in Table 4-3

and are discussed in Sections 4.2.1 and 4.2.2.
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NUREG-1437, Supplement 27 4-16 October 2006

Table 4-3. Category 2 and Uncategorized Issues Applicable to the Palisades Transmission

Lines During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS

Sections

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

HUMAN HEALTH

Electromagnetic fields, acute effects

(electric shock)

4.5.4.1 H 4.2.1

| Electromagnetic fields, chronic effects 4.5.4.2 NA(a) 4.2.2

| (a) Not addressed.

| 4.2.1 Electromagnetic Fields – Acute Effects

Based on the GEIS, the Commission found that electric shock resulting from direct access to

energized conductors or from induced charges in metallic structures has not been found to be a

problem at most operating plants and generally is not expected to be a problem during the

license renewal term. However, site-specific review is required to determine the significance of

the electric shock potential along the portions of the transmission lines that are within the scope

| of this SEIS. 

In the GEIS (NRC 1996), the NRC staff found that without a review of the conformance of each

nuclear plant transmission line with National Electrical Safety Code (NESC) (IEEE 2002)

criteria, it was not possible to determine the significance of the electric shock potential. 

Evaluation of individual plant transmission lines is necessary because the issue of electric

shock safety was not addressed in the licensing process for some plants. For other plants, land

use in the vicinity of transmission lines may have changed, or power distribution companies may

have chosen to upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant

must provide an assessment of the potential shock hazard if the transmission lines that were

constructed for the specific purpose of connecting the plant to the transmission system do not

meet the recommendations of the NESC for preventing electric shock from induced currents.

Both transmission lines associated with Palisades were constructed in accordance with NESC

and industry guidance in effect at that time. The transmission facilities are maintained to ensure

continued compliance with current standards. Since the lines were constructed, a new criterion

has been added to the NESC for power lines with voltages exceeding 98 kV. This

criterion states that the minimum clearance for a line must limit induced currents due to static

effects to 5 mA.

NMC (2005a) has reviewed the power lines for compliance with this criterion. Spans where the

potential for induced current would be the greatest were identified. The electric field strengths
Environmental Impacts of Operation

October 2006 4-17 NUREG-1437, Supplement 27

and potential induced currents for these spans were calculated by using Version 2.5 of the

ENVIRO computer code (EPRI 1996). Input to the code included line sag at a 120°F conductor

temperature, maximum operating voltage during normal load conditions, and a large

tractor-trailer parked under the line in a position to maximize the induced current. The

calculated induced currents for both Palisades 345-kV lines at six locations ranged from

1.6 to 4.9 mA, all below the NESC 5-mA criterion (NMC 2005a).

The NRC staff has reviewed the available information, including the applicant’s evaluation and

computational results. Based on this information, the NRC staff has evaluated the potential

impacts for electric shock resulting from operation of Palisades and its associated transmission

lines. The NRC staff concludes that the impacts of electric shock during the renewal period

would be SMALL, and that no further mitigation measures would be warranted.

4.2.2 Electromagnetic Fields – Chronic Effects |

In the GEIS, the chronic effects of 60-Hz electromagnetic fields from power lines were not

designated as Category 1 or 2, and will not be until a scientific consensus is reached on the

health implications of these fields.

The potential for chronic effects from these fields continues to be studied and is not known at

this time. The National Institute of Environmental Health Sciences (NIEHS) directs related

research through the U.S. Department of Energy (DOE). The report by NIEHS (1999) contains

the following conclusion:

The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic field]

exposure cannot be recognized as entirely safe because of weak scientific evidence that

exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant

aggressive regulatory concern. However, because virtually everyone in the United States

uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is

warranted such as continued emphasis on educating both the public and the regulated

community on means aimed at reducing exposures. The NIEHS does not believe that other

cancers or noncancer health outcomes provide sufficient evidence of a risk to currently

warrant concern.

This statement is not sufficient to cause the NRC staff to change its position with respect to the

chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of “Not

Applicable” still appropriate and will continue to follow developments on this issue.
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NUREG-1437, Supplement 27 4-18 October 2006

4.3 Radiological Impacts of Normal Operations

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

Palisades in regard to radiological impacts are listed in Table 4-4. NMC stated in its ER

(NMC 2005a) that it is not aware of any new and significant information associated with the

renewal of the Palisades OL. The NRC staff has not identified any new and significant

| information during its independent review of the NMC ER, the site visit, the scoping process,

| and its evaluation of other available information and public comments on the draft SEIS. 

Therefore, the NRC staff concludes that there are no impacts related to these issues beyond

those discussed in the GEIS. For these issues, the NRC staff concluded in the GEIS that the

impacts are SMALL, and additional plant-specific mitigation measures are not likely to be

sufficiently beneficial to be warranted.

Table 4-4. Category 1 Issues Applicable to Radiological Impacts of Normal Operations

During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

HUMAN HEALTH

Radiation exposures to public (license renewal term) 4.6.2

Occupational radiation exposures (license renewal term) 4.6.3

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1,

for each of these issues follows:

| C Radiation exposures to the public (license renewal term). Based on information in the

GEIS, the Commission found that

Radiation doses to the public will continue at current levels associated with

normal operations.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts of radiation exposures to the public during the

renewal term beyond those discussed in the GEIS.
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October 2006 4-19 NUREG-1437, Supplement 27

 C Occupational radiation exposures (license renewal term). Based on information in the

GEIS, the Commission found that

Projected maximum occupational doses during the license renewal term are

within the range of doses experienced during normal operations and normal

maintenance outages, and would be well below regulatory limits.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts of occupational radiation exposures during the

renewal term beyond those discussed in the GEIS.

There are no Category 2 issues related to radiological impacts of routine operations.

4.4 Socioeconomic Impacts of Plant Operations During the

License Renewal Period

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

socioeconomic impacts during the renewal term are listed in Table 4-5. NMC stated in its ER

(NMC 2005a) that it is not aware of any new and significant information associated with the

renewal of the Palisades OL. The NRC staff has not identified any new and significant

information during its independent review of the NMC ER, the site visit, the scoping process, |

and its evaluation of other available information and public comments on the draft SEIS. |

Therefore, the NRC staff concludes that there are no impacts related to these issues beyond

those discussed in the GEIS (NRC 1996). For these issues, the NRC staff concluded in the

GEIS that the impacts are SMALL, and additional plant-specific mitigation measures are not

likely to be sufficiently beneficial to be warranted.

Table 4-5. Category 1 Issues Applicable to Socioeconomics During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections

SOCIOECONOMICS

Public services: public safety, social services, and tourism and recreation 4.7.3; 4.7.3.3; 4.7.3.4;

4.7.3.6

Public services: education (license renewal term) 4.7.3.1

Aesthetic impacts (license renewal term) 4.7.6

Aesthetic impacts of transmission lines (license renewal term) 4.5.8
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NUREG-1437, Supplement 27 4-20 October 2006

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1,

for each of these issues follows:

 C Public services: public safety, social services, and tourism and recreation. Based on

information in the GEIS, the Commission found that

Impacts on public safety, social services, and tourism and recreation are

expected to be of SMALL significance at all sites.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts on public safety, social services, and tourism and

recreation during the renewal term beyond those discussed in the GEIS.

 C Public services: education (license renewal term). Based on information in the GEIS,

the Commission found that

Only impacts of SMALL significance are expected.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no impacts on education during the renewal term beyond

those discussed in the GEIS.

 C Aesthetic impacts (license renewal term). Based on information in the GEIS, the

Commission found that

No significant impacts are expected during the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no aesthetic impacts during the renewal term beyond those

discussed in the GEIS.

 C Aesthetic impacts of transmission lines (license renewal term). Based on information in

the GEIS, the Commission found that

No significant impacts are expected during the license renewal term.
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October 2006 4-21 NUREG-1437, Supplement 27

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no aesthetic impacts of transmission lines during the renewal

term beyond those discussed in the GEIS.

Table 4-6 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and

environmental justice, which was not addressed in the GEIS.

Table 4-6. Environmental Justice and GEIS Category 2 Issues Applicable 

to Socioeconomics During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 GEIS Sections

10 CFR 51.53(c)(3)(ii)

Subparagraph SEIS Section

SOCIOECONOMICS

Housing impacts 4.7.1 I 4.4.1

Public services: public utilities 4.7.3.5 I 4.4.2

Offsite land use (license renewal term) 4.7.4 I 4.4.3

Public services, transportation 4.7.3.2 J 4.4.4

Historic and archaeological resources 4.7.7 K 4.4.5

Environmental justice Not addressed(a) Not addressed(a) 4.4.6

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated revision to

10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in the NRC staff’s

environmental impact statement.

4.4.1 Housing Impacts During Operations

In determining housing impacts, the applicant chose to follow Appendix C of the GEIS

(NRC 1996), which presents a population characterization method that is based on two factors,

“sparseness” and “proximity” (GEIS Section C.1.4 (NRC 1996)). Sparseness measures

population density within 20 mi of the site, and proximity measures population density and city

size within 50 mi. Each factor has categories of density and size (GEIS Table C.1), and a

matrix is used to rank the population category as low, medium, or high (GEIS Figure C.1).

In 2000, 118,667 people were living within 20 mi of the Palisades site. Based on the GEIS

measure of sparseness, the area within 20 mi has a density of 238 persons/mi2

, placing it in the

least sparse (high-density) category, Category 4 (NMC 2005a; U.S. Census Bureau 2004). In

2000, 1,287,558 persons lived within 50 mi of the plant, giving the area a density of
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NUREG-1437, Supplement 27 4-22 October 2006

283 persons/mi2. According to the NRC sparseness and proximity matrix, the area falls into

Category 4 for both measures, meaning that the area is classified as a high-density area.

Part 51 of 10 CFR, Subpart A, Appendix B, Table B-1 states that impacts on housing availability

are expected to be of small significance at plants located in a high-population area where

growth-control measures are not in effect. The Palisades site is located in a high-population

area, and Van Buren County is not subject to growth-control measures that would limit housing

development. Based on the NRC criteria, NMC anticipates that housing impacts would be

SMALL during continued operation of Palisades (NMC 2005a).

SMALL impacts result when no discernible change in housing availability occurs, changes in

rental rates and housing values are similar to those occurring statewide, and no housing

construction or conversion is required to meet new demand (NRC 1996). The NMC ER

(NMC 2005a) assumes that a small number of additional workers might be needed during the

license renewal period to perform routine maintenance and other activities.

The housing vacancy rate in 2000 was 17.6 percent in Van Buren County and 13.4 percent in

Berrien County. If these vacancy rates continue, small increases in the number of workers

required at the plant would not require any new housing construction.

The NRC staff reviewed the available information relative to housing impacts and NMC’s

conclusions. Based on this review, the NRC staff concludes that the impact on housing during

the license renewal period would be SMALL, and additional mitigation is not warranted.

4.4.2 Public Services: Public Utility Impacts During Operations

Impacts on public utility services are considered SMALL if there is little or no change in the

ability of the system to respond to the level of demand, and thus there is no need to add capital

facilities. Impacts are considered MODERATE if overtaxing of service capabilities occurs during

periods of peak demand. Impacts are considered LARGE if existing levels of service (e.g.,

water or sewer services) are substantially degraded and additional capacity is needed to meet

ongoing demands for services. The GEIS indicates that, in the absence of new and significant

information to the contrary, the only impacts on public utilities that could be significant are

impacts on public water supplies (NRC 1996).

Analysis of impacts on the public water supply system considered both plant demand and plantrelated population growth. Section 2.2.2 describes the Palisades permitted withdrawal rate and

actual use of water.

The NRC staff has reviewed the available information, including permitted and actual water use

rates at Palisades, and water use and water supply capacities for the major water supply

systems in Van Buren County. Based on this information, the NRC staff concludes that the
Environmental Impacts of Operation

October 2006 4-23 NUREG-1437, Supplement 27

potential impacts of Palisades operation during the license renewal period would be SMALL. 

During the course of its evaluation, the NRC staff considered mitigation measures for continued

operation of Palisades. Based on this evaluation, the NRC staff expects that mitigation

measures in place at Palisades are appropriate, and that no additional mitigation measures are

warranted.

4.4.3 Offsite Land Use During Operations

Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51,

Subpart A, Appendix B, Table B-1). Table B-1 of 10 CFR Part 51, Subpart A, Appendix B notes

that “significant changes in land use may be associated with population and tax revenue

changes resulting from license renewal.”

Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant

operation during the license renewal term as follows:

SMALL – Little new development and minimal changes to an area’s land-use pattern.

MODERATE – Considerable new development and some changes to the land-use pattern.

LARGE – Large-scale new development and major changes in the land-use pattern.

NMC expects to use existing employees, possibly adding a maximum of two employees, to

support Palisades operations during the license renewal term. In Section 3.7.5 of the GEIS

(NRC 1996), the NRC staff stated that if plant-related population growth is less than 5 percent of

the study area’s total population, offsite land-use changes would be SMALL, especially if the

study area has established patterns of residential and commercial development, a population

density of at least 60 persons/mi2

, and at least one urban area with a population of 100,000 or

more within a 50-mi radius. In this case, population growth would be 0 percent of the total

2000 population of 1,287,558 within the 50-mi radius. The area has established patterns of

residential and commercial development, a population density of 283 persons/mi2

, and at least

one urban area (Kalamazoo-Battle Creek Metropolitan Statistical Area) with a population of

100,000 or more within the 50-mi radius. Consequently, the NRC staff concludes that

population changes resulting from renewal of the Palisades OL would likely result in SMALL

impacts on offsite land use.

Tax revenue can affect land use because it enables local jurisdictions to provide the public

services (e.g., transportation and utilities) necessary to support development. In Section 4.7.4.1

of the GEIS, the NRC staff states that the assessment of tax-driven, land-use impacts during the

license renewal term should consider (1) the size of the plant’s payments relative to the

community’s total revenues, (2) the nature of the community’s existing land-use pattern, and
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-24 October 2006

(3) the extent to which the community already has public services in place to support and guide

development. If the plant’s tax payments are projected to be small relative to the community’s

total revenue, tax-driven land-use changes during the plant’s license renewal term would be

SMALL, especially where the community has pre-established patterns of development and has

provided adequate public services to support and guide development. Section 4.7.2.1 of the

GEIS states that if tax payments by the plant owner are less than 10 percent of the taxing

jurisdictions revenue, the significance level would be SMALL. If the plant’s tax payments are

projected to be medium to large relative to the community’s total revenue, new tax-driven landuse changes would be MODERATE. If the plant’s tax payments are projected to be a dominant

source of the community’s total revenue, new tax-driven land-use changes would be LARGE. 

This would be especially true where the community has no pre-established pattern of

development or has not provided adequate public services to support and guide development.

Covert Township and Covert School District receive significant tax payments from Consumers

| Energy property tax payments. As discussed in Section 2.2.8.6 and shown in Table 2-9,

| Consumers Energy paid $0.9 million in property taxes to the township in 2004, or approximately

| 56 percent of the township’s revenues. The Covert School District received $2.7 million from

| taxes paid by Consumers Energy in 2004. These payments represent a substantial, positive

impact on the fiscal condition of the township and the school district. In addition to the Covert

School District, Covert Township forwards the balance of the property tax revenues to the

Van Buren Intermediate School District and Van Buren County. Both the Van Buren

| Intermediate School District and Van Buren County received $0.8 million, respectively, in

| property tax payments in 2004, or 3 and 4 percent, respectively, of revenues in each jurisdiction.

Because no refurbishment or new construction activities are associated with the license

renewal, no additional sources of plant-related tax payments are expected that could influence

land use in the township or the county. The continued collection of property taxes from

Consumers Energy for Palisades will result in moderate indirect tax-driven land-use impacts

through sewer and water system improvements and expansion, lower property taxes, and

improved educational services and facilities. This source of revenue allows the township,

school district, and county to keep tax rates below the levels they would otherwise have in order

to fund the higher levels of public infrastructure and services, schools, and government

services.

Van Buren County’s population growth rates over the last 30 years have been both moderate

and stable (Table 2-8). NMC projects the addition of one or two additional employees to

| support the operation of Palisades during the license renewal term; thus, land-use changes

from Palisades population-related growth would be negligible. While the county has

experienced significant residential, industrial, and commercial growth during this 30-year period,

Van Buren County has developed an overall land-use decision-making strategy that encourages
Environmental Impacts of Operation

(a) Interview with K. Getman and M. Thomas, Michigan Economic Development Corporation (July 2005).

October 2006 4-25 NUREG-1437, Supplement 27

municipalities to implement a “smart growth” methodology that relies on a mix of development

and planning tools.(a)

NMC projects that annual property taxes from Palisades to Covert Township, Covert School

District, Van Buren County Intermediate School District, and Van Buren County will remain

relatively constant throughout the license renewal period. However, the Michigan Public

Service Commission is currently implementing the electric utility restructuring legislation that

was enacted in June 2000, and the impacts are not fully known at this time. Any changes to tax

rates for the Palisades property due to the restructuring would be independent of license

renewal (NMC 2005a).

No adverse impacts on offsite land use would occur because of license renewal. Consequently,

the NRC staff concludes that offsite land-use impacts would likely be SMALL, and additional

mitigation is not warranted.

4.4.4 Public Services: Transportation Impacts During Operations

On October 4, 1999, 10 CFR 51.53(c)(3)(ii)(J) and 10 CFR Part 51, Subpart A, Appendix B,

Table B-1 were revised to clearly state that “Public Services: Transportation Impacts During

Operations” is a Category 2 issue (see NRC 1999 for more discussion of this clarification). The

issue is treated as such in this SEIS. |

Given the small number of additional workers required during the renewal period, there would

be no additional impacts on the transportation network in the vicinity of the Palisades site. 

Therefore, the NRC staff concludes that during the license renewal period, transportation

impacts during operation would likely be SMALL. Additional mitigation is not warranted.

4.4.5 Historic and Archaeological Resources

The National Historic Preservation Act of 1966 (NHPA), as amended through 2000, requires

Federal agencies to take into account the potential effects of their undertakings on historic

properties. The historic-review process mandated by Section 106 of the NHPA is outlined in

regulations issued by the Advisory Council on Historic Preservation at 36 CFR Part 800. The

renewal of an OL for a nuclear power plant is an undertaking that could potentially affect either

known or potential historic properties that may be located at the plant’s site. In accordance with

the provisions of the NHPA, the NRC is required to make a reasonable effort to identify historic

properties in the potentially affected areas and notify the State Historic Preservation Office
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NUREG-1437, Supplement 27 4-26 October 2006

(SHPO) before proceeding. If historic properties are determined to be present, an assessment

is required to resolve any possible adverse effects of the undertaking.

At Palisades, the potential exists that presently unknown significant archaeological resources

may be present on or below the ground surface at the site and along the transmission line

corridors. Any such resources could be inadvertently disturbed or destroyed by construction or

other ground-disturbing activities. The applicant has indicated that no major refurbishment or

replacement activities at Palisades or along the transmission line corridors are associated with

its license renewal request (NMC 2005a). However, routine operations and maintenance

activities that will take place during the renewal period could potentially affect presently

| unknown archaeological resources. The applicant has procedures in place to protect any

resources from such inadvertent disturbance or destruction from these activities.

The NRC staff reviewed the applicant’s environmental review procedures for Palisades during

| the site audit. These procedures are in place to ensure that any archaeological resources that

may be present receive consideration and protection. The procedures require that an

archaeological survey be undertaken for any construction and modification activities that involve

all ground-disturbing activities in the owner-controlled area of NMC operated nuclear facilities

and to those activities including, but not limited to the construction or expansion of buildings,

facilities, substations, parking lots, roads, or overhead or underground utility lines. In the event

that items of potential historic significance are discovered during surveys, NMC and Consumers

Energy would consult with the SHPO prior to proceeding. The NRC staff’s independent review

of records on file at the SHPO office did not locate records related to project-specific

archaeological surveys conducted at Palisades for ground-disturbing activities. However,

Consumers Energy did locate in its records one such report that documented a cultural

resource field visit to the Palisades site by archaeologists in 1982 for three proposed projects

(CAI 1982). 

During the site audit, the NRC staff also reviewed the applicant’s excavation and trenching

control procedures, which require that any planned excavation activities that occur at a depth

greater than 6 in. within previously undisturbed land be reviewed by the NMC Environmental

Coordinator. The Environmental Coordinator’s responsibilities (as defined in NMC’s

Archaeological, Cultural & Historic Resources procedures) include reviewing excavation and

trenching plans to determine if any known archaeological resources are located within the

proposed ground disturbance area, assessing the potential importance of any archaeological

resources discovered during construction, and coordinating with the SHPO when potentially

culturally important resource discoveries are made. The procedures also include a list of the

types of archaeological materials that could be encountered during construction. During the site

audit, the NRC staff expressed concerns about the NMC procedures not requiring a qualified

archaeologist to survey the proposed ground disturbance area for archaeological resources

prior to construction. In addition, the NRC staff noted that the procedure did not specify the

training, experience, or credential requirements for the site’s Environmental Coordinator to
Environmental Impacts of Operation

(a) The NRC Guidance for performing environmental justice reviews defines “minority” as American

Indian or Alaskan Native; Asian; Native Hawaiian or other Pacific Islander; Black races; or Hispanic

ethnicity. “Other” races and multiracial individuals may be considered as separate minorities

(NRC 2004a).

October 2006 4-27 NUREG-1437, Supplement 27

recognize archaeological materials or assess the potential significance of historic or

archaeological resources. Subsequent to the NRC staff’s comments, the applicant revised and

implemented its procedures in January 2006 (NMC 2006a) to reflect these concerns. |

Based on the NRC staff’s review of agency files, published literature, and information provided

by the applicant, the NRC staff concludes that potential impacts on historic and archaeological

resources would be SMALL. This conclusion is based on the fact that (1) no major |

refurbishment or replacement activities would occur during the renewal period; and (2) the

applicant has environmental review procedures in place to ensure that any archaeological |

resources that may be present receive consideration and protection.

4.4.6 Environmental Justice

Environmental justice refers to a Federal policy that requires that Federal agencies identify and

address, as appropriate, disproportionately high and adverse human health or environmental

impacts of its actions on minority(a) or low-income populations. The memorandum

accompanying Executive Order 12898 (59 FR 7629) directs Federal executive agencies to

consider environmental justice under the National Environmental Policy Act of 1969 (NEPA). |

The Council on Environmental Quality (CEQ) has provided guidance for addressing

environmental justice (CEQ 1997). Although the Executive Order is not mandatory for

independent agencies, the NRC has voluntarily committed to undertake environmental justice

reviews. Specific guidance is provided in NRC Office of Nuclear Reactor Regulation Office

Instruction LIC-203, Procedural Guidance for Preparing Environmental Assessments and

Considering Environmental Issues Rev. 1 (NRC 2004a). In 2004, the Commission issued a final

Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and

Licensing Actions (NRC 2004b).

The scope of the review, as defined in NRC guidance (NRC 2004a), includes identification of

impacts on minority and low-income populations, the location and significance of any

environmental impacts during operations on populations that are particularly sensitive, and

information pertaining to mitigation. It also includes evaluation of whether these impacts are

likely to be disproportionately high and adverse. The NRC staff looks for minority and lowincome populations within the 50-mi radius of the site. For the NRC staff’s review, a minority
Environmental Impacts of Operation

(a) A census block group is a combination of census blocks, which are statistical subdivisions of a census

tract. A census block is the smallest geographic entity for which the U.S. Census Bureau collects and

tabulates decennial census information. A census tract is a small, relatively permanent statistical

subdivision of counties delineated by local committees of census data users in accordance with

U.S. Census Bureau guidelines for the purpose of collecting and presenting decennial census data. 

Census block groups are subsets of census tracts (U.S. Census Bureau 2004).

NUREG-1437, Supplement 27 4-28 October 2006

population exists in a census block group(a) if the percentage of each minority and aggregated

minority category within the census block group exceeds the percentage of minorities in the

state of which it is a part by 20 percentage points, or the corresponding percentage of minorities

within the census block group is at least 50 percent. A low-income population exists if the

percentage of low-income population within a census block group exceeds the corresponding

percentage of low-income population in the state of which it is a part by 20 percentage points, or

if the corresponding percentage of low-income population within a census block group is at least

50 percent.

For the Palisades review, the NRC staff examined the geographic distribution of minority and

low-income populations within 50-mi of the site, employing data from the 2000 census for

low-income populations and for minority populations (NMC 2005a). The analysis was

supplemented by discussions with the planning department and social service agencies in

Van Buren County. 

Figures 4-1 and 4-2 show the geographic distribution of minority and low-income groups within

50 mi of the plant. A number of tracts within Van Buren County exceed the NRC thresholds

defining low-income; these are located in Covert. Other tracts within the 50-mi region are

located in Kalamazoo to the east of Palisades and South Bend to the southeast. Census block

groups with a minority population within the 50-mi region in Michigan are located in Covert and

Keeler in Van Buren County, and in Berrien, Cass, Van Buren, and Allegan Counties. In

Indiana, minority populations are located in South Bend, Mishawaka, and Elkhart.

With the locations of minority and low-income populations identified, the NRC staff proceeded to

evaluate whether any of the environmental impacts of the proposed action could affect these

populations in a disproportionately high and adverse manner. Based on NRC staff guidance

(NRC 2004a), air, land, and water resources within about 50-mi of the Palisades site were

examined. Within that area, a few potential environmental impacts could affect human

populations; all of these were considered SMALL for the general population.

| The pathways through which the environmental impacts associated with license renewal for

| Palisades can affect human populations are discussed throughout this SEIS. The NRC staff

evaluated whether minority and low-income populations could be disproportionately affected by
Environmental Impacts of Operation

October 2006 4-29 NUREG-1437, Supplement 27

Figure 4-1. Geographic Distribution of Minority Populations (shown in shaded 

areas) Within 50 mi of Palisades Based on Census Block Group

Data
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-30 October 2006

Figure 4-2. Geographic Distribution of Low-Income Populations (shown in 

 Shaded areas) Within 50 mi of Palisades Based on Census Block

 Group Data
Environmental Impacts of Operation

October 2006 4-31 NUREG-1437, Supplement 27

these impacts. The NRC staff found no unusual resource dependencies or practices, such as

subsistence agriculture, hunting, or fishing, through which the populations could be

disproportionately high and adversely affected. In addition, the NRC staff did not identify any

location-dependent disproportionately high and adverse impacts affecting these minority and

low-income populations, including impacts on the seasonal migrant farm labor force, many of |

whom could be minority. The NRC staff concludes that offsite impacts from Palisades on |

minority and low-income populations would be SMALL, and no special mitigation actions are

warranted.

4.5 Groundwater Use and Quality

Of the Category 1 issues related to groundwater use and quality that are identified in

10 CFR Part 51, Subpart A, Appendix B, Table B-1, only one is applicable to Palisades and it is

listed in Table 4-7.

Table 4-7. Category 1 Issue Applicable to Groundwater Use and Quality During

the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1

GEIS

Section

GROUNDWATER USE AND QUALITY

Groundwater use conflicts (potable and service water; plants that use <100 gpm). 4.8.1.1

A brief description of the NRC staff’s review regarding this issue and the GEIS conclusions, as

codified in Table B-1, 10 CFR Part 51, follows.

 C Groundwater use conflicts (potable and service water; plants that use <100 gpm). 

Based on information in the GEIS, the Commission found that

Plants using less than 100 gpm are not expected to cause any groundwater use

conflicts.

As discussed in Section 2.2.2, Palisades has three operable groundwater production wells for

grounds maintenance or other miscellaneous uses. Their combined pumping rate is 24 gpm,

which is below the 100-gpm threshold. 

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other available |

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that |

there would be no impacts related to this issue beyond those discussed in the GEIS. For this
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NUREG-1437, Supplement 27 4-32 October 2006

| issue, the GEIS concluded that the impacts would be SMALL, and additional plant-specific

mitigation measures are not likely to be sufficiently beneficial to be warranted.

4.6 Threatened or Endangered Species

Threatened or endangered species are listed as a Category 2 issue in 10 CFR Part 51,

Subpart A, Appendix B, Table B-1. This issue is listed in Table 4-8.

Table 4-8. Category 2 Issue Applicable to Threatened or Endangered Species During

the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS

Section

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

THREATENED OR ENDANGERED SPECIES (FOR ALL PLANTS)

Threatened or endangered species 4.1 E 4.6

This issue requires consultation with appropriate agencies to determine whether threatened or

endangered species are present and whether they would be adversely affected by continued

operation of the nuclear plant during the license renewal term. The presence of Federally listed

threatened or endangered species in the vicinity of the Palisades site and its associated

transmission lines is discussed in Sections 2.2.5 and 2.2.6.

On June 30, 2005, the NRC contacted the FWS to request information on Federally listed

threatened and endangered species and the impacts of relicensing (NRC 2005). In response,

on July 29, 2005, the FWS provided information regarding Federally listed species that could

occur in the vicinity of Palisades or along the transmission line rights-of-way (FWS 2005b).

4.6.1 Aquatic Species

The NRC staff has reviewed the information provided by the applicant and public information

and has contacted the FWS and the MDNR. No Federally listed threatened or endangered

aquatic species occur in Lake Michigan in the vicinity of the Palisades site, and no Federally

listed threatened or endangered species occur in the streams crossed by the Palisades-Argenta

transmission line. Therefore, license renewal would have no effect on any Federally listed

aquatic species.
Environmental Impacts of Operation

(a) Interview with G. Dawson, Consumers Energy Company, Environmental and Laboratory Services

(July 26, 2005).

October 2006 4-33 NUREG-1437, Supplement 27

4.6.2 Terrestrial Species

The FWS identified four Federally listed and one candidate terrestrial species that they believe

could occur on the Palisades site or along the associated transmission line rights-of-way: 

Pitcher’s thistle (Cirsium pitcheri; threatened), Karner blue butterfly (Lycaeides melissa

samuelis; endangered), Mitchell’s satyr butterfly (Neonympha mitchelli mitchelli; endangered),

Indiana bat (Myotis sodalis; endangered), and eastern massasauga rattlesnake (Sistrurus

catenatus catenatus; candidate) (FWS 2005b). These species, their preferred habitat, and

county distributions are described in Section 2.2.6.

Pitcher’s thistle is the only Federally listed species known to exist on the Palisades site, where it

occurs in open dune habitats (NMC 2005a).(a) License renewal and continued operation of

Palisades are not likely to adversely affect the Pitcher’s thistle for several reasons. No

refurbishment is considered necessary during the license renewal period at the Palisades site

(NMC 2005a); therefore, significant land disturbance during that period is not considered likely. |

However, any activities during the renewal period that could result in land disturbance would

undergo a predisturbance evaluation and consideration of impacts to threatened and

endangered species (NMC 2005a). In addition, all dune areas on the site where the Pitcher’s

thistle is most likely to occur are protected under authority of Michigan’s Natural Resources and

Environmental Protection Act, Part 353, and any action that would disturb dune habitats would

require a permit from the State (MDEQ 2005). The Pitcher’s thistle does not occur in areas

affected by current operations, including those areas affected by cooling-tower drift. On the

basis of these considerations, continued operation of Palisades during the license renewal

period would not be expected to adversely affect the Pitcher’s thistle.

Of the counties in the project area, the Karner blue butterfly is known only from Allegan County

(MNFI 2005; FWS 2005a), which is crossed by a very short length of the Palisades-Argenta line |

(NMC 2005a). However, Czarnecki (FWS 2005b) suggests that the species could also occur

near the Argenta-E. Elkhart line in the eastern portion of Van Buren County. This species was

not observed during field surveys of the Palisades site and transmission line corridors

conducted in 1979 (Asplundh 1979) and 1991 (Higman and Goff 1991; Goff 1992). The

applicant’s vegetation-management practices that maintain habitat within transmission line

rights-of-way in early successional stages (NMC 2005a) are consistent with protecting habitats

occupied by this species, and continued maintenance over the license renewal period is not

expected to adversely affect this species or its habitat. The owner of Palisades is partnering

with the MDNR, the Nature Conservancy, and others to develop a habitat conservation plan for

the Karner blue butterfly (NMC 2005a).
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-34 October 2006

The Mitchell’s satyr butterfly may occur in wetland areas along portions of the transmission lines

in Kalamazoo and Van Buren Counties (FWS 2005a; MNFI 2005); however, this species was

not observed during field surveys conducted in 1979 (Asplundh 1979) and 1991 (Higman and

Goff 1991; Goff 1992). License renewal and continued operations of Palisades are not likely to

adversely affect the Mitchell’s satyr butterfly for several reasons. Preferred habitat for this

species (calcareous wetlands) is not known to occur within or adjacent to transmission line

rights-of-way associated with Palisades (NMC 2005a). The applicant’s vegetation-management

practices that maintain habitat within transmission line rights-of-way as herbaceous or

low-growing shrub communities (NMC 2005a) are consistent with protecting habitats occupied

by this species. Therefore, continued maintenance of rights-of-way over the license renewal

period would not be expected to adversely affect this species or its habitat.

The Indiana bat is not known to occur at the Palisades site or along associated transmission

lines, but potential habitat occurs within the project area (FWS 2005b). It should be noted,

however, that this species is difficult to detect without conducting specialized surveys, and such

surveys of the site have not been conducted. The Indiana bat is reported to occur in suitable

habitat during the summer months in all counties crossed by the Palisades transmission line

| (FWS 2005a). Tree species, such as the shagbark hickory (Carya ovata), red oak

| (Quercus rubra), and bur oak (Quercus macrocarpa), often have loose or decaying bark that

provide nursery habitat for females with young. License renewal and continued operations of

Palisades are not likely to adversely affect the Indiana bat for several reasons. No

refurbishment is considered necessary during the license renewal period at the Palisades site

(NMC 2005a), and, therefore, significant land disturbance during that period is not considered

likely. However, any activities during the renewal period that could result in land disturbance

would undergo a predisturbance evaluation and consideration of impacts on threatened and

endangered species (NMC 2005a). Vegetation management within the transmission line rightsof-way prevents the establishment of large trees within the rights-of-way that could be used by

the Indiana bat. Only danger trees in the border zone of the rights-of-way are removed during

routine vegetation management (NMC 2005a). This greatly limits the likelihood that a tree used

by Indiana bats for roosting or nursery habitat would be affected. On the basis of these

considerations, continued operation of Palisades during the license renewal period would not be

expected to adversely affect the Indiana bat.

The eastern massasauga rattlesnake, a Federal candidate for listing, could occur in wetland

areas such as bogs, ponds, or swamps, and prefers open canopy with a sedge or grass ground

cover (FWS 2005b). It is unlikely that the eastern massasauga would be adversely affected by

continued operation of Palisades during the license renewal period because no land-disturbing

refurbishment activities are planned at the Palisades site, and vegetation maintenance

procedures for Palisades transmission line rights-of-way (NMC 2005a) maintain the open

habitats preferred by this species.
Environmental Impacts of Operation

October 2006 4-35 NUREG-1437, Supplement 27

Based on the NRC staff’s review of the applicant’s environmental report and the NRC staff’s

independent analysis, the NRC staff has concluded that continued operation of Palisades during

the license renewal term would not likely adversely affect any species that are Federally listed,

proposed for listing, or candidates for listing as endangered or threatened within the immediate

vicinity of the Palisades site and its associated transmission lines. The applicant currently plans

no power plant refurbishment activities. The NRC staff anticipates that best management

practices for protecting Federally listed species and their habitats, while carrying out vegetationmanagement activities, will be implemented by the applicant and its contractors. Therefore, it is

the NRC staff’s finding that the impact on threatened or endangered species of an additional

20 years of operation of Palisades and associated transmission lines would be SMALL, and

further mitigation is not warranted.

4.7 Evaluation of New and Potentially Significant

Information on Impacts of Operations During the

Renewal Term

The NRC staff has not identified any new and significant information on environmental issues |

listed in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, related to operation during the

renewal term. The NRC staff also determined that information provided during the public

comment period did not identify any new issue that requires site-specific assessment. The NRC

staff reviewed the discussion of environmental impacts associated with operation during the

renewal term in the GEIS and has conducted its own independent review, including public

scoping meetings, to identify issues with new and significant information. Processes for

identification and evaluation of new information are described in Section 1.2.2. 

4.8 Cumulative Impacts of Operations During the Renewal

Term

4.8.1 Cumulative Impacts Resulting from Operation of the Plant Cooling System

For the purposes of this analysis, the geographic area considered for cumulative impacts

resulting from operation of the Palisades cooling system is primarily the southeastern portion of

Lake Michigan, particularly that portion bounded by South Haven to the north and Hagar Shore

to the south and extending to about 1.9 mi from shore (i.e., the location of the thermal bar

separating the inshore and offshore water masses during spring (Thurber and Jude 1985)). As

discussed in Section 4.1, the NRC staff found no new and significant information that would

indicate that the conclusions regarding any of the cooling-system-related Category 1 issues

related to Palisades are inconsistent with the conclusions in the GEIS (NRC 1996). Because

Palisades has a closed-cycle cooling system, impacts from Category 2 plant cooling system
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-36 October 2006

issues (i.e., entrainment, impingement, and heat shock) that would have an impact on local

water quality and aquatic resources are not addressed in Section 4.1. Nevertheless,

entrainment, impingement, and heat shock have not been found to have greater than a minimal

impact on aquatic biota (Consumers Energy and NMC 2001; NRC 1978). Therefore, operation

of the Palisades cooling system would not contribute significantly to the cumulative impacts that

would impact water quality and aquatic resources of southeastern Lake Michigan.

The cumulative impacts of past actions have resulted in the existing conditions of local water

quality and aquatic resources. Section 2.2.5 discusses the major changes and modifications

within Lake Michigan that have had the greatest impacts on aquatic resources. These include

physical and chemical stresses, lakefront developments, overfishing, and introduction of

non-native species. Physical and chemical stresses that have impacted Lake Michigan and its

tributaries include urban, industrial, and agricultural contaminants (e.g., nutrients, toxic

chemicals, and sediments); stream modifications (e.g., dams); land-use changes

(e.g., residential, recreational, agricultural, and industrial development); dredging; shoreline

modifications; wetland elimination and modification; water diversions (e.g., canals);

impingement and entrainment in water-intake structures; thermal loading from cooling water; ice

control for navigation; and major degradative incidents or catastrophes (Francis et al. 1979;

Fuller et al. 1995). These in turn can affect fish, benthos, and plankton populations; cause a

loss of habitat; cause deformities or tumors in fish and other biota; and contaminate fish, which

leads to restrictions on human consumption (Eshenroder et al. 1995). 

The dramatic changes that have occurred in the fish communities due to habitat modification

and development, overfishing, and non-native species introductions have been reviewed for the

period from the 1800s to 1970 (Wells and McLain 1973) and from 1970 to 2000 (Madenjian et

al. 2002). Disruptions in the native fish community (primarily caused by introduction of the sea

lamprey (Petromyzon marinus) and alewife [Alosa pseudoharengus]), coupled with habitat

alterations and degradation, contributed to the decline of important commercial and sport

fisheries by the end of the 1950s (IDNR 2004). In the 1960s, programs to extend control of sea

lamprey and stock trout and salmon species began to rehabilitate the Lake Michigan fish

community, control alewife numbers, and provide recreational fisheries (Eshenroder et al.

1995).

Future contributions to cumulative impacts on aquatic resources within Lake Michigan would

generally occur from those actions that currently cause impacts (e.g., human habitation, urban

and industrial development, agriculture, commercial and recreational fisheries, and spread of

non-native species). Primary management challenges will be to keep the salmonid community

in balance with an available forage base, while keeping alewife levels suppressed at a level that

does not threaten native species (Eshenroder et al. 1995). Remaining problems include

inadequate natural reproduction of salmonids, low abundance or complete loss of many native

fish stocks, continued problems with exotic species, continued difficulties in suppressing sea
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October 2006 4-37 NUREG-1437, Supplement 27

lampreys, and continued unacceptable levels of pollution and toxic chemicals (Eshenroder et al.

1995).

Large oil or chemical spills could potentially severely impact aquatic resources within

Lake Michigan; the probability of such spills, however, is relatively small. The probability of

smaller spills is higher, but the impacts from such spills would probably be small, temporary,

additive, and unlikely to severely affect aquatic resources, especially if spill response activities |

are undertaken when such events occur.

The potential exists for the expansion of non-native species, which has already begun to occur

in Lake Michigan, and for additional non-native species to become established within the lake

(Ricciardi and MacIsaac 2000; Ricciardi and Rasmussen 1998). Any future ecological changes

that may be associated with global climate change would occur much more slowly than those

induced by invasions of non-native species (Madenjian et al. 2002).

The lake water supply is adequate to meet the needs of the facility for cooling purposes under

all conditions. The NRC staff, while preparing this assessment, assumed that other industrial,

commercial, or public installations could be located in the general vicinity of the Palisades site

prior to the end of plant operations. The discharge of water to Lake Michigan from these

facilities would be regulated by the MDEQ. The discharge limits are set considering the overall

or cumulative impact of all other regulated activities in the area. Compliance with the Clean

Water Act of 1977 and the NPDES permit for Palisades minimizes cumulative impacts on |

aquatic resources. Continued operation of Palisades would require renewed discharge permits

from the MDEQ, which could address changing requirements so that cumulative water quality |

objectives are served.

The NRC staff concludes that the SMALL impacts of the Palisades cooling system operations,

including entrainment and impingement of fish and shellfish, heat shock, or any of the cooling

system-related Category 1 issues, would not contribute to an overall decline in water quality or |

the status of the fishery or other aquatic resources. Therefore, the NRC staff concludes that the

potential cumulative impacts of operation of the cooling system of Palisades would be SMALL,

and that no further mitigation measures would be warranted.

4.8.2 Cumulative Impacts Resulting from Continued Operation of the

Transmission Lines

Continued operation of the electrical transmission facilities associated with license renewal for

Palisades was evaluated to determine if there is the potential for interactions with other past,

present, and future actions that could result in adverse cumulative impacts on terrestrial

resources (e.g., wildlife populations, the size and distribution of habitat areas), wetlands,

floodplains, or aquatic resources. For the purposes of this analysis, the geographic area that
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NUREG-1437, Supplement 27 4-38 October 2006

encompasses the past, present, and foreseeable future actions that could contribute to adverse

cumulative impacts includes those Michigan counties that contain the transmission lines

associated with Palisades (Allegan, Kalamazoo, and Van Buren Counties).

As described in Section 4.2, the NRC staff found no new and significant information indicating

that the conclusions regarding any of the transmission-line-related Category 1 issues as related

to Palisades are inconsistent with the conclusions within the GEIS. The applicant uses

vegetation-management procedures over all of its rights-of-way that are protective of wildlife

and habitat resources (NMC 2005a). These vegetation-management practices are not

| expected to change during the license renewal period and, therefore, are not expected to result

in any changes to current levels of cumulative impacts. None of the management procedures

alter wetland or floodplain hydrology or adversely affect vegetation characteristics of these

habitats or other habitats. Vegetation-maintenance procedures within rights-of-way ensure

minimal disturbance to ecological systems and species. In addition, these procedures maintain

habitats that are beneficial to some of the Federally listed threatened and endangered species

that could occur within them. Continued operation and maintenance of these rights-of-way are

not likely to contribute to a regional decline in wildlife and habitat resources.

As discussed in Section 2.2.6, four Federally listed threatened or endangered species are

known to occur or could occur within this area. These species include the Pitcher’s thistle,

Karner blue butterfly, Mitchell’s satyr butterfly, and Indiana bat. The eastern massasauga

rattlesnake, a candidate for Federal listing, could also occur in habitats traversed by Palisades

| transmission lines. No critical habitat, as designated in the Endangered Species Act of 1973,

| occurs in the area affected by Palisades or its associated transmission lines. The NRC staff’s

findings, presented in Section 4.6, are that continued operation of Palisades during the license

| renewal period would not likely adversely affect listed, proposed, or candidate species;

therefore, the impact on these species would be SMALL. Consequently, the continued

operation of Palisades during the renewal term would not contribute to cumulative impacts on

| these species. Therefore, the cumulative impacts on these species would be SMALL, and

| additional mitigation measure would not be warranted.

Based on these considerations, the NRC staff has determined that the cumulative impacts of

| the continued operation of the Palisades transmission lines would be SMALL, and no additional

mitigation is warranted.

4.8.3 Cumulative Radiological Impacts

The radiological dose limits for protection of the public and workers have been developed by the

U.S. Environmental Protection Agency and the NRC to address the cumulative impact of acute

and long-term exposure to radiation and radioactive material. These dose limits are codified in

| 40 CFR Part 190, 10 CFR Part 20, and 10 CFR Part 50, Appendix I. For the purpose of this

analysis, the area within a 50-mi radius region of interest (ROI) of the Palisades site was
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October 2006 4-39 NUREG-1437, Supplement 27

included. The Indiana and Michigan Power Company’s Donald C. Cook Nuclear Plant (D.C. |

Cook) Units 1 and 2 are located approximately 28 mi south-southwest of Palisades on the shore |

of Lake Michigan. |

As stated in Section 2.2.7, NMC has conducted a radiological environmental monitoring |

program (REMP) around the Palisades site since 1971, with results presented annually in the

Palisades Annual Radiological Environmental Operating Report (NMC 2001, 2002, 2003a,

2004, 2005b, 2006b). The REMP measures radiation and radioactive materials from all |

sources, including Palisades and D.C. Cook. The results presented in the reports, therefore, do |

consider the cumulative radiological impacts within the 50-mi ROI. On the basis of our |

evaluation, in Sections 2.2.7 and 4.3, the NRC staff concluded that impacts of radiation |

exposure to the public and workers (occupational) from operation of Palisades during the

renewal term would be SMALL. With respect to the future, the REMP has not identified |

increasing levels or the accumulation of radioactivity in the environment over time. In addition, |

the NRC staff is not aware of any plans or proposals for new nuclear facilities in the vicinity of |

Palisades that would potentially contribute to cumulative radiological impacts. The NRC and the |

States of Michigan and Indiana would regulate any future actions in the vicinity of the Palisades

site that could contribute to cumulative radiological impacts. Therefore, the NRC staff

concludes that future cumulative radiological impacts would be SMALL, and that no further

mitigation measures are warranted.

4.8.4 Cumulative Socioeconomic Impacts

Continued operation of Palisades would not likely result in significant cumulative impacts for any

of the socioeconomic impact measures assessed in Section 4.4 of this SEIS (public services,

housing, and offsite land use). This is because operating expenditures, NMC staffing levels, |

and local tax payments during renewal would be similar to those during the current license

period. Similarly, the proposed action would not likely result in significant cumulative impacts on

historic and archaeological resources.

When combined with the impact of other potential activities likely in the area surrounding the

plant, socioeconomic impacts resulting from license renewal for Palisades would not produce an |

incremental change in any of the impact measures used. The NRC staff, therefore, determined

that the impacts on employment, personal income, housing, local public services, utilities, and

education occurring in the local socioeconomic environment as a result of license renewal

activities, in addition to the impacts of other potential economic activity in the area, would be

SMALL. The NRC staff determined that the impact on offsite land use would be SMALL |

because no refurbishment activities are planned at Palisades, and no new incremental changes

to plant-related tax payments are expected that could influence land use by fostering

considerable growth. The impacts of license renewal on transportation and environmental
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NUREG-1437, Supplement 27 4-40 October 2006

justice would also be SMALL. There are no reasonably foreseeable scenarios that would alter

these conclusions in regard to cumulative impacts.

Although no archaeological or architectural surveys have been conducted to date at the

Palisades site, and the potential exists for significant cultural resources to be present within the

site boundaries, it does not appear likely that the proposed license renewal would adversely

affect these resources. The applicant has indicated that no refurbishment or replacement

activities, including additional land-disturbing activities, at the plant site (or along existing

transmission corridors) are planned for the license renewal period (NMC 2005a). Absent landdisturbing activities, continued operation of Palisades would likely protect any cultural resources

present within the Palisades site boundary by protecting those lands from development and

providing secured access. If prior to ground-disturbing activity in an undisturbed area, the

applicant would evaluate the potential for impacts on cultural resources in consultation with the

SHPO and appropriate Native American Tribes, as required under Section 106 of the NHPA, the

contribution to a cumulative impact on cultural resources by continued operation of Palisades

during the license renewal period would be SMALL. 

|

4.8.5 Cumulative Impacts on Groundwater Use and Quality

Regional geology in Van Buren County consists of 300 to 400 ft of glacial and post-glacial

deposits overlying sedimentary bedrock consisting of shale or limestone of the lower

Mississippian Coldwater Formation (STS 1987; NMC 2003b). A drilling program conducted at

Palisades in the 1960s indicated that the uppermost material is dune sand, which ranges in

thickness from about 10 ft in the switchyard area to well over 100 ft near the lake (NMC 2003b). 

Below the dune sand is dense to very dense gray silty sand or sandy silt, stiff gray clay, and stiff

to hard gray glacial till. The bedrock underlies these glacial sediments. The early site studies

indicate that unconfined groundwater in the vicinity of Palisades has a hydraulic gradient of

approximately 13 ft/mi in a westerly direction, flowing to Lake Michigan at an estimated rate of

650 ft/yr. Field permeability tests during exploratory drilling in 1965 yielded values ranging from

30 to 1720 ft/yr in the site area.

At the power block area, groundwater elevations averaged 580 ft above mean sea level (MSL),

approximately equal to the mean level of Lake Michigan. In the eastern portion of the property,

groundwater was at approximately 601 ft MSL; beneath the substation, it was at approximately

604 ft MSL (NMC 2003b). These elevations correspond to depths below ground surface of

approximately 45 ft at the power block to approximately 10 to 15 ft near the eastern end of the

site (NMC 2003b). Hydrogeologic analysis, focused on the sanitary drainfield located just south

of the power block, showed the water table to be approximately 30 ft below the surface of the

| drainfield. The calculated groundwater flow velocity at this site is westward at approximately

23 ft/yr. Groundwater sampling and analysis found no halogenated or aromatic hydrocarbons or

metals above detection limits; all parameters detected were present at concentrations well

below recommended maximum contaminant levels (STS 1987).
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October 2006 4-41 NUREG-1437, Supplement 27

Municipal water has been available at Palisades since approximately 2002. Groundwater use at

Palisades since then has been only by three small production wells with a combined production

capacity of 24 gpm. The pumped water is for grounds maintenance or other miscellaneous

uses. NMC does not expect to develop or use any additional groundwater resources at

Palisades in the future. 

Several releases to site groundwater and soil have occurred and been remediated. One was a

hydrocarbon release at a fuel depot. MDEQ has concurred that the remediation of this site is

completed. Another was a release of solvents (trichloroethylene and perchloroethylene) from

barrels stored onsite. Following a remediation that included pumping and vapor extraction,

MDEQ approved closure of this site (MDEQ 2000). In a 1995 incident, 5 to 10 gal of hydraulic

oil were released from mechanical equipment due to a line break. The contaminated soil was

removed, and MDNR concurred that no further action was necessary (Consumers Power 1995). |

Groundwater monitoring wells are now only at the Steam Generator Storage Building, which

houses former equipment. 

Groundwater is no longer used significantly as a resource at Palisades. The facility relies on

municipal water, and the three remaining production wells are used for landscape watering at

low withdrawal rates. Potential impacts on local groundwater have included fuel and solvent

leaks, which have been remediated adequately. Septic systems were constructed with

approved methods. Their sludge is monitored for detectable radioactivity twice per year on a

voluntary basis. The downgradient groundwater flow direction from facilities at Palisades is

west, toward Lake Michigan. 

Because of the lack of groundwater receptors, the remediation of past sources of groundwater

contamination, and good management practices relative to groundwater quality, the cumulative

impact on groundwater resources during the license renewal period would be SMALL, and

additional mitigation would not be warranted. 

4.8.6 Conclusions Regarding Cumulative Impacts

The NRC staff considered the potential impacts resulting from operation of Palisades during the

license renewal term and other past, present, and future actions in the vicinity of Palisades. 

The NRC staff’s determination is that the potential cumulative impacts resulting from operation |

of Palisades during the license renewal term would be SMALL. |
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-42 October 2006

4.9 Summary of Impacts of Operations During the Renewal

Term

Based on its analysis, NMC has stated that it is not aware of information that is both new and

significant related to any of the applicable Category 1 issues associated with operation of

Palisades during the renewal term. The NRC staff, after reviewing the application and

performing the site audit, also did not find any new and significant information related to any of

the applicable Category 1 issues associated with operations of Palisades during the renewal

term. Consequently, the NRC staff concludes that the environmental impacts associated with

these issues are bounded by the impacts described in the GEIS. For each of these issues, the

GEIS concluded that the impacts would be SMALL, and that additional plant-specific mitigation

measures are not likely to be sufficiently beneficial to warrant implementation.

Plant-specific environmental evaluations were conducted for eight Category 2 issues applicable

| to operation of Palisades during the renewal term and for environmental justice and chronic

| effects of electromagnetic fields. For all eight issues and environmental justice, the NRC staff

concludes that the potential environmental impact of operation of Palisades during the renewal

term would be of SMALL significance in the context of the standards set forth in the GEIS, and

| that additional mitigation would not be warranted. In addition, the NRC staff determined that a

| conclusion has not been reached by the appropriate Federal health agencies regarding chronic

adverse effects from electromagnetic fields. Therefore, the NRC staff did not conduct an

evaluation of this issue.

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of any other action undertaken by agencies or persons. For purposes of

this analysis, where Palisades license renewal impacts are deemed to be SMALL, the NRC staff

concluded that these impacts would not result in significant cumulative impacts on potentially

affected resources. 

4.10 References

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for

Protection Against Radiation.” 

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests and Public Property,

| Part 800, “Protection of Historic Properties.”
Environmental Impacts of Operation

October 2006 4-43 NUREG-1437, Supplement 27

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,

“Environmental Radiation Protection Standards for Nuclear Power Operations.” 

Asplundh Environmental Services and S & R Environmental Consulting (Asplundh). 1979. 

Terrestrial Ecological Survey for the Palisades Site. Report for Consumers Power Company,

Jackson, Michigan. (December 1979). |

Asplundh Environmental Services and S & R Environmental Consulting (Asplundh). 1979. |

Terrestrial Ecological Survey for the Palisades Site. Report for Consumers Power Company, |

Jackson, Michigan. (December 1979). |

Clean Water Act (CWA) of 1977, P.L. 95-217.

Commonwealth Associates, Inc. (CAI). 1982. Letter report from W.E. Rutter, Commonwealth

Associates, Inc., to G.A. Dawson, Consumers Power Company, Jackson, Michigan. Letter No. |

62-0392-000. No subject. (August 27, 1982). |

Consumers Energy Company and Nuclear Management Company, LLC (Consumers Energy

and NMC). 2001. Palisades Nuclear Plant Biological Assessment of the 1999 Cooling Water

Flow Increase at the Palisades Plant, near South Haven, Michigan. Consumers Energy

Company, Jackson, Michigan, and Nuclear Management Company, LLC, Covert, Michigan. |

(May 2001). 

Consumers Power Company (Consumers Power). 1995. Letter from W. Wilson, Consumers |

Power Company, Jackson, Michigan, to Michigan Department of Natural Resources, Lansing, |

Michigan. Subject: “Report of Hydraulic Oil Release.” (September 6, 1995). |

Council on Environmental Quality (CEQ). 1997. Environmental Justice: Guidance Under the

National Environmental Policy Act. Executive Office of the President, Washington, D.C.

Electric Power Research Institute (EPRI). 1996. TL Workstation: ENVIRO Code Version 2.5. 

Palo Alto, California.

Endangered Species Act of 1973 (ESA). 16 USC 1531, et. seq.

Eshenroder, R.L., M.E. Holey, T.K. Gorenflo, and R.D. Clark, Jr. 1995. “Fish-Community

Objectives for Lake Michigan.” Great Lakes Fishery Commission, Spec. Pub. 95-3. Available

URL: http://www.glfc.org/pubs/SpecialPubs/Sp95_3.pdf (Accessed January 25, 2004).

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority and

Low-Income Populations.” Federal Register. Vol. 59, No. 32, p. 7629. Washington, D.C. |

(February 16, 1994).
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-44 October 2006

Francis, G.R., J.J. Magnuson, H.A. Regier, and D.R. Talhelm. 1979. “Rehabilitating Great

Lakes Ecosystems.” Great Lakes Fishery Commission, Tech. Report No. 37. Available URL: 

http://www.glfc.org/pubs/TechReports?Tr37.pdf (Accessed April 27, 2004).

Fuller, K., H. Shear, and J. Witting, eds. 1995. “The Great Lakes: An Environmental Atlas and

Resource Book.” 3rd Ed. Government of Canada and U.S. Environmental Protection Agency. 

Available URL: http://www.epa.gov/glnpo/atlas/index.html (Accessed February 25, 2004). 

Goff, F.G. 1992. Supplement #1 to: Ecological Assessment of the Palisades Plant Site and

Ecological Enhancement Plan. Vital Resources Consulting, Report to Consumers Power

Company, Jackson, Michigan (May 20, 1992).

Higman, P.J., and F.G. Goff. 1991. Ecological Assessment of the Palisades Plant Site and

Ecological Enhancement Plan. Vital Resources Consulting, Report to Consumers Power

Company, Jackson, Michigan (November 1991).

Indiana Department of Natural Resources (IDNR). 2004. “Fishing Northwest Indiana’s Lake

Michigan Shoreline and Tributaries.” Indiana Department of Natural Resources, Indianapolis,

Indiana. Available URL: http://www.in.gov/dnr/fishwild/fish/lkmich/lmfish.pdf (Accessed January

22, 2004). 

Institute of Electrical and Electronics Engineers, Inc. (IEEE). 2002. National Electric Safety

Code.

Madenjian, C.P., G.L. Fahnenstiel, T.H. Johengen, T.F. Nalepa, H.A. Vanderploeg,

G.W. Fleischer, P.J. Schneeberger, D.M. Benjamin, E.B. Smith, J.R. Bence, E.S. Rutherford,

| D.S. Lavis, D.M. Robertson, D.J. Jude, and M.P. Ebener. 2002. “Dynamics of the Lake

Michigan Food Web, 1970–2000.” Canadian Journal of Fisheries and Aquatic Sciences,

| Vol. 59, pp. 736–753. 

Michigan Department of Environmental Quality (MDEQ). 2000. Letter from D. O’Donnell,

| Michigan Department of Environmental Quality, Lansing, Michigan, to Consumers Energy

| Company, Jackson, Michigan. Subject: “Notice of Approval of Generic Residential Closure for

the North Fuel Depot Solvent Spill Area, Palisades Nuclear Plant.” (October 11, 2000). 

Michigan Department of Environmental Quality (MDEQ). 2005. “The Sand Dunes Program.” 

Lansing, Michigan. Available URL: http://www.michigan.gov/deq/0,1607, 7-135-3311_4114_

| 4236-9832--,00.html (Accessed July 13, 2005).

Michigan Natural Features Inventory (MNFI). 2005. “Michigan County Element Lists –

| March 2001.” Lansing, Michigan. Available URL: http://web4.msue.msu.edu/mnfi/data/

County_lists_2001.pdf (Accessed July 1, 2005). 
Environmental Impacts of Operation

October 2006 4-45 NUREG-1437, Supplement 27

National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321, et seq.

National Historic Preservation Act of 1966 (NHPA). 16 USC 470, et seq. 

National Institute of Environmental Health Sciences (NIEHS). 1999. NIEHS Report on Health

Effects from Exposure to Power Line Frequency and Electric and Magnetic Fields. Publication

No. 99-4493. Research Triangle Park, North Carolina. |

Nuclear Management Company, LLC (NMC). 2001. 2000 Annual Radiological Environmental

Operating Report, January 1, 2000 through December 31, 2000, Palisades Nuclear Plant. 

Docket No. 50-255. Covert, Michigan. (April 30, 2001). |

Nuclear Management Company, LLC (NMC). 2002. 2001 Annual Radiological Environmental

Operating Report, January 1, 2001 through December 31, 2001, Palisades Nuclear Plant. 

Docket No. 50-255. Covert, Michigan. (May 8, 2002). |

Nuclear Management Company, LLC (NMC). 2003a. 2002 Annual Radiological Environmental

Operating Report, January 1, 2002 through December 31, 2002, Palisades Nuclear Plant. 

Docket No. 50-255. Covert, Michigan. (May 12, 2003). |

Nuclear Management Company, LLC (NMC). 2003b. Final Safety Analysis Report (FSAR) –

Palisades Nuclear Plant. Rev. 24. Covert, Michigan. (October 2003). |

Nuclear Management Company, LLC (NMC). 2004. 2003 Annual Radiological Environmental |

Operating Report, January 1, 2003 through December 31, 2003, Palisades Nuclear Plant. |

Docket No. 50-255. Covert, Michigan. (May 10, 2004). |

Nuclear Management Company, LLC (NMC). 2005a. Applicant’s Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255. |

Covert, Michigan. (March 2005). |

Nuclear Management Company, LLC (NMC). 2005b. 2004 Annual Radiological Environmental

Operating Report, January 1, 2004 through December 31, 2004, Palisades Nuclear Plant. 

Docket No. 50-255. Covert, Michigan. (May 12, 2005). |

Nuclear Management Company, LLC (NMC). 2006a. Personal communication with |

attachments from J. Holthaus, Environmental, Nuclear Management Company, LLC, Covert,

Michigan, to B. Pham, U.S. Nuclear Regulatory Commission, Rockville, Maryland. Subject: |

“Palisades Cultural Resources Procedures.” Attachment 1: “Archaeological, Cultural and |

Historic Resources,” FP-RP-ENV-01; Attachment 2: “Palisades Cultural Resources,” LM-330.

(January 24, 2006).
Environmental Impacts of Operation

NUREG-1437, Supplement 27 4-46 October 2006

| Nuclear Management Company, LLC (NMC). 2006b. Palisades Nuclear Plant 2005

| Radiological Environmental Operating Report. Docket No. 50-255. Covert, Michigan. 

| (May 10, 2006).

Ricciardi, A., and H. J. MacIsaac. 2000. “Recent Mass Invasion of the North American Great

| Lakes by Ponto-Caspian Species.” Trends in Ecology & Evolution, Vol. 15, pp. 62–65. 

Ricciardi, A., and J. B. Rasmussen. 1998. “Predicting the Identity and Impact of Future

Biological Invaders: A Priority for Aquatic Resource Management.” Canadian Journal of

| Fisheries and Aquatic Sciences, Vol. 55, pp. 1759–1765. Letter No. 62-0392-000. No subject. 

| (August 27, 1982).

STS Consultants, Inc. (STS). 1987. Palisades Nuclear Power Plant Hydrogeologic Study. 

Report to Consumers Power Company, Jackson, Michigan (September 16, 1987). 

Thurber, N.J., and D.J. Jude. 1985. “Impingement Losses at the D.C. Cook Nuclear Power

Plant during 1975–1982 with a Discussion of Factors Responsible and Possible Impact on Local

Populations.” Special Report No. 115 of the Great Lakes Research Division. Great Lakes and

Marine Waters Center, The University of Michigan, Ann Arbor, Michigan. 

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Palisades Nuclear Generating Plant, Consumers Power Company. Docket

| No. 50-255. Directorate of Licensing, Washington, D.C. (June 1972).

| U.S. Census Bureau. 2004. “American Fact Finder.” U.S. Census Bureau, Washington, D.C.

Available URL: http://factfinder.census.gov/ (Accessed July 2005).

U.S. Fish and Wildlife Service (FWS). 2005a. “County Distribution of Michigan’s Federally

Threatened, Endangered, Proposed, and Candidate Species.” U.S. Fish and Wildlife Service,

Region 3. Available URL: http://www.fws.gov/midwest/endangered/lists/michigan-cty.html

(Accessed July 6, 2005). 

U.S. Fish and Wildlife Service (FWS). 2005b. Letter from C. Czarnecki, U.S. Fish and Wildlife

Service, East Lansing, Michigan, to P.T. Kuo, U.S. Nuclear Regulatory Commission, Rockville,

Maryland. Subject: “Endangered Species List Request, Proposed Palisades Nuclear Plant

(Palisades) License Renewal Project, Allegan, Berrien, Kalamazoo, and Van Buren Counties,

Michigan.” (July 29, 2005). 

U.S. Nuclear Regulatory Commission (NRC). 1978. Final Addendum to the Final

Environmental Statement Related to Operation of Palisades Nuclear Generating Plant

Consumers Power Company. Docket No. 50-255. NUREG-0343. Office of Nuclear Reactor

Regulation, Washington, D.C. (February 1978). 
Environmental Impacts of Operation

October 2006 4-47 NUREG-1437, Supplement 27

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C. |

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, |

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004a. “Procedural Guidance for Preparing

Environmental Assessments and Considering Environmental Issues.” Rev. 1. Appendix D to |

NRR Office Instruction LIC-203. Washington, D.C. (May 24, 2004).

U.S. Nuclear Regulatory Commission (NRC). 2004b. “Policy Statement on the Treatment of

Environmental Justice Matters in NRC Regulatory and Licensing Actions.” Federal Register,

Vol. 69, pp. 52040–52048. Washington, D.C. (August 24, 2004). |

U.S. Nuclear Regulatory Commission (NRC). 2005. Letter from P. T. Kuo, U.S. Nuclear

Regulatory Commission, Rockville, Maryland, to C. Czarnecki, U.S. Fish and Wildlife Service,

East Lansing, Michigan. Subject: “Request for List of Protected Species Within the Area Under

Evaluation for the Palisades Nuclear Plant License Renewal.” (June 30, 2005). |

Wells, L., and A. L. McLain. 1973. “Lake Michigan: Man’s Effects on Native Fish Stocks and

Other Biota.” Technical Report No. 20. Great Lakes Fishery Commission, Ann Arbor, Michigan. 

Available URL: http://www.glfc.org/pubs/TechReports/Tr20.pdf 

(Accessed April 26, 2004). 

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and Addendum 1.

October 2006 5-1 NUREG-1437, Supplement 27

5.0 Environmental Impacts of Postulated Accidents

Environmental issues associated with postulated accidents are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS includes a determination of whether the

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues are then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and,

therefore, additional plant-specific review of these issues is required.

This chapter describes the environmental impacts from postulated accidents that might occur

during the license renewal term.

5.1 Postulated Plant Accidents

Two classes of accidents are evaluated in the GEIS. These are design-basis accidents and

severe accidents, as discussed below. 
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NUREG-1437, Supplement 27 5-2 October 2006

5.1.1 Design-Basis Accidents

| In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear

power facility, an applicant for an initial operating license (OL) must submit a Safety Analysis

Report (SAR) as part of its application. The SAR presents the design criteria and design

information for the proposed reactor and comprehensive data on the proposed site. The SAR

also discusses various hypothetical accident situations and the safety features that are provided

to prevent and mitigate accidents. The NRC staff reviews the application to determine whether

| the plant design meets the Commission’s regulations and requirements and includes, in part,

the nuclear plant design and its anticipated response to an accident.

Design-basis accidents (DBAs) are those accidents that both the licensee and the NRC staff

evaluate to ensure that the plant can withstand normal and abnormal transients, and a broad

spectrum of postulated accidents, without undue hazard to the health and safety of the public. 

A number of these postulated accidents are not expected to occur during the life of the plant,

but are evaluated to establish the design basis for the preventive and mitigative safety systems

of the facility. The acceptance criteria for DBAs are described in Part 50 and Part 100 of

Title 10 of the Code of Federal Regulations (10 CFR Part 50 and 10 CFR Part 100).

The environmental impacts of DBAs are evaluated during the initial licensing process, and the

ability of the plant to withstand these accidents is demonstrated to be acceptable before

issuance of the OL. The results of these evaluations are found in license documentation such

as the applicant’s Final Safety Analysis Report (FSAR), the NRC staff’s Safety Evaluation

| Report (SER), the Final Environmental Statement (FES), and Section 5.1 of this Supplemental

Environmental Impact Statement (SEIS). A licensee is required to maintain the acceptable

design and performance criteria throughout the life of the plant, including any extended-life

operation. The consequences for these events are evaluated for the hypothetical maximally

exposed individual; as such, changes in the plant environment will not affect these evaluations. 

Because of the requirements that continuous acceptability of the consequences and aging

management programs be in effect for license renewal, the environmental impacts as calculated

for DBAs should not differ significantly from initial licensing assessments over the life of the

plant, including the license renewal period. Accordingly, the design of the plant relative to DBAs

during the extended period is considered to remain acceptable, and the environmental impacts

of those accidents were not examined further in the GEIS.

The Commission has determined that the environmental impacts of DBAs are of SMALL

significance for all plants because the plants were designed to successfully withstand these

accidents. Therefore, for the purposes of license renewal, DBAs are designated as a

Category 1 issue in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. The early resolution of

the DBAs makes them a part of the current licensing basis of the plant; the current licensing

basis of the plant is to be maintained by the licensee under its current license, and, therefore,

under the provisions of 10 CFR 54.30, is not subject to review under license renewal. This

issue, applicable to the Palisades Nuclear Plant (Palisades), is listed in Table 5-1. 
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October 2006 5-3 NUREG-1437, Supplement 27

Table 5-1. Category 1 Issue Applicable to Postulated Accidents During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 GEIS Sections

POSTULATED ACCIDENTS

Design-basis accidents 5.3.2; 5.5.1

Based on information in the GEIS, the Commission found that

The NRC staff has concluded that the environmental impacts of design-basis 

accidents are of small significance for all plants.

Nuclear Management Company, LLC (NMC) stated in its Environmental Report (ER)

(NMC 2005a) that it is not aware of any new and significant information associated with the |

renewal of the Palisades OL. The NRC staff has not identified any new and significant

information during its independent review of the NMC ER, the site visit, the scoping process,

and its evaluation of other available information and public comments on the draft SEIS. |

Therefore, the NRC staff concludes that there are no impacts related to DBAs beyond those

discussed in the GEIS.

5.1.2 Severe Accidents 

Severe nuclear accidents are those that are more severe than DBAs because they could result

in substantial damage to the reactor core, regardless of offsite consequences. In the GEIS, the

NRC staff assessed the impacts of severe accidents using the results of existing analyses and

site-specific information to conservatively predict the environmental impacts of severe accidents

for each plant during the renewal period.

Severe accidents initiated by external phenomena, such as tornadoes, floods, earthquakes,

fires, and sabotage, have not traditionally been discussed in quantitative terms in FESs and

were not specifically considered for the Palisades site in the GEIS (NRC 1996). However, in the

GEIS, the NRC staff did evaluate existing impact assessments performed by the NRC and by

the industry at 44 nuclear plants in the United States and concluded that the risk from beyond- |

design-basis earthquakes at existing nuclear power plants is SMALL. Additionally, compliance |

with the NRC regulatory requirements under 10 CFR Part 73 provide reasonable assurance that |

the risk from sabotage is SMALL. Even if such events were to occur, the Commission would |

expect that resultant core damage and radiological releases would be no worse than those |

expected from internally initiated events. Based on the above, the Commission concludes that |

the risk from sabotage and beyond design basis earthquakes at existing nuclear power plants is |
Environmental Impacts of Operation

NUREG-1437, Supplement 27 5-4 October 2006

| small and additionally, that the risks from other external events, are adequately addressed by a

| generic consideration of internally initiated severe accidents.

Based on information in the GEIS, the Commission found that

The probability-weighted consequences of atmospheric releases, fallout onto open

bodies of water, releases to groundwater, and societal and economic impacts from

severe accidents are small for all plants. However, alternatives to mitigate severe

accidents must be considered for all plants that have not considered such 

alternatives.

Therefore, the Commission has designated mitigation of severe accidents as a Category 2 issue

in 10 CFR Part 51, Subpart A, Appendix B, Table B-1. This issue, applicable to Palisades, is

listed in Table 5-2.

Table 5-2. Category 2 Issue Applicable to Postulated Accidents During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1

GEIS

Sections

10 CFR 51.53(c)(3)(ii)

Subparagraph

SEIS

Section

POSTULATED ACCIDENTS

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3;

5.3.3.4; 5.3.3.5; 5.3.4;

5.4; 5.5.2

L 5.2

The NRC staff has not identified any new and significant information with regard to the

consequences from severe accidents during its independent review of the NMC ER, the site

| visit, the scoping process, and its evaluation of other available information and public comments

| on the draft SEIS. Therefore, the NRC staff concludes that there are no impacts of severe

accidents beyond those discussed in the GEIS. However, in accordance with 10 CFR

51.53(c)(3)(ii)(L), the NRC staff has reviewed severe accident mitigation alternatives (SAMAs)

for Palisades. The results of its review are discussed in Section 5.2.

5.2 Severe Accident Mitigation Alternatives

Section 51.53(c)(3)(ii)(L) of 10 CFR requires that license renewal applicants consider

| alternatives to mitigate severe accidents if the NRC staff has not previously evaluated SAMAs

| for the applicant's plant in an EIS or related supplement or in an environmental assessment. 

The purpose of this consideration is to ensure that plant changes (i.e., hardware, procedures,

and training) with the potential for improving severe accident safety performance are identified

| and evaluated. SAMAs have not been previously considered for Palisades; therefore, the

remainder of Chapter 5 addresses those alternatives.
Environmental Impacts of Operation

October 2006 5-5 NUREG-1437, Supplement 27

5.2.1 Introduction

This section presents a summary of the SAMA evaluation for Palisades conducted by NMC, as

described in the ER, and the NRC staff's review of this evaluation. The details of the review are

described in the NRC staff evaluation that was prepared with contract assistance from Pacific

Northwest National Laboratory. The entire evaluation for Palisades is presented in Appendix G.

The SAMA evaluation for Palisades was conducted with a four-step approach. In the first step,

NMC quantified the level of risk associated with potential reactor accidents using the

plant-specific Probabilistic Safety Assessment (PSA) and other risk models. |

In the second step, NMC examined the major risk contributors and identified possible ways

(i.e., SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, |

systems, procedures, and training. NMC initially identified 23 potential SAMAs for Palisades. 

NMC then screened out 14 SAMAs from further consideration because of non-applicability at

Palisades due to (1) design differences; (2) the required extensive changes that would involve

implementation costs known to exceed any possible benefit; (3) the excessive dollar value

associated with completely eliminating all internal and external event severe accident risk at

Palisades, or (4) having only effects on systems with low risk significance based on the plantspecific PSA. The remaining 9 SAMAs were subjected to further evaluation. During the second

phase of the evaluation, NMC screened out one additional SAMA based on risk insights and

other factors, leaving 8 SAMAs to be evaluated.

In the third step, NMC estimated the benefits and the costs associated with each of the

remaining SAMAs. Estimates were made of how much each SAMA could reduce risk. Those

estimates were developed in terms of dollars in accordance with NRC guidance for performing

regulatory analyses (NRC 1997). The cost of implementing the proposed SAMAs was also

estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the

SAMA were greater than the cost (positive cost-benefit). NMC found five SAMAs to be

potentially cost-beneficial in the baseline analysis, and one additional SAMA to be potentially

cost-beneficial when alternative discount rates and analysis uncertainties are considered

(NMC 2005a).

None of the SAMAs evaluated relate directly to adequately managing the effects of aging during

the period of extended operation; therefore, they need not be implemented as part of license

renewal pursuant to 10 CFR Part 54. NMC has indicated that it plans to further evaluate the |

potentially cost-beneficial SAMAs for possible implementation. NMC's SAMA analyses and the

NRC's review are discussed in more detail below.
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NUREG-1437, Supplement 27 5-6 October 2006

5.2.1 Estimate of Risk

| NMC submitted an assessment of SAMAs for Palisades as part of its ER (NMC 2005a) for

license renewal. This assessment was based on the most recent Palisades PSA available at

that time, a plant-specific offsite consequence analysis performed using the MELCOR Accident

Consequence Code System 2 (MACCS2) computer program, and insights from the Palisades

| Individual Plant Examination (IPE) (Consumers Power 1993) and Individual Plant Examination

| of External Events (IPEEE) (Consumers Power 1995, 1996).

The baseline core damage frequency (CDF) for the purpose of the SAMA evaluation is

approximately 4.05 x 10-5 per year. This CDF is based on the risk assessment for internallyinitiated events. NMC did not include the contribution to risk from external events within the

Palisades risk estimates; however, it did account for the potential risk reduction benefits

associated with external events by increasing the estimated benefits for internal events by a

| factor of 2. The breakdown of CDF by initiating event is provided in Table 5-3.

As shown in Table 5-3, events initiated by loss of offsite power, small break loss of coolant

accidents (LOCAs), and steam generator tube rupture (SGTR) are the dominant contributors to

CDF.

| In the ER, NMC estimated the dose to the population within 50 mi of the Palisades site to be

| approximately 0.319 person-Sv per year. The breakdown of the total population dose by

| containment release mode is summarized in Table 5-4. Basemat failures SGTRs dominate the

population dose risk at Palisades.

The NRC staff has reviewed NMC's data and evaluation methods and concludes that the quality

of the risk analyses is adequate to support an assessment of the risk reduction potential for

candidate SAMAs. Accordingly, the NRC staff based its assessment of offsite risk on the CDFs

and offsite doses reported by NMC.

5.2.2 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, NMC searched for ways to reduce

that risk. In identifying and evaluating potential SAMAs, NMC considered insights from the

plant-specific PSA (i.e., SAMA analyses performed for other operating plants that have

submitted license renewal applications, as well as SAMAs that could further reduce the risk of

the dominant fire areas and seismic risk contributors). NMC identified 23 potential risk-reducing

| improvements (SAMAs) to plant components, systems, procedures, and training.
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October 2006 5-7 NUREG-1437, Supplement 27

Table 5-3. Palisades Core Damage Frequency for Internal Events

Initiating Event

CDF

(Per Year)

% Contribution

to CDF

Loss of offsite power (including station blackout) 1.24 × 10-5 31

Small break loss of coolant accident 1.02 × 10-5 25

SGTR 6.06 × 10 | -6 15

General transient with main condenser available 2.94 × 10-6 7

Loss of instrument air 2.41 × 10-6 6

Loss of service water 1.84 × 10-6 5

Loss of main feedwater 9.07 × 10-7 2

Loss of the main condenser 6.46 × 10-7 2

Pressurizer safety valve spurious opening 4.08 × 10-7 1

Other initiators 2.69 × 10-7 6

Total CDF (internal events) 4.05 × 10-5 100(a) |

(a) Total may not equal 100% because of rounding. |

Table 5-4. Breakdown of Population Dose by Containment Release Mode |

Containment Release Mode

Population Dose

(Person-Rem(a) per Year) % Contribution 

SGTR 7.6 23.9 |

Early containment failure 1.6 5 |

Late containment failure 0.3 0.9 |

Intact containment 0.6 1.9 |

Basemat failure 21.6 67.8 |

Containment isolation failure 0.2 0.6 |

Total population dose 31.9 100 | (b)

(a) One person-rem = 0.01 person-Sv. |

(b) Total may not equal 100% because of rounding. |

Fourteen SAMAs were removed from further consideration because of nonapplicability at |

Palisades due to (1) design differences; (2) the required extensive changes that would involve

implementation costs known to exceed any possible benefit, or (3) the excessive dollar value

associated with completely eliminating all internal and external event severe accident risk at

Palisades, or (4) having only effects on systems with low risk significance based on the plant-
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NUREG-1437, Supplement 27 5-8 October 2006

specific PSA. The remaining nine SAMAs were subjected to further evaluation. During the

second phase of the evaluation, NMC screened out one additional SAMA based on risk insights

and other factors. A detailed cost-benefit analysis was performed for each of the eight

remaining SAMAs.

The NRC staff concludes that NMC used a systematic and comprehensive process for

identifying potential plant improvements for Palisades, and that the set of potential plant

improvements identified by NMC is reasonably comprehensive and, therefore, acceptable. 

5.2.3 Evaluation of Risk Reduction and Costs of Improvements

In the third step of its SAMA evaluation, NMC evaluated the risk-reduction potential for each of

the remaining eight SAMAs. Most of the SAMA evaluations were performed in a bounding

fashion in that the SAMA was assumed to completely eliminate the risk associated with the

proposed enhancement.

NMC estimated the costs of implementing the eight candidate SAMAs through the application of

engineering judgment, use of other licensees’ estimates for similar improvements, and

development of site-specific cost estimates. The cost estimates conservatively did not include

the cost of replacement power during extended outages required to implement the

modifications, nor did they include contingency costs associated with unforeseen

implementation obstacles.

The NRC staff reviewed NMC’s bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and conservative (i.e., the estimated risk reduction is similar to or higher than

what would actually be realized). Accordingly, the NRC staff based its estimates of averted risk

for the various SAMAs on NMC’s risk reduction estimates.

The NRC staff reviewed the bases for the applicant’s cost estimates. For certain improvements,

the NRC staff also compared the cost estimates to estimates developed elsewhere for similar

improvements, including estimates developed as part of other licensees’ analyses of SAMAs for

operating reactors and advanced light-water reactors. The NRC staff found the cost estimates

to be consistent with estimates provided in support of other plants’ analyses.

Subsequently, the NRC staff concludes that the risk reduction and the cost estimates provided

by NMC are sufficient and appropriate for use in the SAMA evaluation.
Environmental Impacts of Operation

October 2006 5-9 NUREG-1437, Supplement 27

5.2.4 Cost-Benefit Comparison

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-0184

(NRC 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently |

been revised to reflect the NRC’s revised policy on discount rates. Revision 4 of

NUREG/BR-0058 states that two sets of estimates should be developed – one at 3 percent and |

one at 7 percent (NRC 2004). NMC provided both sets of estimates (NMC 2005a). |

NMC identified five potentially cost-beneficial SAMAs in the baseline analysis contained in the

ER (using a 7 percent discount rate). Based on an analysis using a 3 percent real discount

rate, as recommended in NUREG/BR-0058 (NRC 2004), no additional SAMA candidates were

determined to be potentially cost-beneficial. The potentially cost-beneficial SAMAs are:

C SAMA 10 – Modify the turbine-driven auxiliary feedwater (AFW) system so that it can

operate indefinitely without alternating current (AC), direct current (DC), or pneumatic |

support. This SAMA involves a procedural revision and analysis to direct AFW flow |

adjustments based on decay heat level so that the steam generator level can be |

maintained when instrumentation fails on DC power depletion.

C SAMA 13 – Add a nitrogen station. This SAMA involves the use of a nitrogen station to |

automatically provide backup air supply for critical instrumentation and reduce the

importance of loss of instrument air.

C SAMA 16 – Add insulation to the emergency diesel generator (EDG) exhaust ducts. 

This SAMA involves insulating the EDG exhaust ducts and making procedural |

modifications to prevent overheating of the EDGs engines.

C SAMA 22 – Replace undervoltage relays with seismically qualified model. This SAMA

involves replacing relays to reduce the likelihood of failure of automatic start of the EDGs

and reduce the contributions from loss of power due to the relays.

C SAMA 23 – Modify procedures for primary coolant system cooldown and provide

associated training. This SAMA involves procedural modifications to reduce the |

probability of reactor coolant pump seal failures related to long-term high temperature

exposure after recovery of component cooling water.

NMC performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment (NMC 2005a). With the benefits

increased by a factor of 2.3 to account for uncertainties, one additional SAMA (SAMA 3 – Add a

direct drive diesel-driven injection pump) was determined to be potentially cost-beneficial. |
Environmental Impacts of Operation

NUREG-1437, Supplement 27 5-10 October 2006

NMC noted in its ER that while the above results are believed to accurately reflect areas for

improvement at the plant, additional engineering reviews are necessary to determine ultimate

implementation. NMC stated that it will implement or continue to consider the six SAMAs

identified in the analysis through the appropriate Palisades design process (SAMAs 3, 10, 13,

16, 22, and 23). In response to requests for additional information by the NRC staff

| (NMC 2005b, 2005c), NMC also committed to further evaluate possible lower cost alternatives

for two SAMAs originally eliminated in the Phase 1 screening analysis (SAMAs 1 and 18), and

to further evaluate two additional SAMAs determined to be applicable to Palisades but not yet

evaluated by NMC (adding capability to flash the field on the EDG and replacing an existing airoperated containment sump valve with a motor-operated valve). NMC has entered these 10

potentially cost-beneficial items into the Palisades corrective action system for further review. If

determined to be cost-beneficial, these alternatives will be evaluated for possible

implementation in accordance with Palisades plant design processes.

The NRC staff, therefore, concludes that with the exception of the 10 potentially cost-beneficial

SAMAs discussed above, the costs of the SAMAs evaluated would be higher than the

associated benefits.

5.2.5 Conclusions

The NRC staff reviewed NMC’s analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

| supports the general conclusion that the SAMA evaluations performed by NMC are reasonable

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

events was limited by the unavailability of an external event PSA, the likelihood of there being

cost-beneficial enhancements in this area was minimized by including several candidate SAMAs

related to dominant seismic and fire events and increasing the estimated SAMA benefits for

| internal events by a factor of 2 to account for potential benefits in external events.

Based on its review of the SAMA analysis, the NRC staff concurs with NMC’s identification of

areas in which risk can be further reduced in a cost-beneficial manner through the

implementation of all or a subset of the identified, potentially cost-beneficial SAMA. Given the

potential for cost-beneficial risk reduction, the NRC staff agrees that further evaluation of these

SAMAs by NMC is warranted. However, none of the potentially cost-beneficial SAMAs directly

relate to adequately managing the effects of aging during the period of extended operation. 

Therefore, they need not be implemented as part of the license renewal pursuant to

10 CFR Part 54.
Environmental Impacts of Operation

October 2006 5-11 NUREG-1437, Supplement 27

5.3 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of

Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of |

Plants and Materials.” |

|

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site

Criteria.”

Consumers Power Company (Consumers Power). 1993. Letter from G.B. Slade, Consumers |

Power Company, Jackson, Michigan, to Nuclear Regulatory Commission Document Control |

Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 - Palisades Plant - |

Individual Plant Examination for Severe Accident Vulnerabilities (IPE).” (January 29, 1993). |

|

Consumers Power Company (Consumers Power). 1995. Letter from K.M. Haas, Consumers |

Power Company, Jackson, Michigan, to U.S. Nuclear Regulatory Commission Document |

Control Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 - Palisades |

Plant, Response to Generic Letter 88-20 Supplement 4, ‘Individual Plant Examination of |

External Events for Severe Accident Vulnerabilities, Final Report.’” (June 30, 1995). |

|

Consumers Power Company (Consumers Power). 1996. Letter from R.W. Smedley, |

Consumers Power Company, Jackson, Michigan, to U.S. Nuclear Regulatory Commission |

Document Control Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 - |

Palisades Plant, Submittal of Revised IPEEE Report Based on Re-analysis of Internal Fires, |

‘Individual Plant Examination of External Events Report, Revision 1, Final Report.’” (May 22, |

1996). |

Nuclear Management Company, LLC (NMC). 2005a. Applicant’s Environmental Report – |

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255. 

Covert, Michigan. (March 2005).

Nuclear Management Company, LLC (NMC). 2005b. Letter from P.A. Harden, Nuclear |

Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission |
Environmental Impacts of Operation

NUREG-1437, Supplement 27 5-12 October 2006

| Document Control Desk, Rockville, Maryland. Subject: “Response to NRC Requests for

| Additional Information Dated August 24, 2005, Relating to License Renewal for the Palisades

| Nuclear Plant.” (October 21, 2005).

|

| Nuclear Management Company, LLC (NMC). 2005c. Letter from J. Holthaus, Nuclear

| Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission

| Document Control Desk, Rockville, Maryland. Subject: “Supplement to ‘Response to NRC

| Request for Additional Information Dated August 24, 2005 relating to License Renewal for the

| Palisades Nuclear Plant,’ dated October 21, 2005, (Accession Number ML052990316) and

| telecon on November 10, 2005.” (November 18, 2005).

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2. Washington, D.C.

| U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation

| Handbook. NUREG/BR-0184, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

| U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the

| U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 6-1 NUREG-1437, Supplement 27

6.0 Environmental Impacts of the Uranium

Fuel Cycle and Solid Waste Management

Environmental issues associated with the uranium fuel cycle and solid waste management are

discussed in the Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GEIS), NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999.)(a) The GEIS includes a

determination of whether the analysis of the environmental issue could be applied to all plants

and whether additional mitigation measures would be warranted. Issues are then assigned a

Category 1 or a Category 2 designation. As set forth in the GEIS, Category 1 issues are those

that meet all of the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste (HLW) and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and,

therefore, additional plant-specific review of these issues is required.

This chapter addresses the issues that are related to the uranium fuel cycle and solid waste

management during the license renewal term that are listed in Table B-1 of Title 10, Part 51, of

the Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B, and are applicable

to the Palisades Nuclear Plant (Palisades). The generic potential impacts of the radiological

and nonradiological environmental impacts of the uranium fuel cycle and transportation of

nuclear fuel and wastes are described in detail in the GEIS based, in part, on the generic

impacts provided in 10 CFR 51.51(b), Table S-3, “Table of Uranium Fuel Cycle Environmental
Fuel Cycle

NUREG-1437, Supplement 27 6-2 October 2006

Data,” and in 10 CFR 51.52(c), Table S-4, “Environmental Impact of Transportation of Fuel and

| Waste to and from One Light-Water-Cooled Nuclear Power Reactor.” The U.S. Nuclear

| Regulatory Commission (NRC) staff also addresses the impacts from radon-222 and

technetium-99 in the GEIS. 

6.1 The Uranium Fuel Cycle

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

Palisades from the uranium fuel cycle and solid waste management are listed in Table 6-1. 

Table 6-1. Category 1 Issues Applicable to the Uranium Fuel Cycle and Solid Waste

Management During the Renewal Term

ISSUE–10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section

URANIUM FUEL CYCLE AND WASTE MANAGEMENT

Offsite radiological impacts (individual effects from other than the

disposal of spent fuel and high-level waste)

6.1; 6.2.1; 6.2.2.1; 6.2.2.3; 6.2.3;

6.2.4; 6.6

Offsite radiological impacts (collective effects) 6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6

Offsite radiological impacts (spent fuel and high-level waste

disposal)

6.1; 6.2.2.1; 6.2.3; 6.2.4; 6.6

Nonradiological impacts of the uranium fuel cycle 6.1; 6.2.2.6; 6.2.2.7; 6.2.2.8;

6.2.2.9; 6.2.3; 6.2.4; 6.6

Low-level waste storage and disposal 6.1; 6.2.2.2; 6.4.2; 6.4.3; 6.4.3.1;

6.4.3.2; 6.4.3.3; 6.4.4; 6.4.4.1;

6.4.4.2; 6.4.4.3; 6.4.4.4; 6.4.4.5;

6.4.4.5.1; 6.4.4.5.2; 6.4.4.5.3;

6.4.4.5.4; 6.4.4.6; 6.6

Mixed waste storage and disposal 6.1; 6.4.5.1; 6.4.5.2; 6.4.5.3;

6.4.5.4; 6.4.5.5; 6.4.5.6; 6.4.5.6.1;

6.4.5.6.2; 6.4.5.6.3; 6.4.5.6.4; 6.6

Onsite spent fuel 6.1; 6.4.6; 6.4.6.1; 6.4.6.2;

6.4.6.3; 6.4.6.4; 6.4.6.5; 6.4.6.6;

6.4.6.7; 6.6

Nonradiological waste 6.1; 6.5; 6.5.1; 6.5.2; 6.5.3; 6.6

Transportation 6.1; 6.3.1; 6.3.2.3; 6.3.3; 6.3.4;

6.6; Addendum 1
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October 2006 6-3 NUREG-1437, Supplement 27

Nuclear Management Company, LLC (NMC), stated in its Environmental Report (ER) |

(NMC 2005) that it is not aware of any new and significant information associated with the

renewal of the Palisades operating license (OL). The NRC staff has not identified any new and

significant information during its independent review of the NMC ER, the site visit, the scoping

process, and its evaluation of other available information and public comments on the draft |

Supplemental Environmental Impact Statement (SEIS). Therefore, the NRC staff concludes |

that there are no impacts related to these issues beyond those discussed in the GEIS. For

these issues, the NRC staff concluded in the GEIS that the impacts are SMALL except for the

collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal,

as discussed below, and that additional plant-specific mitigation measures are not likely to be

sufficiently beneficial to be warranted.

A brief description of the NRC staff review and the GEIS conclusions, as codified in Table B-1,

10 CFR Part 51, for each of these issues follows:

 C Offsite radiological impacts (individual effects from other than the disposal of spent fuel

and HLW). Based on information in the GEIS, the Commission found that 

Offsite impacts of the uranium fuel cycle have been considered by the Commission in

Table S-3 of this Part [10 CFR 51.51(b)]. Based on information in the GEIS, impacts on

individuals from radioactive gaseous and liquid releases, including radon-222 and

technetium-99, are small.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other available |

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that |

there would be no offsite radiological impacts of the uranium fuel cycle during the renewal term |

beyond those discussed in the GEIS.

 C Offsite radiological impacts (collective effects). Based on information in the GEIS, the

Commission found that

The 100-year environmental dose commitment to the U.S. population from the fuel cycle,

HLW and spent fuel disposal excepted, is calculated to be about 14,800 person rem, or

12 cancer fatalities, for each additional 20-year power reactor operating term. Much of

this, especially the contribution of radon releases from mines and tailing piles, consists

of tiny doses summed over large populations. This same dose calculation can

theoretically be extended to include many tiny doses over additional thousands of years

as well as doses outside the United States. The result of such a calculation would be

thousands of cancer fatalities from the fuel cycle, but this result assumes that even tiny

doses have some statistical adverse health effect that will not ever be mitigated (e.g., no
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NUREG-1437, Supplement 27 6-4 October 2006

cancer cure in the next thousand years), and that these doses projected over thousands

of years are meaningful. However, these assumptions are questionable. In particular,

science cannot rule out the possibility that there will be no cancer fatalities from these

tiny doses. For perspective, the doses are very small fractions of regulatory limits and

even smaller fractions of natural background exposure to the same populations.

Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA

[National Environmental Policy Act] implications of these matters should be made and it

makes no sense to repeat the same judgment in every case. Even taking the

uncertainties into account, the Commission concludes that these impacts are acceptable

in that these impacts would not be sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation under 10 CFR Part 54 should be

eliminated. Accordingly, while the Commission has not assigned a single level of

significance for the collective effects of the fuel cycle, this issue is considered

Category 1.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other available

| information and public comments on the draft SEIS. Therefore, the NRC staff concludes that

| there would be no offsite radiological impacts (collective effects) from the uranium fuel cycle

during the renewal term beyond those discussed in the GEIS.

 C Offsite radiological impacts (spent fuel and HLW disposal). Based on information in the

GEIS, the Commission found that

For the HLW and spent fuel disposal component of the fuel cycle, there are no current

regulatory limits for offsite releases of radionuclides for the current candidate repository

site. However, if we assume that limits are developed along the lines of the 1995

National Academy of Sciences (NAS) report, Technical Bases for Yucca Mountain

Standards, and that in accordance with the Commission’s Waste Confidence Decision,

10 CFR 51.23, a repository can and likely will be developed at some site which will

comply with such limits, peak doses to virtually all individuals will be 100 mrem per year

or less. However, while the Commission has reasonable confidence that these

assumptions will prove correct, there is considerable uncertainty since the limits are yet

to be developed, no repository application has been completed or reviewed, and

uncertainty is inherent in the models used to evaluate possible pathways to the human

environment. The NAS report indicated that 100 mrem per year should be considered

as a starting point for limits for individual doses, but notes that some measure of

consensus exists among national and international bodies that the limits should be a

fraction of the 100 mrem per year. The lifetime individual risk from a 100-mrem annual

dose limit is about 3 × 10-3.
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October 2006 6-5 NUREG-1437, Supplement 27

Estimating cumulative doses to populations over thousands of years is more problematic. The likelihood and consequences of events that could seriously compromise the

integrity of a deep geologic repository were evaluated by the Department of Energy in

the Final Environmental Impact Statement: Management of Commercially Generated

Radioactive Waste, October 1980 (DOE 1980). The evaluation estimated the 70-year

whole-body dose commitment to the maximum individual and to the regional population

resulting from several modes of breaching a reference repository in the year of closure,

after 1,000 years, after 100,000 years, and after 100,000,000 years. Subsequently, the

NRC and other federal agencies have expended considerable effort to develop models

for the design and for the licensing of a HLW repository, especially for the candidate

repository at Yucca Mountain. More meaningful estimates of doses to population may

be possible in the future as more is understood about the performance of the proposed

Yucca Mountain repository. Such estimates would involve very great uncertainty,

especially with respect to cumulative population doses over thousands of years. The

standard proposed by the NAS is a limit on maximum individual dose. The relationship

of potential new regulatory requirements, based on the NAS report, and cumulative

population impacts has not been determined, although the report articulates the view

that protection of individuals will adequately protect the population for a repository at

Yucca Mountain. However, the EPA’s generic repository standards in 40 CFR Part 191

generally provide an indication of the order of magnitude of cumulative risk to population

that could result from the licensing of a Yucca Mountain repository, assuming the

ultimate standards will be within the range of standards now under consideration. The

standards in 40 CFR Part 191 protect the population by imposing “containment requirements” that limit the cumulative amount of radioactive material released over

10,000 years. Reporting performance standards that will be required by the EPA are

expected to result in releases and associated health consequences in the range

between 10 and 100 premature cancer deaths, with an upper limit of 1,000 premature

cancer deaths, worldwide for a 100,000 metric tonne (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment as to the regulatory NEPA

implications of these matters should be made and it makes no sense to repeat the same

judgment in every case. Even taking the uncertainties into account, the Commission

concludes that these impacts are acceptable in that these impacts would not be

sufficiently large to require the NEPA conclusion, for any plant, that the option of

extended operation under 10 CFR Part 54 should be eliminated. Accordingly, while the

Commission has not assigned a single level of significance for the impacts of spent fuel

and HLW disposal, this issue is considered Category 1.

On February 15, 2002, based on a recommendation by the Secretary of the Department of

Energy, the President recommended the Yucca Mountain site for the development of a

repository for the geologic disposal of spent nuclear fuel and high-level nuclear waste. The U.S.

Congress approved this recommendation on July 9, 2002, in Joint Resolution 87, which
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NUREG-1437, Supplement 27 6-6 October 2006

designated Yucca Mountain as the repository for spent nuclear waste. On July 23, 2002, the

President signed Joint Resolution 87 into law; Public Law 107-200, 116 Stat. 735 (2002)

designates Yucca Mountain as the repository for spent nuclear waste. This development does

not represent new and significant information with respect to the offsite radiological impacts

from license renewal related to disposal of spent nuclear fuel and high-level nuclear waste.

| The U.S. Environmental Protection Agency (EPA) developed Yucca-Mountain-specific

repository standards, which were subsequently adopted by the NRC in 10 CFR Part 63. In an

opinion issued July 9, 2004, the U.S. Court of Appeals for the District of Columbia Circuit

(the Court) vacated the EPA's radiation protection standards for the candidate repository, which

required compliance with certain dose limits over a 10,000-year period. The Court's decision

also vacated the compliance period in NRC's licensing criteria for the candidate repository in

10 CFR Part 63. In response to the Court’s decision, the EPA issued its proposed revised

standards on August 22, 2005 (Federal Register, Volume 40, page 49014 (70 FR 49014)). In

order to be consistent with the EPA’s revised standards, the NRC proposed revisions to 10 CFR

Part 63 on September 8, 2005 (70 FR 53313).

Therefore, for the HLW and spent fuel disposal component of the fuel cycle, there is some

uncertainty with respect to regulatory limits for offsite releases of radioactive nuclides for the

current candidate repository site. However, prior to promulgation of the affected provisions of

the Commission's regulations, the NRC staff assumed that limits would be developed along the

lines of the 1995 NAS report, Technical Bases for Yucca Mountain Standards, and that in

accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23, a repository that

would comply with such limits could and likely would be developed at some site. 

Despite the current uncertainty with respect to these rules, some judgment as to the regulatory

NEPA implications of offsite radiological impacts of spent fuel and HLW disposal should be

made. The NRC staff concludes that these impacts are acceptable in that the impacts would

not be sufficiently large to require the NEPA conclusion that the option of extended operation

under 10 CFR Part 54 should be eliminated.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other available

| information and public comments on the draft SEIS. Therefore, the NRC staff concludes that

| there would be no offsite radiological impacts related to spent fuel and HLW disposal during the

renewal term beyond those discussed in the GEIS.

 C Nonradiological impacts of the uranium fuel cycle. Based on information in the GEIS,

the Commission found that 

The nonradiological impacts of the uranium fuel cycle resulting from the renewal of an

operating license for any plant are found to be small.
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October 2006 6-7 NUREG-1437, Supplement 27

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other available |

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that |

there would be no nonradiological impacts of the uranium fuel cycle during the renewal term |

beyond those discussed in the GEIS.

 C Low-level waste storage and disposal. Based on information in the GEIS, the

Commission found that

The comprehensive regulatory controls that are in place and the low public doses being

achieved at reactors ensure that the radiological impacts to the environment will remain

small during the term of a renewed license. The maximum additional on-site land that

may be required for low-level waste storage during the term of a renewed license and

associated impacts will be small. Nonradiological impacts on air and water will be

negligible. The radiological and nonradiological environmental impacts of long-term

disposal of low-level waste from any individual plant at licensed sites are small. In

addition, the Commission concludes that there is reasonable assurance that sufficient

low-level waste disposal capacity will be made available when needed for facilities to be

decommissioned consistent with NRC decommissioning requirements.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other available |

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that |

there would be no impacts of low-level waste storage and disposal associated with the renewal |

term beyond those discussed in the GEIS.

 C Mixed waste storage and disposal. Based on information in the GEIS, the Commission

found that

The comprehensive regulatory controls and the facilities and procedures that are in

place ensure proper handling and storage, as well as negligible doses and exposure to

toxic materials for the public and the environment at all plants. License renewal will not

increase the small, continuing risk to human health and the environment posed by mixed

waste at all plants. The radiological and nonradiological environmental impacts of longterm disposal of mixed waste from any individual plant at licensed sites are small. In

addition, the Commission concludes that there is reasonable assurance that sufficient

mixed waste disposal capacity will be made available when needed for facilities to be

decommissioned consistent with NRC decommissioning requirements.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other available |

information and public comments on the draft SEIS. Therefore, the NRC staff concludes that |
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NUREG-1437, Supplement 27 6-8 October 2006

| there would be no impacts of mixed waste storage and disposal associated with the renewal

term beyond those discussed in the GEIS.

 C Onsite spent fuel. Based on information in the GEIS, the Commission found that

The expected increase in the volume of spent fuel from an additional 20 years of

operation can be safely accommodated onsite with small environmental effects through

dry or pool storage at all plants if a permanent repository or monitored retrievable

storage is not available.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other available

| information and public comments on the draft SEIS. Therefore, the NRC staff concludes that

| there would be no impacts of onsite spent fuel associated with license renewal beyond those

discussed in the GEIS.

 C Nonradiological waste. Based on information in the GEIS, the Commission found that

No changes to generating systems are anticipated for license renewal. Facilities and

procedures are in place to ensure continued proper handling and disposal at all plants.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other available

| information and public comments on the draft SEIS. Therefore, the NRC staff concludes that

| there would be no nonradiological waste impacts during the renewal term beyond those

discussed in the GEIS.

 C Transportation. Based on information contained in the GEIS, the Commission found that

The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with

average burnup for the peak rod to current levels approved by the NRC up to

62,000 MWd/MTU and the cumulative impacts of transporting HLW to a single

repository, such as Yucca Mountain, Nevada, are found to be consistent with the impact

values contained in 10 CFR 51.52(c), Summary Table S-4, “Environmental Impact of

Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power

Reactor.” If fuel enrichment or burnup conditions are not met, the applicant must submit

an assessment of the implications for the environmental impact values reported in the

summary table.

Palisades meets the fuel-enrichment and burnup conditions set forth in Addendum 1 to the

GEIS. The NRC staff has not identified any new and significant information during its

| independent review of the NMC ER, the site visit, the scoping process, and its evaluation of

| other available information, and public comments on the draft SEIS. Therefore, the NRC staff
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October 2006 6-9 NUREG-1437, Supplement 27

concludes that there would be no impacts of transportation associated with license renewal |

beyond those discussed in the GEIS.

There are no Category 2 issues for the uranium fuel cycle and solid waste management.

6.2 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, “Disposal of HighLevel Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191,

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear

Fuel, High-Level and Transuranic Radioactive Waste.”

Joint Resolution Approving the Site at Yucca Mountain, Nevada, for the Development of a

Repository for the Disposal of High-Level Radioactive Waste and Spent Nuclear Fuel, pursuant

to the Nuclear Waste Policy Act of 1982. 2002. Public Law 107-200. 116 Stat. 735.

National Academy of Sciences (NAS). 1995. Technical Bases for Yucca Mountain Standards. 

Washington, D.C.

National Environmental Policy Act of 1969 (NEPA), as amended, 42 USC 4321, et. seq. |

Nuclear Management Company, LLC (NMC). 2005. Applicant’s Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255. Covert,

Michigan. (March 2005).

U.S. Department of Energy (DOE). 1980. Final Environmental Impact Statement: 

Management of Commercially Generated Radioactive Waste, DOE/EIS-0046F, |

Washington, D.C.

U.S. Environmental Protection Agency (EPA). 2005. “Public Health and Environmental

Radiation Protection Standards for Yucca Mountain, Nevada.” Federal Register, Vol. 70,

No. 161, pp. 49014–49068. Washington, D.C. (August 22, 2005).
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NUREG-1437, Supplement 27 6-10 October 2006

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005. “Implementation of a Dose Standard After

10,000 Years.” Federal Register, Vol. 63, No. 173, pp. 53313–53320. Washington, D.C. 

(September 8, 2005).
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 7-1 NUREG-1437, Supplement 27

7.0 Environmental Impacts of Decommissioning

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in the Generic Environmental

Impact Statement for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the

Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC 2002). The

U.S. Nuclear Regulatory Commission (NRC) staff’s evaluation of the environmental impacts of

decommissioning presented in NUREG-0586, Supplement 1, identifies a range of impacts for

each environmental issue. 

The incremental environmental impacts associated with decommissioning activities resulting

from continued plant operation during the renewal term are evaluated in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999).(a) The GEIS includes a determination of whether the

analysis of the environmental issue could be applied to all plants and whether additional

mitigation measures would be warranted. Issues were then assigned a Category 1 or a

Category 2 designation. As set forth in the GEIS, Category 1 issues are those that meet all of

the following criteria:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation. 

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required unless new and significant information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1, and,

therefore, additional plant-specific review of these issues is required. There are no Category 2

issues related to decommissioning.
Environmental Impacts of Decommissioning

NUREG-1437, Supplement 27 7-2 October 2006

7.1 Decommissioning

Category 1 issues in Table B-1 of Part 51 of Title 10 of the Code of Federal Regulations

(10 CFR Part 51), Subpart A, Appendix B, that are applicable to Palisades Nuclear Plant

(Palisades) decommissioning following the renewal term are listed in Table 7-1. Nuclear

| Management Company, LLC (NMC), stated in its Environmental Report (ER) (NMC 2005) that it

is aware of no new and significant information regarding the environmental impacts of license

| renewal for Palisades. The NRC staff has not identified any new and significant information

| during its independent review of the NMC ER, the site visit, the scoping process, and its

| evaluation of other available information and comments on the draft Supplemental

| Environmental Impact Statement (SEIS). Therefore, the NRC staff concludes that there are no

impacts related to these issues beyond those discussed in the GEIS. For all of these issues,

the NRC staff concluded in the GEIS that the impacts are SMALL, and additional plant-specific

mitigation measures are not likely to be sufficiently beneficial to be warranted.

Table 7-1. Category 1 Issues Applicable to the Decommissioning of Palisades

Following the Renewal Term

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 GEIS Section

DECOMMISSIONING

Radiation doses 7.3.1; 7.4

Waste management 7.3.2; 7.4

Air quality 7.3.3; 7.4

Water quality 7.3.4; 7.4

Ecological resources 7.3.5; 7.4

Socioeconomic impacts 7.3.7; 7.4

A brief description of the NRC staff’s review and the GEIS conclusions, as codified in Table B-1,

for each of the issues follows:

 C Radiation doses. Based on information in the GEIS, the Commission found that

Doses to the public will be well below applicable regulatory standards regardless

of which decommissioning method is used. Occupational doses would increase

| no more than 1 person-rem caused by buildup of long-lived radionuclides during

the license renewal term.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, the evaluation of other available
Environmental Impacts of Decommissioning

October 2006 7-3 NUREG-1437, Supplement 27

information, or public comments on the draft SEIS. Therefore, the NRC staff concludes that |

there would be no radiation dose impacts associated with decommissioning following the |

license renewal term beyond those discussed in the GEIS.

 C Waste management. Based on information in the GEIS, the Commission found that

Decommissioning at the end of a 20-year license renewal period would generate

no more solid wastes than at the end of the current license term. No increase in

the quantities of Class C or greater than Class C wastes would be expected.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts from solid waste associated with |

decommissioning following the license renewal term beyond those discussed in the GEIS.

 C Air quality. Based on information in the GEIS, the Commission found that

Air quality impacts of decommissioning are expected to be negligible either at the

end of the current operating term or at the end of the license renewal term.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts on air quality associated with decommissioning |

following the license renewal term beyond those discussed in the GEIS.

 C Water quality. Based on information in the GEIS, the Commission found that

The potential for significant water quality impacts from erosion or spills is no

greater whether decommissioning occurs after a 20-year license renewal period

or after the original 40-year operation period, and measures are readily available

to avoid such impacts.

The NRC staff has not identified any new and significant information during its independent

review of the NMC ER, the site visit, the scoping process, and its evaluation of other |

available information and public comments on the draft SEIS. Therefore, the NRC staff |

concludes that there would be no impacts on water quality associated with decommissioning |

following the license renewal term beyond those discussed in the GEIS.
Environmental Impacts of Decommissioning

NUREG-1437, Supplement 27 7-4 October 2006

 C Ecological resources. Based on information in the GEIS, the Commission found that

Decommissioning after either the initial operating period or after a 20-year

license renewal period is not expected to have any direct ecological impacts.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

| concludes that there would be no impacts on ecological resources associated with

decommissioning following the license renewal term beyond those discussed in the GEIS.

| C Socioeconomic impacts. Based on information in the GEIS, the Commission found that

Decommissioning would have some short-term socioeconomic impacts. The

impacts would not be increased by delaying decommissioning until the end of a

20-year relicense period, but they might be decreased by population and

economic growth.

The NRC staff has not identified any new and significant information during its independent

| review of the NMC ER, the site visit, the scoping process, and its evaluation of other

| available information and public comments on the draft SEIS. Therefore, the NRC staff

concludes that there would be no socioeconomic impacts associated with decommissioning

following the license renewal term beyond those discussed in the GEIS.

7.2 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

Nuclear Management Company, LLC (NMC). 2005. Applicant's Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255, Covert,

Michigan (March 2005).

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.
Environmental Impacts of Decommissioning

October 2006 7-5 NUREG-1437, Supplement 27

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement

for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of

Nuclear Power Reactors. NUREG-0586, Supplement 1, Washington, D.C.

(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 8-1 NUREG-1437, Supplement 27

8.0 Environmental Impacts of Alternatives

to License Renewal

This chapter examines the potential environmental impacts associated with denying the renewal

of an operating license (OL) (i.e., the no-action alternative); the potential environmental impacts

from electric-generating sources other than Palisades Nuclear Plant (Palisades); the possibility

of purchasing electric power from other sources to replace power generated by Palisades and

the associated environmental impacts; the potential environmental impacts from a combination

of generating and conservation measures; and other generation alternatives that were deemed

unsuitable for replacement of power generated by Palisades. The environmental impacts are

evaluated using the U.S. Nuclear Regulatory Commission’s (NRC’s) three-level standard of

significance – SMALL, MODERATE, or LARGE – developed using the Council on

Environmental Quality guidelines and set forth in the footnotes to Table B-1 of Part 51 of Title 10

of the Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B:

SMALL – Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize

important attributes of the resource.

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

The impact categories evaluated in this chapter are the same as those used in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS) NUREG-1437,

Volumes 1 and 2 (NRC 1996, 1999),(a) with the additional impact category of environmental

justice and transportation.

8.1 No-Action Alternative

The NRC’s regulations implementing the National Environmental Policy Act of 1969 (NEPA), |

10 CFR Part 51, Subpart A, Appendix A(4), specify that the no-action alternative be discussed

in an NRC Environmental Impact Statement (EIS). For license renewal, the no-action

alternative refers to a scenario in which the NRC would not renew the Palisades OL, and

Nuclear Management Company, LLC (NMC), would then cease plant operations by the end of |
Alternatives

(a) Appendix J of NUREG-0586, Supplement 1, discusses the socioeconomic impacts of plant closure.

The results of the analysis in Appendix J, however, were not incorporated into the analysis presented

in the main body of the NUREG.

NUREG-1437, Supplement 27 8-2 October 2006

the current license and initiate the decommissioning of the plant. NMC would be required to

shut down Palisades and to comply with NRC decommissioning requirements in 10 CFR 50.82,

whether or not the OL is renewed. If the Palisades OL is renewed, shutdown of the unit and

decommissioning activities would not be avoided, but would be postponed for up to an

additional 20 years.

The environmental impacts associated with decommissioning under a license renewal or the noaction alternative would be bounded by the discussion of impacts in Chapter 7 of the license

| renewal GEIS (NRC 1996), Chapter 7 of this Supplemental Environmental Impact Statement

(SEIS), and the Final Generic Environmental Impact Statement on Decommissioning of Nuclear

Facilities, NUREG-0586, Supplement 1 (NRC 2002). The impacts of decommissioning after

60 years of operation are not expected to be significantly different from those occurring after

40 years of operation.

Impacts from the decision to permanently cease operations are not considered in NUREG-0586,

Supplement 1.(a) Therefore, immediate impacts that occur between plant shutdown and the

beginning of decommissioning are considered here. These impacts would occur when the unit

shuts down regardless of whether the license is renewed or not and are discussed below, with

the results presented in Table 8-1. Plant shutdown would result in a net reduction in power

production capacity. The power not generated by Palisades during the license renewal term

would likely be replaced by (1) power purchased from other electricity providers, (2) generating

alternatives other than Palisades, (3) demand-side management (DSM) and energy

conservation, or (4) some combination of these options. The environmental impacts of these

options are discussed in Section 8.2. 

 C Land Use

In Chapter 4, the NRC staff concluded that the impacts of continued plant operation on land

use would be SMALL. Onsite land use would not be affected immediately by the cessation

of operations. Plant structures and other facilities are likely to remain in place until

decommissioning. The transmission lines associated with the project are expected to

remain in service after the plant stops operating. As a result, maintenance of the

rights-of-way will continue as before. Therefore, the NRC staff concludes that the impacts

on land use from plant shutdown would be SMALL.
Alternatives

October 2006 8-3 NUREG-1437, Supplement 27

Table 8-1. Summary of Environmental Impacts of the No-Action Alternative

Impact Category Impact Comment

Land use SMALL Impacts are expected to be SMALL because plant

shutdown would not be expected to result in changes

to onsite or offsite land use.

Ecology SMALL Impacts are expected to be SMALL because aquatic

impacts would be reduced, and terrestrial impacts are

not expected because there would not be any

changes in rights-of-way maintenance practices. 

Water use and quality – |

surface water

SMALL Impacts are expected to be SMALL because surfacewater intake and discharges would be eliminated. 

Water use and quality – |

groundwater

SMALL Impacts are expected to be SMALL because

discharge to the sanitary drain field would be

eliminated.

Air quality SMALL Impacts are expected to be SMALL because

emissions related to plant operation and worker

transportation would decrease. 

Waste SMALL Impacts are expected to be SMALL because

generation of high-level waste would stop, and

generation of low-level and mixed waste would

decrease.

Human health SMALL Impacts are expected to be SMALL because

radiological doses to workers and members of the

public, which are within regulatory limits, would be

further reduced.

Socioeconomics SMALL to 

LARGE

Impacts are expected to range from SMALL to LARGE

because of a decrease in employment and tax

revenues.

Transportation SMALL Impacts are expected to be SMALL because the

decrease in employment would reduce traffic.

Aesthetics SMALL Impacts are expected to be SMALL because plant

structures would remain in place, and the visibility of

plumes from the cooling towers would be eliminated. 

Historic and archaeological

resources

SMALL Impacts are expected to be SMALL because

shutdown of the plant would not result in land

disturbance.

Environmental justice SMALL to 

 LARGE

Impacts are expected to range from SMALL to LARGE

because a loss of employment opportunities would be

expected.
Alternatives

NUREG-1437, Supplement 27 8-4 October 2006

 C Ecology

| In Chapter 4 of this SEIS, the NRC staff concluded that the ecological impacts of continued

plant operation would be SMALL. Cessation of operations would be accompanied by a

reduction in cooling-water flow and the thermal plume from the plant. These changes would

| reduce environmental impacts on aquatic species. The transmission lines associated with

Palisades are expected to remain in service after Palisades stops operating. As a result,

maintenance of the rights-of-way and subsequent impacts on the terrestrial ecosystem

would continue as before. Therefore, the NRC staff concludes that ecological impacts from

shutdown of the plant would be SMALL.

| C Water Use and Quality – Surface Water

| In Chapter 4 of this SEIS, the NRC staff concluded that impacts of continued plant operation

on surface-water use and quality would be SMALL. When the plant stops operating, there

would be an immediate reduction in the consumptive use of water because of reduction in

cooling-water flow and in the amount of heat rejected to Lake Michigan. Therefore, the NRC

staff concludes that the impacts on surface-water use and quality from plant shutdown

would be SMALL. 

| C Water Use and Quality – Groundwater

| In Chapter 4 of this SEIS, the NRC staff concluded that impacts of continued plant

groundwater use on groundwater availability and quality would be SMALL. Groundwater

use is limited to that used only for maintenance of the grounds. When the plant stops

operating, there would be virtually no change in groundwater use at the site as the facilities

would remain until decommissioning. In addition, domestic water disposal would no longer

| occur at the three onsite sanitary drain fields. Therefore, the NRC staff concludes that

groundwater use and quality impacts from shutdown of the plant would be SMALL.

 C Air Quality

| In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant

operation on air quality would be SMALL. When the plant stops operating, there would be a

reduction in emissions from activities related to plant operation, such as the use of diesel

generators and worker transportation. Therefore, the NRC staff concludes that the impacts

on air quality from shutdown of the plant would be SMALL.

 C Waste

The impacts of waste generated by continued plant operation are discussed in Chapter 6. 

The impacts of low-level and mixed waste from plant operation are characterized as SMALL. 

When Palisades stops operating, it would stop generating high-level waste (HLW), and the
Alternatives

October 2006 8-5 NUREG-1437, Supplement 27

generation of low-level and mixed waste associated with plant operation and maintenance

would be reduced. Therefore, the NRC staff concludes that the impact of waste generated

after shutdown of the plant would be SMALL.

 C Human Health

In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant |

operation on human health would be SMALL. After the cessation of operations, the amount

of radioactive material released to the environment in gaseous and liquid forms would be

reduced. Therefore, the NRC staff concludes that the impact of shutdown of the plant on

human health would be SMALL. In addition, the variety of potential accidents at the plant

would be reduced to a limited set associated with shutdown events and fuel handling. In

Chapter 5 of this SEIS, the NRC staff concluded that the impacts of accidents during

operation would be SMALL. Therefore, the NRC staff concludes that the impacts of

potential accidents following shutdown of the plant would be SMALL.

 C Socioeconomics

In Chapter 4 of this SEIS, the NRC staff concluded that the socioeconomic impacts of |

continued plant operation would be SMALL. There would be immediate socioeconomic

impacts associated with the shutdown of the plant because of the reduction in the staff at

the plant. There may also be an immediate reduction in property tax revenues for Covert

Township and Van Buren County. The overall impacts would depend on the state of the |

economy, the net change in workforce at the plant, and the changes in local government tax

receipts. Appendix J of Supplement 1 to NUREG-0586 (NRC 2002) shows that the overall

socioeconomic impact of plant closure plus decommissioning could be greater than SMALL. 

The NRC staff concludes that the socioeconomic impacts of plant shutdown would range

from SMALL to LARGE. Some of these impacts could be offset if new power-generating

facilities are built at or near the current site. 

 C Transportation

In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant |

operation on transportation would be SMALL. Cessation of operations would be

accompanied by a reduction of traffic in the vicinity of the plant. Most of the reduction would

be associated with a reduction in the plant workforce, but there would also be a reduction in

shipment of material to and from the plant. Therefore, the NRC staff concludes that the

impacts of plant closure on transportation would be SMALL.
Alternatives

NUREG-1437, Supplement 27 8-6 October 2006

 C Aesthetics

| In Chapter 4 of this SEIS, the NRC staff concluded that the aesthetic impacts of continued

plant operation would be SMALL. Cessation of operations would be accompanied by the

elimination of visible plumes from the cooling towers. Plant structures and other facilities

are likely to remain in place until decommissioning. Therefore, the NRC staff concludes that

the aesthetic impacts of plant closure would be SMALL.

 C Historic and Archaeological Resources

| In Chapter 4 of this SEIS, the NRC staff concluded that the impacts of continued plant

operation on historic and archaeological resources would likely be SMALL. Onsite land use

would not be affected immediately by the cessation of operations. Plant structures and

other facilities would likely remain in place until decommissioning. The transmission lines

associated with the project are expected to remain in service after the plant stops operating. 

As a result, maintenance of transmission line rights-of-way would continue as before. 

Therefore, the NRC staff concludes that the impacts on historic and archaeological

resources from plant shutdown would be SMALL.

 C Environmental Justice

| In Chapter 4 of this SEIS, the NRC staff concluded that the environmental justice impact of

continued operation of the plant would be SMALL. Continued operation of the plant would

not have a disproportionately high and adverse impact on minority and low-income

populations. Shutdown of the plant could have disproportionately high and adverse impacts

on minority and low-income populations because of the loss of employment opportunities at

the site and because of secondary socioeconomic impacts (e.g., loss of patronage at local

businesses). The NRC staff concludes that the environmental justice impacts of plant

shutdown could range from SMALL to LARGE. Some of these impacts could be offset if

new power-generating facilities are built at or near the current site. See Appendix J to

NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of these impacts.

8.2 Alternative Energy Sources

This section discusses the environmental impacts associated with alternative sources of electric

power to replace the power generated by Palisades, assuming that the OL for Palisades is not

renewed. The order of presentation of alternative energy sources in Section 8.2 does not imply

which alternative would be most likely to occur or to have the least environmental impacts. The

following generation alternatives are considered in detail:
Alternatives

October 2006 8-7 NUREG-1437, Supplement 27

 C Coal-fired generation at an alternate site (Section 8.2.1),

 C Natural-gas-fired generation at the Palisades site and an alternate site (Section 8.2.2), and

 C Nuclear generation at the Palisades site and an alternate site (Section 8.2.3).

The alternative of purchasing power from other sources to replace power generated at

Palisades is discussed in Section 8.2.4. Other power-generation alternatives and conservation

alternatives considered by the NRC staff and found not to be reasonable replacements for

Palisades are discussed in Section 8.2.5. Section 8.2.6 discusses the environmental impacts of

a combination of generation and conservation alternatives. 

Each year, the Energy Information Administration (EIA), a component of the U.S. Department of

Energy (DOE), issues an Annual Energy Outlook. In its Annual Energy Outlook 2006 with |

Projections to 2030, the EIA projects that more than 57 percent of new electric-generating |

capacity between 2006 and 2030 will be coal-fired plants (EIA 2006). The amount of electricity |

produced by coal-fired plants will rise slowly in the near future but will grow considerably |

compared with other types of plants because of reliability and rising natural gas prices. Natural- |

gas-fired plants accounted for 18 percent of the total supply in 2004, but the EIA predicts that |

their contribution will decline to 17 percent by 2030 (EIA 2006). A slight rise in the percentage |

of natural-gas-fired plants in the near term is predicted because of new, more efficient |

technologies; however, the rising cost of natural gas will eventually reduce this share. |

Renewable fuel technologies, such as wind, solar, and hydropower, provided 9 percent of the |

total electricity consumed in 2004 and this is expected to rise to only 9.4 by 2030 (EIA 2006). |

Of the renewable fuels, hydropower provides the most power at 6.8 percent in 2004 and is |

expected to fall to 5.1 percent in 2030 (EIA 2006). The drop in hydropower is due to the lack of |

new locations for development. The share of power resulting from other renewable sources of |

power is expected to rise from 2.2 in 2004 to 4.3 percent in 2030 because of technological |

advances and State and Federal support (EIA 2006). |

|

Nuclear plants currently provide 20 percent of the power in the United States (EIA 2006). New |

nuclear plants are expected to be built partly due to Energy Policy Act of 2005 tax incentives. |

By 2030, nuclear power is expected to drop to only 15 percent of the total power produced in |

the United States (EIA 2006). Despite that projection, there has been an increased interest in |

constructing new nuclear power facilities, as evidenced by the certification of three standard

nuclear power plant designs and recent activities involving the review of other plant designs and

potential sites (see Section 8.2.3). In addition, the NRC established a new reactor licensing

program organization in 2001 to prepare for and manage future reactor and site licensing

applications (NRC 2001). Furthermore, the Energy Policy Act contains provisions to ensure that |

nuclear energy continues to be a major component of the nation’s energy supply. This Act also |

establishes a production tax credit for new nuclear power facilities. Therefore, despite the EIA |
Alternatives

(a) Heat rate is a measure of generating station thermal efficiency. In English units, it is generally

expressed in British thermal units (Btus) per net kilowatt-hour (kWh). It is computed by dividing the

total Btu content of the fuel burned for electric generation by the resulting kWh generation.

(b) The capacity factor is the ratio of electricity generated, for the period of time considered, to the energy

that could have been generated at continuous full-power operation during the same period.

NUREG-1437, Supplement 27 8-8 October 2006

| projection, a new nuclear plant alternative for replacing power generated by Palisades is

| considered in this SEIS.

Palisades has a net summer capacity of 786 megawatts electric (MW(e)) (NMC 2005). For the

coal-fired and natural gas alternatives, the NRC staff assumed construction of an approximately

800-MW(e) plant, which is consistent with NMC’s Environmental Report (ER) (NMC 2005). For

the new nuclear alternative, the staff assumed the same capacity as Palisades.

The Palisades site does not have sufficient land suitable for siting a coal-fired plant; thus, only

an alternate site is considered under this alternative. Approximately 30 ac is available in the

northeast quadrant of the Palisades site, which could be developed to house a gas-fired plant;

therefore, both the Palisades site and an alternate site are evaluated under the gas-fired

alternative. No specific alternate sites were identified by the applicant in the ER for the coalfired or gas-fired plants; however, it was assumed that a suitable location could be found in the

region (NMC 2005). A new nuclear alternative was not considered by the applicant. Therefore,

| this SEIS evaluates both the Palisades site and an alternate generic site for the analysis of

environmental impacts for the nuclear alternative.

8.2.1 Coal-Fired Generation

The coal-fired alternative is analyzed for a generic alternate site. Unless otherwise indicated,

the assumptions and numerical values used in Section 8.2.1 are from the NMC ER (NMC 2005). 

The staff reviewed the information in the NMC ER and compared it with environmental impact

information in the GEIS for license renewal. Although the OL renewal period is only 20 years,

the impact of operating the coal-fired alternative for 40 years is considered (as a reasonable

projection of the operating life of a coal-fired plant). The NRC staff assumed the Palisades plant

would remain in operation while the alternative coal-fired plant was constructed.

The NRC staff assumed the construction of two standard 400-MW(e) units for a total capacity of

800 MW(e), as potential replacements for Palisades, which is consistent with the NMC ER

(NMC 2005). The coal-fired plant would consume approximately 3.2 million tons per year of

pulverized bituminous coal with an ash content of approximately 7.66 percent (NMC 2005). 

NMC assumes a heat rate(a) of 9800 Btu/kWh and a capacity factor(b) of 0.85 in its ER

(NMC 2005). 
Alternatives

October 2006 8-9 NUREG-1437, Supplement 27

In addition to the impacts discussed below for a coal-fired plant at an alternate site, impacts

would occur offsite as a result of the mining of coal and limestone. Impacts of mining

operations would include an increase in fugitive dust emissions; surface-water runoff; erosion;

sedimentation; changes in water quality; disturbance of vegetation and wildlife; disturbance of

historic and archaeological resources; changes in land use; and impacts on employment.

The magnitude of these offsite impacts would largely be proportional to the amount of land

affected by mining operations. In the GEIS, the staff estimated that approximately 22,000 ac

would be affected for mining the coal and disposing of the waste to support a 1000-MW(e) coal- |

fired plant during its operational life (NRC 1996). Proportionally, less land would be affected

with the construction of an 800-MW(e) plant. Partially offsetting this offsite land use would be

the elimination of the need for uranium mining to supply fuel for Palisades. In the GEIS, the

NRC staff estimated that approximately 1000 ac would be affected for mining the uranium and

processing it during the operating life of a nuclear power plant.

8.2.1.1 Closed-Cycle Cooling System

In this section, the NRC staff evaluates the impacts of a coal-fired plant located at a generic

alternate site that uses a closed-cycle cooling system. 

The overall impacts of the coal-fired generating system are discussed in the following sections

and summarized in Table 8-2. The magnitude of impacts for an alternate site would depend on

the particular site selected.

 C Land Use

The GEIS estimates that approximately 1700 ac would be needed for a 1000-MW(e) coalfired plant (NRC 1996). This estimate would be scaled down for the 800-MW(e) capacity of

the proposed coal-fired alternative (i.e., 1360 ac). Additional land might be needed for

transmission lines and rail lines, depending on the location of the site relative to the nearest

intertie connection and rail spur. 

Up to 160 ac could be needed for a rail spur if the alternative site is within 10 mi of the

nearest railway connection. Additional land would likely be needed for a transmission line to

connect to existing lines to transmit power to NMC customers in the area. NMC estimated

that approximately 5 mi of a new 345-kV transmission line would be needed (NMC 2005).
Alternatives

NUREG-1437, Supplement 27 8-10 October 2006

Table 8-2. Summary of Environmental Impacts of Coal-Fired Generation Using Closed-Cycle 

 Cooling at an Alternate Site 

Impact

Category Impact Comments

Land use MODERATE

to LARGE

Uses approximately 1460 ac for plant, offices, parking, and waste

disposal. Additional land (amount dependent on site chosen) needed

for rail spur and transmission line.

Ecology MODERATE

to LARGE

Impact would depend on location and ecology of the site, surfacewater body used for intake and discharge, and transmission line and

rail spur routes; potential habitat loss and fragmentation; reduced

productivity and biological diversity. 

Water use and

| quality – surface

water

SMALL to

MODERATE

Impact would depend on the volume of water withdrawn and

discharged and the characteristics of the surface-water body.

Water use and

| quality –

groundwater

SMALL to

MODERATE

Impact would depend on the volume of water withdrawn and

discharged and the characteristics of the aquifers. 

Air quality MODERATE Sulfur oxides

 C 2750 tons/yr

Nitrogen oxides

 C 690 tons/yr

Particulates

 C 120 tons/yr of total suspended particulates

 C 28 tons/yr of PM10

Carbon monoxide

 C 800 tons/yr

Small amounts of mercury and other hazardous air pollutants and

naturally occurring radioactive materials – mainly uranium and

thorium.

Waste MODERATE Total waste volume would be approximately 319,000 tons/yr of ash

and scrubber sludge, requiring approximately 100 ac for disposal

during the 40-year life of the plant. Debris would be generated and

removed during construction.

Human health SMALL Impacts are uncertain, but considered SMALL in the absence of more

quantitative data.
Alternatives

October 2006 8-11 NUREG-1437, Supplement 27

Table 8-2. (contd)

Impact

Category Impact Comments

Socioeconomics SMALL to

LARGE 

Construction impacts depend on location, but could be LARGE if plant

is located in an area that is rural. Up to 1500 workers during the peak

period of the 5-year construction period. Operation would result in a

workforce of 75 to 120 full-time employees, which is a net loss of

approximately 500 jobs. Van Buren County’s tax base would

experience a loss and an additional reduction in employment if the

alternate site is not located within the county. Employment impacts

could be offset by other economic growth in the area.

Transportation SMALL to

LARGE

Transportation impacts associated with construction workers could be

MODERATE to LARGE.

Transportation impacts related to commuting of plant operating

personnel would also be site dependent, but can be characterized as

SMALL to MODERATE.

For rail transportation of coal and lime, the impact is considered

MODERATE to LARGE.

Aesthetics MODERATE

to LARGE

Aesthetic impacts due to the presence of plant units, cooling towers,

plume stacks, and coal piles.

Intermittent noise from construction, commuter traffic, and waste

disposal; continuous noise from cooling towers and mechanical

equipment. Rail transportation of coal and lime would result in

MODERATE noise impacts.

Additional impacts would occur from the new transmission line and

rail spur that would be needed. Depending on the location of the site

chosen, these impacts could be LARGE.

Historic and

archaeological |

resources

SMALL to

MODERATE

An alternate location would necessitate cultural resource studies to

identify, evaluate, and mitigate potential impacts of new plant

construction at developed and undeveloped sites.

Environmental

justice

SMALL to

MODERATE 

Impacts would vary depending on population distribution and makeup

at the site. Impacts should be similar to those experienced by the

population as a whole. Some impacts on housing could occur during

construction. Loss of jobs could reduce employment prospects. 

Impacts could be offset by economic growth in the area and the ability

of affected workers to commute to other jobs.
Alternatives

(a) Only half of the land area needed for by-product disposal is directly attributable to the alternative of

renewing the Palisades OL for 20 years. 

NUREG-1437, Supplement 27 8-12 October 2006

The waste would be disposed of onsite, accounting for approximately 100 ac of land area

over the 40-year plant life.(a)

Depending particularly on the location and length of the transmission line and rail line

routing, this alternative would result in MODERATE to LARGE land-use impacts.

 C Ecology

Locating a coal-fired plant at an alternate site would result in construction and operational

impacts. Approximately 1460 ac of land would be converted to industrial use. Even

assuming siting at a previously disturbed area, the impacts would affect ecological

resources. Impacts could include wildlife habitat loss, reduced productivity, habitat

fragmentation, and a local reduction in biological diversity. Use of cooling makeup water

from a nearby surface-water body could cause entrainment and impingement of fish and

other aquatic organisms, and result in adverse impacts on aquatic resources. If needed,

construction and maintenance of an electric power transmission line and a rail spur also

would have ecological impacts. There would be some additional impact on terrestrial

ecology from drift from the cooling towers. Overall, the ecological impacts of constructing a

coal-fired plant with a closed-cycle cooling system at an alternate site are considered to be

MODERATE to LARGE and would be greater than renewal of the Palisades OL.

 C Water Use and Quality

| Surface water. The coal-fired generation alternative at an alternate site is assumed to use a

closed-cycle cooling system with cooling towers. For alternate sites, the impact on the

surface water would depend on the volume of water needed for makeup water, the

discharge volume, and the characteristics of the receiving body of water. Intake from and

discharge to any surface body of water would be regulated by the State of Michigan. The

impacts would be SMALL to MODERATE and dependent on the receiving body of water.

Groundwater. Groundwater use is possible for a coal-fired plant at an alternate site if

surface-water resources are limited for makeup and potable water. Groundwater withdrawal

could require a permit. Impacts on groundwater use and quality of a coal-fired plant with a

closed-cycle cooling system at an alternate site would be SMALL to MODERATE,

depending on the volume of groundwater withdrawn.
Alternatives

October 2006 8-13 NUREG-1437, Supplement 27

 C Air Quality

The air quality impacts of coal-fired generation vary considerably from those of nuclear

generation due to emissions of sulfur oxides (SOx), nitrogen oxides (NOx), particulate matter,

carbon monoxide (CO), hazardous air pollutants such as mercury, and naturally occurring

radioactive materials.

A new coal-fired generating plant located in southern Michigan would likely need a

prevention of significant deterioration (PSD) permit and an operating permit under the Clean

Air Act. The plant would need to comply with the new source performance standards for

such plants as set forth in 40 CFR Part 60, Subpart D(a). The standards establish limits for

particulate matter and opacity (40 CFR 60.42(a)), sulfur dioxide (SO2) (40 CFR 60.43(a)),

and NOx (40 CFR 60.44(a)).

The U.S. Environmental Protection Agency (EPA) has various regulatory requirements for

visibility protection in 40 CFR Part 51, Subpart P, including a specific requirement for review

of any new major stationary source in an area designated as attainment or unclassified

under the Clean Air Act. All of Michigan has been classified as attainment or unclassified for

criteria pollutants (40 CFR 81.323). In the posted amendment to that classification, dated

April 30, 2004, there are several instances of nonattainment for ozone, including one for

Van Buren County (EPA 2004a).

Section 169A of the Clean Air Act establishes a national goal of preventing future and

remedying existing impairment of visibility in mandatory Class I Federal areas when

impairment results from man-made air pollution. The EPA issued a new regional haze rule

in 1999 (EPA 1999). The rule specifies that for each mandatory Class I Federal area |

located within a state, the state must establish goals that provide for reasonable progress

toward achieving natural visibility conditions. The reasonable progress goals must provide

for an improvement in visibility for the most-impaired days over the period of the

implementation plan and ensure no degradation in visibility for the least-impaired days over

the same period (40 CFR 51.308(d)(1)). If a coal-fired plant were located close to a

mandatory Class I area, additional air pollution control requirements could be imposed. Isle

Royale National Park and Seney National Wildlife Refuge are Class I areas where visibility

is an important value (40 CFR 81.407). Both of these areas are located in the Upper

Peninsula of Michigan. Air quality in these areas would not likely be affected by a coal-fired

plant at an alternate site in southern Michigan in the vicinity of Palisades. 

In 1998, the EPA issued a rule requiring 22 eastern states, including Michigan, to revise

their state implementation plans to reduce NOx emissions. Nitrogen oxide emissions

contribute to violations of the national ambient air quality standard for ozone (40 CFR 50.9). 
Alternatives

NUREG-1437, Supplement 27 8-14 October 2006

The total amount of NOx that can be emitted by each of the 22 states in the year 2007 ozone

season (May 1 to September 30) is presented in 40 CFR 51.121(e). For Michigan, the

amount is 229,702 tons.

Anticipated impacts for particular pollutants that would result from a coal-fired plant at an

alternate site are as follows:

Sulfur oxides. A new coal-fired power plant would be subject to the requirements in Title IV

of the Clean Air Act. Title IV was enacted to reduce SO2 and NOx emissions, the two

principal precursors of acid rain, by restricting emissions of these pollutants from power

plants. Title IV caps aggregate annual power plant SO2 emissions and imposes controls on

SO2 emissions through a system of marketable allowances. The EPA issues one allowance

for each ton of SO2 that a unit is allowed to emit. New units do not receive allowances but

are required to have allowances to cover their SO2 emissions. Owners of new units must

therefore acquire allowances from owners of other power plants by purchase or reduce SO2

emissions at other power plants they own. Allowances can be banked for use in future

years. Thus, a new coal-fired power plant would not add to net regional SO2 emissions,

although it might do so locally. Regardless, SO2 emissions would be greater for the coal

alternative than the OL renewal alternative.

NMC estimates that by using wet limestone flue gas desulfurization to minimize SOx

emissions (90 percent removal), the total annual stack emissions would be approximately

2750 tons of SOx (NMC 2005).

Nitrogen oxides. Section 407 of the Clean Air Act establishes technology-based emission

limitations for NOx emissions. The market-based allowance system used for SO2 emissions

is not used for NOx emissions. A new coal-fired power plant would be subject to the new

source performance standards for such plants at 40 CFR 60.44a(d)(1). This regulation,

| issued on September 16, 1998 (EPA 1998), limits the discharge of any gases that contain

NOx (expressed as NO2) in excess of 200 ng/J of gross energy output (1.6 lb/MWh), based

on a 30-day rolling average.

NMC estimates that by using NOx burners with overfire air and selective catalytic reduction

(SCR) (95 percent reduction), the total annual NOx emissions for a new coal-fired power

plant would be approximately 690 tons (NMC 2005). This level of NOx emissions would be

greater than the Palisades OL renewal alternative.

Particulate matter. NMC estimates that the total annual stack emissions would include

120 tons of filterable total suspended particulates and 28 tons of particulate matter having

an aerodynamic diameter less than or equal to 10 :m (PM10) (40 CFR 50.6). Fabric filters

(99.9 percent removal) would be used for control. In addition, coal-handling equipment

would introduce fugitive particulate emissions. Particulate emissions would be greater

under the coal alternative than under the Palisades OL renewal alternative.
Alternatives

October 2006 8-15 NUREG-1437, Supplement 27

During the construction of a coal-fired plant, fugitive dust would be generated. In addition,

exhaust emissions would come from vehicles and motorized equipment used during the

construction process.

Carbon monoxide. NMC estimates that the total CO emissions would be approximately

800 tons per year (NMC 2005). This level of emissions is greater than that under the

Palisades OL renewal alternative.

Hazardous air pollutants, including mercury. In December 2000, the EPA issued regulatory

findings on emissions of hazardous air pollutants from electric utility steam-generating units

(EPA 2000a). The EPA determined that coal- and oil-fired electric utility steam-generating

units are significant emitters of hazardous air pollutants. The EPA found that coal-fired

power plants emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen chloride,

hydrogen fluoride, lead, manganese, and mercury (EPA 2000a). The EPA concluded that

mercury is the hazardous air pollutant of greatest concern. The EPA found that (1) there is

a link between coal consumption and mercury emissions; (2) electric utility steam-generating

units are the largest domestic source of mercury emissions; and (3) certain segments of the

U.S. population (e.g., the developing fetus and subsistence fish-eating populations) are

believed to be at potential risk of adverse health effects due to mercury exposures resulting

from consumption of contaminated fish (EPA 2000a). Accordingly, on March 15, 2005, the

EPA issued the Clean Air Mercury Rule to permanently cap and reduce mercury emissions

from coal-fired power plants (EPA 2005).

Uranium and thorium. Coal contains uranium and thorium. Uranium concentrations are

generally in the range of 1 to 10 parts per million. Thorium concentrations are generally

about 2.5 times greater than uranium concentrations (Gabbard 1993). One estimate is that

a typical coal-fired plant released roughly 5.2 tons of uranium and 12.8 tons of thorium in

1982 (Gabbard 1993). The population dose equivalent from the uranium and thorium

releases and daughter products produced by the decay of these isotopes has been

calculated to be significantly higher than that from nuclear power plants (Gabbard 1993).

Carbon dioxide. A coal-fired plant would also have unregulated carbon dioxide emissions

that could contribute to global warming. The level of emissions from a coal-fired plant would

be greater than that under the OL renewal alternative.

Summary. The GEIS analysis did not quantify emissions from coal-fired power plants, but

implied that air impacts would be substantial. The GEIS also mentioned global warming

from unregulated carbon dioxide emissions and acid rain from SOx and NOx emissions as

potential impacts (NRC 1996). Adverse human health effects, such as cancer and

emphysema, have been associated with the products of coal combustion. The appropriate

characterization of air impacts from coal-fired generation at an alternate site would be

MODERATE. The impacts would be clearly noticeable but would not destabilize air quality.
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NUREG-1437, Supplement 27 8-16 October 2006

 C Waste

Debris would be generated during construction activities. During operations, coal

combustion generates waste in the form of ash, and equipment for controlling air pollution

generates additional ash and scrubber sludge. Two 400-MW(e) coal-fired plants would

generate approximately 319,000 tons of this waste annually for 40 years (NMC 2005). The

ash and scrubber sludge would be disposed of onsite, accounting for approximately 100 ac

of land area over the 40-year plant life. Waste impacts on groundwater and surface water

could extend beyond the operating life of the plant if leachate and runoff from the waste

storage area occurs. Disposal of the waste could noticeably affect land use and

groundwater quality; however, with appropriate management and monitoring, it would not

destabilize any resources. After closure of the waste site and revegetation, the land could

be available for other uses. 

In May 2000, the EPA issued a “Notice of Regulatory Determination on Wastes from the

Combustion of Fossil Fuels” (EPA 2000b). The EPA concluded that some form of national

regulation is warranted to address coal combustion waste products because: (a) the

composition of these wastes could present danger to human health and the environment

under certain conditions; (b) the EPA has identified 11 documented cases of proven

damages to human health and the environment by improper management of these wastes in

landfills and surface impoundments; (c) present disposal practices are such that, in 1995,

these wastes were being managed in 40 to 70 percent of landfills and surface

impoundments without reasonable controls in place, particularly in the area of groundwater

monitoring; and (d) the EPA identified gaps in State oversight of coal combustion wastes. 

Accordingly, the EPA announced its intention to issue regulations for disposal of coal

| combustion waste under Subtitle D of the Resource Conservation and Recovery Act of

| 1976.

For all of the preceding reasons, the appropriate characterization of impacts from waste

generated from burning coal is MODERATE; the impacts would be clearly noticeable but

would not destabilize any important resource.

 C Human Health

Coal-fired power generation introduces worker risks from fuel and limestone mining, from

fuel and lime/limestone transportation, and from disposal of coal combustion waste. In

addition, there are public risks from inhalation of stack emissions. Emission impacts can be

widespread and health risks difficult to quantify. The coal alternative also introduces the risk

of coal-pile fires and attendant inhalation risks.

In the GEIS, the NRC staff stated that there could be human health impacts (cancer and

emphysema) from inhalation of toxins and particulates, but it did not identify the significance

of these impacts (NRC 1996). In addition, the discharges of uranium and thorium from coal-
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October 2006 8-17 NUREG-1437, Supplement 27

fired plants can potentially produce radiological doses in excess of those arising from

nuclear power plant operations (Gabbard 1993). 

Regulatory agencies, including the EPA and state agencies, set air emission standards and

requirements based on human health impacts. These agencies also impose site-specific

emission limits as needed to protect human health. As discussed previously, the EPA has

recently concluded that certain segments of the U.S. population (e.g., the developing fetus

and subsistence fish-eating populations) are believed to be at potential risk of adverse

health effects due to mercury exposures from sources such as coal-fired power plants. 

However, in the absence of more quantitative data, human health impacts from radiological

doses and inhaling toxins and particulates generated by burning coal are characterized as

SMALL.

 C Socioeconomics

Construction of a coal-fired plant would take approximately 5 years. The NRC staff |

assumed that construction would take place while Palisades continues operation and would

be completed by the time Palisades permanently ceases operations. The workforce would

be expected to vary between 600 and 1500 workers during the 5-year construction period

(NRC 1996). These workers would be in addition to the approximately 644 workers

employed at Palisades (534 permanent employees and 110 contractors as of the writing of

the ER; NMC 2005). During construction, the surrounding communities would experience

demands on housing and public services that could have MODERATE impacts. These

impacts would be tempered by construction workers commuting to the site from other parts

of Van Buren and Berrien Counties or from other counties in the Kalamazoo area. After

construction, the communities would be impacted by the loss of the construction jobs,

although this loss would be possibly offset by other growth currently being projected for the

Kalamazoo area.

Construction of a replacement coal-fired power plant at an alternate site would impact the

communities around Palisades as they would experience the impact of operational job loss. |

The communities around the new site would have to absorb the impacts of a large,

temporary workforce (up to 1500 workers at the peak of construction) and a permanent

workforce of approximately 75 to 120 workers. In the GEIS, the NRC staff stated that |

socioeconomic impacts at a rural site would be larger than at an urban site, because more

of the peak construction workforce would need to move to the area to work. Alternate sites

would need to be analyzed on a case-by-case basis, and socioeconomic impacts could

range from SMALL to LARGE.
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NUREG-1437, Supplement 27 8-18 October 2006

 C Transportation

During the 5-year construction period of replacement coal-fired units, up to

1500 construction workers would be working at the site. The addition of these workers

could affect traffic loads on existing highways. Transportation-related impacts associated

with commuting construction workers at an alternate site are site dependent, but could be

MODERATE to LARGE. Transportation impacts related to commuting of plant operating

personnel would also be site dependent, but can be characterized as SMALL to

MODERATE.

At an alternate site, coal and lime would likely be delivered by rail. Transportation impacts

would depend upon the site location. Socioeconomic impacts associated with rail

transportation would likely be MODERATE to LARGE.

 C Aesthetics

The two coal-fired power plant units could be as much as 200 ft tall with cooling towers,

stacks, and coal piles visible in daylight hours. The exhaust stacks could be as much as

650 ft high. The units and associated stacks would also be visible at night because of

outside lighting. Visual impacts of a new coal-fired plant could be mitigated by landscaping

and color selection for buildings that is consistent with the environment. Visual impact at

night could be mitigated by reduced use of lighting, providing that the lighting meets Federal

Aviation Administration requirements (FAA 2000), and appropriate use of shielding. There

could be a significant impact if construction of a new transmission line and/or rail spur is

needed. Overall, the addition of a coal-fired plant and the associated stacks at an alternate

site would likely have a MODERATE aesthetic impact.

| Coal-fired plant generation would introduce mechanical sources of noise that would be

audible offsite. Sources contributing to total noise produced by plant operation are classified

as continuous or intermittent. Continuous sources include the mechanical equipment

associated with normal plant operations, such as cooling towers. Intermittent sources

include the equipment related to coal handling, solid-waste disposal, transportation related

to coal and lime delivery, use of outside loudspeakers, and the commuting of plant

employees. These impacts are considered to be MODERATE.

Noise impacts associated with rail delivery of coal and lime to a plant at an alternate site

would be most significant for residents living in the vicinity of the facility and along the rail

route. Although noise from passing trains significantly raises noise levels near the rail

corridor, the short duration of the noise reduces the impact. Nevertheless, given the

frequency of train transport and the many residents likely to be within hearing distance of the

rail route, the impacts of noise on residents in the vicinity of the facility and the rail line are

considered MODERATE.
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October 2006 8-19 NUREG-1437, Supplement 27

Aesthetic impacts associated with the construction and presence of the new transmission

line and rail spur could be LARGE, depending on the location of the site chosen. Overall,

the aesthetic impacts associated with locating a coal-fired plant at an alternate site can be

categorized as MODERATE to LARGE. 

 C Historic and Archaeological Resources

Before construction or any ground disturbance at an alternate site, studies would likely be

needed to identify, evaluate, and address mitigation of the potential impacts of new plant

construction on historic and archaeological resources. The studies would likely be needed

for all areas of potential disturbance at the proposed plant site and along associated

corridors where new construction would occur (e.g., roads, transmission corridors, rail lines,

or other rights-of-way). Other lands, if any, that are acquired to support the plant would also

likely need an inventory of cultural resources to identify and evaluate existing historic and

archaeological resources and possible mitigation of adverse effects from subsequent

ground-disturbing actions related to physical expansion of the plant site.

Historic and archaeological resources must be evaluated on a site-specific basis. The

impacts can generally be effectively managed under current laws and regulations, and as

such, the categorization of impacts could range from SMALL to MODERATE, depending on

what resources are present, and whether mitigation is necessary.

 C Environmental Justice

Environmental justice impacts would depend upon the site chosen and the nearby

population distribution. Construction activities would offer new employment possibilities.

This could affect housing availability and prices during construction, which could

disproportionately affect minority and low-income populations. The closure of Palisades

would result in a decrease in employment of approximately 644 operating employees. 

However, these projected job losses could be offset by economic growth in the Kalamazoo

area. Overall, environmental justice impacts would range from SMALL to MODERATE.

8.2.1.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a coal-fired generation system

using once-through cooling at an alternate site. The impacts (SMALL, MODERATE, or LARGE)

of this option are the same as the impacts for a coal-fired plant using the closed-cycle system. 

However, there are minor environmental differences between the closed-cycle and oncethrough cooling systems. Table 8.3 summarizes the incremental differences. However, the

design and operation of the intake would need to comply with Phase II performance standards |

of the EPA’s 316(b) regulations to minimize adverse impacts associated with water withdrawal,

and heated discharges would need to comply with 316(a) regulations.
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NUREG-1437, Supplement 27 8-20 October 2006

Table 8-3. Summary of Environmental Impacts of Coal-Fired Generation Using 

Once-Through Cooling at an Alternate Site

Impact Category

Change in Impacts from

Closed-Cycle Cooling System

Land use Impacts may be less (e.g., through elimination of cooling

towers) or greater (e.g., if a reservoir is required).

Ecology Impacts would depend on ecology at the site. Possible

impacts associated with entrainment of fish and shellfish in

early life stages, impingement of fish and shellfish, and heat

shock. No impact on terrestrial ecology from cooling-tower

drift.

| Water use and quality – surface water Increased water withdrawal leading to possible water-use

conflicts; thermal load higher on receiving body of water

than with closed-cycle cooling; no discharge of coolingtower blowdown.

| Water use and quality – groundwater No change

Air quality No change

Waste No change

Human health No change

Socioeconomics No change

Transportation No change

Aesthetics Less aesthetic impact because cooling towers would not be

used.

Historic and archaeological resources No change

Environmental justice No change

8.2.2 Natural-Gas-Fired Generation

The environmental impacts of the natural-gas-fired generation alternative are examined in this

section for both the Palisades site and an alternate site. The NRC staff assumed that the plant

would use a closed-cycle cooling system (Section 8.2.2.1). In Section 8.2.2.2, the staff also

evaluated the impacts of an open-cycle cooling system at an alternate site.
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October 2006 8-21 NUREG-1437, Supplement 27

The existing switchyard, offices, and transmission lines would be used for the gas-fired

alternative at the Palisades site. For purposes of analysis, NMC estimates that approximately

5 mi of buried gas supply pipeline would need to be constructed (NMC 2005).

If a new natural-gas-fired plant were built at an alternate site in southern Michigan to replace

Palisades, construction of a new natural gas supply pipeline and a new transmission line would

be needed. NMC estimated 5 mi of new gas pipeline would be needed and approximately 10 mi

of new 345-kV transmission line (NMC 2005). In the GEIS, the NRC staff estimated disturbance

of up to 2500 ac for construction of a 60-mi transmission line to an alternate greenfield site

(NRC 1996).

The NRC staff assumed that a replacement natural-gas-fired plant would use combined-cycle

technology (NMC 2005). In a combined-cycle unit, hot combustion gases in a combustion

turbine rotate the turbine to generate electricity. Waste combustion heat from the combustion

turbine is routed through a heat-recovery boiler to make steam to generate additional electricity.

NMC assumed two standard-sized units – a 530-MW(e) unit and a 263-MW(e) unit – with a total

capacity of 793 MW(e), as the gas-fired alternative at Palisades (NMC 2005). This capacity is

approximately equivalent to the Palisades total net capacity of 786 MW(e). NMC estimates that

the plant would consume approximately 38.4 billion ft3

 of gas annually (NMC 2005).

Unless otherwise indicated, the assumptions and numerical values used in Section 8.2.2 are

from the NMC ER (NMC 2005). The NRC staff reviewed this information and compared it with

environmental impact information in the GEIS. Although the OL renewal period is only 20 years,

the impact of operating a natural-gas-fired plant for 40 years is considered (as a reasonable |

projection of the operating life of a natural-gas-fired plant).

8.2.2.1 Closed-Cycle Cooling System

The overall impacts of the natural-gas-generating system are discussed in the following

sections and summarized in Table 8-4. The extent of impacts at an alternate site would depend |

on the location of the particular site selected.
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NUREG-1437, Supplement 27 8-22 October 2006

Table 8-4. Summary of Environmental Impacts of Natural-Gas-Fired Generation Using

Closed-Cycle Cooling at the Palisades Site and at an Alternate Site

| Palisades Site Alternate Site

Impact

Category Impact Comments Impact Comments

Land use MODERATE to

LARGE

Uses approximately 30 ac for

power block, cooling towers,

roads, and parking areas. 

Additional impact of up to

approximately 120 ac for

construction of 5 mi of

underground gas pipeline.

MODERATE

to LARGE

Uses approximately 87 ac

for power block, cooling

towers, offices, roads, and

parking areas. Additional 

land needed for new

transmission line (amount

dependent on site chosen)

and for construction and/or

upgrade of an underground

gas pipeline.

Ecology MODERATE to

LARGE

Uses undeveloped areas at

current Palisades site, plus

construction of a gas pipeline.

Impacts on terrestrial ecology

from cooling-tower drift are

expected.

MODERATE

to LARGE

| Impacts depend on the

location and ecology of the

site, surface-water body

used for intake and discharge, and transmission

and pipeline routes; potential habitat loss and fragmentation; reduced productivity and biological

diversity. 

Water use and

| quality – surface

water

SMALL Discharge of cooling tower

blowdown containing increased

dissolved solids and intermittent

low concentrations of biocides

would be released to Lake

Michigan. Temporary erosion

and sedimentation could occur

in streams crossed by rights-ofway during pipeline

construction.

SMALL to

MODERATE

Impacts depend on volume

of water withdrawn and

discharged and

characteristics of surfacewater body. Discharge of

cooling-tower blowdown

containing increased

dissolved solids and

intermittent low

concentrations of biocides

would be released to

surface water. Temporary

erosion and sedimentation

could occur in streams

crossed by rights-of-way

during pipeline

construction.
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October 2006 8-23 NUREG-1437, Supplement 27

Table 8-4. (contd)

Palisades Site Alternate Site |

Impact

Category Impact Comments Impact Comments

Water use and

quality – |

groundwater

SMALL Use of groundwater limited to

grounds maintenance.

Adequate surface water

available from Lake Michigan.

SMALL to

MODERATE

Impacts depend on location

of site, volume of water

withdrawn and discharged,

and characteristics of the

aquifer.

Air quality MODERATE Sulfur oxides

 C 12 tons/yr

Nitrogen oxides

 C 190 tons/yr

Carbon monoxide

 C 292 tons/yr

PM10 particulates

 C 37 tons/yr

Some hazardous air pollutants. 

MODERATE Same emissions as

Palisades site, although

pollution control standards

may vary depending on

location.

Waste SMALL Minimal waste from fuel

production. Debris would be

generated and removed during

construction.

SMALL Same waste produced as if

produced at the Palisades

site. Waste disposal

constraints may vary.

Human health SMALL Human health risks associated

with gas-fired plants may result

from NOx emissions, which are

regulated. Impacts are

expected to be SMALL.

SMALL Same impacts as the

Palisades site.

Socioeconomics SMALL to

MODERATE

During construction, impacts

would be MODERATE. Up to

420 additional workers during

the peak of the 3-year construction period, followed by a reduction of the current Palisades

workforce from 644 to 30. Van

Buren County would experience

reduced demand on

socioeconomic resources as

well as a loss in its tax base

and employment, but potentially |

offset by projected economic

growth in the area. Impacts

during operation would be

SMALL.

SMALL to

MODERATE

During construction,

impacts would be

MODERATE. Up to

420 additional workers

during the peak of the

3-year construction period. 

Van Buren County would

experience a loss in its tax

base and employment,

potentially offset by

projected economic growth

in the area.
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NUREG-1437, Supplement 27 8-24 October 2006

Table 8-4. (contd)

| Palisades Site Alternate Site

Impact

Category Impact Comments Impact Comments

Transportation SMALL to

MODERATE

Transportation impacts

associated with construction

workers would be MODERATE

as 644 Palisades workers and

420 construction workers would

be commuting to the site.

Impacts during operation would

be SMALL as the workforce

would be reduced to

30 commuters.

SMALL to

MODERATE

Transportation impacts

associated with

420 construction workers

and 30 plant workers would

be MODERATE and

SMALL, respectively.

Aesthetics MODERATE MODERATE aesthetic impacts

due to impact of plant units,

exhaust stacks, and gas

compressors. 

Intermittent noise from

construction and continuous

noise from cooling towers and

mechanical equipment would

result in MODERATE impacts.

MODERATE

to LARGE

Impacts would be similar to

the Palisades site with

additional impact from the

new 345-kV transmission

line that would be needed.

Historic and

| archaeological

resources

SMALL to

MODERATE

Some construction would affect

previously developed parts of

the Palisades site; a cultural

resource inventory would be

needed to identify, evaluate,

and mitigate potential impacts

of new plant construction on

cultural resources in

undeveloped areas. 

SMALL to

MODERATE

Cultural resource studies

would be needed to

identify, evaluate, and

mitigate potential impacts

of new plant construction at

developed and

undeveloped sites.

Environmental

justice

SMALL to

MODERATE

Impacts on minority and lowincome communities should be

similar to those experienced by

the population as a whole.

Some impacts on housing may

occur during construction; loss

of 614 operating jobs at

Palisades could reduce employment prospects for minority and

low-income populations. 

Impacts could be offset by

projected economic growth and

ability of affected workers to

commute to other jobs.

SMALL to

MODERATE 

Impacts would vary

depending on population

distribution and makeup at

site.
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October 2006 8-25 NUREG-1437, Supplement 27

In addition to the impacts discussed below for a gas-fired plant at either the Palisades site or at

an alternate site, impacts would occur offsite as a result of gas production and transportation. 

Impacts of production operations would include an increase in fugitive dust emissions,

surface-water runoff, erosion, and sedimentation; changes in water quality; disturbance of |

vegetation and wildlife; disturbance of historic and archaeological resources; changes in land

use; and impacts on employment. The magnitude of these offsite impacts would largely be

proportional to the amount of land affected by the production and distribution. 

 C Land Use

For siting at Palisades, existing facilities and infrastructure would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

staff assumed that the natural-gas-fired replacement plant alternative would use the

switchyard, offices, and transmission lines. Much of the land that would be used has been

previously disturbed. At Palisades, the staff assumed that approximately 30 ac would be

needed for the plant and associated infrastructure. There would be an additional impact of

up to approximately 120 ac for construction of a gas pipeline. Approximately 30 ac of

undeveloped land at the Palisades site is available in the northeastern portion of the site. 

However, there would be insufficient buffer available between the plant and Van Buren State

Park (adjacent to the Palisades site to the north).

For construction at an alternate site, the NRC staff assumed in the GEIS that 110 ac would

be needed for a 1000-MW(e) plant and associated infrastructure (NRC 1996). This estimate

would be scaled down for the 793-MW(e) capacity of the proposed gas-fired alternative

(i.e., 87 ac). The additional amount of land impacted by the construction of a new

transmission line and a gas pipeline is dependent on the site location chosen. The NRC

staff assumed in the GEIS that approximately 2500 ac would be impacted for construction of

a 60-mi transmission line (NRC 1996), although NMC estimates only 10 mi of transmission

line might be needed. In addition, approximately 120 ac could be disturbed during

construction and/or upgrade of an underground pipeline, assuming an alternate site would

be located within 5 mi of a gas pipeline connection. 

Regardless of where a gas-fired plant is built, additional land (approximately 3600 ac) would |

be required for natural gas wells and collection stations (NRC 1996). Partially offsetting

these offsite land requirements would be the elimination of the need for uranium mining to

supply fuel for Palisades. In the GEIS (NRC 1996), the NRC staff estimated that

approximately 1000 ac would be affected for mining the uranium and processing it during

the operating life of a nuclear power plant. Overall, land-use impacts would be MODERATE

to LARGE.

 
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NUREG-1437, Supplement 27 8-26 October 2006

C Ecology

At the Palisades site, there would be ecological impacts related to possible habitat loss and

to cooling-tower drift associated with siting of the gas-fired plant. There would also be

ecological impacts associated with bringing a new underground gas pipeline to the

Palisades site. Impacts due to habitat loss could be reduced through the use of previously

impacted land. Ecological impacts at an alternate site would depend on the nature of the

land converted for the plant and the possible need for a new gas pipeline and/or

transmission line. Construction of the transmission line and construction and/or upgrading

of the gas pipeline to serve the plant would be expected to have temporary ecological

impacts. Ecological impacts on the plant site and utility easements could include impacts on

threatened or endangered species, wildlife habitat loss and reduced productivity, habitat

fragmentation, and a local reduction in biological diversity. The cooling makeup water intake

and discharge could have aquatic resource impacts. Overall, the ecological impacts are

considered MODERATE to LARGE at either location.

 C Water Use and Quality

| Surface water. Each of the natural-gas-fired units would include a heat-recovery boiler,

using a portion of the waste heat from the combustion turbines to make steam. The steam

would then turn an electric generator. The net result would be an overall reduction in the

amount of waste heat rejected from the plant, with an associated reduction in the amount of

cooling water required by the plant. Thus, the cooling-water requirements for the naturalgas-fired combined-cycle units would be much less than those for conventional steamelectric generators, including the existing nuclear unit. Plant discharge would consist mostly

of cooling-tower blowdown, with the discharge having a higher temperature and increased

concentration of dissolved solids relative to the receiving body of water and intermittent low

concentrations of biocides (e.g., chlorine). In addition to the cooling-tower blowdown,

treated process waste streams and sanitary wastewater might also be discharged. All

discharges would be regulated by the State of Michigan through a permit. There would be

consumptive use of water due to evaporation from the cooling towers. Construction could

cause temporary erosion and sedimentation in streams crossed by the rights-of-way. 

Overall, the surface-water impacts of the natural-gas-fired alternative at the Palisades site

are considered SMALL. 

A natural-gas-fired plant at an alternate site is assumed to use a closed-cycle cooling

system with cooling towers. The staff assumed that surface water would be used for cooling

makeup water and discharge. Intake and discharge would involve relatively small quantities

of water compared with the coal alternative. The impact on the surface water would depend

on the volume of water needed for makeup water, the discharge volume, and the

characteristics of the receiving body of water. Discharges would be the same as those

described above for the Palisades site. Construction could cause temporary erosion and

sedimentation in streams crossed by the rights-of-way. Intake from and discharge to any
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October 2006 8-27 NUREG-1437, Supplement 27

surface body of water would be regulated by the State of Michigan. The impacts would be

SMALL to MODERATE.

Water-quality impacts from sedimentation during construction were characterized in the

GEIS as SMALL (NRC 1996). The NRC staff also noted in the GEIS that operational waterquality impacts would be similar to, or less than, those from other generating technologies.

Groundwater. Any groundwater withdrawal would require a permit from the local permitting

authority. Impacts on groundwater would depend on the volume and other characteristics of

the source water budget. Use of groundwater at the Palisades site is unlikely because

adequate surface water is available from Lake Michigan. Therefore, groundwater impacts at

the Palisades site would be SMALL. Impacts at an alternate site would be SMALL to

MODERATE depending on site-specific conditions. 

 C Air Quality

Natural gas is a relatively clean-burning fuel. The gas-fired alternative would release similar

types of emissions, but in lesser quantities than the coal-fired alternative.

A new gas-fired generating plant located in Michigan would likely need a PSD permit and an

operating permit under the Clean Air Act. A new combined-cycle natural gas power plant

would also be subject to the new source performance standards for such units at 40 CFR

Part 60, Subparts D(a) and GG. These regulations establish emission limits for particulates,

opacity, SO2, and NOx.

In 1998, the EPA issued a rule requiring 22 eastern states, including Michigan, to revise

their state implementation plans to reduce NOx emissions. Nitrogen oxide emissions

contribute to violations of the national ambient air quality standard (40 CFR 50.9) for ozone. 

The total amount of NOx that can be emitted by each of the 22 states in the 2007 ozone

season (May 1 to September 30) is presented in 40 CFR 51.121(e). For Michigan, the

amount is 229,702 tons.

The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

Subpart P, including a specific requirement for review of any new major stationary source in

an area designated attainment or unclassified under the Clean Air Act. All of Michigan has

been classified as attainment or unclassified for criteria pollutants (40 CFR 81.323). In the

posted amendment to that classification dated April 30, 2004, there are several instances of

nonattainment for ozone, including one for Van Buren County (EPA 2004a).

Section 169A of the Clean Air Act establishes a national goal of preventing future and

remedying existing impairment of visibility in mandatory Class I Federal areas when

impairment results from man-made air pollution. The EPA issued a new regional haze rule
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NUREG-1437, Supplement 27 8-28 October 2006

in 1999 (64 FR 35714; July 1,1999 (EPA 1999)). The rule specifies that for each mandatory

Class I Federal area located within a state, the state must establish goals that provide for

reasonable progress toward achieving natural visibility conditions. The reasonable progress

goals must provide for an improvement in visibility for the most impaired days over the

period of the implementation plan and ensure no degradation in visibility for the leastimpaired days over the same period (40 CFR 51.308(d)(1)). If a natural-gas-fired plant were

located close to a mandatory Class I area, additional air pollution control requirements could

be imposed. Isle Royale National Park and Seney National Wildlife Refuge are Class I

areas where visibility is an important value (40 CFR 81.407). Both of these areas are

located in the Upper Peninsula of Michigan, and air quality in these areas would not likely be

affected by a gas-fired plant at the Palisades site or at an alternate site in southern

Michigan. 

NMC projects the following emissions for the natural gas-fired alternative (NMC 2005):

Sulfur oxides – 12 tons/yr

Nitrogen oxides – 190 tons/yr

Carbon monoxide – 292 tons/yr

PM10 particulates – 37 tons/yr

A natural-gas-fired plant would also have unregulated carbon dioxide emissions that could

contribute to global warming.

In December 2000, the EPA issued regulatory findings on emissions of hazardous air

pollutants from electric utility steam-generating units (EPA 2000a). The EPA found that

natural-gas-fired power plants emit arsenic, formaldehyde, and nickel (EPA 2000a). Unlike

coal- and oil-fired plants, the EPA did not determine that emissions of hazardous air

pollutants from natural-gas-fired power plants should be regulated under Section 112 of the

Clean Air Act.

Construction activities would result in temporary fugitive dust. Exhaust emissions would

also come from vehicles and motorized equipment used during the construction process.

The preceding emissions would likely be the same at Palisades or at an alternate site. 

Impacts from the above emissions would be clearly noticeable but would not be sufficient to

destabilize air resources as a whole. 

Therefore, the overall air quality impact for a new natural-gas-fired plant sited at Palisades

or at an alternate site is considered MODERATE.
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October 2006 8-29 NUREG-1437, Supplement 27

 C Waste

There will be spent SCR catalyst from NOx emissions control and small amounts of solidwaste products (i.e., ash) from burning natural gas fuel. In the GEIS, the NRC staff

concluded that waste generation from gas-fired technology would be minimal (NRC 1996). 

Gas firing results in very few combustion by-products because of the clean nature of the

fuel. Waste-generation impacts would be so minor that they would not noticeably alter any

important resource attribute. Construction-related debris would be generated during

construction activities. 

Overall, the waste impacts would be SMALL for a natural-gas-fired plant sited at Palisades

or at an alternate site.

 C Human Health

In Table 8-2 of the GEIS, the NRC staff identifies cancer and emphysema as potential

health risks from gas-fired plants (NRC 1996). The risk may be attributable to NOx

emissions that contribute to ozone formation, which in turn contribute to health risks. NOx

emissions from any gas-fired plant would be regulated. For a plant sited in Michigan, NOx

emissions would be regulated by the Michigan Department of Environmental Quality

(MDEQ). Human health effects would not be detectable or would be sufficiently minor that

they would neither destabilize nor noticeably alter any important attribute of the resource. 

Overall, the impacts on human health of the natural-gas-fired alternative sited at Palisades

or at an alternate site are considered SMALL.

 C Socioeconomics

Construction of a natural-gas-fired plant would take approximately 3 years. Peak

employment would be approximately 420 workers (NMC 2005). The NRC staff assumed

that construction would take place while Palisades continues operation and would be

completed by the time it permanently ceases operations. During construction, the

communities surrounding the Palisades site would experience demands on housing and

public services that could have MODERATE impacts. These impacts would be tempered by

construction workers commuting to the site from other parts of Van Buren and Berrien

Counties or from other counties. After construction, the communities would be impacted by

the loss of jobs. The current Palisades workforce (approximately 644 workers) would

decline through a decommissioning period to a minimal maintenance size. The gas-fired

plant would introduce a replacement tax base at Palisades or at an alternate site and

approximately 30 new permanent jobs. This would represent a net loss of 614 jobs at the

Palisades site.
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NUREG-1437, Supplement 27 8-30 October 2006

In the GEIS (NRC 1996), the NRC staff concluded that socioeconomic impacts from

constructing a natural-gas-fired plant would not be very noticeable and that the small

operational workforce would have the lowest socioeconomic impacts of any nonrenewable

technology. Compared with the coal-fired and nuclear alternatives, the smaller size of the

construction workforce, the shorter construction time frame, and the smaller size of the

operations workforce would mitigate socioeconomic impacts. The loss of 614 permanent

jobs (up to 644 jobs if an alternate site is not located in Van Buren County) may be partially

tempered by the projected economic growth of the Kalamazoo area. For these reasons,

gas-fired generation socioeconomic impacts associated with construction and operation of a

natural-gas-fired power plant would be SMALL to MODERATE for siting at Palisades or at

an alternate site. Depending on other growth in the area, socioeconomic effects could be

noticed, but they would not destabilize any important socioeconomic attribute.

 C Transportation

Transportation impacts associated with construction and operating personnel commuting to

the plant site would depend on the population density and transportation infrastructure in the

vicinity of the site. The impacts can be classified as SMALL to MODERATE for siting at

Palisades or at an alternate site.

 C Aesthetics

The turbine buildings (approximately 100 ft tall) and exhaust stacks (approximately 125 ft

tall) would be visible during daylight hours from offsite. The gas pipeline compressors would

also be visible. Noise and light from the plant would be detectable offsite. Intermittent noise

from construction and continuous noise from cooling towers and mechanical equipment

would result in MODERATE impacts. Noise impacts would be similar to those described for

the Palisades site. Overall, the aesthetic impacts associated with construction and

operation of a gas-fired plant at the Palisades site are categorized as MODERATE to

LARGE.

At an alternate site, the buildings, cooling towers, cooling-tower plumes, and the associated

transmission line and gas pipeline compressors would be visible offsite. There would also

be a visual impact from a new 345-kV transmission line. Aesthetic impacts would be

mitigated if the plant were located in an industrial area adjacent to other power plants. 

Noise impacts would be similar to those described for the Palisades site. Overall, the

aesthetic impacts associated with an alternate site are categorized as MODERATE to

LARGE. Depending on the site chosen, the greatest contributor to aesthetic impact would

be the new transmission line.
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October 2006 8-31 NUREG-1437, Supplement 27

 C Historic and Archaeological Resources

Before construction or any ground disturbance at Palisades or at an alternate site, studies

would likely be needed to identify, evaluate, and address mitigation of the potential impacts

of new plant construction on historic and archaeological resources. The studies would likely

be needed for all areas of potential disturbance at the proposed plant site and along

associated corridors where new construction would occur (e.g., roads, transmission and

pipeline corridors, or other rights-of-way). Other lands, if any, that are acquired to support

the plant would also likely need an inventory of cultural resources to identify and evaluate

existing historic and archaeological resources and possible mitigation of adverse effects

from subsequent ground-disturbing actions related to physical expansion of the plant site.

Historic and archaeological resources must be evaluated on a site-specific basis. The

impacts can generally be effectively managed under current laws and regulations, and as

such, the categorization of impacts ranges from SMALL to MODERATE, depending on what

resources are present and whether mitigation is necessary.

 C Environmental Justice

No environmental pathways or locations have been identified that would result in disproportionately high and adverse environmental impacts on minority and low-income

populations if a replacement natural-gas-fired plant were built at the Palisades site. Some

impacts on housing availability and prices during construction might occur, and this could

disproportionately affect minority and low-income populations. Closure of Palisades would

result in a decrease in employment of approximately 644 operating employees, possibly

offset by general growth in the Kalamazoo area. Following construction, it is possible that

the ability of local government to maintain social services could be reduced at the same time

as diminished economic conditions reduce employment prospects for minority or low-income

populations. Overall, impacts are expected to be SMALL to MODERATE. Projected

economic growth in the Kalamazoo area and the ability of minority and low-income

populations to commute to other jobs outside the area could mitigate any adverse effects.

Impacts at an alternate site would depend upon the site chosen and the nearby population

distribution; therefore, impacts could range from SMALL to MODERATE.

8.2.2.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a natural-gas-fired generation

system at an alternate site using once-through cooling. The impacts (SMALL, MODERATE, or

LARGE) of this option are the same as the impacts for a natural-gas-fired plant using the

closed-cycle system. However, there are minor environmental differences between the closedcycle and once-through cooling systems. Table 8.5 summarizes the incremental differences. 

However, the design and operation of the intake would need to comply with Phase II |
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NUREG-1437, Supplement 27 8-32 October 2006

performance standards of EPA’s 316(b) regulations to minimize adverse impacts associated

with water withdrawal, and heated discharges would need to comply with 316(a) regulations.

8.2.3 Nuclear Power Generation

| Since 1997, the NRC has certified four new standard designs for nuclear power plants under

| 10 CFR Part 52, Subpart B. These designs are the 1300-MW(e) U.S. Advanced Boiling Water

| Reactor (10 CFR Part 52, Appendix A), the 1300-MW(e) System 80+ Design (10 CFR Part 52,

| Appendix B), the 600-MW(e) AP600 Design (10 CFR Part 52, Appendix C), and the advanced

| 1117- to 1154-MW(e) AP1000 design (10 CFR Part 52, Appendix D). All these plants are

| light-water reactors. Although no applications for a construction permit or a combined license 

Table 8-5. Summary of Environmental Impacts of Natural-Gas-Fired Generation Using 

Once-Through Cooling at an Alternate Site

Impact Category

Change in Impacts from

Closed-Cycle Cooling System

Land use Impacts may be less (e.g., through elimination of cooling

towers) or greater (e.g., if a reservoir is required).

Ecology Impacts would depend on the ecology at the site. 

Potential impacts associated with entrainment of fish and

shellfish in early life stages, impingement of fish and

shellfish, and heat shock. No impact on terrestrial

ecology from cooling-tower drift.

| Water use and quality – surface water Increased water withdrawal leading to possible water-use

conflicts, thermal load higher on receiving body of water

than with closed-cycle cooling; no discharge of coolingtower blowdown.

| Water use and quality – groundwater No change

Air quality No change

Waste No change

Human health No change

Socioeconomics No change

Transportation No change

Aesthetics Less aesthetic impact because cooling towers would not

be used.

Historic and archaeological resources No change

Environmental justice No change
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October 2006 8-33 NUREG-1437, Supplement 27

based on these certified designs have been submitted to the NRC, the submission of the design

certification applications indicates continuing interest in the possibility of licensing new nuclear

power plants. In addition, recent escalation in prices of natural gas and electricity have made

new nuclear power plant construction more attractive from a cost standpoint. In addition,

System Energy Resources, Inc., Exelon Generations Company, LLC, and Dominion Nuclear

North Anna, LLC, have recently submitted applications for early site permits for new advanced

nuclear power plants under the procedures in 10 CFR Part 52, Subpart A (SERI 2003;

Exelon 2003; Dominion 2003). Consequently, construction of a new nuclear power plant at

either the Palisades site or at an alternate site is considered in this section. The NRC staff

assumed that the new nuclear plant would have a 40-year lifetime. Consideration of a new

nuclear generating plant to replace Palisades was not included in the NMC ER (NMC 2005). |

The NRC has summarized environmental data associated with the uranium fuel cycle in

Table S-3 of 10 CFR 51.51. The impacts shown in Table S-3 are representative of the impacts

that would be associated with a replacement nuclear power plant built to one of the certified

designs, sited at Palisades or at an alternate site. The impacts shown in Table S-3 are for a

1000-MW(e) reactor and would need to be adjusted to reflect the replacement of 786 MW(e)

generated by Palisades. The environmental impacts associated with transporting fuel and

waste to and from a light-water-cooled nuclear power reactor are summarized in Table S-4 of 10

CFR 51.52. The summary of the NRC’s findings on NEPA issues for license renewal of nuclear

power plants in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, is also relevant, although

not directly applicable, for consideration of environmental impacts associated with the operation

of a replacement nuclear power plant. Additional environmental impact information for a

replacement nuclear power plant using closed-cycle cooling is presented in Section 8.2.3.1, and

using open-cycle cooling is presented in Section 8.2.3.2.

8.2.3.1 Closed-Cycle Cooling System

The overall impacts of the nuclear generating system are discussed in the following sections. 

The impacts are summarized in Table 8-6. The extent of impacts at an alternate site will

depend on the location of the particular site selected.

In addition to the impacts discussed below, impacts would occur offsite as a result of uranium

mining. Impacts of mining would include an increase in fugitive dust emissions, surface-water

runoff, erosion, sedimentation, changes in water quality, disturbance of vegetation and wildlife,

disturbance of historic and archaeological resources, changes in land use, and impacts on |

employment.

The magnitude of these offsite impacts would largely be proportional to the amount of land

affected by mining. However, there would be no net change in land needed for uranium mining
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NUREG-1437, Supplement 27 8-34 October 2006

Table 8-6. Summary of Environmental Impacts of New Nuclear Power Generation Using

 Closed-Cycle Cooling at the Palisades Site and at an Alternate Site

| Palisades Site Alternate Site

Impact Category Impact Comments Impact Comments

Land use MODERATE

to LARGE

Requires approximately 500 to

1000 ac for the plant; would

likely require the acquisition of

additional land. 

MODERATE

to LARGE

Same as Palisades site plus

additional land for

transmission line.

Ecology MODERATE

to LARGE

Uses undeveloped areas at

current Palisades site and

additional undeveloped land

adjacent to the site. Impacts

dependent on specific location

and ecology of the site. 

Impacts on terrestrial ecology

from cooling-tower drift are

expected. Use of cooling

makeup water could affect

aquatic resources.

MODERATE

to LARGE

Impacts would depend on

location and ecology of

the site, surface-water body

used for intake and

discharge, and transmission

line route; potential habitat

loss and fragmentation;

reduced productivity and

biological diversity. Impacts

on terrestrial ecology from

cooling-tower drift are

expected. 

Water use and

| quality – surface

water

SMALL Discharge of cooling-tower

blowdown containing increased

dissolved solids and intermittent

low concentrations of biocides

would be released to Lake

Michigan. 

SMALL to

MODERATE

Impacts would depend on

the volume of water

withdrawn and discharged

and the characteristics of

the surface-water body. 

Discharge of cooling-tower

blowdown containing

increased dissolved solids

and intermittent low

concentrations of biocides

would be released to

surface water. 

Water use and

| quality –

groundwater

SMALL Use of groundwater is unlikely

because the Palisades site has

adequate surface water

available from Lake Michigan.

SMALL to

MODERATE

Impacts would depend on

the volume of water

withdrawn and discharged

and the characteristics of

the aquifer.

Air quality SMALL to

MODERATE

Fugitive emissions and

emissions from vehicles and

equipment during construction

would be MODERATE. Small

amount of emissions from

diesel generators and possibly

other sources during operation

would be similar to current

operation of Palisades.

SMALL to

MODERATE

Same impacts as Palisades

site.
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October 2006 8-35 NUREG-1437, Supplement 27

Table 8-6. (contd)

Palisades Site Alternate Site |

Impact Category Impact Comments Impact Comments

Waste SMALL Waste impacts for an operating

nuclear power plant are

presented in 10 CFR Part 51,

Appendix B, Table B-1. Debris

would be generated and

removed during construction.

SMALL Same impacts as Palisades

site.

Human health SMALL Human health impacts for an

operating nuclear power plant

are presented in 10 CFR

Part 51, Appendix B, Table B-1.

SMALL Same impacts as Palisades

site.

Socioeconomics SMALL to

MODERATE

During construction, impacts

would be MODERATE. Up to

2500 workers during peak

period of the 6-year

construction period. Operating

workforce assumed to be

similar to Palisades; tax base

preserved. Impacts during

operation would be SMALL.

SMALL to

LARGE 

Construction impacts would

depend on location. 

Impacts at a rural location

could be LARGE. 

Van Buren County would

experience a loss in its tax

base and employment if the

chosen site is located

outside of the county,

possibly offset by economic

growth in the area.

Transportation SMALL to

LARGE

Transportation impacts

associated with 2500

construction workers in addition

to 644 Palisades workers would

be LARGE. Transportation

impacts of commuting plant

personnel would be SMALL.

SMALL to

LARGE 

Impacts would depend on

the location of the site.

Transportation impacts of

2500 construction workers

could be MODERATE to

LARGE. Transportation

impacts of 644 commuting

plant personnel could be

SMALL to MODERATE.

Aesthetics SMALL to

MODERATE

Aesthetic impacts due to

addition of containment and

other associated buildings

would be SMALL. No exhaust

stacks would be needed, and

existing cooling towers would

be used, if possible.

Intermittent noise from

construction and commuter

traffic and continuous noise

from cooling towers and

mechanical equipment could

result in impacts ranging from

SMALL to MODERATE. 

MODERATE

to LARGE

Impacts would depend on

the characteristics of the

alternate site but would be

similar to those at the

Palisades site. Impacts

would be less if the site

selected is next to an

industrial area. Impacts

would be greater if a nonindustrial site is selected. 

Additional visual impacts

would occur from the new

transmission line that would

be needed.
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NUREG-1437, Supplement 27 8-36 October 2006

Table 8-6. (contd)

| Palisades Site Alternate Site

Impact Category Impact Comments Impact Comments

Historic and

| archaeological

resources

SMALL to

MODERATE

Some construction would affect

previously developed parts of

the Palisades site; a cultural

resource inventory would be

needed to identify, evaluate,

and mitigate potential impacts

of new plant construction on

cultural resources in

undeveloped areas. 

SMALL to

MODERATE

Cultural resource studies

would be needed to identify,

evaluate, and mitigate

potential impacts of new

plant construction at

developed and undeveloped

sites. 

Environmental

justice

SMALL to

MODERATE

Impacts on minority and lowincome communities should be

similar to those experienced by

the population as a whole. 

MODERATE impacts on

housing may occur during

construction. Employment

impacts would be similar to the

current operation of Palisades.

SMALL to

LARGE 

Impacts would vary depending on population distribution

and makeup at the site.

because land needed for the new nuclear plant would offset land needed to supply uranium for

fuel at Palisades.

 C Land Use

The existing facilities and infrastructure at the Palisades site would be used to the extent

practicable, limiting the amount of new construction that would be required. Specifically, the

NRC staff assumed that a replacement nuclear power plant would use the existing cooling

towers, switchyard, offices, and transmission line rights-of-way. Much of the land that would

be used has been previously disturbed. A replacement nuclear power plant at the Palisades

site would alter approximately 500 to 1000 ac of land, excluding power lines (NRC 1996).

The impact of a replacement nuclear generating plant on land use at the existing Palisades

site is best characterized as MODERATE to LARGE, because the existing site is not large

enough to accept the additional land requirements for construction. Additional land would

have to be obtained outside of the existing boundaries, or Palisades would have to be

dismantled before new construction began. The impact would be greater than the OL

renewal alternative.

Land-use impacts at an alternate site would be similar to siting at Palisades except for the

land needed for a 345-kV transmission line to connect to existing lines to transmit power to

NMC’s customers in Michigan. The amount of land needed for the transmission line is

dependent upon the location of the alternate site. In addition, it may be necessary to
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October 2006 8-37 NUREG-1437, Supplement 27

construct a rail spur to an alternate site to bring in equipment during construction. 

Depending particularly on transmission line routing, siting a new nuclear plant at an

alternate site would result in MODERATE to LARGE land-use impacts.

 C Ecology

Locating a replacement nuclear power plant at the Palisades site would alter ecological

resources because of the need to convert roughly 500 to 1000 ac of land to industrial use. 

Some of this land, however, would have been previously disturbed.

Siting at Palisades would have a MODERATE to LARGE ecological impact that would be

greater than renewal of the Palisades OL.

At an alternate site, there would be construction impacts and new incremental operational

impacts. Even assuming siting at a previously disturbed area, the impacts would affect

ecological resources. Impacts could include wildlife habitat loss, reduced productivity,

habitat fragmentation, and a local reduction in biological diversity. Use of cooling makeup

water from a nearby surface-water body could have adverse aquatic resource impacts. 

Impacts on terrestrial ecology could result from cooling-tower drift. Construction and

maintenance of the transmission line, if needed, would have ecological impacts. Overall,

the ecological impacts at an alternate site would be MODERATE to LARGE and would

depend on the ecological conditions at the site.

 C Water Use and Quality

Surface water. The replacement nuclear plant alternative at the Palisades site is assumed |

to use the existing closed-cycle cooling tower system, which would minimize incremental

water-use and quality impacts. Plant discharge would consist mostly of cooling-tower

blowdown, with the discharge having a higher temperature and increased concentration of

dissolved solids relative to the receiving body of water and intermittent low concentrations of

biocides (e.g., chlorine). In addition to the cooling-tower blowdown, treated process waste

streams and sanitary wastewater might also be discharged. All discharges would be

regulated by the State of Michigan through a permit. Surface-water impacts are expected to

remain SMALL; the impacts would be sufficiently minor that they would not noticeably alter

any important attribute of the resource.

Cooling towers would likely be used at an alternate site. For an alternate site, the impact on

the surface water would depend on the volume of water needed for makeup water, the

discharge volume, and the characteristics of the receiving body of water. Intake from and

discharge to any surface body of water would be regulated by the State of Michigan. The

impacts would be SMALL to MODERATE.
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NUREG-1437, Supplement 27 8-38 October 2006

Groundwater. The NRC staff assumed that a new nuclear power plant located at Palisades

would obtain potable, process, and fire-protection water from the South Haven Municipal

Water Authority, similar to the current practice for Palisades (see Section 2.2.2).

No groundwater is currently used for operation of Palisades other than for maintenance of

the grounds. It is unlikely that groundwater would be used for an alternative nuclear power

plant sited at Palisades. Use of groundwater for a nuclear power plant sited at an alternate

site is a possibility. Any groundwater withdrawal would require a permit from the local

permitting authority.

Overall, the impacts on groundwater use and quality from a closed-cycle new nuclear

alternative at the Palisades site is considered SMALL. Impacts from a similar plant at an

alternate site are considered to be SMALL to MODERATE, depending on the volume of

groundwater used and characteristics of the aquifer.

 C Air Quality

Construction of a new nuclear plant sited at Palisades or at an alternate site would result in

fugitive emissions during the 6-year construction period. Exhaust emissions would also

come from vehicles and motorized equipment used during the construction process. Air

quality impacts from construction could be MODERATE. An operating nuclear plant would

have minor air emissions associated with diesel generators and other minor intermittent

sources and would be similar to the current impacts associated with operation of Palisades

(i.e., SMALL). These emissions are not regulated. Emissions for a plant sited in Michigan

would be regulated by the MDEQ. Overall, emissions and associated impacts are

considered SMALL to MODERATE.

 C Waste

The waste impacts associated with operation of a nuclear power plant are presented in

Table B-1 of 10 CFR Part 51, Subpart A, Appendix B. Construction-related debris would be

generated during construction activities and removed to an appropriate disposal site. 

Overall, waste impacts are considered SMALL.

Siting the replacement nuclear power plant at a site other than Palisades would not alter

waste generation. Therefore, the impacts would be SMALL.

 C Human Health

Human health impacts for an operating nuclear power plant are presented in

10 CFR Part 51, Subpart A, Appendix B, Table B-1. Overall, human health impacts are

considered SMALL.
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October 2006 8-39 NUREG-1437, Supplement 27

Siting the replacement nuclear power plant at a site other than Palisades would not alter

human health impacts. Therefore, the impacts would be SMALL.

 C Socioeconomics

The construction period and the peak workforce associated with construction of a new

nuclear power plant are currently unquantified (NRC 1996). In the absence of quantitative

data, NRC staff assumed a construction period of 6 years and a peak workforce of 2500. 

Additional land would have to be acquired to construct a new nuclear plant at the Palisades

site, or Palisades would have to be decommissioned and dismantled before construction

began. During construction, the communities surrounding the Palisades site would

experience demands on housing and public services that could have MODERATE impacts. 

These impacts would be tempered by construction workers commuting to the site from other

parts of Van Buren and Berrien Counties or from other counties. 

The replacement nuclear unit is assumed to have an operating workforce comparable to the

644 workers currently working at Palisades. The replacement nuclear unit would provide a

new tax base to offset the loss of tax base associated with decommissioning of Palisades. 

For all of these reasons, the appropriate characterization of nontransportation

socioeconomic impacts for replacement nuclear units constructed at Palisades would be

SMALL to MODERATE; the socioeconomic impacts would be noticeable, but would be

unlikely to destabilize the area.

If a new nuclear power plant were constructed at an alternate site, the communities around

the Palisades site would experience the impact of Palisades’ operational job loss (although

potentially tempered by projected economic growth in the area). The communities around

the new site would have to absorb the impacts of a large, temporary workforce (up to

2500 workers at the peak of construction) and a permanent workforce of approximately

644 workers. In the GEIS (NRC 1996), the NRC staff indicated that socioeconomic impacts

at a rural site would be larger than at an urban site because more of the peak construction

workforce would need to move to the area to work. Alternate sites would need to be

analyzed on a case-by-case basis, and impacts could range from SMALL to LARGE. 

 C Transportation

During the 6-year construction period, up to 2500 construction workers and 644 Palisades

workers would be commuting to the Palisades site. The addition of the construction workers

could place significant traffic loads on existing highways. Such impacts would be

MODERATE to LARGE. Transportation impacts related to commuting of plant operating

personnel would be similar to current impacts associated with operation of Palisades and

are considered SMALL.
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Transportation-related impacts associated with commuting construction workers at an

alternate site are site dependent, but could be MODERATE to LARGE. Transportation

impacts related to commuting of plant operating personnel would also be site dependent,

but can be characterized as SMALL to MODERATE.

 C Aesthetics

The containment buildings for a replacement nuclear power plant sited at Palisades and

other associated buildings would likely be visible in daylight hours over many miles. Natural

| draft towers could be up to 500 ft high. Mechanical-draft towers could be up to 100 ft high

and would also have an associated noise impact and condensate plumes. The replacement

nuclear units would also likely be visible at night because of outside lighting. Visual impacts

could be mitigated by landscaping and selecting a color for buildings that is consistent with

the environment. Visual impact at night could be mitigated by reduced use of lighting and

appropriate use of shielding. No exhaust stacks would be needed. Existing cooling towers

would be used, if possible.

Intermittent noise impacts from construction and commuter traffic is likely. More continuous

noise from a new nuclear plant would potentially be audible offsite in calm wind conditions or

when the wind is blowing in the direction of the listener. Noise impacts from a new nuclear

plant would be similar to those from the existing Palisades unit. Mitigation measures, such

as reduced or no use of outside loudspeakers, can be employed to reduce noise impacts to

levels that would ranges from SMALL to MODERATE.

At an alternate site, there would be an aesthetic impact from the buildings, cooling towers,

and the plume associated with the cooling towers. There would also be a significant

aesthetic impact associated with construction of a new transmission line. The length of the

transmission line would be dependent upon the location of the plant. Noise and light from

the plant would be detectable offsite. The impact of noise and light would be less if the plant

were located in an industrial area adjacent to other power plants. Overall, the aesthetic

impacts associated with locating at an alternative site can be categorized as MODERATE to

LARGE. Depending on the location chosen, the greatest contributor to this categorization

could be the aesthetic impact of the new transmission line.

 C Historic and Archaeological Resources

Before construction or any ground disturbance at Palisades or at an alternate site, studies

would likely be needed to identify, evaluate, and address mitigation of the potential impacts

of new plant construction on historic and archaeological resources. The studies would likely

be needed for all areas of potential disturbance at the proposed plant site and along

associated corridors where new construction would occur (e.g., roads, transmission and

pipeline corridors, or other rights-of-way). Other lands, if any, that are acquired to support

the plant would also likely need an inventory of cultural resources to identify and evaluate
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October 2006 8-41 NUREG-1437, Supplement 27

existing historic and archaeological resources and possible mitigation of adverse effects

from subsequent ground-disturbing actions related to physical expansion of the plant site.

Historic and archaeological resources must be evaluated on a site-specific basis. The

impacts can generally be effectively managed under current laws and regulations, and as

such, the categorization of impacts ranges from SMALL to MODERATE, depending on what

resources are present and whether mitigation is necessary.

 C Environmental Justice

No environmental pathways or locations have been identified that would result in disproportionately high and adverse environmental impacts on minority and low-income populations if a replacement nuclear plant were built at the Palisades site. Some impacts on

housing availability and prices during construction might occur, and this could disproportionately affect the minority and low-income populations. After completion of construction, it

is possible that the ability of the local government to maintain social services could be

reduced at the same time as diminished economic conditions reduce employment prospects

for the minority and low-income populations. Overall, impacts are expected to be SMALL to

MODERATE. Projected economic growth in the Kalamazoo area and the ability of minority

and low-income populations to commute to other jobs outside the Van Buren County area

could mitigate any adverse effects.

Impacts at an alternate site would depend upon the site chosen and the nearby population

distribution and are likely to vary from SMALL to LARGE. |

8.2.3.2 Once-Through Cooling System

This section discusses the environmental impacts of constructing a nuclear power plant at an

alternate site using once-through cooling. The impacts (SMALL, MODERATE, or LARGE) of

this option are the same as the impacts for a nuclear power plant using a closed-cycle system. 

However, there are minor environmental differences between the closed-cycle and oncethrough cooling systems. Table 8-7 summarizes the incremental differences. However, the |

design and operation of the intake would need to comply with Phase II performance standards |

of the EPA’s 316(b) regulations to minimize adverse impacts associated with water withdrawal,

and heated discharges would need to comply with 316(a) regulations.
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| Table 8-7. Summary of Environmental Impacts of a New Nuclear Power Plant Using 

 Once-Through Cooling at an Alternate Site

Impact Category

Change in Impacts from

Closed-Cycle Cooling System

Land use Impacts may be less (e.g., through elimination of

cooling towers) or greater (e.g., if a reservoir is 

required).

Ecology Impacts would depend on the ecology at the site. 

Possible impacts associated with entrainment of fish

and shellfish in early life stages, impingement of fish

and shellfish, and heat shock. No impact on terrestrial

| ecology from cooling-tower drift.

| Water use and quality – surface water Increased water withdrawal leading to possible wateruse conflicts, thermal load higher on receiving body of

water than with closed-cycle cooling; no discharge of

cooling-tower blowdown.

| Water use and quality – groundwater No change

Air quality No change

Waste No change

Human health No change

Socioeconomics No change

Transportation No change

Aesthetics Less aesthetic impact because cooling towers are not

used.

Historic and archaeological resources No change

Environmental justice No change

8.2.4 Purchased Electrical Power

If available, purchased power from other sources could potentially obviate the need to renew the

Palisades OL. It is unlikely, however, that sufficient baseload, firm power supply would be

available to replace the Palisades capacity.
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October 2006 8-43 NUREG-1437, Supplement 27

Imported power from Canada or Mexico is unlikely to be available for replacement of Palisades

capacity. In Canada, 60 percent of the country’s electrical generation capacity is derived from

renewable energy sources, principally hydropower (EIA 2004). Canada plans to expand

hydroelectric capacity, including large-scale projects (EIA 2004). Canada’s nuclear generation

is projected to increase from 10,000 MW in 2001 to 15,200 MW in 2020 before reaching a

forecasted decline to 12,400 MW in 2025 (EIA 2004). The EIA projected that total gross

U.S. imports of electricity from Canada and Mexico will gradually increase from 38.4 billion kWh

in 2001 to 47.2 billion kWh in 2010 and then gradually decrease to 15.2 billion kWh in 2025

(EIA 2004). Consequently, it is unlikely that electricity imported from Canada or Mexico would

be able to replace the capacity of Palisades. |

If power to replace the capacity of Palisades were to be purchased from sources within the |

United States or a foreign country, the generating technology would likely be one of those

described in this SEIS and in the GEIS (probably coal, natural gas, or nuclear). The description |

of the environmental impacts of other technologies in Chapter 8 of the GEIS is representative of

the purchased electrical power alternative to renewal of the Palisades OL. Thus, the

environmental impacts of imported power would still occur but would be located elsewhere

within the region, nation, or another country.

8.2.5 Other Alternatives

Other generation technologies considered by the NRC are discussed in the following

paragraphs.

8.2.5.1 Oil-Fired Generation

EIA projects that oil-fired plants will account for very little of the new generation capacity in the

United States during the 2004 to 2025 time period because of higher fuel costs and lower

efficiencies (EIA 2004). Nevertheless, an oil-fired generating alternative at the Palisades site for

replacement of power generated by Palisades is considered in this section. 

Consumers Energy has two oil/gas coal-fired units. These units produce about 1 percent of

Consumers Energy’s total power (NMC 2005). Oil-fired operation is more expensive than

nuclear or coal-fired operation. In addition, future increases in oil prices are expected to make

oil-fired generation increasingly more expensive than coal-fired generation. The high cost of oil

has prompted a steady decline in its use for electricity generation. For these reasons, oil-fired

generation is not an economically feasible alternative to license renewal for Palisades. |

Construction and operation of an oil-fired plant would have environmental impacts. For

example, in Section 8.3.11 of the GEIS, the NRC staff estimated that construction of a 1000-

MWe oil-fired plant would require about 120 acres (NRC 1996). In addition, operation of oil-fired
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NUREG-1437, Supplement 27 8-44 October 2006

plants would have environmental impacts (including impacts on the aquatic environment and

air) that would be similar to those from a coal-fired plant.

8.2.5.2 Wind Power

| Wind power, by itself, is not a suitable alternative to replace the large baseload electrical

| generating capacity of Palisades. As discussed in Section 8.3.1 of the GEIS, wind has a high

degree of intermittency, and average annual capacity factors for wind plants are relatively low

(on the order of 30 percent) (NRC 1996). Wind power, in conjunction with energy storage

mechanisms, might serve as a means of providing baseload power. However, current energy

storage technologies are too expensive for wind power to serve as a large baseload generator.

The Lake Michigan shoreline region in the State of Michigan, including Van Buren County, has

good wind power potential. The annual average wind power for this part of the state is rated as

Class 3. Areas designated Class 3 or greater are suitable for most wind energy applications

(DOE 2004a). However, the wind power class attenuates rapidly to Class 2 inland from the

lake’s coastline. Michigan also has good wind resources in the northern part of the Lower

Peninsula. These areas, however, are confined to exposed hilltops and ridge crests, which

makes them unsuitable for utility-scale wind energy applications. Further, land-use conflicts,

such as urban development and environmentally sensitive areas, minimize the amount of land

suitable for wind energy applications (PNL 1986). 

| DOE’s National Renewable Energy Laboratory (NREL) estimates that the footprint of a 1.5-MW

| wind turbine is between 0.25 and 0.5 ac. In addition, a spacing interval of 5 to 10 turbine rotor

| diameters between wind turbines is typically maintained to prevent interferences between

| turbines (NREL 2006). Five turbine rotor diameters would be suitable for optimal wind

| conditions, increasing to 10 depending on the amount of wind turbulence and other potential

| topographic disturbances. Land disturbance during construction to install the turbine is

| estimated to be between 1 to 3 ac per turbine related to grading the site for installation, laydown

| areas for equipment and materials, and staging areas for construction equipment used to hoist

| the turbines and their towers into place. The area surrounding the turbine is then reclaimed

| after construction is completed. These estimates do not include land used for substations,

| control buildings, access roads, and other related facilities. Assuming the largest available

| land-based turbine is used (currently, 1.5 MW), 524 turbines are estimated to be needed in land

| areas with a wind class of Class 3 or greater to produce 786 MW(e), using the NREL’s Wind

| Farm Area Calculator (NREL 2006). Assuming a rotor diameter of roughly 200 ft for a 1.5-MW

| turbine, the total acreage for a wind farm with 524 turbines in optimal wind conditions could

| require more than 2,000 ac; 262 ac would be dedicated to the turbine footprint (assuming a

| spacing interval of five turbine rotor diameters and approximately 0.5 ac per turbine base), and

| the remaining land between turbines could be available for other uses, such as grazing or

| agricultural land. These numbers do not take into account the low annual capacity factor of

| approximately 30 percent that is associated with wind energy.
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October 2006 8-45 NUREG-1437, Supplement 27

Consequently, the NRC staff concludes that the current Palisades site is too small to support a |

baseload level of wind generation capacity. At an alternate site, this large amount of land |

required along the coastline could result in a LARGE environmental impact. Larger turbines |

could be used for offshore wind development where the wind class is greater, but even a 4-MW |

turbine (the largest currently available turbine for offshore use is 3.6 MW) would require about |

196 turbines, with greater spacing required between turbines because of the greater rotor |

lengths, to produce 786 MW(e). Although impacts would depend on the site chosen, common |

issues of concern include visual impacts, noise, potential interferences with aircraft operations, |

and bird and bat collisions. |

8.2.5.3 Solar Power

Solar technologies use the sun’s energy and light to provide heat and cooling, light, hot water,

and electricity for homes, businesses, and industry. In the GEIS, the NRC staff noted that by its

nature, solar power is intermittent. Therefore, solar power by itself is not suitable for baseload

capacity and is not a feasible alternative to license renewal of Palisades. The average capacity

factor of photovoltaic cells is about 25 percent, and the capacity factor for solar thermal systems

is about 25 to 40 percent. Solar power, in conjunction with energy storage mechanisms, might

serve as a means of providing baseload power. However, current energy storage technologies

are too expensive to permit solar power to serve as a large baseload generator. 

Therefore, solar power technologies (photovoltaic and thermal) cannot currently compete with

conventional fossil-fueled technologies in grid-connected applications, due to high costs per

kilowatt of capacity (NRC 1996).

There are substantial impacts on natural resources (wildlife habitat, land-use, and aesthetic

impacts) from construction of solar-generating facilities. As stated in the GEIS, land

requirements are high – 35,000 ac per 1000 MW(e) for photovoltaic and approximately

14,000 ac per 1000 MW(e) for solar thermal systems. Neither type of solar electric system

would fit at the Palisades site, and both would have large environmental impacts at an alternate

site.

Michigan receives between approximately 2.5 to 3.5 kWh of solar radiation per square meter

per day, compared with 6 to 8 kWh of solar radiation per square meter per day in areas of the

southwestern United States, such as Arizona and California, which are most promising for solar

technologies (DOE 2005). Because of the natural resource impacts (land and ecological), the

area’s relatively low rate of solar radiation, and high cost, solar power is not deemed a feasible

baseload alternative to renewal of the Palisades OL. Some solar power may substitute for

electric power in rooftop and building applications. Implementation of non-rooftop solar

generation on a scale large enough to replace Palisades would likely result in LARGE

environmental impacts.
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NUREG-1437, Supplement 27 8-46 October 2006

8.2.5.4 Hydropower

There are no remaining sites in Michigan that would be environmentally suitable for a

| hydroelectric facility (INEEL 1998). In Section 8.3.4 of the GEIS, the NRC staff points out that

hydropower’s percentage of U.S. generating capacity is expected to decline because

hydroelectric facilities have become difficult to site as a result of public concern about flooding,

destruction of natural habitat, and alteration of natural river courses. 

The NRC staff estimated in the GEIS that land requirements for hydroelectric power are

approximately 1 million ac per 1000 MW(e). Replacement of Palisades generating capacity

would require flooding more than this amount of land. Because of the lack of suitable sites in

Michigan and the large land-use and related environmental and ecological resource impacts

associated with siting hydroelectric facilities large enough to replace Palisades, the NRC staff

| concludes that local hydropower is not a feasible alternative to renewal of the Palisades OL on

its own. Any attempts to site hydroelectric facilities large enough to replace Palisades would

result in LARGE environmental impacts.

8.2.5.5 Geothermal Energy

Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

power where available. However, geothermal technology is not widely used as baseload

generation due to the limited geographical availability of the resource and immature status of

the technology (NRC 1996). As illustrated by Figure 8.4 in the GEIS, geothermal plants are

most likely to be sited in the western continental United States, Alaska, and Hawaii where

hydrothermal reservoirs are prevalent. There is no feasible location in Michigan for geothermal

capacity to serve as an alternative to Palisades. The NRC staff concludes that geothermal

energy is not a feasible alternative to renewal of the Palisades OL.

8.2.5.6 Wood Waste

The use of wood waste to generate electricity is largely limited to those states with significant

wood resources, such as California, Maine, Georgia, Minnesota, Oregon, Washington, and

Michigan. Electric power is generated in these states by the pulp, paper, and paperboard

industries, which consume wood and wood waste for energy, benefitting from the use of waste

materials that could otherwise represent a disposal problem.

DOE estimates that Michigan has good resources for wood fuels consisting of urban, mill, and

forest residues; at least 3,720,000 dry tons/yr are available in Michigan (Walsh et al. 2000). 

| NREL has estimated that 1100 kWh of electricity can be produced by one dry ton of wood

residue. Therefore, 1.9 TWh of electricity can be generated from wood residue in Michigan

(NREL 2004).
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October 2006 8-47 NUREG-1437, Supplement 27

A wood-burning facility can provide baseload power and operate with an average annual

capacity factor of around 70 to 80 percent and with 20 to 25 percent efficiency (NRC 1996). 

The fuels required are variable and site-specific. A significant barrier to the use of wood waste

to generate electricity is the high delivered-fuel cost and high construction cost per MW of

generating capacity. The larger wood-waste power plants are only 40 to 50 MW(e) in size. 

Estimates in the GEIS suggest that the overall level of construction impact per MW of installed

capacity should be approximately the same as that for a coal-fired plant, although facilities using

wood waste for fuel would be built at smaller scales. Like coal-fired plants, wood-waste plants

require large areas for fuel storage and processing and involve the same type of combustion

equipment.

While wood resources in Michigan are adequate, wood energy is not considered as a |

reasonable alternative to renewal of the Palisades OL because of the disadvantages of low heat

content, handling difficulties, and high transportation costs. There is also no significant

environmental advantage.

8.2.5.7 Municipal Solid Waste

Municipal waste combustors incinerate the waste and use the resultant heat to generate

steam, hot water, or electricity. The combustion process can reduce the volume of waste by up

to 90 percent and the weight of the waste by up to 75 percent (EPA 2004b). Municipal waste

combustors use three basic types of technologies: mass burn, modular, and refuse-derived fuel

(EIA 2001). Mass-burning technologies are most commonly used in the United States. This

group of technologies processes raw municipal solid waste “as is,” with little or no sizing,

shredding, or separation before combustion. 

Growth in the municipal waste combustion industry slowed dramatically during the 1990s

after rapid growth during the 1980s. The slower growth was due to three primary factors: 

(1) the Tax Reform Act of 1986, which made capital-intensive projects such as municipal waste

combustion facilities more expensive relative to less capital-intensive waste disposal

alternatives such as landfills; (2) the 1994 Supreme Court decision (C&A Carbone, Inc. v. Town

of Clarkstown), which struck down local flow control ordinances that required waste to be

delivered to specific municipal waste combustion facilities rather than landfills that may have

had lower fees; and (3) increasingly stringent environmental regulations that increased the

capital cost necessary to construct and maintain municipal waste combustion facilities

(EIA 2001).

The decision to burn municipal waste to generate energy is usually driven by the need for an

alternative to landfills rather than by energy considerations. The use of landfills as a waste

disposal option is likely to increase in the near term; however, it is unlikely that many landfills

will begin converting waste to energy because of unfavorable economics, particularly with

electricity prices declining in real terms. U.S. electricity prices in 2002 dollars are expected to
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NUREG-1437, Supplement 27 8-48 October 2006

decline by 8 percent between 2002 and 2008 and remain stable until 2011 (EIA 2004). Prices

are expected to increase by 0.3 percent per year from 2011 until 2025, following the trend of the

generation component of electricity price (EIA 2004).

Municipal solid-waste combustors generate an ash residue that is buried in landfills. The ash

residue is composed of bottom ash and fly ash. Bottom ash refers to that portion of the

unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small

particles that rise from the furnace during the combustion process. Fly ash is generally

removed from flue-gases using fabric filters or scrubbers (EIA 2001).

Currently, there are approximately 89 waste-to-energy plants operating in the United States. 

These plants generate approximately 2500 MW(e), or an average of approximately 28 MW(e)

per plant (Integrated Waste Services Association 2004), a much smaller capacity than that

needed to replace the 786 MW(e) of Palisades.

The initial capital costs for municipal solid-waste plants are greater than for comparable steamturbine technology at wood-waste facilities. This is due to the need for specialized wasteseparation and -handling equipment for municipal solid waste (NRC 1996). Furthermore,

estimates in the GEIS suggest that the overall level of construction impact from a waste-fired

plant should be approximately the same as that for a coal-fired plant. In addition, waste-fired

plants have the same or greater operational impacts (including impacts on the aquatic

environment, air, and waste disposal). Some of these impacts would be moderate, but still

larger than the environmental effects of license renewal of Palisades. Therefore, municipal

solid waste would not be a feasible alternative to renewal of the Palisades OL, particularly at the

scale required.

8.2.5.8 Other Biomass-Derived Fuels

In addition to wood and municipal solid-waste fuels, there are several other concepts for fueling

electric generators, including burning crops, converting crops to a liquid fuel such as ethanol,

and gasifying crops (including wood waste). In the GEIS, the NRC staff points out that none of

these technologies has progressed to the point of being competitive on a large scale or of being

reliable enough to replace a baseload plant such as Palisades. For these reasons, such fuels

do not offer a feasible alternative to renewal of the Palisades OL.

8.2.5.9 Fuel Cells

Fuel cells work without combustion and its environmental side effects. Power is produced

electrochemically by passing a hydrogen-rich fuel over an anode and air over a cathode and

separating the two by an electrolyte. The only by-products are heat, water, and carbon dioxide. 

Hydrogen fuel can come from a variety of hydrocarbon resources by subjecting them to steam

under pressure. Natural gas is typically used as the source of hydrogen.
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October 2006 8-49 NUREG-1437, Supplement 27

Phosphoric acid fuel cells are generally considered first-generation technology. These fuel cells

are commercially available at a cost of approximately $4000 to $4500 per kW of installed

capacity (DOE 2004b). Higher-temperature second-generation fuel cells achieve higher fuel-toelectricity and thermal efficiencies. The higher temperatures contribute to improved efficiencies

and give the second-generation fuel cells the capability to generate steam for cogeneration and

combined-cycle operations. 

It is unlikely that the costs of existing fuel cell systems will drop below $1000/kW; therefore,

the DOE has formed the Solid State Energy Conversion Alliance (SECA), with the goal of

producing new fuel cell technologies at a cost of $400/kW or lower by 2010 (DOE 2004c). 

Fuel cells have the potential to become economically competitive if SECA can reach its goal. 

For comparison, the installed capacity cost for a natural-gas-fired, combined-cycle plant is about

$500 to $600/kW (Northwest Power Planning Council 2000). At the present time, fuel cells are

not economically or technologically competitive with other alternatives for baseload electricity

generation. Consequently, fuel cells are not a feasible alternative to renewal of the Palisades

OL.

8.2.5.10 Delayed Retirement

NMC has no current plans to retire any existing generating units. For this reason, delayed

retirement of other NMC generating units would not be a feasible alternative to renewal of the

Palisades OL. NMC concluded in its ER (NMC 2005) that the environmental impacts of delayed

retirement are similar to those of the coal- and gas-fired alternatives.

8.2.5.11 Utility-Sponsored Conservation

Market conditions that initially favored utility-sponsored conservation programs (i.e., DSM),

including educational programs, energy efficiency programs, and load management programs,

have changed significantly and are no longer cost-effective. The viability of new or expanded

DSM programs has decreased in recent years because of increased competition in the electric

utility industry, mandated energy efficiency standards, and years of customer education

programs that have made efficiency the normal practice. The implementation of deregulation

resulted in the discontinuation of many of the DSM programs that Consumers Energy once

implemented (NMC 2005). A peak load management program is still in effect, but it serves a

broader purpose of maintaining system reliability. The environmental impacts of implementing a

DSM program would be SMALL, but implementation would not be able to realistically replace

the 786 MW(e) of net generating capacity of Palisades. Therefore, the conservation alternative

by itself is not considered a reasonable alternative to renewing the Palisades OL.
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NUREG-1437, Supplement 27 8-50 October 2006

8.2.6 Combination of Alternatives

Even though individual alternatives to Palisades might not be sufficient on their own to replace

| the capacity of Palisades due to the small size of the resource or lack of cost-effective

opportunities, it is conceivable that a combination of alternatives might be cost-effective. 

| As discussed previously, Palisades has a combined net summer rating of 786 MW(e). For the

coal- and natural gas-fired alternatives, the NMC ER (NMC 2005) assumes the use of standard-

| sized units as potential replacements for Palisades. This approach is followed in this SEIS. 

There are many possible combinations of alternatives. Table 8-8 contains a summary of the

environmental impacts of one assumed combination of alternatives consisting of 530 MW(e) of

combined-cycle natural gas-fired generation using closed-cycle cooling, a 40-MW wind power

facility, and 216 MW in purchased power. The NRC staff considered a natural-gas-fired plant

over a coal-fired plant because a comparison of the impacts indicates that a coal-fired plant

would have greater impacts than a similar-sized gas-fired plant (see Tables 8-2 and 8-4). Also,

the footprint of the natural-gas-fired plant is smaller and could be accommodated within the

Palisades site. Consumers Energy does not anticipate any new or expanded DSM programs

(Section 8.2.5.11); therefore, DSM is not considered part of the combination of alternatives. 

Although Michigan was identified in Section 8.2.5.6 as a state with significant wood resources,

the use of wood waste was not considered in a combination of alternatives because a woodburning facility is not as efficient as the other electrical generation plants considered by the

NRC, and the cost of transporting the fuel would be very high. The impacts are based on the

gas-fired generation impact assumptions discussed in Section 8.2.2, adjusted for the reduced

generating capacity. 

Operation of a new natural-gas-fired plant would result in increased emissions (compared with

the OL alternative) and other environmental impacts. Installation of new wind power facilities

would have land-use, ecology, and aesthetic impacts. The environmental impacts of power

generation associated with power purchased from other generators would still occur, but would

be located elsewhere in the region, nation, or another country (Canada) as discussed in

Section 8.2.4. The environmental impacts associated with purchased power are not shown in

Table 8-8.
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October 2006 8-51 NUREG-1437, Supplement 27

Table 8-8. Summary of Environmental Impacts of Combination of Alternatives

at the Palisades Site and at an Alternate Site

Palisades Site Alternate Site |

Impact

Category Impact Comments Impact Comments

Land use MODERATE to

LARGE

Uses 20 ac for power block,

offices, roads, and parking

areas. Additional impact of up

to approximately 120 ac for

construction of a 5-mi

underground gas pipeline.

Approximately 175 ac of |

additional land offsite for wind

farm.

MODERATE

to LARGE

Uses 58 ac for powerblock, offices, roads, and

parking areas. 

Approximately 175 ac for |

wind farm. Additional land

needed for transmission

line (amount dependent on

site chosen) and for

construction and/or

upgrade of an underground

gas pipeline.

Ecology MODERATE to

LARGE

Uses developed and

undeveloped areas at current

Palisades site, plus construction

of a gas pipeline. Impacts

dependent on the specific

location and ecology of the site.

See Table 8-4 for impacts on

terrestrial and aquatic ecology

for a gas-fired plant. Impacts on

ecological resources from wind

power development would

include the potential for bird and

bat collisions with turbines.

MODERATE

to LARGE

Impacts depend on location

and ecology of the site,

surface-water body used

for intake and discharge,

and transmission and

pipeline routes; potential

habitat loss and

fragmentation; reduced

productivity and biological

diversity. Likely plant sites

already have power

generation facilities.

Water use and

quality – surface |

water

SMALL to

MODERATE

Discharge of cooling-tower

blowdown containing dissolved

solids and intermittent low

concentrations of biocides would

be released to Lake Michigan. 

Temporary erosion and

sedimentation could occur in

streams during pipeline and

wind farm construction.

SMALL to

MODERATE

Impacts depend on volume

of water withdrawn and

discharged and

characteristics of surfacewater body. Discharge of

cooling-tower blowdown

containing dissolved solids

and intermittent low

concentrations of biocides

would be released to

surface water. Temporary

erosion and sedimentation

could occur in streams

during pipeline and wind

farm construction.
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NUREG-1437, Supplement 27 8-52 October 2006

Table 8-8. (contd)

Palisades Site Alternate Site

Impact

Category Impact Comments Impact Comments

Water use and

| quality –

groundwater

SMALL Use of groundwater very unlikely

because the Palisades site has

adequate surface water

available from Lake Michigan.

SMALL to

MODERATE

Impacts depend on volume

of water withdrawn and

discharged and the

characteristics of the

aquifer.

Air quality MODERATE Natural-gas-fired units

Sulfur oxides

 C 8 tons/yr

Nitrogen oxides

 C 127 tons/yr

Carbon monoxide

 C 195 tons/yr

PM10 particulates

 C 25 tons/yr

Some hazardous air pollutants.

MODERATE Same as siting at

Palisades, although

pollution control standards

may vary depending on

location.

For wind power, fugitive

emissions and emissions from

vehicles and equipment during

construction.

Waste SMALL Minimal waste product from fuel

production. Debris would be

generated and removed during

construction.

SMALL Same waste produced as if

produced at Palisades site.

Waste disposal constraints

may vary.

Human health SMALL Human health risks associated

with gas-fired plants may be

attributable to NOx emissions,

which are regulated. Impacts

considered SMALL.

SMALL Same impacts as

Palisades site.

Socioeconomics SMALL to

MODERATE

During construction, impacts

would be MODERATE. Up to

420 additional workers during

the peak of the 3-year

construction period, followed by

reduction in the current

Palisades workforce of 644 to

30. Impacts during operation

would be SMALL.

SMALL to

MODERATE

Construction impacts

depend on location, but

could be significant if

location is in a more rural

area than Palisades. Van

Buren County would

experience a loss in its tax

base and employment,

potentially offset by

projected economic growth.
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October 2006 8-53 NUREG-1437, Supplement 27

Table 8-8. (contd)

Palisades Site Alternate Site |

Impact

Category Impact Comments Impact Comments

Transportation SMALL to

MODERATE

Transportation impacts

associated with construction

workers would be MODERATE.

Impacts during operation would

be SMALL.

SMALL to

MODERATE

Transportation impacts

associated with 

construction workers would

be SMALL to MODERATE,

depending on the site

chosen.

Aesthetics MODERATE to

LARGE

MODERATE aesthetic impacts

due to impacts of plant units,

cooling towers, plume stacks,

gas pipeline compressors, and

wind turbines and ancillary

facilities.

MODERATE

to LARGE

Impacts would be similar to

the Palisades site with

additional impact from the

new transmission line that

would be needed.

Historic and

archaeological |

resources

SMALL to

MODERATE

Some construction would affect

previously developed parts of

the Palisades site; a cultural

resource inventory would be

needed to identify, evaluate, and

mitigate potential impacts of new

plant construction on cultural

resources in undeveloped areas.

SMALL to

MODERATE

Cultural resource studies

needed to identify, |

evaluate, and mitigate

potential impacts of new

plant construction at

developed and

undeveloped sites. 

Environmental

justice

SMALL to

MODERATE

Impacts on minority and lowincome communities should be

similar to those experienced by

the population as a whole. 

Some impacts on housing may

occur during construction; loss

of 644 operating jobs at

Palisades could reduce

employment prospects for

minority and low-income

populations. Impacts could be

offset by projected economic

growth and the ability of affected

workers to commute to other

jobs.

SMALL to

MODERATE 

Impacts would vary,

depending on population

distribution and makeup at

site. 

The NRC staff concludes that it is very unlikely that the environmental impacts of any

reasonable combination of generating and conservation options could be reduced to the level of

impacts associated with renewal of the Palisades OL.
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NUREG-1437, Supplement 27 8-54 October 2006

8.3 Summary of Alternatives Considered

The environmental impacts of the proposed action, renewal of the Palisades OL, would be

SMALL for all impact categories, except for collective offsite radiological impacts from the fuel

cycle and from HLW and spent fuel disposal. Collective offsite radiological impacts from the

fuel cycle and from HLW and spent fuel disposal were not assigned a single significance level

but were determined by the Commission to be Category 1 issues nonetheless. The alternative

actions, that is, no-action alternative (discussed in Section 8.1), new generation alternatives

(from coal, natural gas, and nuclear discussed in Sections 8.2.1 through 8.2.3, respectively),

purchased electrical power (discussed in Section 8.2.4), alternative technologies (discussed in

Section 8.2.5), and the combination of alternatives (discussed in Section 8.2.6) were

considered.

The no-action alternative would require the replacement of electrical generating capacity by

(1) DSM and energy conservation, (2) power purchased from other electricity providers,

(3) generating alternatives other than Palisades, or (4) some combination of these options. For

each of the new generation alternatives (coal, natural gas, and nuclear), the environmental

impacts would not be less than the impacts of license renewal. For example, the landdisturbance impacts resulting from construction of any new facility would be greater than the

impacts of continued operation of Palisades. The impacts of purchased electrical power

(imported power) would still occur, but would occur elsewhere. Alternative technologies are not

considered feasible at this time, and it is very unlikely that the environmental impacts of any

reasonable combination of generation and conservation options could be reduced to the level of

impacts associated with renewal of the Palisades OL.

The NRC staff concludes that the alternative actions, including the no-action alternative, may

have environmental effects in at least some impact categories that reach MODERATE or

LARGE significance.

8.4 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of

Production and Utilization Facilities.”

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Functions.”

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Early Site Permits;

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.”
Alternatives

October 2006 8-55 NUREG-1437, Supplement 27

40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50,

“National Primary and Secondary Ambient Air Quality Standards.”

40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

“Requirements for Preparation, Adoption, and Submittal of Implementation Plans.”

40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

“Standards of Performance for New Stationary Sources.”

40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81,

“Designation of Areas for Air Quality Planning Purposes.”

Clean Air Act (CAA). 42 USC. 7401, et seq.

C & A Carbone, Inc. v. Town of Clarkstown, New York, 511 U.S. 383, (U.S. Supreme Court

1994).

Dominion Nuclear North Anna, LLC (Dominion). 2003. Letter from D.A. Christian, Dominion, to

J.E. Dyer, U.S. Nuclear Regulatory Commission. Subject: “North Anna Early Site Permit

Application.” (September 25, 2003).

Energy Information Administration (EIA). 2001. Renewable Energy 2000: Issues and Trends.

DOE/EIA-0628 (2000). Washington, D.C.

Energy Information Administration (EIA). 2004. Annual Energy Outlook 2004 with Projections

to 2025. DOE/EIA-0383 (2004). Washington, D.C.

Energy Information Administration (EIA). 2006. Annual Energy Outlook with Projections to |

2030. DOE/EIA-0383 (2006). Washington, D.C. |

Energy Policy Act of 2005. 42 USC 20. |

Exelon Generation Company, LLC (Exelon). 2003. Letter from M.C. Kray, Exelon, to

U.S. Nuclear Regulatory Commission. Subject: “Early Site Permit Application.” (September 25,

2003).

Federal Aviation Administration (FAA). 2000. “Obstruction Marking and Lighting.” Advisory

Circular AC 70/7460-1K. Available URL: http://www.faa.gov/ats/ata/ai/circV.pdf (Accessed

November 10, 2005).
Alternatives

NUREG-1437, Supplement 27 8-56 October 2006

Gabbard, A. 1993. “Coal Combustion: Nuclear Resource or Danger,” Oak Ridge National

Laboratory Review. Oak Ridge, Tennessee. Summer/Fall 1993. Available URL: 

http://www.ornl.gov/ORNLReview/rev26-34/text/colmain.html.

Idaho National Engineering and Environmental Laboratory (INEEL). 1998. U.S. Hydropower

| Resource Assessment for Michigan. DOE/ID-10430(MI). Idaho Falls, Idaho. (February 1998). 

Integrated Waste Services Association. 2004. Waste-to-Energy: Clean, Reliable, Renewable

Power. Fact Sheet. Washington, D.C. (June 2004).

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

| National Renewable Energy Laboratory (NREL). 2004. “Biomass and Biofuels.” 

| Available URL: http://www.nrel.gov/gis/il_biomass.html (Accessed June 16, 2004).

| National Renewable Energy Laboratory (NREL). 2006. “Wind Farm Area Calculator.” 

| Available URL: www.nrel.gov/analysis/power_databook_3ed/calc_wind.php. 

| (Accessed April 14, 2006)

Northwest Power Planning Council. 2000. Northwest Power Supply Adequacy/Reliability Study

Phase I Report. 

Nuclear Management Company, LLC (NMC). 2005. Applicant’s Environmental Report –

Operating License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255, Covert,

| Michigan. (March 2005).

| Pacific Northwest Laboratory (PNL). 1986. Wind Energy Resource Atlas of the United States. 

| DOE/CH 10093-4. Solar Energy Research Institute, Golden, Colorado. (October 1986).

Resource Conservation and Recovery Act of 1976 (RCRA). 42 USC 6901, et seq.

| Systems Energy Resources, Inc. (SERI). 2003. Letter from W.A. Eaton, SERI, to U.S. Nuclear

Regulatory Commission. Subject: “Early Site Permit Application.” (October 16, 2003).

U.S. Department of Energy (DOE). 2004a. “U.S. Wind Energy Resource Map.” Available URL: 

http://www.eere.energy.gov/windandhydro/wind_potential.html?print (Accessed May 13, 2004).

U.S. Department of Energy (DOE). 2004b. “Phosphoric Acid Fuel Cells.” Available URL: 

http://www.fe.doe.gov/programs/powersystems/fuelcells/fuelcells_phosacid.shtml (Accessed

June 2, 2004).
Alternatives

October 2006 8-57 NUREG-1437, Supplement 27

U.S. Department of Energy (DOE). 2004c. “Solid State Energy Conversion Alliance.” Available

URL: http://www.fe.doe.gov/programs/powersystems/fuelcells/fuelcells_seca.shtml (Accessed

June 2, 2004).

U.S. Department of Energy (DOE). 2005. “Alternative Energy Resources in Michigan.” 

Available URL: http://www.eere.energy.gov/states/alternatives/resources_mi.cfm (Accessed

December 16, 2005).

U.S. Environmental Protection Agency (EPA). 1998. "Revision of Standards of Performance for

Nitrogen Oxide Emissions from New Fossil-Fuel Fired Steam Generating Units; Revisions to

Reporting Requirements for Standards of Performance for New Fossil-Fuel Fired Steam

Generating Units, Final Rule.” Federal Register, Vol. 63, No. 179, pp. 49442–49455. 

Washington, D.C. (September 16, 1998).

U.S. Environmental Protection Agency (EPA). 1999. "Regional Haze Regulations, Final Rule."

Federal Register, Vol. 64, No. 126, pp. 35714–3577. Washington, D.C. (July 1, 1999).

U.S. Environmental Protection Agency (EPA). 2000a. “Regulatory Finding on the Emissions of

Hazardous Air Pollutants from Electric Utility Steam Generating Units.” Federal Register,

Vol. 65, No. 245, pp. 79825–79831. Washington, D.C. (December 20, 2000).

U.S. Environmental Protection Agency (EPA). 2000b. “Notice of Regulatory Determination on

Wastes from the Combustion of Fossil Fuels.” Federal Register, Vol. 65, pp. 32214–32237. 

Washington, D.C. (May 22, 2000.) |

U.S. Environmental Protection Agency (EPA). 2004a. “Designation of Areas for Air Quality

Planning Purposes.” Federal Register, Vol. 69, pp. 23910. Washington, D.C. (April 30, 2004).

U.S. Environmental Protection Agency (EPA). 2004b. “Municipal Solid Waste.” Available URL: 

http://www.epa.gov/epaoswer/non-hw/muncpl/facts.htm.

U.S. Environmental Protection Agency (EPA). 2005. “Mercury – Controlling Power Plant

Emissions: Overview.” Available URL: http://www.epa.gov/mercury/control_emissions/ |

index.htm (Accessed December 15, 2005). |

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.
Alternatives

NUREG-1437, Supplement 27 8-58 October 2006

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

| for License Renewal of Nuclear Plants: Main Report, “Section 6.3 – Transportation, Table 9.1

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2001. “NRC Organizes Future Licensing Project

Organization.” Press Release No. 01-035, March 30, 2001. Available URL: 

http://www.nrc.gov/OPA/gmo/nrarcv/01-035.html.

U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Environmental Impact

Statement on Decommissioning Nuclear Facilities, Supplement 1, Regarding the

Decommissioning of Nuclear Power Reactors. NUREG-0586, Vols. 1 and 2. Washington, D.C.

Walsh, M.E., et al., 2000. “Biomass Feedstock Availability in the United States: 1999 State

| Level Analysis.” Available URL: http://bioenergy.ornl.gov/resourcedata/index.html 

(Accessed December 15, 2005).
(a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 9-1 NUREG-1437, Supplement 27

9.0 Summary and Conclusions

By letter dated March 22, 2005, Nuclear Management Company, LLC (NMC), submitted an |

application to the U.S. Nuclear Regulatory Commission (NRC) to renew the operating license

(OL) for the Palisades Nuclear Plant (Palisades) for an additional 20-year period (NMC 2005a). 

If the OL is renewed, State regulatory agencies and NMC will ultimately decide whether the

plant will continue to operate based on factors such as the need for power, or other matters |

within the State’s jurisdiction or the purview of the owners. If the OL is not renewed, then the

plant must be shut down at or before the expiration of the current OL, which expires on

March 24, 2011.

Section 102 of the National Environmental Policy Act (NEPA) directs that an Environmental

Impact Statement (EIS) is required for major Federal actions that significantly affect the quality

of the human environment. The NRC has implemented Section 102 of NEPA in Part 51 of

Title 10 of the Code of Federal Regulations (10 CFR Part 51). Part 51 of 10 CFR identifies

licensing and regulatory actions that require an EIS. In 10 CFR 51.20(b)(2), the Commission

requires preparation of an EIS or a supplement to an EIS for renewal of a reactor OL; 10 CFR

51.95(c) states that the EIS prepared at the OL renewal stage will be a supplement to the

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS),

NUREG-1437, Volumes 1 and 2 (NRC 1996, 1999).(a)

Upon acceptance of the NMC application, the NRC began the environmental review process

described in 10 CFR Part 51 by publishing a Notice of Intent to prepare an EIS and conduct

scoping (Federal Register, Volume 70, page 36967 (70 FR 36967) (NRC 2005a)) on June 27,

2005. The NRC staff visited the Palisades site in July 2005 and held public scoping meetings

on July 28, 2005, in South Haven, Michigan (NRC 2005b). The NRC staff reviewed the NMC

Environmental Report (ER) (NMC 2005b) and compared it with the GEIS, consulted with other

agencies, and conducted an independent review of the issues following the guidance set forth in

NUREG-1555, Supplement 1, the Standard Review Plans for Environmental Reviews for

Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC 2000). The NRC staff

also considered the public comments received during the scoping process for preparation of this

Supplemental Environmental Impact Statement (SEIS) for Palisades. The public comments |

received during the scoping process that were considered to be within the scope of the

environmental review are provided in Appendix A, Part I, of this SEIS. |

The NRC staff held two public meetings in South Haven, Michigan, on April 5, 2006, to describe |

the preliminary results of the NRC environmental review and to answer questions to provide
Summary and Conclusions

NUREG-1437, Supplement 27 9-2 October 2006

members of the public with information to assist them in formulating their comments on this

| SEIS. The comment period ended May 18, 2006. All the comments received on the draft SEIS

| were considered by the NRC staff in developing this final SEIS and are presented in

| Appendix A, Part II.

| This SEIS includes the NRC staff’s analysis that considers and weighs the environmental

effects of the proposed action, including cumulative impacts, the environmental impacts of

alternatives to the proposed action, and mitigation measures available for reducing or avoiding

| adverse impacts. This SEIS also includes the NRC staff’s recommendation regarding the

proposed action.

The NRC has adopted the following statement of purpose and need for license renewal from the

GEIS:

The purpose and need for the proposed action (renewal of an operating license) is to

provide an option that allows for power generation capability beyond the term of a

current nuclear power plant operating license to meet future system generating needs,

as such needs may be determined by State, utility, and where authorized, Federal (other

than NRC) decision makers.

The evaluation criterion for the NRC staff’s environmental review, as defined in

10 CFR 51.95(c)(4) and the GEIS, is to determine

. . . whether or not the adverse environmental impacts of license renewal are so great

that preserving the option of license renewal for energy planning decision makers would

be unreasonable.

Both the statement of purpose and need and the evaluation criterion implicitly acknowledge that

there are factors, in addition to license renewal, that will ultimately determine whether an

existing nuclear power plant continues to operate beyond the period of the current OL.

NRC regulations (10 CFR 51.95(c)(2)) contain the following statement regarding the content of

SEISs prepared at the license renewal stage:

The supplemental environmental impact statement for license renewal is not required to

include discussion of need for power or the economic costs and economic benefits of

the proposed action or of alternatives to the proposed action except insofar as such

benefits and costs are either essential for a determination regarding the inclusion of an

alternative in the range of alternatives considered or relevant to mitigation. In addition,

the supplemental environmental impact statement prepared at the license renewal stage

need not discuss other issues not related to the environmental impacts of the proposed

action and the alternatives, or any aspect of the storage of spent fuel for the facility
Summary and Conclusions

(a) The title of 10 CFR 51.23 is “Temporary storage of spent fuel after cessation of reactor

operations–generic determination of no significant environmental impact.”

October 2006 9-3 NUREG-1437, Supplement 27

within the scope of the generic determination in § 51.23(a) and in accordance with

§ 51.23(b).(a)

The GEIS contains the results of a systematic evaluation of the consequences of renewing an

OL and operating a nuclear power plant for an additional 20 years. It evaluates

92 environmental issues using the NRC’s three-level standard of significance – SMALL,

MODERATE, or LARGE – developed using Council on Environmental Quality guidelines. The

following definitions of the three significance levels are set forth in the footnotes to Table B-1 of

10 CFR Part 51, Subpart A, Appendix B:

SMALL – Environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource.

MODERATE – Environmental effects are sufficient to alter noticeably, but not to

destabilize, important attributes of the resource.

LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource.

For 69 of the 92 issues considered in the GEIS, the staff analysis in the GEIS shows the

following:

(1) The environmental impacts associated with the issue have been determined to apply

either to all plants or, for some issues, to plants having a specific type of cooling system

or other specified plant or site characteristics.

(2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to

the impacts (except for collective offsite radiological impacts from the fuel cycle and from

high-level waste (HLW) and spent fuel disposal).

(3) Mitigation of adverse impacts associated with the issue has been considered in the

analysis, and it has been determined that additional plant-specific mitigation measures

are likely not to be sufficiently beneficial to warrant implementation.
Summary and Conclusions

NUREG-1437, Supplement 27 9-4 October 2006

These 69 issues were identified in the GEIS as Category 1 issues. In the absence of new and

significant information, the NRC staff relied on conclusions as amplified by supporting

information in the GEIS for issues designated Category 1 in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B. The staff also determined that information provided during the public

comment period did not identify any new issue that requires site-specific assessment.

Of the 23 issues that do not meet the criteria set forth above, 21 are classified as Category 2

issues requiring analysis in a plant-specific supplement to the GEIS. The remaining two issues,

environmental justice and chronic effects of electromagnetic fields, were not categorized. 

Environmental justice was not evaluated on a generic basis and must also be addressed in a

plant-specific supplement to the GEIS. Information on the chronic effects of electromagnetic

fields was not conclusive at the time the GEIS was prepared.

| This SEIS documents the NRC staff’s consideration of all 92 environmental issues identified in

the GEIS. The NRC staff considered the environmental impacts associated with alternatives to

license renewal and compared the environmental impacts of license renewal and the

alternatives. The alternatives to license renewal that were considered include the no-action

alternative (not renewing the OL for Palisades) and alternative methods of power generation. 

These alternatives were evaluated assuming that the replacement power-generation plant is

located at either the Palisades site or at some other unspecified location.

| 9.1 Environmental Impacts of the Proposed Action –

| License Renewal

NMC and the NRC staff have established independent processes for identifying and evaluating

the significance of any new information on the environmental impacts of license renewal. 

Neither NMC nor the NRC staff has identified information that is both new and significant related

to Category 1 issues that would call into question the conclusions in the GEIS. Similarly, the

NRC staff did not identify, during the scoping process, any new issue applicable to Palisades

that had a significant environmental impact. Therefore, the NRC staff relies upon the

conclusions of the GEIS for all Category 1 issues that are applicable to Palisades.

NMC’s license renewal application presents an analysis of the Category 2 issues that are

applicable to Palisades. The NRC staff has reviewed the NMC analysis for each issue and has

conducted an independent review of each issue plus environmental justice and chronic effects

from electromagnetic fields. Nine Category 2 issues are not applicable because they are

related to plant design features or site characteristics not found at Palisades. Four Category 2

| issues are not discussed in this SEIS because they are specifically related to refurbishment. 

NMC (NMC 2005a) has stated that its evaluation of structures and components, as required by

10 CFR 54.21, did not identify any major plant refurbishment activities or modifications as

necessary to support the continued operation of Palisades for the license renewal period. In
Summary and Conclusions

October 2006 9-5 NUREG-1437, Supplement 27

addition, any replacement of components or additional inspection activities are within the

bounds of normal plant component replacement, and, therefore, are not expected to affect the

environment outside of the bounds of the plant operations evaluated in the Final Environmental

Statement Related to Operation of Palisades Nuclear Plant (AEC 1972).

Eight Category 2 issues related to operational impacts and postulated accidents during the

renewal term, as well as environmental justice and chronic effects of electromagnetic fields, are

discussed in detail in this SEIS. Four of the Category 2 issues and environmental justice apply |

to both refurbishment and operation during the renewal term and are discussed in this SEIS |

only in relation to operation during the renewal term. For all eight of the Category 2 issues and |

environmental justice, the NRC staff concludes that the potential environmental effects would be

of SMALL significance in the context of the standards set forth in the GEIS. In addition, the

NRC staff determined that appropriate Federal health agencies have not reached a consensus

on the existence of chronic adverse effects from electromagnetic fields. Therefore, no further

evaluation of this issue is required. For severe accident mitigation alternatives (SAMAs), the

NRC staff concurs with NMC’s identification of areas in which risk can be further reduced in a

cost-beneficial manner through the implementation of all or a subset of the identified, potentially

cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff |

agrees that further evaluation of these SAMAs by NMC is warranted. However, none of the

potentially cost-beneficial SAMAs directly relate to adequately managing the effects of aging

during the period of extended operation. Therefore, they need not be implemented as part of

the license renewal pursuant to 10 CFR Part 54.

Cumulative impacts of past, present, and reasonably foreseeable future actions were

considered, regardless of any other actions taken by agencies or persons. For purposes of this

analysis, the overall conclusion of the NRC staff is that these impacts would not result in

significant cumulative impacts on potentially affected resources.

The following sections discuss unavoidable adverse impacts, irreversible or irretrievable

commitments of resources, and the relationship between local short-term use of the

environment and long-term productivity.

9.1.1 Unavoidable Adverse Impacts

An environmental review conducted at the license renewal stage differs from the review

conducted in support of a construction permit because the plant is in existence at the license

renewal stage and has operated for a number of years. As a result, adverse impacts associated

with the initial construction have been avoided, have been mitigated, or have already occurred. 

The environmental impacts to be evaluated for license renewal are those associated with

refurbishment and continued operation during the renewal term.
Summary and Conclusions

NUREG-1437, Supplement 27 9-6 October 2006

The overall adverse impacts of continued operation identified are considered to be of SMALL

significance. The adverse impacts of likely alternatives if Palisades ceases operation at or

before the expiration of the current OL would not be smaller than those associated with

continued operation of this unit, and they may be greater for some impact categories in some

locations.

9.1.2 Irreversible or Irretrievable Resource Commitments

The commitment of resources related to construction and operation of Palisades during the

current license period was made when the plant was built. The resource commitments to be

| considered in this SEIS are associated with continued operation of the plant for an additional

20 years. These resources include materials and equipment required for plant maintenance

and operation, the nuclear fuel used by the reactors, and ultimately, permanent offsite storage

space for the spent fuel assemblies.

The most significant resource commitments related to operation during the renewal term are the

fuel and the permanent storage space. Palisades replaces a portion of the fuel assemblies in

its unit during every refueling outage, which occurs on an 18-month cycle.

The likely power generation alternatives if Palisades ceases operation on or before the

expiration of the current OL would require a commitment of resources for construction of the

replacement plant as well as for fuel to run the plant.

9.1.3 Short-Term Use Versus Long-Term Productivity

An initial balance between short-term use and long-term productivity of the environment at the

Palisades site was set when the unit was approved and construction began. That balance is

now well-established. Renewal of the OL for Palisades and continued operation of the plant

would not alter the existing balance, but may postpone the availability of the site for other uses. 

Denial of the application to renew the OL would lead to shutdown of the plant and would alter

the balance in a manner that depends on subsequent uses of the site. For example, the

environmental consequences of turning the Palisades site into a park or an industrial facility

would be quite different.

9.2 Relative Significance of the Environmental Impacts of

License Renewal and Alternatives

The proposed action is renewal of the OL for Palisades. Chapter 2 describes the site, the plant,

and interactions of the plant with the environment. As noted in Chapter 3, no refurbishment and

no refurbishment impacts are expected at Palisades. Chapters 4 through 7 discuss

environmental issues associated with renewal of the OL. Environmental issues associated with
Summary and Conclusions

October 2006 9-7 NUREG-1437, Supplement 27

the no-action alternative and alternatives involving power generation and use reduction are

discussed in Chapter 8.

The significance of the environmental impacts from the proposed action (approval of the

application for renewal of the OL); the no-action alternative (denial of the application);

alternatives involving nuclear, coal, or gas generation of power at the Palisades site and an

unspecified alternate site; and a combination of alternatives are compared in Table 9-1. 

Closed-cycle cooling systems are assumed for all alternatives.

Table 9-1 shows that the significance of the environmental impacts of the proposed action

would be SMALL, except in one instance: collective offsite radiological impacts from the fuel

cycle and from HLW and spent fuel disposal, for which a single significance level was not

assigned (see Chapter 6). The alternative actions, including the no-action alternative, may have

environmental impacts in at least some impact categories that reach MODERATE or LARGE

significance.

9.3 NRC Staff Conclusions and Recommendations

Based on (1) the analysis and findings in the GEIS (NRC 1996, 1999), (2) the ER submitted by

NMC (NMC 2005b), (3) consultation with Federal, State, and local agencies, (4) the NRC staff’s

own independent review, and (5) the NRC staff’s consideration of public comments received

during the scoping process, the recommendation of the NRC staff is that the Commission |

determine that the adverse environmental impacts of license renewal for Palisades would not be

so great that preserving the option of license renewal for energy-planning decision makers

would be unreasonable.
Table 9-1. Summary of Environmental Significance of License Renewal, the No-Action Alternative, and Alternative

 Methods of Generation Using Closed-Cycle Cooling

Proposed

Action

No-Action

Alternative

Coal-Fired

Generation Natural-Gas-Fired Generation

New Nuclear

Generation

Combination of

Alternatives

Impact Category

License

Renewal

Denial ofRenewal Alternate Site Palisades Site Alternate Site Palisades Site Alternate Site Palisades Site Alternate Site

Land use SMALL SMALL MODERATE to

LARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

Ecology SMALL SMALL MODERATE to

LARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

Water useand quality–surface water

SMALL SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

SMALL toMODERATE

SMALL toMODERATE

Water use andquality–groundwater

SMALL SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

SMALL SMALL to

MODERATE

Air quality SMALL SMALL MODERATE MODERATE MODERATE SMALL to

MODERATE

SMALL toMODERATE

MODERATE MODERATE

Waste SMALL SMALL MODERATE SMALL SMALL SMALL SMALL SMALL SMALLHuman health SMALL(a) SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Socioeconomics SMALL SMALL to LARGE SMALL to LARGE SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL to LARGE SMALL to MODERATE SMALL to MODERATE

Transportation SMALL SMALL SMALL to

LARGE

SMALL to MODERATE

SMALL toMODERATE

SMALL toLARGE

SMALL toLARGE

SMALL toMODERATE

SMALL toMODERATE

Aesthetics SMALL SMALL MODERATE to

LARGE

MODERATE MODERATE to

LARGE

SMALL toMODERATE

MODERATE toLARGE

MODERATE toLARGE

MODERATE toLARGE

Historic andarchaeologicalresources

 SMALL SMALL SMALL to

MODERATE

SMALL toMODERATE

SMALL toMODERATE

SMALL toMODERATE

SMALL toMODERATE

SMALL toMODERATE

SMALL toMODERATE

Environmental justice

SMALL SMALL to 

LARGE

SMALL toMODERATE

SMALL to MODERATE

SMALL toMODERATE

SMALL toMODERATE

SMALL toLARGE

SMALL toMODERATE

SMALL toMODERATE

(a) Except for collective offsite radiological impacts from the fuel cycle and from HLW and spent fuel disposal, for which a significance level was not assigned. See Chapter 6 for |

details.

NUREG-1437, Supplement 27 9-8 October 2006

Summary and Conclusions
Summary and Conclusions

October 2006 9-9 NUREG-1437, Supplement 27

9.4 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

Nuclear Management Company, LLC (NMC). 2005a. Palisades Nuclear Plant. Application for

Renewed Operating License. Covert, Michigan. (March 22, 2005).

Nuclear Management Company (NMC). 2005b. Applicant’s Environmental Report – Operating

License Renewal Stage, Palisades Nuclear Plant. Docket No. 50-255. Covert, Michigan. 

March, 2005).

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to

Operation of Palisades Nuclear Plant, Nuclear Management Company. Docket No. 50-255. 

Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report.” NUREG-1437 Vol. 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. NUREG-1555,

Supplement 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005a. “Notice of Intent to Prepare an

Environmental Impact Statement and Conduct Scoping Process.” Federal Register, Vol. 70,

No. 122, pp. 36967-36968. Washington, D.C. (June 27, 2005).

U.S. Nuclear Regulatory Commission (NRC). 2005b. Environmental Impact Statement Scoping

Process: Summary Report – Palisades Nuclear Plant, Van Buren County, Michigan. 

Washington, D.C. |

Appendix A

Comments Received on the Environmental Review

 

October 2006 A-1 NUREG-1437, Supplement 27

Appendix A

Comments Received on the Environmental Review

Part I – Comments Received During Scoping

On June 27, 2005, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of Intent

in the Federal Register (Volume 70, page 36967) to notify the public of the NRC staff’s intent to

prepare a plant-specific supplement to the Generic Environmental Impact Statement for License

Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2, to review the renewal

application for the Palisades operating license and to conduct scoping. The plant-specific

supplement to the GEIS has been prepared in accordance with the National Environmental

Policy Act (NEPA) of 1969, as amended, Council on Environmental Quality (CEQ) guidance,

and Part 51 of Title 10 of the Code of Federal Regulations (10 CFR Part 51). As outlined by

NEPA, the NRC initiated the scoping process with the issuance of the Federal Register Notice. 

The NRC invited the applicant; Federal, State, and local government agencies; Native American

tribal organizations; local organizations; and individuals to participate in the scoping process by

providing comments at the scheduled public meetings and/or by submitting written suggestions

and comments no later than August 22, 2005. 

The scoping process included two public scoping meetings that were held at Lake Michigan

College, South Haven, Michigan, on July 28, 2005. Approximately 65 members of the public

attended the meetings. Both sessions began with NRC staff members providing a brief

overview of the license renewal process and the NEPA process. After the NRC’s prepared

statements, the meetings were open for public comments. Nineteen attendees provided oral

statements that were recorded and transcribed by a certified court reporter and written

statements that were appended to the transcript. The meeting transcripts are attached to the

October, 2005, Scoping Meeting Summary and supplement dated September 21, 2005. In

addition to the comments received during the public meetings, eight comment letters and copies

of two news articles were received by the NRC in response to the Notice of Intent.

At the conclusion of the scoping period, the NRC staff and its contractor reviewed the

transcripts and all written materials to identify specific comments and issues. Each set of |

comments from a given commenter was given a unique identifier (Commenter ID), so that each

set of comments from a commenter could be traced back to the transcript or letter by which the

comments were submitted. Specific comments were numbered sequentially within each

comment set. Several commenters submitted comments through multiple sources

(e.g., afternoon and evening scoping meetings). All comments received and NRC staff

responses are included in the Palisades Scoping Summary Report dated December 14, 2005.

Table A-1 identifies the individuals who provided comments applicable to the environmental

review and the Commenter ID associated with each person’s set(s) of comments. The
Appendix A

NUREG-1437, Supplement 27 A-2 October 2006

| individuals are listed in the order in which they spoke at the public meeting. To maintain

consistency with the Palisades Scoping Summary Report, the unique identifier used in that

report for each set of comments is retained in this appendix.

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by the commenters. 

The comments fall into one of the following general groups:

 C Specific comments that address environmental issues within the purview of the NRC

environmental regulations related to license renewal. These comments address

Category 1 or Category 2 issues or issues that were not addressed in the GEIS. They

also address alternatives and related Federal actions. 

 C General comments (1) in support of or opposed to nuclear power or license renewal or

(2) on the renewal process, the NRC’s regulations, and the regulatory process. These

comments may or may not be specifically related to the Palisades license renewal

application.

 C Questions that do not provide new information.

 C Specific comments that address issues that do not fall within or are specifically excluded

from the purview of NRC environmental regulations related to license renewal. These

comments typically address issues such as the need for power, emergency

preparedness, security, current operational safety issues, and safety issues related to

operation during the renewal period.
Appendix A

October 2006 A-3 NUREG-1437, Supplement 27

Table A-1. Individuals Providing Comments During Scoping Comment Period

Commenter 

ID Commenter

Affiliation 

(If Stated) Comment Source(a)

PS-A Ken Richards Afternoon Scoping Meeting |

PS-B Kevin Kamps Nuclear Information and Resource Service Afternoon Scoping Meeting |

PS-C Barbara Geisler Afternoon Scoping Meeting |

PS-D Corinne Carey Don’t Waste Michigan Afternoon Scoping Meeting |

PS-E Dale Lewis Mayor, South Haven Afternoon Scoping Meeting |

PS-F Tom Tanzlos County Commissioner, First District of Van |

Buren County

Afternoon Scoping Meeting

PS-G Paul Harden Site Vice President of Palisades Afternoon Scoping Meeting |

PS-H Nancy Whaley Afternoon Scoping Meeting |

PS-I Leroy Wolins Afternoon Scoping Meeting |

PS-J Chuck Jordan Afternoon Scoping Meeting |

PS-K Michael Keegan Evening Scoping Meeting |

PS-L Gary Karch Evening Scoping Meeting |

PS-M Kathy Barnes Evening Scoping Meeting |

PS-N Corinne Carey Don’t Waste Michigan Evening Scoping Meeting |

PS-O Maynard Kaufman Evening Scoping Meeting |

PS-P Ken Richards Evening Scoping Meeting |

PS-Q Kevin Kamps Nuclear Information and Resource Service Evening Scoping Meeting |

PS-R Ross Stein Supervisor, South Haven Charter Township Evening Scoping Meeting |

PS-S Paul Harden Site Vice President of Palisades Evening Scoping Meeting |

PS-T Larry King Greater South Haven Chamber of Commerce Evening Scoping Meeting |

PS-U Elizabeth Anderson Evening Scoping Meeting |

PS-V Marilyn Miller Evening Scoping Meeting |

PS-W Wayne Rendell Supervisor, Covert Township Evening Scoping Meeting |

PS-X Tonya Schuitmaker Letter (ML052420495) |

PS-Y Nancy Ann Whaley Supervisor, Geneva Township Letter (ML052420497) |

PS-Z Wayne Rendell Supervisor, Covert Township Letter (ML052420503) |

PS-AA Swami Tapasanarda Letter (ML052420506) |

PS-BB Murielle and John Clark Letter (ML052510389) |

PS-CC Gary Karch Letter (ML052510391) |

PS-DD Kathryn Barnes Letter (ML052510393) |

PS-EE Kevin Kamps Nuclear Information and Resource Service Letter (ML052510468) |

PS-FF Kevin Kamps Nuclear Information and Resource Service Letter (ML052420502) |

PS-GG Kenneth Richards Letter (ML052420501) |

(a) The afternoon and evening transcripts can be found under accession numbers ML052630432 and ML052630449,

respectively.
Appendix A

NUREG-1437, Supplement 27 A-4 October 2006

Comments applicable to this environmental review and the NRC staff’s responses are

| summarized in this appendix. The parenthetical alphanumeric identifier after each comment

refers to the comment set (Commenter ID) and the comment number. This information, which

was extracted from the Palisades Scoping Summary Report, is provided for the convenience of

those interested in the scoping comments applicable to this environmental review. The

comments that are general or outside the scope of the environmental review for Palisades are

not included here. More detail regarding the disposition of general or inapplicable comments

can be found in the Summary Report. The Agencywide Document Access and Management

System (ADAMS) accession number for the Scoping Summary Report is ML053490390.

This accession number is provided to facilitate access to the document through the Public

Electronic Reading Room (ADAMS) (http://www.nrc.gov/reading-rm.html).

Comments in this section are grouped in the following categories:

A.1.1 License Renewal Process

A.1.2 Support of License Renewal at Palisades Nuclear Plant

A.1.3 Opposition to License Renewal at Palisades Nuclear Plant

A.1.4 Opposition to Nuclear Power

A.1.5 Aquatic Ecology

A.1.6 Threatened and Endangered Species

A.1.7 Surface-Water Quality, Hydrology, and Use

A.1.8 Human Health

A.1.9 Socioeconomics

A.1.10 Postulated Accidents

A.1.11 Uranium Fuel Cycle and Waste Management

A.1.12 Alternative Energy Sources

A.1 Comments and Responses

A.1.1 Comments Concerning License Renewal and Its Processes

Comment: I'm glad you are asking for public input. And it may be that NRC meetings are of a

different sort. Maybe hearings that I have attended in the past have needed to seem almost

closed. But I'm reading from someone in your system who says, I am truly embarrassed by the

way the public is systematically excluded from the regulatory process. It reminds me of the old

Soviet bloc countries when they conducted elections with only one name on the ballot. The

nuclear industry is carrying a sign in one hand proclaiming that nuclear power is a solution to

the global warming problem. It's other hand is locking the door on public participation in the

regulatory process. Now today so far that doesn't seem to be true. So I'm hoping that there's
Appendix A

October 2006 A-5 NUREG-1437, Supplement 27

been a change within the NRC and those plants that it is in a sense responsible for, and that,

not just at this meeting, but at all meetings, comments will be taken seriously as a part of a

democratic planning process. (PS-C-8)

Comment: I'd like to commend the NRC for having these meetings at times that people could

come whether during the day or in the evening. I think that is a change that's very good. 

(PS-J-1)

Comment: I really can't truly say that I feel NRC or the company representatives are truly

advocates of the public. And, I understand there are some areas that do have such a

commission or an individual, I think Wisconsin has something close to that, if anybody can

correct me. I understand that Nevada has something in that line, where the public truly feels

that, that they are truly represented. And, I just don't think that that's our feeling here. Even

though you're nice guys; I don't, I'm not questioning that you're nice guys. I'm just feeling that

the system needs more to be viable. (PS-–18)

Comment: A process that appears designed to intentionally disenfranchise a population with

which it is supposed to promote dialogue can only be looked at with skepticism and must be

considered a ruse and a sham. Although the model as presented for public comment regarding

the request for a 20-year license extension for the Palisades Nuclear Plant in Van Buren

County, Michigan, meets guidelines as established by the NRC, it provides little opportunity and

draconian deadlines for true citizen participation to exist. Such restrictions may have been

dismissed by communities in which other license renewals have been requested and approved,

but I submit that Southwest Michigan holds itself to higher standards and wishes to challenge

the industry paradigm and demand a more reasonable and humane response to this license

renewal process than the flawed one that has been foisted upon us. 

Current standards only allow for easy participation from persons living within the industrydesignated 10-mile radius emergency planning zone. Obviously radiation travels far greater

distances than that, and even the extended 50-mile radius does not realistically encompass the

distance a radiation release can travel. Meetings have been scheduled only in the South Haven

area with limited publicity and at times that impede a working public's ability to attend. These

dates and locations may be convenient for Palisades representatives and NRC staff but not to

residents in the greater area affected by the plant's existence. For example, the next public

meeting in which these and other comments submitted by today's deadline will be discussed is

scheduled for the Friday before Labor Day. This insults the public, inhibits participation by

interested citizens, and denigrates the integrity of the process. 

Materials pertinent to the license currently available only at the South Haven library should be

made available in a majority of libraries located within the 50-mile radius. The whole process

needs to be expanded to include public meetings and comment opportunities in all communities
Appendix A

NUREG-1437, Supplement 27 A-6 October 2006

within the entire 50-mile radius who wish to request them. If the plant owners and managers

have nothing to hide and take pride in their operation, then they should have no reservations

about taking their meetings on the road and extending the process to a more reasoned pace. 

And if the NRC believes in the integrity of their process, they should likewise be up to this

challenge. It is 6 years before the current license expires. There is no need to rush through the

process. In fact, a more lengthy approach that is truly inclusive of citizen participation from

affected communities should be encouraged. (PS-CC-1)

Response: The comments are in regard to license renewal and its processes in general. The

Commission has established a process, by rule, for the environmental and safety reviews to be

conducted to review a license renewal application. The development of the Commission's

regulations governing the license renewal process was subject to public review and comment. 

The comments will not be evaluated further. 

Comment: On this August 22nd deadline. When does the clock start ticking on that, and I

guess why such a short deadline given that today is July 27th? (PS-B-2)

Comment: And I would ask that the August 22nd deadline for comments be extended because

this really is the first opportunity for people to learn about this environmental review process. 

So that doesn't leave much time for people to get up to speed to read these very thick

documents and to submit comments. And I guess I'd just like to end by saying that there's a

growing coalition of individuals and organizations in this area who fully intend on intervening

against the license extension at Palisades. And we would, perhaps this isn't the exact correct

forum, but we would express a request for an extension to that August 8th deadline as well,

given the limited resources of these nonprofit groups and individuals. (PS-B-19)

Comment: And, the last thing that I'll bring up is, I have to choose here. I would again

reemphasize the importance of extending the deadlines, because we're 5 years out right now

from the year 2011 when this license expires. So, the question is, what's the rush? Why are

these deadlines so rushed? And, also, it's a 20-year license extension. So, we should have

more than just 60 days to comment on 20 years of impacts. But, of course, as Mr. Karch said,

it's a lot longer than 20 years. The waste is going to be here forever. (PS-Q-13)

Comment: The public is not given enough notification about the meetings, and the meetings

are few and poorly scheduled for times most cannot attend. The public is expected to offer

comments on the EIS and scope and screening, etcetera, without adequate preparation. 

Although the current license is valid through 2011, at this time, 2005, an extension is being

sought and the time allotted for public comment, debate, and even awareness is under pressure

and time constraints. What is the rush? I would like to request an extension beyond August 22

for public comment on the scope of the Palisades-specific supplement to the generic

environmental impact statement for a much later date after the public is aware of such

documentation and such is offered. (PS-DD-4)
Appendix A

October 2006 A-7 NUREG-1437, Supplement 27

Comment: 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 a 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. (PS-EE-40)

Response: The comments request an extension to the scoping comment period. The

U.S. Nuclear Regulatory Commission (NRC) established the time period for comments on the

scope of the environmental review for license renewal to balance the Commission’s goal of

ensuring openness in the regulatory processes, with its goal of ensuring that the NRC’s actions

are effective, efficient, realistic, and timely. The requests did not provide a sufficient basis for

an extension to the established comment period. The comments will not be evaluated further.

The regulations permit a nuclear power plant licensee to apply to the NRC to renew a license as

early as 20 years before expiration of the current license. The NRC staff has determined that

20 years of operating experience is sufficient to assess aging and environmental issues at the

site. A major consideration for seeking license renewal so far in advance of the expiration date

of the current license is that it can take up to about 10 years to design and construct major new

generating facilities, and long lead times are required by energy-planning decision makers. 

Comment: I'd also like to point out that this entire licensing or license extension proceeding is

premature because the Nuclear Regulatory Commission is reevaluating its pressurized thermal

shock rule. And this revision is not complete. So, this proceeding should be postponed until

after that proceeding is complete. And, I need clarification from the NRC as to whether the old

rule applies at Palisades or the new rule is going to apply at Palisades. And, for that reason

alone, this entire proceeding should be postponed. That's another reason for the deadlines to

be extended. (PS-Q-5)

Response: Nuclear plant licensees are required to comply with all applicable currently effective

NRC regulations, including the Pressurized Thermal Shock (PTS) Rule. In the event that the

PTS Rule is revised, Nuclear Management Company, LLC (NMC), the Palisades licensee, will

be expected to comply with the new rule in accordance with the effective date and any

implementation date provided for in the revised rule. The comment will not be evaluated further.

Comment: Further, I would ask as I have at public meetings, that certain essential elements

not be excluded from evaluation. 
Appendix A

NUREG-1437, Supplement 27 A-8 October 2006

4. The actual and complete analysis of the plant by a scientific and independent agency, and

not by Palisades or its subsidiaries, and an analysis not dependent on documentation by

Palisades, but based on the actual scientific evaluation of the current status of the facility,

including, but not limited to, embrittlement. (PS-DD-7)

Response: NRC is an independent agency established by the Energy Reorganization Act of

1974 to regulate civilian use of nuclear materials. The NRC's mission is to regulate the nation's

civilian use of by-product, source, and special nuclear materials to ensure adequate protection

of public health and safety, to promote the common defense and security, and to protect the

environment. As part of this mission, the NRC is responsible for the reviewing and issuance of

initial licenses and renewed licenses for nuclear power facilities. 

The Advisory Committee on Reactor Safeguards (ACRS) is an advisory committee mandated

by the Atomic Energy Act of 1954, as amended, under the Federal Advisory Committee Act

(FACA). The ACRS is independent of the NRC staff and reports directly to the Commission,

which appoints its members. The operational practices of the ACRS are governed by the

provisions of the FACA. The ACRS is composed of recognized technical experts in their fields. 

It is structured so that experts representing many technical perspectives can provide

independent advice, which can be factored into the Commission’s decision-making process. 

| Most ACRS meetings are open to the public, and any member of the public may request an

| opportunity to make an oral statement during a committee meeting. 

During the license renewal process, the ACRS acts as an independent third-party oversight

group that reviews and makes recommendations to the Commission on the safety aspects of

renewal applications. The ACRS mandate does not include National Environmental Policy Act

(NEPA) reviews. The comment will not be evaluated further.

Comment: I'm looking forward to intervening. But, on the schedule that you put up with all the

dates, perfunctory meetings and niceties, I didn't see a scheduling for the ASLB in there. And,

what happens once we intervene? And, what happens to this process then? (PS-K-5)

Response: The Atomic Safety and Licensing Board establishes schedules for its proceedings

independently of the NRC staff's safety and environmental reviews. The schedule established

by the board is dependent upon the filing of petitions and motions by interested parties. 

| The schedule initially established by the NRC staff for the safety and environmental reviews

presumes that a hearing will be held. This schedule will be revised as appropriate during the

| review based on the board's decisions on the admissibility of any contentions filed. The

comment will not be evaluated further.
Appendix A

October 2006 A-9 NUREG-1437, Supplement 27

Comment: Relating to the EIS, is an Environmental Impact Statement required, or are you

going to be looking at an environmental assessment with a FONSI [Finding of No Significant

Impact], or are we going to have a full EIS? (PS-K-2)

Response: The Commission has decided that the NRC will prepare a site-specific supplement

(SEIS) to the generic environmental impact statement on license renewal (GEIS; NUREG-1437)

for each license renewal application. This decision was made to ensure that the public had the

highest level of participation in and confidence about the NRC’s action on a license renewal

application. The NRC will be issuing a supplement to the GEIS for the renewal of the operating

license (OL) of Palisades Nuclear Plant. The comment will not be evaluated further.

A.1.2 Comments in Support of License Renewal at Palisades Nuclear Plant

Comment: Our City Council passed a resolution favoring the renewal of the Palisades license

agreement or renewal. Palisades has been a very good neighbor to South Haven. We kind of

wish though that it was in the city so we get more taxes. Palisades has provided many good

paying jobs and that's what we're looking for. And Palisades is probably the biggest single

employer of our citizens of South Haven. It would be very detrimental to the economy of South

Haven, you know, if Palisades were to close. (PS-E-1)

Comment: The plant was built in 1971 and began operation about that time. But I think the

track record over the last 35 years has indicated that the plant has operated in an

environmentally safe manner. It has been closed down from time to time for refurbishing and

changes that come along. (PS-F-1)

Comment: The Mayor is right, it is a large employer to the community. A large part of our tax

base. But if it wasn't for the safe operation of that plant we would not support its continued

operation. (PS-F-2)

Comment: On March 22nd, we unanimously passed a resolution in support of the continuing

operation of the plant and the extension of the license. (PS-F-3)

Comment: Palisades has received letters and resolutions of support from 13 different local

government bodies, including the City of South Haven; the townships of Covert, South Haven,

Geneva, Antwerp, Columbia, Decatur, and Pine Grove; the Greater South Haven Area Chamber

of Commerce; U.S. Representative Fred Upton; and the concurrent resolution from the Michigan

State House and Senate. These bodies wouldn't have supported our license renewal if they

also didn't feel that we could continue to be a safe provider for another 20 years. (PS-G-3;

PS-S-2)
Appendix A

NUREG-1437, Supplement 27 A-10 October 2006

Comment: At our April 12th, 2005, board meeting, the Geneva Township Board unanimously

voted to support the license renewal by resolution which was presented to Mark Savage at this

meeting. It is my strong belief that the negative personal and economic impact that all of us will

feel if the operating license for Palisades is not extended. The loss would be a great magnitude

to this community. (PS-H-2)

Comment: Earlier in the year, we passed a motion at a township board meeting supporting the

licensing process for Palisades Nuclear Plant. Palisades has been an excellent neighbor for the

community. The people that work there are civic minded. We have people that are Boy Scout

leaders, have served on township boards. Palisades has been very community oriented. 

They've helped the, I'm chairman of the emergency services. They've helped the fire

department, the emergency services. They help community functions also, so, it's a very

welcome aspect to this community. The people there provide, buy homes, have children for the

schools. (PS-R-1)

Comment: As probably everybody in this room knows, for every dollar that's spent in the

community, that dollar's circulated six or seven times, so it's a good economic asset to the

community. (PS-R-2)

Comment: And, you can see in that involvement their commitment to safety out at the plant. I

do know a number of folks that work out there, and they are very safety conscious, and they

bring that home with them and into the work that they do in the community and in their social

lives. So, we're very pleased to have the plant here, and encourage the relicensing and

reinvestment here in the South Haven Area. (PS-T-2)

Comment: I really didn't come prepared to speak, but, I wanted to correct, Gary Karch said

Covert hasn't benefitted from this power plant. That's very far from the truth. We have a

wonderful fire department, we have a full time police department. We have water throughout

the township. Without Consumers help with this, that wouldn’t happen. Covert is very much in

favor of this renewal. (PS-W-1)

Comment: Attached is a copy of House Concurrent Resolution 8 sponsored by myself

supporting the relicensure of Consumer Energy’s Palisades Nuclear Power Plant. This

resolution was adopted unanimously by the Michigan Legislature demonstrating our position

that the State of Michigan fully supports the relicensure and long-term support of this facility. 

(PS-X-1)

Comment: As the Representative of Covert, home of Palisades, I can assure you of their

outstanding and expletory record throughout the community as an employer, neighbor, and

communicator with the entire Southwest Michigan area. Consumers Energy works tirelessly to

keep the public informed and give surety to individuals with questions or concerns. (PS-X-2)
Appendix A

October 2006 A-11 NUREG-1437, Supplement 27

Comment: At the April 12, 2005, board meeting, the Geneva Township Board unanimously

voted to support the license renewal by resolution which was presented to Mark Savage at that

meeting. (PS-Y-5)

Comment: It is my strong belief that the negative personal and economic impact that all of us

will feel if the operating license for Palisades is not extended would be of great magnitude to

this community. I am asking your full support for the 20-year renewal of the licensing of

Palisades. (PS-Y-6) 

Comment: Throughout the years, Consumers Energy (now managed by Nuclear Management

Company) and the Palisades Nuclear Plant have been good neighbors. Covert Township is

very much in support of their efforts to get their operating license renewal. (PS-W-5)

Response: The comments are supportive of license renewal at Palisades and are general in

nature. The comments will not be evaluated further.

A.1.3 Comments in Opposition to License Renewal at Palisades Nuclear Plant 

Comment: I understand that many people are employed by Palisades and it's a part of the

economy here and that makes it difficult to criticize. However, if we look ahead to the seventh

generation, as Native Americans say, there are some problems. (PS-C-3)

Comment: We do not need it, and we should stop making it as fast as we can. And the

quickest way to do that in this area; we have a chance, we don't have to do anything. We just

have to get the NRC to not renew the license of these people out here who are producing all

this death potential waiting for that clunk, clunk, clunk, clunk for somebody to drill a hole and

open up Pandora's Box and kill God knows how many millions of people. Because that is the

ultimate result of nuclear power. Whether, how safe it is now it's like jumping off the Empire

State Building. As you go by the fifty-second story, see I haven't been hurt a bit. (PS-I-8)

Comment: But this is very important, and I hope people will listen that death is coming if we

stay with these nuclear power plants, and this is one chance to get rid of one of them. (PS-I-9)

Comment: We are opposed to renewing the Palisades license for two main reasons. (PS-J-3)

Comment: So we as Greens oppose the renewal of the Palisades Plant because of its age,

because it's old, and because there are no solutions to what to do with the waste. (PS-J-7)

Comment: It's all public risk, private profit. And, I have a problem with that. And, this is an

aging plant...This plant should have been shut down in 1981. (PS-K-12)
Appendix A

NUREG-1437, Supplement 27 A-12 October 2006

Comment: I also have a problem with them, Consumers having a fire where trailers of

documentation were burnt on the casks; the documentation about the cask was burnt in a fire

that was suspect and is still under, I don't know if it's still under investigation, but, I don't believe

arson was ever ruled out. A caveat to that was that Consumers Power did provide the local fire

department, about 5, 6 years previously, with about an $800,000 piece of fire equipment. So, if

it looks like a duck, walks like a duck, smells like a duck, it's a duck. And this is a rotten eggs

here. So, don't bring us 20 more years of this. (PS-K-15)

Comment: So, I would just point that out. Let's not make 20 more years, because there

certainly is no place for that. There's no place for the first 40 years of waste. (PS-K-16)

Comment: So, I have a lot of concerns about this [Palisades] and I think that it needs to be

shut down. (PS-—16)

Comment: And, I think that another 20 years of this nuclear power plant in operation is risking

a meltdown and I don't want it. And, I think anybody in this room does not want that to happen

here. And, honestly, I think from studying everything, especially because it's too much of the

fox in the hen house doing the reporting, it just cannot be guaranteed. (PS-—19)

Comment: We need to not sell our souls for jobs or for a “solution” that creates eons of

poisonous aftermath. (PS-–12)

Comment: You know, I know I'm being sold a bill of goods here. I know we're got this 40-year

old reactor out there that we're going to just, we're going to run it for another 20 years. I'm

nervous about that. It gives me great cause for concern, and I just don't think it's a good idea. 

(PS-P-2)

Comment: We can turn this greenhouse effect around. We can fix these problems, but right

now, we want most of our resources going to what's making the right people a lot of money. 

And, they're just trapped there. And, we're just getting this continual PR [expletive] that that's all

going to be okay. And, I just don't want South Haven, I don't want my hometown to be the place

where this really goes wrong, when the world gets taught a lesson it'll never forget, like they had

to do over in Russia. Not here. (PS-P-5)

Comment: I just think that maybe it's good, we've got a new power plant right across the way. 

And, maybe that could just, you know, ease this one [Palisades Nuclear Plant] out and pump

this one up. (PS-U-3)

Comment: Relicensing Palisades Nuclear Plant in Michigan is a bad idea. (PS-AA-1)
Appendix A

October 2006 A-13 NUREG-1437, Supplement 27

Comment: I support saving nuclear power. Put money into Pebble Bed Reactors. We don’t

need another meltdown like Chernobyl! I live nearby! If you do give it another 20 years at least

send iodine tablets to everyone in a 50-mile radius! (PS-AA-2)

Comment: The United States decided to put nuclear on hold for a lot of reasons; nothing has

changed with respect to those concerns, to fire up nuclear generation again. The Great Lakes

are far to valuable a water resource to have it ringed by nuclear power plants and nuclear waste

storage. (PS-BB-3)

Comment: We vote NO. (PS-BB-4)

Response: The comments oppose license renewal at Palisades Nuclear Plant and are general

in nature. The comments will not be evaluated further.

Comment: I feel that to relicense a dangerous, embrittled, and aged plant on the shores of

Lake Michigan is pure folly as is the storage of the spent fuel rods which many of us tried

through an organization called Palisades Watch to stop a few years ago. We were

unsuccessful. I feel this plant should be shut down and retired for service as I believe was

originally planned. I may be confused about that but I thought in all of these plants in the

beginning it was said, you know, they won't operate forever. They'll last a certain amount of

time then they'll be retired because they're not going to be safe after that. So I'm confused as to

why relicense, relicense, relicense, how long would this go on? I need more information. I do

not feel that it is socially or fiscally prudent to relicense Palisades. I feel it is unacceptable to put

local residents at such grave risk. (PS-C-10)

Comment: I say, our psychological body burden, we've had enough psychological body burden

in Michigan, here, especially in southwestern Michigan. We've got [DC] Cook and it's probably

a done deal that they're going to get another 20 years. But, we don't need this little Palisades

with all its history of safety infractions in the hundreds that made headlines over the years. We

don't need this anymore. (PS-L-4)

Comment: I believe because of the embrittlement of Palisades, and because of the history of

problems with the plant, including staff/management problems and repair backlogs, and after

speaking with local residents and finding that there is a cancer pocket in the beach community,

and that Palisades has repeatedly asked for safety exceptions to keep operating, one can only

conclude that this is a nuclear reactor that is past due and should not be relicensed. (PS-DD-1)

Comment: Since the water of the Great Lakes is being bottled and sold as drinking water, it is

an invaluable resource to the citizens of the region and the world. It is not enough to repair

problems as they occur, but it is imperative to put an end to the premise that such repairs will
Appendix A

NUREG-1437, Supplement 27 A-14 October 2006

always be possible, and in acknowledging that with a cracked and aging nuclear facility, that is,

Palisades, it is not worth the risk to keep it running. (PS-DD-8)

Response: The NRC makes the decision to grant or deny a license renewal based on whether

the applicant has demonstrated that the environmental and safety requirements in the NRC’s

| regulations can be met during the renewal term. The NRC’s ongoing reactor licensing and

oversight programs focus on prevention of safety problems so that potential issues such as

aging and reactor vessel embrittlement do not lead to accidents and subsequent environmental

impacts. The intent of the NRC’s safety review is to determine if the licensee has adequately

demonstrated that the effects of aging will not adversely affect any systems, structures, or

components identified in Part 54.4 of Title 10 of the Code of Federal Regulations (10 CFR 54.4). 

The safety review process includes site inspections to assess whether the applicant has

implemented and complied with the regulations for license renewal. The review results in a

publicly available Safety Evaluation Report (SER) available online at http://www.nrc.gov/. The

comments oppose license renewal and are general in nature. The comments will not be

evaluated further.

Comment: It is time to close it. It should have been closed a long time ago. We would have

had less waste lying out on the shores of Lake Michigan ready for terrorists to make possible

use of. (PS-I-5)

Response: The NRC and other Federal agencies have heightened vigilance and implemented

initiatives to evaluate and respond to possible threats posed by terrorists, including the use of

aircraft against commercial nuclear power plants and independent spent fuel storage

installations (ISFSIs). Malevolent acts remain speculative and beyond the scope of a NEPA

review. The NRC routinely assesses threats and other information provided to it by other

Federal agencies and sources. The NRC also ensures that licensees meet appropriate security

levels. The NRC will continue to focus on prevention of terrorist acts for all nuclear facilities and

will not focus on site-specific evaluations of speculative environmental impacts. While these are

legitimate matters of concern, they should continue to be addressed through the ongoing

regulatory process as a current and generic regulatory issue that affects all nuclear facilities. 

The NRC has taken a number of actions to respond to the events of September 11, 2001, and

plans to take additional measures. However, the issue of security and risk from malevolent acts

at nuclear power plants is not unique to facilities that have requested a renewal to their license

and, therefore, will not be addressed within the scope of this SEIS. The comment opposes

license renewal at Palisades and will not be evaluated further.

A.1.4 Comments in Opposition to Nuclear Power

Comment: Anyway I was very interested in atomic power and along came my Scientific

American and my Popular Mechanics and so on. We're going to have electricity for one cent a
Appendix A

October 2006 A-15 NUREG-1437, Supplement 27

kilowatt hour I was told on the cover of one of those magazines. This is atomic energy. And I

believed it all. I have since come to believe otherwise. (PS-I-1)

Comment: It is false pride, and it is not worth it, because, you talk about kids. What are you

going to do if there is a meltdown? How are you ever going to get your kids back? You won't. 

You will give everything you have to get your life back and get your kids back. You might have

kids that have cancer. You might have kids that are killed instantly. You could have kids that

will have kids like at Chernobyl, your grandkids might be mutated. I mean, I've met the kids of

Chernobyl. And, if you saw those kids, how wounded they were. They were blind, they were

handicapped, it was so sad. And, there was American kids who were healthy and playing and

vibrant and alive and here are these poor kids. And, the only difference is, a meltdown. 

(PS-—18)

Comment: Now, I have the impression after 20 years of Don't Waste Michigan, that the public

really doesn't know very much about nuclear issues although I think that, at least I find there are

people scattered everywhere I go that are very much interested because they realize that

energy is one of the major issues that is part of our world today and our future, my grandkids'

time. And, that, yes, we need to do something about these energy issues. But, I still, I'm very

much, I'm sorry, my e-mail address is [auntynuke]. And, so you can contact me, [auntynuke]

AOL.com. (PS-–3)

Comment: I think, I agree with him, that the only place for a nuclear reactor is on the sun and

obviously we're not going to shoot the waste or do our nuclear stuff on the sun because getting

up there is the other part of the problem. (PS-–4)

Comment: One more comment about clean. Nuclear power is clean in that you cannot taste,

or you cannot smell it. You can't see it, you can't write your name on it on the windshield of the

car. The particulates are so very very fine that when they use it in depleted uranium

ammunition, etcetera, which is involved quite directly with the whole power situation, that the

very very fine particulate is very incendiary, and anytime it's, a metal piercing ammunition is, I

understand is depleted uranium whether it's done by plane or some ground firing or whatever. 

But, it's very very fine and it burns and it invades the environment. Now, how much of that very

fine particulate is also part of the picture of a nuclear power plant? How much does it invade

the environment, in comparison to the heavy particulates of fossil fuels? Oh, and clean, I

mentioned this morning that I understand that yes, you can taste a radioactive exposure. It

gives a metallic taste on the tongue, you taste a penny. So, I'm not a scientist, obviously, but I

am very concerned that we need all forms of science and the emotion that comes from human

beings in order to take good care of my five grandkids. (PS-–13)
Appendix A

NUREG-1437, Supplement 27 A-16 October 2006

Comment: We can't really call it clean when we look at the results of the DU ammo. Depleted

uranium ammunition that is being used has been used in every war the United States has been

in since Bosnia including Afghanistan, including two now in the Iraq area etcetera. (PS-D-7)

Comment: I don't want to see anybody lose their jobs. But, I must admit, I was raised by

people who were against nuclear power. (PS-U-1)

Response: The comments oppose nuclear power, in general, and will not be evaluated further.

A.1.5 Comments Concerning Aquatic Ecology Issues

As stated in 10 CFR Part 51, Table B-1, Category 1 aquatic ecology issues for plants with

| cooling-tower heat dissipation systems include:

Category 1

• Accumulation of contaminants in sediments or biota

• Entrainment of phytoplankton and zooplankton

• Cold shock

• Thermal plume barrier to migrating fish

• Distribution of aquatic organisms

• Premature emergence of aquatic insects 

• Gas supersaturation (gas bubble disease)

• Low dissolved oxygen in the discharge

• Losses from predation, parasitism, and disease among organisms exposed to sublethal

stresses

• Stimulation of nuisance organisms (e.g., shipworms)

• Entrainment of fish and shellfish in early life stages

• Impingement of fish and shellfish

• Heat shock

Comment: 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 [International Joint Commission]

also called for virtual elimination of toxic discharges into the Great Lakes, and identified

radionuclides 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 bioaccumulation of radionuclides in Great Lakes biota. 

(PS-EE-14)

Response: The accumulation of contaminants is a Category 1 issue that has been evaluated

in the GEIS. All effluent discharges are regulated under the provisions of the Clean Water Act
Appendix A

October 2006 A-17 NUREG-1437, Supplement 27

and the implementing effluent guidelines, limitations, and standards established by the

U.S. Environmental Protection Agency (EPA) and the delegated State authorities. Conditions of |

discharge for each plant are specified in its National Pollutant Discharge Elimination System |

(NPDES) permit issued by the State or the EPA. [In its response to the Ninth Biennial

International Joint Commission (IJC) Report, the EPA concluded that “The U.S. will continue to

monitor nuclear generating stations to insure that toxic chemicals are not being used in large

quantities and that radioactive forms of toxic chemicals are not being generated in sufficient

amounts to cause significant impact on the Great Lakes ecosystem” (EPA 2006).] The |

comment does not provide new and significant information, and therefore, will not be further

evaluated.

Comment: 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 reactor? What has been the bioaccumulation and

bioconcentration of persistent toxics both radiological and nonradiological contamination in

recreational and commercial game fish? (PS-EE-38)

Response: Zebra mussel control is discussed in Sections 2.2.3 and 2.2.5 of the SEIS. 

Quagga mussels are not present at the Palisades site. Aquatic ecology impacts are Category 1

issues that were analyzed in the GEIS. The comment does not provide new and significant

information in these areas; therefore, it will not be evaluated further.

A.1.6 Comments Concerning Threatened and Endangered Species

Comment: 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. Twenty 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
Appendix A

NUREG-1437, Supplement 27 A-18 October 2006

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. 

(PS-EE-31)

Response: The NRC conducts an independent analysis of the impacts of license renewal on

threatened and endangered species. Federally listed and State-listed threatened and

endangered species that have the potential to occur in the vicinity of Palisades are discussed in

Sections 2.2.5 and 2.2.6 of the SEIS. The potential impacts of renewing the Palisades OL on

Federally listed threatened and endangered species are discussed in Section 4.6 of the SEIS. 

A.1.7 Comments Concerning Surface-Water Quality, Hydrology, and Use Issues 

Comment: Over the years I've been watching this thing among the issues that first came up is

there was a 7-mile cooling tube that went out into the lake from the plant to cool this. That's

why eventually they had to build the steam, they had to build the cooling towers because there

was a lot of complaint about this, what effect this cooling tube would have on the lake, on the

environment, and under the snail garter thing and all of that. And as I understand it, they are

using that cooling tube from time to time. So is it really correct to say that, you know, we don't

have a pond, we have a fuel pool that we store the old assemblies until they started taking them

out and putting them on the beach? But are they still using the cooling tube out there then? 

(PS-A-1)

| Response: A description of the Palisades Nuclear Plant cooling-water systems will be provided

in Chapter 2 of the SEIS. 

Comment: And I'd ask you to look at the impacts of the recently built water intake for the

drinking water supply of South Haven, just a few years ago, which I was shocked to see was

located so very close to the Palisades reactor. So I'd ask you to look at the outflow, the

discharge of radioactive particles as well as toxic chemicals from the Palisades Nuclear Plant

being drawn into that water intake. What kind of impact that's having on South Haven residents

and tourists who are visiting? (PS-B-12)

Comment: The National Discharge Permit, is this part of the consideration? I'm talking about

the biocides, the slimicides, the – size, the heavy metals, the petrochemicals that are put out of

this plant on a daily, routine basis. Are those going to be part of the EIS? (PS-K-1)

Comment: There are so many things going on in this community. There's a high cancer rate. I

have got, you know, different things have happened to me. Swimming, etcetera. When I was a

kid, I came here and swam. And, the water was clean, I could drink it. Now, it's full, it's

scummy, it's full of algae. It's a huge change in the quality. The water's still cold. That does not

explain the algae. So, there's a lot of things in the environment I think that are happening that

are unexplained. (PS-M-6)
Appendix A

October 2006 A-19 NUREG-1437, Supplement 27

Comment: 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." (PS-EE-13)

Comment: 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. (PS-EE-2)

Response: The comments are related to Category 1 surface-water quality, hydrology, and use

issues evaluated in the GEIS. Consumers Energy Company Palisades Nuclear Plant's

compliance with NPDES requirements and the operations of the South Haven water treatment

system will be discussed in Chapter 2 of the SEIS. 

The EPA reviewed the Ninth Biennial IJC Report and concluded that “The U.S. will continue to

monitor nuclear generating stations to insure that toxic chemicals are not being used in large

quantities and that radioactive forms of toxic chemicals are not being generated in sufficient

amounts to cause significant impact on the Great Lakes ecosystem” (EPA 2006). The

comments do not provide new and significant information; therefore, they will not be evaluated

further.

Comment: 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. (PS-EE-30)
Appendix A

NUREG-1437, Supplement 27 A-20 October 2006

Response: While climate change is a legitimate concern, the specific impacts of climate

change within a particular region or watershed are still highly speculative, and are therefore

beyond the scope of a NEPA review for reactor license renewal. Furthermore, any changes in

watershed characteristics would likely be gradual, allowing water-use conflicts to be resolved as

needed. The comment does not provide new and significant information; therefore, it will not be

evaluated further.

A.1.8 Comments Concerning Human Health Issues

As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 human health issues include:

Category 1

• Microbiological organisms (occupational health)

• Noise

• Radiation exposures to public (license renewal term)

• Occupational radiation exposures (license renewal term)

Category 2

• Electromagnetic fields, acute effects (electric shock)

Comment: In other words you said air, water, and health. But, you know, what are some of

the, what's some of the specific monitoring that you're doing which would include these

questions of mine? (PS-C-2)

Comment: 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. (PS-EE-33)

Response: The radiological monitoring program at Palisades will be discussed in Chapter 2 of

the SEIS.

Comment: The same thing has happened in Lake Michigan, that the fallout that occurred

during the aboveground testing before 1963 turned out to be fallout like all over everywhere. 

There are some books, one called Under the Cloud, where it'll say Sparta, Michigan, and name

several of the other towns in succession where the plumes had gone. In the case of Lake

Michigan, there was a Michigan State professor who, a few years back but quite a while back,

had mapped the hot spots in Lake Michigan because the fallout occurred in successive
Appendix A

October 2006 A-21 NUREG-1437, Supplement 27

sedimentary layers. And then the storm times come, that's November isn't it, and, you know,

the Edward Fitzgerald time etcetera. And the waters rile up and then settle down and rile up

and settle down. So there are unexpected hot spots that have been mapped in Lake Michigan. 

(PS-D-5)

Comment: Oh, the hot spots issue. I would like to see a map of the hot spots in Lake

Michigan. Is there one somewhere near our plant here. What has our plant fed into it? When I

talk hot spots, around Chernobyl the fallout settled down and the winds came along and picked

it up and moved it someplace else. And the winds came along and picked it up and moved it

someplace else, creating hot spots in very unexpected locations. The same thing has

happened to Lake Michigan. Ever since the fallout time stopped in 1963 from the aboveground

testing, which laid down layers of sediments of radioactivity, those have done the same thing in

storm time, November. And, it gets it up and it settles down. It gets up and it settles down. 

And, I feel that a map of that needs to be part of this relicensing process. That's environmental. 

And, how much of it would our plant here add to it? (PS-N-12)

Response: It is likely that there is some variation in radionuclide concentrations in lake bed

sediments either due to variability in natural background radiation or due to resettlement of

radionuclides resulting from weapon program fallout or effluents from Palisades. However, such

concentrations, or variations thereof, are expected to fall within the range of natural background

radiation found in the area. The doses resulting from radionuclides originating in the Palisades

Nuclear Plant are expected to be well below any applicable regulatory limits.

The comments relate to Category 1 human health issues that were evaluated in the GEIS. The

comments provide no new and significant information; therefore, they will not be evaluated

further in this SEIS.

Comment: I hear from the NRC that natural radiation is no more dangerous than the radiation

produced out here. (PS-A-4)

Comment: There's like you said, there's not that much nuclear energy being, or radiation out

there. The problem is we don't know how much is too much. And any addition is more than

enough. (PS-J-2)

Comment: So I would ask you to look at the, the health impacts on African-American workers

at the facility. I'd ask you to look at health impacts on Latin Americans who work in the

agricultural industry in this area. (PS-B-8)

Response: The comments relate to Category 1 human health issues that were evaluated and

discussed in the GEIS. The comments provide no new and significant information; therefore,

they will not be evaluated further in the SEIS.
Appendix A

NUREG-1437, Supplement 27 A-22 October 2006

Comment: I mean we've got to have a better way than putting this stuff out on the beach 150

yards from the lake. I mean that's, yes, I realize in 20 years I haven't seen where this industry

has killed anybody. I've heard some things, you know, of people getting cancer, suing the

place, the company quickly settling out of court with them. Well, maybe there's something

there, maybe not. I really don't know. But I'm not particularly scared of being, of radiation

coming my way just living 3 miles from the plant. But I am concerned about those people on the

plant and what happens if one of those casks break. I'm concerned about, you say well, we

don't, the NRC aren't going to monitor this thing we'll let the plant people do it. Well, that's a

requirement for the plant people. When they put on the first VSC24 cask they didn't have

internal monitors in those darn things. They didn't want to put on external monitors until the

public outcry made them. (PS-A-7)

Comment: And I'd ask along those same lines that you look at the impacts on the Palisades

Park community which I visited for the first time recently and was shocked to see how close it

actually is to the Palisades reactor. Actually, the Palisades reactor was built in the Palisades

Park community. So I'd ask you to look at the health impacts on that population there. 

(PS-B-11)

Comment: I was wondering also if you were gathering information from public agencies? Have

you gathered information from the Public Health Department on the cancer rate in South Haven

and Covert? (PS-M-3)

Comment: Do you have any plans to contact the Public Health Department for, you know,

reports about the high incidence of cancer in this area? (PS-M-5)

Comment: The last two meetings I mentioned, you know, let's get the public health reports. 

This should be included. But, no. The public health was not contacted. Do we have to get an

FOIA [Freedom of Information Act] to find out the statistics? As I understand it, there was a

cancer study that was done and should be able to be procured. (PS-M-15)

Comment: Do you in your monitoring even the DEQ [Department of Environmental Quality] or

NRC, do you look at things such as increased cancer rates in the area? Do you look at the soil

and see if it's contaminated in any way? (PS-C-1)

Comment: The study that you just mentioned, I've heard studies that are just the opposite. 

And we have talked with people in this area that up to 8 out of 10 people are saying oh, yes, I

know someone with cancer or I have cancer. So I don't know what current studies are showing

but are any of these studies available on those tables back there? (PS-D-1)

Comment: So, these are such huge issues. Embrittlement, the cancer rate, I've talked to

people in this community who've said different horror stories about workers that have had

cancers and terrible things have happened to them. People that are cancer survivors, people
Appendix A

October 2006 A-23 NUREG-1437, Supplement 27

that have deaths in the family from cancer. Someone said that 8 out of 10 people in this area

either have cancer or know someone with cancer in their family or know someone who has died

from cancer. (PS-M-14)

Comment: And, I'd like you to meet my girlfriend..., a cancer survivor, born and raised here. 

Her mother, cancer survivor, born and raised here. Her sister, cancer survivor born and raised

here. Her sister used to swim down by the nuclear power plant, but, in '95 they had to remove a

seven and half-pound tumor from her abdomen. Now, I don't know if that has to do with nuclear

power, but, you know, they are born and raised here. And, her sister-in-law, her stepfather

worked at the nuclear power plant. And, one day, his lungs filled up with blood and he died at

the age of 39. I don't know what that was from. (PS-U-2)

Comment: I also ask that public health data regarding cancer rates in surrounding

communities of the Palisades Nuclear Plant be included in the discussion, and participation by

Michigan Department of Community Health epidemiologists be present at future hearings. 

(PS-CC-4)

Comment: Further, I would ask as I have at public meetings, that certain essential elements

not be excluded from evaluation. 

1. The public health records of the surrounding counties and downwind regions of Palisades. 

Also, the correlation between the cancer and infant mortality rate as it parallels the plant in

operational mode versus shutdown status. (PS-DD-5)

Comment: Does your environmental review, will it include the recent National Academy of

Sciences' report on biological effects of iodizing radiation? The Number 7 report, including the

finding that low-level radiation does indeed have an adverse health impact? Will that comment

on that? (PS-B-3)

Comment: And I'd also challenge something that was brought up by the health physicist from

NRC. Depending on the United Nations Scientific Committee on the Effects of Ionizing [Atomic]

Radiation [UNSCEAR] is problematic because just to give you one example in their review of

the Chernobyl aftermath on human health, they failed to look at the consequences of internal

doses of radioactivity. All that they were looking at was external doses of radioactivity. But of

course, the people there are eating radiation in their food, drinking it in their water, perhaps

even breathing it in. So that's problematic. So I challenge you to look at internal doses

especially in light of the Biological Effects of Ionizing Radiation report which recently came out

which actually found that at lower levels of radiation the impact may be higher than previously

thought, approaching a direct relationship as you mentioned, the no threshold theory was

retained. So at low levels of radiation which we're talking about here in terms of routine

radiation releases, there is health damage associated with that. (PS-B-18)
Appendix A

NUREG-1437, Supplement 27 A-24 October 2006

Comment: 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 Sciences 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

baseline health studies must be performed before NRC grants Palisades a 20-year license

extension. (PS-EE-15)

Comment: 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. 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. (PS-EE-32)

Comment: And I would challenge the NRC environmental reviewers to look at the lack of

information about cancer rates in the vicinity of nuclear plants like was raised earlier. This

15-year-old study would not include the latency period for certain cancers that have perhaps

happened in the last 15 years. And I would also challenge you to, to look for flaws in the

methodology of that study. A mother in Morris, Illinois, named Cynthia Sauer whose daughter

contracted brain cancer at age 10, age 7 I'm sorry, who is now 10 and in remission, has looked

into that study very carefully and has found flaws in the methodology. And of course, Morris,

Illinois, is the site of three reactors as well as a large waste storage pool. (PS-B-17)

Comment: And another question is this 1990 study that's 15 years ago and my understanding

is latency periods for cancers would not necessarily be included, you know, unless you were to

do a review, an update. So do you plan to do an update on that 1990 study in addition to the

recent findings by the National Academy that low-level radiation does cause adverse health

impacts? (PS-Q-4)

Comment: 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

the 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. (PS-EE-26)
Appendix A

October 2006 A-25 NUREG-1437, Supplement 27

Response: The comments are noted. Radiation exposure to the public during the license

renewal term is a Category 1 issue that was evaluated in the GEIS. Health effects from

radiation are a well-studied environmental hazard according to the General Accounting Office. 

More than 86,000 studies have been performed on the biological effects of radiation, and none

of the scientifically valid studies shows any radiation effects at doses less than 10,000 millirem. 

According to the Health Physics Society (www.hps.com), “below the dose of 10,000 millirem,

estimation of adverse health effects is speculative. Collective dose remains a useful index for

quantifying dose in large populations and in comparing the magnitude of exposure from different

radiation sources. However, for a population in which all individuals receive lifetime doses of

less than 10,000 millirem above background, collective dose is a highly speculative and

uncertain measure of risk and should not be quantified for the purposes of estimating population

health risks.”

The NRC evaluated the recently issued Biological Effects of Ionizing Radiation (BEIR) VII report

and discussed its findings in a report to the Commission (SECY.05-0202; Accession

Number ML052640532). The NRC staff found that the BEIR VII report does not support the

need for fundamental revision to International Commission on Radiological Protection (ICRP)

recommendations. However, it will provide additional technical basis for the ICRP to consider

as it revises its draft 2005 recommendations on radiological protection. The NRC staff will

continue to monitor the ICRP’s activities, review documents when they become available, and

provide comments directly to the ICRP. The NRC staff also will participate in other forums, such

as the Expert Group of the Nuclear Energy Agency or the National Academies Board on

Nuclear and Radiation Sciences, to express the NRC’s views. 

The comments provide no new and significant information; therefore, they will not be evaluated

further in the SEIS.

A.1.9 Comments Concerning Socioeconomic Issues

As stated in 10 CFR Part 51, Table B-1, Category 1 and 2 socioeconomic issues include: 

Category 1

 C Public services: public safety, social services, and tourism and recreation

 • Public services: education (license renewal term)

 • Aesthetic impacts (refurbishment)

 • Aesthetic impacts (license renewal term)

 • Aesthetic impacts of transmission lines (license renewal term)
Appendix A

NUREG-1437, Supplement 27 A-26 October 2006

Category 2

 • Public services: housing impacts

 • Public services: public utilities

 • Public services: education (refurbishment)

 • Offsite land use (refurbishment)

 • Offsite land use (license renewal term)

 • Public services: transportation

 • Historic and archaeological resources

Comment: I appreciate the comments that preceded me and some of the benefits that the

plant provides in the community through the employees, the tax base and the economy from the

payroll that we pay out to our employees. But I also want to mention that all of our employees

live here in the local communities surrounding the plant and the counties, the cities that

surround it. And everyone of those employees also has a vested interest in ensuring that this

plant continues to operate in a safe environmentally sound manner or we wouldn't stand here in

front of you today to support our license renewal process. (PS-G-1)

Comment: Some of the benefits include the support for the local units of government, the

tax-sharing entities, the community schools, the district libraries, hospital authorities. But,

there's also other things. We support the emergency management activities in the area for the

counties of Alleghan, Berrien, and Van Buren. That’s also a very important function. (PS-G-2;

PS-S-1)

Comment: Many Palisades personnel live in Geneva Township and are taxpayers, which

benefits Geneva Township, South Haven area emergency services, Lake Michigan College,

South Haven and Bangor Public Schools, Van Buren Intermediate School District, South Haven

Hospital, South Haven Senior Services, and Van Buren County. Being a South Haven area

emergency services authority board member I have watched as Palisades has contributed

much to our fire and ambulance service in the ways of training, equipment, and support. This

joint effort for the safety of our citizens and Palisades personnel is a tribute to working together

to make our community what it is today. Over the years we have been privileged to reports by

Palisades personnel at our township board meetings keeping us informed on happenings, new

procedures, updating of the siren warning system, and just being available to answer questions

that arise in our public settings.

The seminars presented by Palisades personnel to provide exposure for the local municipalities

and businesses and industries to review the plant and safety procedures that are in place as

well as having contact personnel for our comments and questions is indeed beneficial. 

(PS-H-1)
Appendix A

October 2006 A-27 NUREG-1437, Supplement 27

Comment: What I want to speak to, briefly, is the socioeconomic impact and to reiterate some

of the things that were in our statement from the Chamber board of directors over to the NRC

and the Palisades plant and Nuclear Management Corporation. The plant has a significant

economic impact on the area. Six hundred plus employees, not to mention the contractors in

the area. At least one-third of those folks live right here in the immediate South Haven vicinity. 

That's a lot of payroll dollars being spent right here in our community. A couple of folks I know

that work out there said you could bump the payroll anytime you want. And, the other side of it

is the contractors when you go into an outage. Lots of the small businesses that sit on the

Chamber board and made the decision to support it, look at those outages and those

opportunities when the plant is back reinvesting, cleaning things up, doing a lot of maintenance,

that's a lot of extra folks in town spending money, doing and making things happen. There's

also an element beyond the financial impact from that payroll. That's the involvement of those

men and women that work out there. They are involved in the community. You'll find them

serving on different public boards and commissions. Boy Scouts, Girl Scouts, 4-H, coaching

basketball, baseball, softball. Just a tremendous social impact from their involvement. (PS-T-1)

Comment: I never realized until I became a board member of Geneva Township in 1987 and

became acquainted with the operations and effect of Palisades Nuclear Plant on the structure

and economic well-being of Geneva Township as well as the surrounding area. Palisades Plant

and people continuing to support of our communities, organizations, and businesses through

usage, involvement, and monetary support, enhancing the overall Community Health and

welfare. (PS-Y-1)

Comment: Many Palisades personnel live in Geneva Township and are tax payers which

benefits Geneva Township, South Haven Area Emergency Services, Lake Michigan College,

South Haven & Bangor Public Schools, V.B. Intermediate School District, South Haven Hospital,

South Haven Senior Citizens and Van Buren County. (PS-Y-2)

Comment: Being a South Haven Area Emergency Services Authority Board Member, I have

watched as Palisades has contributed much to our Fire and Ambulance Service in the way of

training, equipment, and support. This joint effort for the safety of our citizens and Palisades

personnel is a tribute to working together to make our community what it is today. (PS-Y-3)

Comment: Funding for the Covert Township Ambulance/Fire Department and Police

Department is through a voted millage for each Department. Currently, the tax revenue from

Consumers Energy’s Palisades Nuclear Plant is roughly 60 percent of the total taxes collected. 

If Covert Township were to lose this tax revenue today, they would have to shut down or

drastically reduce the services that they provide to the community. (PS-Z-2)
Appendix A

NUREG-1437, Supplement 27 A-28 October 2006

Comment: If Palisades Nuclear Plant does not get a license renewal and Covert Township

were to lose their tax base, it would have a very negative effect on the Economic Environment

of a very poor diverse community. (PS-Z-4)

Response: The comments relate to Category 1 socioeconomic issues and are supportive of

license renewal for Palisades. The comments provide no new and significant information;

therefore, they will not be evaluated further.

Comment: I understand, you know, it's about the jobs here. I mean our town here in South

Haven or Covert where they've put the plant officially, I mean we need jobs. But one thing I

don't fear with, if Palisades does not get its license to continue to operate is that we're going to

get a loss of jobs here. (PS-A-2)

Comment: And perhaps we would then say we need to gradually move toward other sources

of employment. Certainly not just one company for our area. And to look to something that can

continue on into the future for many generations. (PS-C-6)

Comment: The tax revenue from the Palisades Nuclear Plant also helps fund the Townships’

water system as well as the Township General Fund. The revenue loss to either of these would

also mean either reduced services or a raise in taxes. (PS-Z-3)

Response: The comments relate to Category 2 socioeconomic issues and will be considered

in the preparation of the SEIS. Socioeconomic issues will be discussed in Chapters 2 and 4 of

the SEIS.

Cultural Resources

Comment: I'd also ask you to look at not only health impacts but cultural impacts and related

socioeconomic impacts on the Native American tribes of this area whose land we stand on and

whose land Palisades is located on if the treaties were honored. (PS-B-9) 

Comment: 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

nonfederally recognized tribes governed by international law. Only three tribes were contacted

by the NRC by August 8, 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,
Appendix A

October 2006 A-29 NUREG-1437, Supplement 27

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-togovernment 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. (PS-EE-18)

Response: The comments relate to Category 2 socioeconomic issues and will be considered

in the preparation of the SEIS. The NRC sent letters to 11 potentially affected American Indian

Tribes, including the Pokagon Band of Potawatomi Indians (Accession Number ML051960173), |

on July 13, 2005, inviting them to participate in the environmental scoping process related to

NMC’s application for the license renewal of Palisades. The potential impact of renewing the

OL of Palisades on cultural resources will be discussed in Chapter 4 of the SEIS.

Environmental Justice

Comment: Another issue, I was surprised when environmental justice was brought up because

my understanding was that the NRC a couple or 3 years ago had largely gutted its

environmental justice policy under pressure from the nuclear industry. So I'm glad to hear that

you're going to look at that and I would request that you look at impacts on the African-American

populations specifically in Covert Township where the facility is located. (PS-B-6)
Appendix A

NUREG-1437, Supplement 27 A-30 October 2006

Comment: And I'd ask that you look at impacts on the low-income community of this area as

well. (PS-B-10)

Comment: As for the tax base, and the loss of tax base, that we had members of the

Chambers of Commerce and Covert Township say is important, that every dollar generated is

circulated seven times or what have you. Coming here, I drove through Covert. First time I

drove through Covert was about 24 years ago. And, I've driven through it since particularly

coming up here when, being involved in the Palisades plant before they even put out one dry

cask. I was involved in some of the organizing against the dry cask. And, I don't see where

Covert has, you know, benefitted anywhere. Maybe, you know, South Haven has, but, talk

about environmental justice. Covert looks just as deprived as it has ever been. (PS-L-1)

Comment: Do you consider Covert as an environmental, what do you call that, what was that

term you used? Yeah, the justice issue? (PS-M-4)

Comment: Covert Township is a very diverse community. The year 2000 U.S. Census report

shows that Covert Township has a 35 percent Black and 15 percent Hispanic population. This

report also shows that Covert Township is one of the poorest Townships in the State with a

Median Household Income of only $22,829. (PS-W-1)

Comment: 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 workplace, including nooses hung in their lockers or in public

places to symbolize lynching, an apparent attempt to silence their public statements for

workplace justice. (PS-EE-17)

Comment: 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 lowincome 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. (PS-EE-21)

Comment: 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
Appendix A

October 2006 A-31 NUREG-1437, Supplement 27

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 hometown 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. (PS-EE-22)

Comment: 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. (PS-EE-19) 

Comment: How has the operation of Palisades impacted Native American fishing rights in the

Great Lakes? (PS-EE-39)

Response: In order to perform a review of environmental justice in the vicinity of a nuclear

power plant, the NRC staff examines the geographic distribution of minority and low-income

populations within 80 kilometers (50 miles) of the site. The NRC staff uses the most recent

census data available. The NRC staff also supplements its analysis by field inquiries to such

groups as county planning departments, social service agencies, agricultural extension

personnel, and private social service agencies. Once the locations of minority and low-income

populations are identified, the staff evaluates whether any of the environmental impacts of the

proposed action could affect these populations in a disproportionately high and adverse

manner.
Appendix A

NUREG-1437, Supplement 27 A-32 October 2006

The comments relate to environmental justice issues and will be considered in the preparation

of the SEIS. The NRC conducts an independent analysis of the impacts of license renewal with

regard to environmental justice; potential impacts will be discussed in Chapter 4 of the SEIS.

A.1.10 Comments Concerning Postulated Accidents

Comment: Farmers downwind of Chernobyl, which melted down as we all know, are out of

business because of contaminated soil. That's, that's our livelihood. We do not want to face

that possible perhaps probable scenario here at home. Human error contributed to the

Chernobyl meltdown and in spite of all the safeguards that you may have in place at Palisades

when you factor that in what will the future bring us? (PS-C-12)

Comment: I live in Grand Rapids, 70 miles away. We are definitely downwind. One of the

maps in the big books shows I believe the 50-mile radius, and as you know Chernobyl has a

19-mile interdiction area but they also find that the fallout that happens when a nuclear

catastrophe does occur, settles down and then the winds pick it up and swirls it around again

and the next windy day or windy season it settles it down again and it goes on and you end up

with unusual, unexpected hot spots in places that people didn't expect. Where they no longer

can go out and collect mushrooms and grow their own apples and so on. (PS-D-4)

Comment: Please don't say that it can't happen here. It can happen here. The chances of it

happening we don't know just like we don't know how much radiation is too much because it's

different for each individual. Okay. It is a possibility. I'd hate to see the year that South Haven

was a town that used to be a great little tourist town. (PS-J-5)

Comment: You know, you can, every nuclear power plant that ever had an accident they said

it wouldn't happen. You know, they didn't think Chernobyl would happen, they didn't think Three

Mile Island would happen. There have been so many nuclear accidents and spills all along the

trail of the nuclear industry from mining on up to transportation. (PS-M-11)

Comment: And, something also that Mr. Keegan mentioned was the environmental review has

to look at the socioeconomic impact of a full-scale catastrophe at Palisades. Tourism was

mentioned. I would also specifically request that casualties be looked at. The number of

deaths, the number of injuries, the number of latent cancer fatalities. The number of genetic

damaged children in future generations. (PS-Q-3)

Comment: 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. 
Appendix A

October 2006 A-33 NUREG-1437, Supplement 27

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. (PS-EE-20)

Response: The comments relate to Category 1 design-basis and severe accidents issues. 

The comments do not provide new and significant information; therefore, they will not be

evaluated further. Environmental justice issues will be discussed in Chapters 2 and 4 of the

SEIS. Issues pertaining to emergency planning are outside the scope of license renewal and

will not be evaluated in the SEIS (see Out of Scope: Emergency Response and Preparedness).

Comment: It has been recently confirmed by the National Academy of Sciences that there is

no safe level of exposure to radiation and that even very low doses can cause cancer. I am

therefore disturbed by nuclear industry corporate culture that has a ubiquitous record of

dismissing legitimate concerns about radiation exposures. In the case of Three Mile Island, it

has been found by a more recent independent analysis of the 1979 accident that placement and

frequency of monitoring devices were highly inadequate and unable to establish accurate data

from which to establish radiation release patterns. For residents of Harrisburg and the

surrounding area, that meant their reported symptoms of metallic taste, erythema, nausea,

vomiting, diarrhea, hair loss, and deaths of pets and farm animals were attributed to stress

brought on by the accident, not radiation releases from the accident. Apparently, if no monitors

were present in any given neighborhood and therefore no radiation data could be collected,

then no radiation had been released. People were treated as though they had psychological

problems, not legitimate symptoms of radiation exposure. Exactly how will the citizens of

Michigan be treated should a similar accident occur at Palisades? I simply refuse to accept my

community being treated in such an insulting and degrading manner. I therefore ask that a

complete map showing existing radiation detection locations for Palisades be provided and

frank discussion on this monitoring methodology be initiated. (PS-CC-3)

Response: The comments relate to Category 1 design-basis and severe accidents issues. 

The comments do not provide new and significant information; therefore, they will not be

evaluated further. Radiological monitoring and sampling locations are identified in the 2004

Radiological Environmental Operating Report (Accession Number ML051390307). Issues

pertaining to emergency planning are outside the scope of license renewal and will not be

evaluated in the SEIS (see Out of Scope: Emergency Response and Preparedness).
Appendix A

NUREG-1437, Supplement 27 A-34 October 2006

A.1.11 Comments Concerning Uranium Fuel Cycle and Waste Management

As stated in 10 CFR Part 51, Table B-1, Category 1 uranium fuel cycle and waste management

issues include:

 • Offsite radiological impacts (individual effects from other than the disposal of spent fuel and

high-level waste)

 • Offsite radiological impacts (collective effects)

 • Offsite radiological impacts (spent fuel and high-level waste disposal)

 • Nonradiological impacts of the uranium fuel cycle

 • Low-level waste storage and disposal

 • Mixed waste storage and disposal

 • Onsite spent fuel

 • Nonradiological waste

 • Transportation

Comment: Someone has said that radioactive waste is the product of a nuclear power

process. The power is a sideline of it. Of course, nuclear power originated because somebody

that was working out at Hanford area realized they were wasting an awful lot of heat in the

making of the original atomic bombs. And so, what can we do with the heat? Uh, we will boil

water, make steam, make power. And so, you know, in a roundabout way we have ended up

with nuclear plants all over the country, all over the world. But we have by far the largest

number. But radioactive waste is definitely the product of it. (PS-D-6)

Comment: Second, we cannot keep producing nuclear waste without a way to protect us from

the nuclear waste. I think enough has been said about that. I won't say a lot more but there is,

there is no good permanent solution. My suggestion is that we send it to Washington, D.C. But

I think some of our people here live in Washington, D.C. and like, like everybody else they do

not want it in their backyard. Nobody wants it in their backyard. I wonder why? (PS-J-6)

Comment: Electricity is but the fleeting by-product 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. (PS-EE-3)

Comment: I've got a lot of questions. One is, are you going to, in the environmental

assessment, take into consideration the creation, storage, and transportation of nuclear waste? 

(PS-M-1)
Appendix A

October 2006 A-35 NUREG-1437, Supplement 27

Comment: We have a high-level nuclear waste dump 3 miles from my home that's going to be

continually decontaminated. Somebody is going to have to be in there taking care of this thing

for thousands of years to come. This is going to be not just my problem it's going to be my

daughter's problem, her children's problem, her children's children's problem. They're all going

to have to pay for that as life goes on. Because this stuff is just going to be around forever and

there's no place. I've looked at Rocky Flats. I have looked at all of these different places that

are producing all this nuclear material, and this country is just teeming with this stuff and we've

got no place to put it. We can't find a safe place. Not Yucca Mountain, they've had

earthquakes, starting to find aquifer down there, Christ, they've been testing bombs

underground there for years and just shattered everything. It's not going to fly. I really wish it

was. I really wish all that stuff could just disappear and we could maybe get on with producing

electricity this way. (PS-A-3)

Comment: If anything, it is the half-life of the waste materials that not only are produced by the

Palisades Plant, 125,000, 150,000 somebody told me today, 150 million years. The half-life for

this deadly poison to reduce itself by natural processes after man has intervened to gather it

together by unnatural processes. When they have that Yucca Mountain thing if they ever get it

organized, which I have some doubts about, to bury all this stuff somebody is going to decide to

build a bridge or a mine or something and they're going to go clunk, clunk, clunk, clunk, clunk,

and they're going to bust it open having forgotten 100 or 150 or a 100,000 years. And they're

going to kill a few hundred million people. That is what the net result of nuclear power is. It is

poison. The worst poison, the most long-lasting poison in the history of the world. (PS-I-2)

Comment: If Yucca Mountain were to open in Nevada, there's enough waste in the

United States by the year 2010 to completely fill it to its legal capacity. It won't be open by

2010, if ever. And so, I just point out the irony of Consumers license expiring in the year 2011

and if Yucca were to open, it possibly could take all the waste generated at Palisades up to that

point. But, everything made after that point, after the year 2010, is excess to Yucca. And, the

second repository in the United States by law would have to be located in the eastern part of the

country. Perhaps Michigan? Who knows? Wisconsin? (PS-K-15)

Comment: But, the professionals in the nuclear industry are being very capricious with the fact

that, you know, they're generating a lethal waste here. How much more waste will be generated

in 24 more years. It is my understanding that if Yucca Mountain were to open tomorrow, which

it's not going to happen because they're still having even more problems there, it already is not

capable of handling all the waste that is already generated and sitting in storage across the

United States. It already could not hold everything that's generated. So, and also I remember

reading not too long ago in the Herald Palladium that there was an article about a new

transportable dry cask that Palisades will be using from now on. And that's all well and good,

but, where is that waste going to go if there is no place for it. This is the most serious

environmental, blatant problem that needs to be addressed. The electricity is fleeting. It's
Appendix A

NUREG-1437, Supplement 27 A-36 October 2006

created and it's gone, it's used. What's left is the waste. So, the truth of the matter here is the

real product is lethal nuclear waste. Electricity is just a by-product. The waste is what is still

here and will be here for hundreds of thousands of years and it is lethal and it is deadly. And

then, we have to go through the process of finding how to keep it safe. This industry is holding

us psychologically hostage. They're creating a waste, and then patting us on the head, and

saying, oh, don't worry, we know what to do with it, it'll be safe, blah, blah, blah. (PS-L-3)

Comment: The nuclear waste issue is a huge issue that isn't being addressed. Twenty more

years of nuclear waste buildup, where is it going to go? Are we going dump it on the Indians? I

mean, that is not right. It is not right to take nuclear waste and track it across country and dump

it on native lands. (PS-M-12)

Comment: The accumulation of nuclear waste along the shore of Lake Michigan is not only a

potential terrorist target, as is the reactor itself, but there are also problems with the casks

themselves, and the geological strata of the area, which includes the unstable sands which the

cask pad sets on. Nuclear waste that is headed for dump sites built on native lands is

"environmental racism," and more operation and creation of wastes should be considered as

such. (PS-DD-2)

Comment: 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”). One hundred and

twenty-five 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. 

(PS-EE-7)

Comment: 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 radionuclides present in the waste? What about

radioactive contamination of 20 percent of the world’s surface freshwater, the drinking water

supply for 35 million people downstream? (PS-EE-8)

Comment: 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. (PS-EE-9)
Appendix A

October 2006 A-37 NUREG-1437, Supplement 27

Comment: When I helped build these plants these fuel containments, these high-level

containments, we weren't told anything, only low-level radioactive material would be brought in

to those for refueling the plant. Once it goes through the reactor cycle it becomes really

radioactive. It was going to be sitting in a fuel pool until there would be a national depository to

ship it to. That never happened. Now we got it piling up out in these concrete casks, metal

casks sitting on the beach out of the high-level containment. (PS-A-6)

Comment: We already have contaminated steam generators and such buried on the site along

with contamination of the plant to deal with. Enough. (PS-A-10)

Comment: What happens with the waste? (PS-C-5)

Comment: One of the questions that hasn't come up enough, I think is, what are the plans for

the rad waste? Now, old Frank Kelly said a long time back, that nobody knows what to do with

a teaspoon full of the stuff. And, we still don't. Sixty years into the nuclear age and we still don't

know. So, I think that has to be a very important environmental component of the issue of

whether this plant is relicensed. To keep on making this stuff doesn't make sense. There's a

whole bunch of questions. There's comments about the dry casks, but, I won't say too much

about that except that there they sit. And, I'm wondering how they're going to get to wherever

they're going to go on site. And, how they're going to get beyond that, because they're 28 tons

each, I understand. And, they're, they can't be moved, transported on the highways at all, or

any other commercial fashion. (PS-N-5)

Comment: Let us not forget that we are discussing the continued production for another

20 years of a lethal waste that requires extreme safety control measures. We are not talking

about a tootsie roll factory here. The waste product is being stored on the shores of a body of

water that constitutes one-fifth of the earth's surface freshwater and which provides potable

water to millions of people. Another 20 years of accumulated waste added to the already

existing lineup of outdoor dry cask storage situated on unstable sand dunes is a major concern. 

(PS-CC-2)

Comment: And, oh, I understand, too, that each dry cask holds the equivalent of 250

Hiroshima bombs. Am I outrageous on that statement? Anybody correct me please? The

other thing is, I understand the last I knew anyway there are 16 dry casks. Are there more? 

What's the current quantity? (PS-N-7)

Comment: What about these 29 casks that are loaded? And, it's my understanding they weigh

132 tons each. This is a defacto high level of a nuclear waste dump on the shore of Lake

Michigan. And there are no plans to get it out. And, you're going to make more, give them a

20-year extension to make more of this. I have a problem with that. (PS-K-14)
Appendix A

NUREG-1437, Supplement 27 A-38 October 2006

Response: The comments are related to Category 1 uranium fuel cycle and waste

management issues. The comments do not provide new and significant information; therefore,

they will not be evaluated further. Issues pertaining to Yucca Mountain and malevolent acts are

outside the scope of license renewal and will not be evaluated in the SEIS (see Out of Scope: 

Separate Proceedings, and Out of Scope: Safeguards and Security).

Licensees storing spent fuel in an ISFSI under a general license for storage of spent fuel

(10 CFR Part 72, Subpart K), as at Palisades, are required to submit documentation registering

the use of each cask at their facility in accordance with 10 CFR 72.212(b)(1)(ii). As of

October 31, 2005, the NRC has received documentation registering the use of 18 VSC-24 casks

and 4 NUHOMS-32PT casks at Palisades. 

A.1.12 Comments Concerning Alternative Energy Sources

Comment: You know, it's using kind of an old nuclear technology. There are new technologies

coming along that are clean and my hope all along, what I can clearly see that immediate

nuclear decommission, cleanup and conversion of the Palisades Nuclear Power Plant and

running it on natural gas like the one they do up in Midland. Or hydrogen fuel is the way it must

go rather than allowing these nuclear fuel rods storage casks to be piled up onsite. (PS-A-9)

Comment: The time to convert Palisades Nuclear Power Plant is now. I mean this, rather than

relicense this and keep running this poor old reactor that's been going for 40 years that was

really embrittled, that they're taking old fuel rod assemblies because they're made out of

stainless steel that have already been through the cycles and sitting for years in the fuel pool,

stuffing them back in the reactor to sop up radiation away from the critical parts that are already

embrittled on the reactor vessel, so if I'm getting a little technical here, but you know, I don't

really lose sleep at night over thinking I'm living next to this dangerous reaction about to go but,

you know, the thing is 40 years old. It's embrittled, folks. If we're going to keep generating

power here we need, what they promised us back when we built the thing in the first place, in

40 years a new plant would come along. It didn't happen. (PS-A-11)

Comment: But what we have learned in 40 years is that there's a heck of a lot of ways to make

electricity. And if we quit putting all our effort and all our rate payers' money in keeping this

dead horse alive and start pursuing some of these new ones and we can do it right out there at

that plant because they got a fine turbine that produces a lot of electricity. And as Ralph Nader

says they're only boiling water. We just got to boil water to 700 degrees and we've got this

electricity. There's a lot of different ways to do it. And I hope everybody here will start pursuing

those different ways than keep going this very dangerous way, which for thousands of years to

come people are going to have to answer for and pay for, just for a little electricity now. 

(PS-A-12)
Appendix A

October 2006 A-39 NUREG-1437, Supplement 27

Comment: My husband cannot be here today because he's hosting a class from the math and

science center in Kalamazoo. This center serves the brightest students in that area. The class

is visiting to learn about our off-the-grid house. Our personal energy needs are met with solar

and wind power and we have a very comfortable life there. This can be done. And we hope

that our model will become a model for this alternative to be embraced by more people in our

area. The utilities themselves have said they want to include more of this. We have a friend,

Art Toy, who has run for office many times in our area who put up a really big wind generator

because he understood that Palisades was mandated to take that energy by law. But they have

put so many barriers in the way of his doing this that it hasn't worked yet. So I would certainly

ask that you reconsider putting barriers in the way of citizens who are trying to help with selling

excess power to you. It, this State is not doing what some other States more intelligently are

doing with this. (PS-C-9)

Comment: Nuclear energy is clean air energy. In that I mean nuclear power plants produce no

controlled air pollutants such as sulfur particulates, green house gases. The use of nuclear

energy in place of other sources does help to keep our air clean. To put it in equivalent terms,

to replace the electricity that Palisades provides it would require approximately 12 million

barrels of oil per year or three million tons of coal per year or the equivalent of about 65 million

cubic feet of natural gas per year. Those are some of the fossil fuels that having Palisades in

the community displaces that would otherwise be needed to meet Michigan's needs. 

Something that some may not be aware of is nuclear power produces approximately 25 percent

of electricity in Michigan, not just the Palisades plant but other nuclear plants as well. (PS-G-4)

Comment: There are ways of making electricity.... We could use solar power. (PS-I-6)

Comment: But that's what happening to solar power. It's coming. And a lot of other good

forms of power are coming. And we don't have to depend on the infinitely prolonged death that

is represented by nuclear power. (PS-I-7)

Comment: Up north, Consumers Energy has been combining with Mackinaw Wind Power and

they're putting up wind generators. It is possible. Wind generator is a clean energy source and

it is like Maynard was saying, it's quick. It takes over quick. It doesn't, it's not like building

another monster. It's just, you put it up and it starts working. Combination of wind and other

systems, and we've got it made here in Michigan and we can keep our water clean. But, if you

take that chance and you relicense this facility thinking well, the next issue we will deal with it,

we can analyze it. (PS-M-17)

Comment: The second question has to do with the notion that there might be renewable

sources of energy as alternatives and I don't know why that wasn't mentioned among the

possibilities that you just reviewed. Because, in fact, wind power is a fantastic source of energy
Appendix A

NUREG-1437, Supplement 27 A-40 October 2006

and it would come online a lot faster than additional nuclear power plants, which I know are

present at a loss. (PS-O-2)

Comment: I just want to reiterate a word about renewable sources of energy. And, I want to

do this in the context of something that all you energy folks are very well aware of which is that

within 5 years or so, we will have reached a global peak in oil production. And, geologists have

been telling us this for 30 years. But, it seems that they were on target and that indeed, that is

going to be happening. And, that means production will decrease as demand, globally,

increases, and that means prices for the fossil fuels will go up and up and up. And, at this point

in time, therefore, it is so important that we do everything we can to not only conserve which we

haven't started yet, but also to use more renewables. And, I'm not here to say that it may not be

possible, after lengthy public participation in this issue of what the proper mix of energy sources

is. It may be possible that nuclear is part of that. Especially in the post-fossil-fuel era. I want

this discussion to be a public discussion. (PS-O-3)

Comment: I think we can have a really good public discussion about what the proper mix of

energy sources is. And, it may be, because nuclear is clean in some ways, that that may be

part of it. I'm not the one to be able to decide. But, in the mean time, there is much that can be

done for renewable energy and incidentally, the argument that you only get it 35 percent of the

time, doesn't really apply too much, because the grid is all over the country, and if you use that

same grid for distribution, there's going to be wind blowing and sun shining someplace in the

country. So, that way we'd have a reasonable source of energy to that as well as whatever

other options exist, but, there'll be a lot less of it than we enjoy now. (PS-O-4)

Comment: Let's see. Oh, one of things that I think most of us haven't recognized is that when

nuclear power came in, the whole electric thing, energy thing became centralized. The little

dam up at Newago, and the other one at Big Rapids. All those little energy producers for their

area, even though they had a few environmental problems where the silt filled in and it may

have destroyed some of the environment, but, still some of those things could have been

handled, but, now they're out. They're gone. So, the de-centralization is what needs to reoccur. 

And, it might even be that we will have solar power, solar panels on our buildings, our church

roofs, in the places where it's possible. And, more and more, we're finding it is. (PS-N-10)

Comment: I wish there was another brand new nuclear power plant to take over, like we were

all thinking back in the 70s. Three Mile Island happened, none of that's ever happened. 

(PS-P-3)

Comment: I'd like to say a little bit about alternatives. I thought it was telling when Bob spoke

that renewables were mentioned last and very briefly. And, I think Maynard, and earlier in the

day, Barb Geisler pointed out the reality of renewables like wind and solar. They're ready to go. 

They're viable. And I would add in there efficiency and conservation as alternatives to nuclear

power. And, something that Mr. Keegan brought up, at a 44 percent rate of operation at
Appendix A

October 2006 A-41 NUREG-1437, Supplement 27

Palisades because of all the breakdowns and violations over the years, how does that compare

to the wind not blowing? I mean, the last time I checked the sun comes up every day. So,

that's pretty reliable source of energy, I would say. (PS-Q-10)

Comment: You know, it's just that there are new technologies coming along all the time and if

we just put half the investment that we put into these old dead industries, that are dying like the

nuclear industry. You know, we could have new stuff here that doesn't pollute. (PS-S-4)

Comment: Other sources of energy are available to ths country and we are failing to maximize

this value and their sustainability, such as wind power doing valuable service in other countries. 

(PS-BB-2)

Comment: The plant can be replaced by wind turbines which will not be a public liability and

which will not endanger the environment and which will produce a profit and not need taxpayer

subsidies to maintain. (PS-DD-10)

Comment: 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, February 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
Appendix A

NUREG-1437, Supplement 27 A-42 October 2006

such as fossil fuels and nuclear power, the NRC should fully examine such alternatives in its

environmental impact statement. (PS-EE-28)

Comment: The other night a man named J. Herman, I think that was his last name, who

approached, he's a bioneer. If you get a chance to look up bioneers in the Internet or

something. And he was talking about his and others’ discovery that nature's major source of

action, energy, has to do with a spiral type of motion that water flows in a spiral. And there is

the answer to our energy problems in the not too distance future. (PS-D-11)

Comment: But I once thought that the hydrogen car was going to be the successor. Now I find

out that yes, the hydrogen car leaks at the back end only water, marvelous. What we are not

being told is the front end, that you need massive electricity to crack the water and make it into

hydrogen so you've got fuel cells. (PS-D-8)

Comment: So there are at least six nuclear plants that are in process, some of them simply

were started and not completed earlier. I think the Watts in the TVA [Tennessee Valley

Authority] system is one of them. And there are others that are being worked up to provide the

extensive amount of electric power needed to make a hydrogen H. So watch it when you talk

hydrogen. (PS-D-9)

Comment: I would strongly suggest that you get a chance to listen to Amory Lovens. He has

been talking best power energy solutions for years now. One of the last times I heard him

personally was talking to the manufactures association over in Lansing. Another time was up at

a renewable resources pageant up in Treavor City. (PS-D-10)

Response: The GEIS includes an extensive discussion of alternative energy sources. 

Environmental impacts associated with various reasonable alternatives to renewal of the OL for

Palisades will be discussed in Chapter 8 of the SEIS.

Comment: And, I would like to point out in terms of renewables, the job potential. Tremendous

job potential. A lot was said about jobs. There's a recent report that the NRC reviewers need to

include in this review which is by Amory Lovens of the Rocky Mountain Institute, where he

points out that renewables already are leaving nuclear power in the dust in terms of

marketplace reality. And, another report by the U.S. Public Research Group shows that

hundreds of thousands of jobs could be created through renewables like wind and solar and

efficiency measures. And, that could, the Kyoto, the Kyoto global warming quotas could be met

in the United States with nuclear power being rolled back 50 percent, we could still meet the

Kyoto standards in this country. And so, nuclear power is not the solution to global warming. It

would cost too much. It would take too long to build new reactors. (PS-Q-11)

Response: The socioeconomic impacts associated with reasonable alternatives to renewal of

the OL for Palisades will be discussed in Chapter 8 of the SEIS.
Appendix A

October 2006 A-43 NUREG-1437, Supplement 27

Part II - Comments Received on the Draft SEIS |

|

Pursuant to 10 CFR Part 51, the NRC staff transmitted the Generic Environmental Impact |

Statement for License Renewal of Nuclear Plants, Regarding Palisades Nuclear Plant, Draft |

Report for Comment (NUREG-1437, Supplement 27, referred to as the draft Supplemental |

Environmental Impact Statement [SEIS]) to Federal, State, and local government agencies; |

certain Indian tribes; and interested members of the public. As part of the process to solicit |

public comments on the draft SEIS, the NRC staff: |

|

 C Placed a copy of the draft SEIS into the NRC’s Public Electronic Reading Room, its |

license renewal website, and at the South Haven Memorial Library; |

|

 C Sent copies of the draft SEIS to the applicant; members of the public who requested |

copies; representatives of certain Indian tribes; and certain Federal, State, and local |

agencies; |

|

 C Published a Notice of Availability of the draft SEIS in the Federal Register on |

February 23, 2006 (71 FR 9383); |

|

 C Issued public announcements, such as advertisements in local newspapers and |

postings in public places, of the availability of the draft SEIS; |

|

 C Announced and held two public meetings at Lake Michigan College in South Haven, |

Michigan, on April 5, 2006, to describe the results of the environmental review and |

answer related questions; |

|

 C Issued public service announcements and press releases announcing the issuance of |

the draft SEIS, the public meetings, and instructions on how to comment on the draft |

SEIS; and |

|

 C Established an e-mail address to receive comments on the draft SEIS through the |

Internet. |

|

During the comment period, the NRC staff received a total of 16 comment letters in addition to |

the comments received during the public meetings. |

|

The NRC staff has reviewed the public meeting transcripts and the 16 comment letters that are |

part of the docket file for the application, all of which are available in the NRC’s Public |

Document Room. Appendix A, Part II, Section A.2, contains a summary of the comments and |

the NRC staff’s responses. Related issues are grouped together. Appendix A, Part II, |

Section A.3, contains references cited in the NRC staff’s responses. Appendix A, Part II, |
Appendix A

NUREG-1437, Supplement 27 A-44 October 2006

| Section A.4, contains excerpts of the April 5, 2006, public meeting transcripts, and Section A.5

| contains the comment letters.

|

| Each comment identified by the NRC staff was assigned a specific alphanumeric identifier

| (marker). That identifier is typed in the transcript at the end of the discussion of the comment or

| in the margin at the beginning of the discussion of the comment in a letter. The speakers at the

| meetings are listed in speaking order. Table A-2 gives the commenter’s ID and affiliation

| (if stated) and the source of the comment (i.e., public meeting transcript or comment letter).

|

|

| Table A-2. Comments Received on the Draft SEIS

|

|

| Commenter

| ID Commenter

Affiliation

(If Stated) Comment Source(a)

| A Kevin Kamps Nuclear Information and Resource Service Afternoon Meeting Transcript

| B Kenneth Richards Palisades Conversion Group Afternoon Meeting Transcript

| C Kathryn Barnes Afternoon Meeting Transcript

| D Ruben Dal Monte Afternoon Meeting Transcript

| E Don Henkel Afternoon Meeting Transcript

| F Corrine Carey Don’t Waste Michigan Afternoon Meeting Transcript

| G Alice Hirt Afternoon Meeting Transcript

| H Mary Ann Middaugh Afternoon Meeting Transcript

| I John Tapper County Board of Commissioners Afternoon Meeting Transcript

| J Nancy Ann Whaley Supervisor, Geneva Township Afternoon Meeting Transcript

| K Lewis Mitchell Afternoon Meeting Transcript

| L Michael Martin Afternoon Meeting Transcript

| M Norm Knight Afternoon Meeting Transcript

| N Paul Harden Site Vice President of Palisades Afternoon Meeting Transcript

| O Kenneth Richards Palisades Conversion Group Evening Meeting Transcript 

| P Maynard Kauffman Michigan Land Trustees Evening Meeting Transcript 

| Q Sandra Adams Evening Meeting Transcript 

| R Wade Adams Evening Meeting Transcript 

| S Unidentified member of the

| audience 

Evening Meeting Transcript 

| T Liz Overheiser Evening Meeting Transcript 

| U Tom Tanlzos County Commissioner, First District of Van

| Buren County 

Evening Meeting Transcript 

| V Richard Freestone County Commissioner, First District of Van

| Buren County 

Evening Meeting Transcript 

| W Wayne Rendell Supervisor, Covert Township Evening Meeting Transcript 

| X Dale Lewis Mayor, South Haven Evening Meeting Transcript 

| Y Ryan McCoy Evening Meeting Transcript 

| Z Robert Hannan Evening Meeting Transcript 

| AA Gary Karch Evening Meeting Transcript 
Appendix A

October 2006 A-45 NUREG-1437, Supplement 27

Table A-2. (contd) |

|

|

Commenter |

ID Commenter |

Affiliation

(If Stated) Comment Source(a)

BB Barbara Geisler Evening Meeting Transcript |

CC Kevin Kamps Nuclear Information and Resource Service Evening Meeting Transcript |

DD Kathryn Barnes Don’t Waste Michigan Evening Meeting Transcript |

EE Paul Harden Site Vice President of Palisades Evening Meeting Transcript |

FF Diane Byrne Letter (ML0613705090) |

GG Tanya Cabala et al. Don’t Waste Michigan; Coalition for a |

Nuclear Free Great Lakes; Nuclear |

Information and Resource Service; Tanya |

Cabala, Great Lakes Consulting; Citizens |

Action Coalition of Indiana; Canadian |

Coalition for Nuclear Responsibility/ |

Regroupement pour la surveillance du |

nucléaire; Citizens for Alternatives to |

Chemical Contamination; Citizens |

Resistance at Fermi Two (CRAFT); Citizens |

for Renewable Energy; Huron |

Environmental Activist League; Clean Water |

Action; Home for Peace and Justice; Great |

Lakes United; IHM Justice, Peace and |

Sustainability Office; Indigenous |

Environmental Network (IEN; International |

Institute of Concern for Public Health; Lone |

Tree Council; Kalamazoo River Protection |

Association; Michigan Citizens for Water |

Conservation; Michigan Land Trustees; |

Michigan Environmental Council; Michigan |

Interfaith Climate and Energy |

Campaign/Voices for Earth Justice; National |

Environmental Trust; Nuclear Energy |

Information Service (NEIS); Nuclear-Free |

Great Lakes Campaign; Nuclear Policy |

Research Institute; Nukewatch; Radiological |

Evaluation & Action Project, Great Lakes; |

Sierra Club, Mackinac (Michigan) Chapter; |

Van Buren County Greens |

Letter (ML061570042) |

HH Marguerite Callaghan Letter (ML0612402061) |

II Michael T. Chezik U.S. Department of the Interior, Office of |

Environmental Policy and Compliance |

Letter (ML061570025)

JJ Ruben Dal Monte Letter (ML060900043) |

KK Morgan Dill Letter (ML0614601460) |

LL Paul French Letter (ML0612100510) |

MM Art Hanson Letter (ML0612100430) |

NN Natalie Hanson Letter (ML0612100440) |

OO Paul Harden Site Vice President of Palisades Letter (ML0613705090) |
Appendix A

NUREG-1437, Supplement 27 A-46 October 2006

| Table A-2. (contd)

|

|

| Commenter

| ID Commenter

Affiliation

(If Stated) Comment Source(a)

| PP Kevin Kamps Nuclear Information and Resource Service Letter (ML0615700220)

| QQ Connie and Jim McAllister Letter (ML061650257)

| RR Terry O’Brien Letter (ML0615700200)

| SS George Richards Letter (ML0611103500) 

| TT Kenneth Richards

| (attachment to transcript)

Palisades Conversion Group Letter (ML061110045)

| UU Kenneth A. Westlake U.S. Environmental Protection Agency,

| Region 5

Letter (ML061640114)

|

| (a) The afternoon and evening transcripts can be found under accession numbers ML061090128 and ML061080579,

| respectively.

|

| The NRC staff made a determination on each comment that it was one of the following:

|

| C A comment that was actually a question and introduces no new information.

|

| C A comment that was either related to support or opposition of license renewal in

| general (or specifically, Palisades) or that makes a general statement about the

| licensing renewal process. It may make only a general statement regarding

| Category 1 and/or Category 2 issues. In addition, it provides no new information and

| does not pertain to 10 CFR Part 54.

|

| C A comment about a Category 1 issue that provided new information that required

| evaluation during the review, or provided no new information.

|

| C A comment about a Category 2 issue that provided information that required

| evaluation during the review, or provided no such information.

|

| C A comment regarding alternatives to the proposed action.

|

| C A comment that raised an environmental issue that was not addressed in the GEIS or

| the draft SEIS.

|

| C A comment outside the scope of license renewal (not related to 10 CFR Parts 51 or

| 54) that includes comments regarding the need for power.

|

| C A comment on safety issues pertaining to 10 CFR Part 54.

|

| C A comment that was editorial in nature.
Appendix A

October 2006 A-47 NUREG-1437, Supplement 27

There was no significant new information provided on Category 1 issues or information that |

required further evaluation on Category 2 issues. Therefore, the conclusions in the GEIS and |

draft SEIS remained valid and bounding, and no further evaluation was performed. |

|

Comments without a supporting technical basis or without any new information are discussed in |

this appendix, and not in other sections of this report. Relevant references that address the |

issues within the regulatory authority of the NRC are provided where appropriate. Many of |

these references can be obtained from the NRC Public Document Room. |

|

Within each section of Part II of this appendix (A.2.1 through A.2.17), similar comments are |

grouped together for ease of reference, and a summary description of the comments is given, |

followed by the NRC staff’s response. Where the comment or question resulted in a change in |

the text of the draft report, the corresponding response refers the reader to the appropriate |

section of this report where the change was made. Revisions to the text in the draft report are |

designated by vertical lines beside the text. |

|
Appendix A

NUREG-1437, Supplement 27 A-48 October 2006

| A.2 Comments and Responses

|

| Comments in this section are grouped in the following categories:

|

| A.2.1 Comments Concerning the License Renewal Process, p. A-49 

|

| A.2.2 Comments in Support of License Renewal at Palisades Nuclear Plant, p. A-52

|

| A.2.3 Comments in Support of Nuclear Power, p. A-59

|

| A.2.4 Comments in Opposition to License Renewal at Palisades Nuclear Plant, p. A-60

|

| A.2.5 Comments in Opposition to Nuclear Power, p. A-63

|

| A.2.6 Comments Concerning Aquatic Ecology, Terrestrial Ecology, and Threatened and

| Endangered Species Issues, p. A-66

|

| A.2.7 Comments Concerning Surface-Water Quality, Hydrology, and Use Issues, p. A-69

|

| A.2.8 Comments Concerning Human Health Issues, p. A-71

|

| A.2.9 Comments Concerning Socioeconomic Issues, p. A-77

|

| A.2.10 Comments Concerning Postulated Accidents, p. A-89

|

| A.2.11 Comments Concerning Uranium Fuel Cycle and Waste Management Issues, p. A-92

|

| A.2.12 Comments Concerning Alternative Energy Sources, p. A-96

|

| A.2.13 Comments Concerning Monitoring Issues, p. A-104

|

| A.2.14 Comments Concerning Decomissioning Issues, p. A-107

|

| A.2.15 Comments Concerning Global Warming, p. A-108

|

| A.2.16 Comments Concerning Editorial Issues, p. A-109

|

| A.2.17 Issues Outside the Scope of the Environmental Review for License Renewal: 

| Safeguards and Security; Cask Incident; Dry Cask Storage, Waste Confidence Rule,

| Spent Fuel; Aging Management; Allegations Process; Cost-Benefit Analysis; Energy

| Policy; and Emergency Response and Preparedness, p. A-115

|

|
Appendix A

October 2006 A-49 NUREG-1437, Supplement 27

A.2.1 Comments Concerning the License Renewal Process |

|

Comment: And my question has to do with the schedule that you went through. My question is |

what is the breakneck speed up there all about? I mean, back in July 28th, we requested an |

extension to the scoping period and I don’t even think we got an answer on that. We sure didn’t |

get an extension, but we didn’t get an answer even. And so my question is if you really want |

public input on this stuff, then, and I know you’re going to say, well, the Commission told us to |

and maybe even, well, Congress told us to beyond that but, this, this breakneck speed, this |

sprint is just, you know, kind of, the writing’s on the wall, I would have to say. I would like to |

make that request. I’d like to ask for another three months on the comment period ---- for |

meaningful public input. (A-1) |

|

Response: The comment requests an extension to the draft comment period. By letter dated |

September 7, 2005, the NRC responded to an August 19, 2005, request for an extension. By |

letter dated May 22, 2006, the NRC also responded to a May 10, 2006, request. In both cases, |

the NRC stated that its established time period for comments on the draft SEIS for license |

renewal balances the Commission’s goal for ensuring openness in the regulatory processes |

with its goal of ensuring that the NRC’s actions are effective, efficient, realistic, and timely. The |

requests did not provide a sufficient basis for an extension to the established comment period. |

The comment will not be evaluated further. |

|

Comment: Well, just to respond to that. I mean, our efforts as local concerned citizens |

regarding this very dangerously deteriorated plant have involved the NRC licensing process, |

performed pro bono by us through completely volunteer efforts on a grass roots level. And so |

this thing is going on at the same time as that licensing process, which we’re still engaged in |

because we’ve appealed the licensing board’s ruling against us. So I think the Commission’s |

regulations are unreasonable. (A-2) |

|

Comment: And also, this whole summation. It’s all, you’re all under the premise on this whole |

review that there’s, nothing’s going to happen. That there’s no accidents. But there’s things |

that happen all the time. So this, you’re, you’re, you’re process, I think it is defective. (C-2) |

|

Comment: Number two because of all this and because of the nature of this dangerous |

industry that has to be closed, it has to be secret, it has to be top down, it has to be |

authoritarian. This isn’t a real democratic meeting here. It couldn’t possibly be, you see. This |

is so we think we have some input. (BB-3) |

|

Comment: I would like to see with your rules, a rule be made if, if this nuclear power plant is |

relicensed that everybody that is in on the decision to relicense it be obligated with their families |

to live within five miles of Palisades until the plant is shut down. (DD-13) |

|
Appendix A

NUREG-1437, Supplement 27 A-50 October 2006

| Comment: NRC’s comment framework unnecessarily restricts public involvement. The NRC

| has established a framework for this application process that unfairly and arbitrarily eliminates a

| huge array of issues from consideration, discussion and comment by individuals, organizations,

| and Native American tribes that provides an effective obstacle to meaningful public

| participation. Because of this, some of these comments will fall “outside” of the scope of this

| process. Regardless, these comments are provided on issues that we believe are germane,

| and we vigorously object to the arbitrary and overly strict limitations on the scope of public input. 

| (GG-1)

|

| Comment: Given what is at stake with consideration of extending an operating license for

| Palisades, a nuclear power plant and waste storage facility unwisely situated within the heart of

| Great Lakes, it is imperative to examine the pertinent issues exhaustively as well as encourage

| the full and meaningful participation of the large constituency of citizens and stakeholders who

| will be affected by the license decision. (GG-3)

|

| Comment: Unfortunately, the NRC’s implicit mission has been more one of protecting the

| nuclear power industry’s interests rather than the interests of the public. (GG-15)

|

| Comment: For the reasons laid out in this document, the coalition of aforementioned

| environmental, social justice, and public interest organizations oppose the application by

| Palisades nuclear power plant to operate for an additional 20 years beyond its original 40 year

| license. The decision to sanction approval of the 20-year license extension appears to have

| been predetermined and the invitation to members of the public and citizens of this region to

| participate in this decision making process has been merely perfunctory. This coalition of

| organizations protests the severe limitations of the process and advocates for a decision-

| making framework that allows for an unbiased, deliberative, participatory discussion as to

| whether or not to allow 20 more years of operation by the Palisades nuclear power plant.

| With a fair and just Environmental Impact Statement – the conclusion reached in the EIS would

| not have been the continued operation of a potentially catastrophic accident risk and terrorist

| target on our beloved Lake Michigan shoreline. These risks are exacerbated by the already

| regrettable high-level radioactive waste storage -- or de facto high-level nuclear dump -- in the

| heart of the Great Lakes.

|

| There are too many explicit threats to the region’s environment and people that have been

| ignored in order to promote the use of an energy that is far too costly, exceedingly hazardous,

| increasingly risky and highly irresponsible, as the question of a solution to the waste problem is

| passed down as a regrettable legacy to future generations.

|

| For these reasons we urge that the proposed 20-year license extension be denied until all

| environmental impact concerns raised here and by other stakeholders are addressed in an

| objective process that is deemed acceptable by the public as prescribed by the 1969 National

| Environmental Policy Act (NEPA). (GG-51)
Appendix A

October 2006 A-51 NUREG-1437, Supplement 27

Comment: Much of the same thing can be said of the NRC during these current rounds of |

scoping meetings concerning the re-licensing endeavor. Long time followers of this issue have |

seen it all from a very different NRC under past presidential administrations. The difference |

between now and say, the early 90s, cannot be denied. This is a very business friendly NRC, |

not public or environmentally friendly. (B-5) (TT-5) |

|

Comment: The NRC presented their fact findings and it seemed evident that the decision to |

renew the Palisades license has been approved, regardless of the concerns, facts and |

alternatives presented by individuals attending this meeting. I question the purpose of this |

meeting--? To sugarcoat the problems with Palisades? And not offer the public any part in the |

decision making process- (QQ-1) |

|

Response: The comments are in regard to license renewal and its processes in general and |

disagree with the Commission’s regulations and the NRC staff’s analysis approach. The |

Commission has established a process, by rule, for the environmental and safety reviews to be |

conducted to review a license renewal application. The development of the Commission’s |

regulations governing the license renewal process was subject to public review and comment. |

|

The comments provide no new and significant information and will not be evaluated further. |

There was no revision to the text of the SEIS. |

|

Comment: Out of 92 issues identified that need to be addressed in an environmental impact |

analysis of re-licensing, the NRC has determined that 69 are already “adequately” addressed in |

the generic impact statement. Only 23 issues were found to require additional assessment for |

at least some plants at the time of the license renewal review. In other words, members of the |

public and those who live around Palisades are not allowed to address the 69 issues in |

comments to the NRC about re-licensing, only the short list of 23 identified by the NRC. At that |

time, over a decade ago, NRC made no meaningful or adequate public outreach in the vicinity |

of Palisades to alert the public and potentially interested stakeholders to the significance of the |

rulemaking and the opportunity to provide meaningful input into the decision. (GG-24) |

|

Response: Section 1.7.6 of the GEIS states: “All comments on the applicability of the |

analyses of impacts codified in the rule and the analysis contained in the draft supplemental EIS |

will be addressed by NRC in the final supplemental EIS in accordance with 40 CFR § 1503.2, |

regardless of whether the comment is directed to impacts in Category 1 or 2.” Therefore, |

comments are considered for all the 92 identified issues. However, for the 69 Category 1 |

issues, the NRC staff must determine whether comments provide new and significant |

information bearing on the previous analysis in the GEIS. If so, these comments will be |

considered and appropriately factored into the Commission’s analysis in the SEIS. If not, then |

the generic conclusion established by the GEIS is adopted. |

|
Appendix A

NUREG-1437, Supplement 27 A-52 October 2006

| A.2.2 Comments in Support of License Renewal at Palisades Nuclear Plant

|

| Comment: During our hearings and other deliberations, it was clear that Michigan needs

| nuclear energy and Michigan needs the Palisades plant as it generates enough power for

| 500,000 of Michigan’s residents. Because Michigan is a peninsula, we’re limited in the amount

| of energy, we can’t come across where the lakes are, limited in the amount of energy we can

| import from contiguous areas. Our committee looked at the environmental and safety record of

| this plant and the record of how the Nuclear Management Company dealt with any problems

| that arose. The record is excellent on both counts. And we, as elected officials, were kept

| apprised of all activities at the plant. I’ve had an opportunity to review the NRC’s draft

| environmental report and want to commend you on a very thorough job you have done. Your

| conclusion that Palisades has not added anything harmful to the environment, has protected the

| endangered Pitcher’s Thistle, monitors fish, water and crops monthly in the surrounding areas,

| and has kept reports and permits current with Michigan Department of Environmental Quality

| matches our findings. Palisades employs about 600 individuals with a payroll of about

| $60 million. We very much need the jobs that Palisades provides to this area. These

| employees are not only responsible while at work, they are also a very real asset to this area of

| the State. They are involved in their churches, schools, families and communities. Palisades is

| also a good corporate neighbor. They pay a great deal of taxes to area governments, and are

| very supportive of the community and work together to make this area of the State a good place

| to live and raise a family. This is evident from the numerous letters and resolutions of support

| of re-licensing of this plant from area governmental bodies. I add my voice of support for

| re-licensure of this environmentally friendly electric generating plant. (H-1)

|

| Comment: Report of the Administrative Affairs Committee. I’m a Board of Commissioners. I

| hope everybody can hear me. Okay, thanks. Whereas, Palisades has been in operation since

| 1971, safely providing electricity to Consumer Energy customers for those 34 years, and;

| Whereas, based on Palisades’ continued improved performance, particularly over the past four

| years since Nuclear Management Company has been operating Palisades, Consumers Energy

| has increased confidence in the plant’s safety, reliability and predictability, and; Whereas, to

| that end, Consumers Energy announced last summer that it would seek a license renewing for

| Palisades. Nuclear Management Company will apply for a 20-year license renewal on behalf of

| the Consumers Energy next month with the U.S. Nuclear Regulatory Commission. When

| approved, Palisades’ license will be renewed through the year 2031, and; Whereas, this means

| continued employment to the residents of Van Buren County who operate and maintain the

| plant, continued tax revenue from the plant that are, revenues that are shared by various

| governments, hospitals, schools, county government, government throughout the region. And

| this really is continued support for the emergency management activities and continued

| employment paychecks that bolster your local economy. Now therefore it be resolved that the

| Van Buren County Board of Commissioners support Consumers Energy in their application

| process. This was approved March 22nd, ‘05 and signed by all seven commissioners. And
Appendix A

October 2006 A-53 NUREG-1437, Supplement 27

really our livelihood since this plant has been here, has certainly helped. Helped schools |

particularly, and not just the Covert region. (I-1) |

|

Comment: I’m Nancy Ann Whaley from Geneva Township. And I, like Mr. Tapper, live on the |

same land that I was born and raised on. I never realized until I became a board member of |

Geneva Township in 1987 and became acquainted with the operations and effects at Palisades |

Nuclear Plant on the structure and economic well being of Geneva Township, as well as the |

surrounding area. Palisades plant and people continuing support of our communities, |

organizations and businesses through usage, involvement and monetary support enhancing the |

overall community health and welfare. (J-1) |

|

Comment: Many Palisades personnel live in Geneva Township and are tax payers which |

benefits Geneva Township, South Haven Area Emergency Services, Lake Michigan College, |

South Haven and Bangor Public Schools, Van Buren County Intermediate School District, South |

Haven Hospital, South Haven Senior Services and Van Buren County. (J-2) |

|

Comment: Being a South Haven Area Emergency Services Authority Board Member, I have |

watched as Palisades has contributed much to our fire and ambulance service in the way of |

training, equipment and support. This joint effort for the safety of our citizens and Palisades’ |

personnel is a tribute to working together to make our community what it is today. (J-3) |

|

Comment: Over the years, we have been privileged to reports by Palisades’ personnel at our |

Township board meetings, keeping us informed on happenings, new procedures, updating of |

siren warning system and just being available to answer questions that arise in our public |

settings. The seminars presented by Palisades’ personnel to provide exposure for the local |

municipalities, businesses and industry to review the plant and safety procedures that are in |

place, as well as having contact personnel for our comments and questions is indeed beneficial. |

Mark Savage, Palisades’ employee as well as property owner in Geneva Township, is always |

available to review any concerns that arise. (J-4) |

|

Comment: At the April 12th 2005 board meeting, the Geneva Township Board unanimously |

voted to support the license renewal by resolution which was presented to Mark Savage at that |

meeting. It is my strong belief that the negative personal and economic impact that all of us will |

feel if the operating license for Palisades is not extended will be a loss of great magnitude to |

this community. I’m asking your full support for the 20 year renewal of the licensing for |

Palisades. (J-5) |

|

Comment: The resolution that was passed at the Geneva Township Board on April 12th, 2005 |

reads: Whereas, Palisades Nuclear Plant has been in operation since December of 1971 safety |

providing, safely providing electricity to Consumers Energy customers for those 34 years, and |

based on Palisades continued improved performance, particularly over the past four years since |
Appendix A

NUREG-1437, Supplement 27 A-54 October 2006

| Nuclear Management Company has been operating Palisades, Consumers Energy has

| increased confidence in the plant’s safety, reliability and predictability, and to that end, CMS

| Energy announced last September that they would seek a license renewal for Palisades. 

| Nuclear Management Company will apply for the 20 year license renewal on behalf of

| Consumers Energy next month with the U.S. Nuclear Regulatory Commission. When approved,

| Palisades license will be renewed through the year 2031, and this means that the residents of

| Geneva Township and surrounding areas are receiving continued employment for those who

| operate and maintain the plant, continued tax revenues from the plant that are shared by the

| various governments, hospitals and schools throughout the region, continued support for energy

| management activities, and continued employee paychecks that bolster local economies, and to

| date, the NRC has approved 30 license renewals for generating stations and is reviewing

| applications for 10 others, and there are 103 operating nuclear plants in the United States that

| generate approximately 20 percent of the nations’ electricity. Therefore, be it resolved that the

| Geneva Township Board of Trustees supports Palisades’ efforts in the application for a 20 year

| renewal of the operating license and their efforts to continue the enhancement of economic

| conditions in our area. This resolution was presented and supported by all Geneva Township

| board members. (J-6)

|

| Comment: Heard a lot of ifs today. If this, if that, if the other thing, and having been in the

| newspaper business, I’m a little more inclined to rely on some facts. Not if this happens or if

| that happens. I’ve never been in the plant. I’ve heard people talk about the condition of it. I’ve

| never been out there, so I do not know anything about the condition of that plant, whether it’s

| good, bad, brittle or whatever. I’ll leave that up to the people that know, the people that are

| experts. I think the NRC has a whole staff of experts and I’d rather trust them than somebody

| that’s not on the site making inspections and so forth. (K-2)

|

| Comment: In my opinion, Palisades is safe and I want to see that license renewed. (K-5)

|

| Comment: But I’ve been a proponent, and I’d like to thank Mr. Mark Savage for the wonderful

| job that he’s done over there at Palisades. And in the winter time, I also winter out in Arizona. 

| At that point I’m about 20 miles from the Palo Verde Nuclear Power Plant, which is the largest

| one in the country. It supplies most of the electricity for Phoenix. I have some pictures which I

| forwarded to Mark Savage, and have some of them here, which involves replacement of the

| steam generators. These came up, these were too large to come through the Panama Canal,

| so they shipped them around South America and up through Mexico, and from there they were

| transported by fazoli trains up to the Palo Verde Nuclear Power Plant. And I still think nuclear

| power is the way to go. I think today, approximately 70 percent of the power that’s distributed in

| France is by nuclear power. Why we can’t go ahead and listen to these people even if we can’t

| speak French. But, I would like to thank everybody here. I enjoyed your program very much. 

| And I’m a proponent of nuclear power, still. (M-1)

|
Appendix A

October 2006 A-55 NUREG-1437, Supplement 27

Comment: First, I’d like to focus my comments on the purpose of the meeting, the Draft |

Supplemental Environmental Impact Statement. And I’d like to commend the NRC on the scope |

and depth of the report. It’s very comprehensive and a lot went into it. A lot of views have gone |

into it. Nuclear Management Company will also have comments on it. Our preliminary review |

showed, has come up with no issues of significance, but as we complete the review we will also |

submit our comments. (N-1) |

|

Comment: Before I address a few of the facts, I’d like to talk about regarding environmental |

impact to operating the plant, I’d first like to state that not everyone in the public is ever going to |

agree on whether nuclear power is a good or bad thing. Not everyone in the public is ever |

going to agree whether the method that this country has chosen to store fuel is a good or bad |

thing. The diversity of the people, the diversity of the views, and our freedom to express them, |

that’s part of what makes this country great. So I think it’s okay that there are differing views out |

there. But I would like to address a few facts regarding the environmental impact of operating |

Palisades Nuclear Plant. Environmental responsibility is built in to the design, the operation, the |

management and the regulation of nuclear power plants. There are multiple redundancies. |

There are multiple levels of safety. There’s defense in depth, and there’s a regulatory agency |

that’s very, very intrusive into how we do business to insure that environmental responsibility. |

The employees at the plant, they’re also residents. We raise our children, my baby in the back |

of the room, here in South Haven and we have a vested interest in also insuring that the plant is |

environmentally responsible. We continuously monitor radiation levels at the plant. We |

continuously monitor the release paths from the plant. That’s not all we do. We go on to verify |

it. We sample soil. We sample fruits. We sample fish. We sample water from surrounding |

areas as an additional validation that we are maintaining the environment safe. And there are |

multiple regulatory agencies, not just the Nuclear Regulatory Commission. There’s |

Environmental Protection Agency, and there’s the Michigan Department of Environmental |

Quality all of which enforce strict regulations and review what we do at the Palisades Nuclear |

Plant to insure that we are safe to the environment. Consumers Energy and Nuclear |

Management Company are convinced that Palisades can be operated safely with minimal |

impact or adverse impact to the environment. That’s why we’re investing millions of dollars in |

the plant in upgrading the plant and the equipment today as we proceed forward with our |

license renewal process. (N-2) |

|

Comment: We’re satisfied the continued operation of this plant is an environmentally |

responsible decision, and I’m also quite gratified that the Draft Supplemental Environmental |

Impact Statement has come to that conclusion. And we look forward to a long and prosperous |

operation and a very safe and environmentally sound manner at the Palisades Nuclear Plant. |

(N-3) |

|
Appendix A

NUREG-1437, Supplement 27 A-56 October 2006

Comment: On March 22nd | we did pass in 2005, we passed the unanimous resolution in support

| of the license renewal of the nuclear power plant and I will submit that as a certified copy to you. 

| (U-1)

|

| Comment: One of the things even though you might see it was an economic decision for the

| County, for the Township and the area, yes, these are all true benefits of having the plant in our

| area. (U-2)

|

| Comment: But if there was any concern that it was harming the environment or the residents of

| this county or this area we would not have taken such action. So I would like to present this to

| you and on behalf of the Board of Commissioners that we unanimously support the license

| renewal application. (U-3)

|

| Comment: I don’t have anything additional to add to what Mr. Tanlzos said. I’m also a county

| commissioner and support the renewal license. (V-1)

|

| Comment: Covert Township has supported Palisades Plant since its inception in 1965. The

| plant’s very location is a direct result of the township’s encouragement to construct and operate

| a nuclear plant in this area. (W-1)

|

| Comment: Consumers Energy, it’s predecessor, Consumers Power and the plant’s current

| operator Nuclear Management Company have been good stewards of the environment. At no

| time since the plant’s beginning operation in December of 1971 to the present has posed any

| threat or danger to the residents of Covert or the surrounding area. (W-2)

|

| Comment: The Covert Township board has officially gone on record to support Palisades

| license renewal activities through a resolution of support enacted on March 8th, 2005. (W-3)

|

| Comment: As the host township for Palisades nuclear plant Covert Township and seven other

| taxing entities received over $6 million annually in taxes from the plant. Over the years this tax

| money for the township has funded paving roads throughout the township, building water mains

| throughout the township, lighting intersections and increased fire and police protection for our

| citizens. Covert public schools receive the lion share of that tax money and provides first class

| school facilities and services. (W-4)

|

| Comment: Covert Township is very much in favor of Palisades Nuclear Plant’s license

| renewal. It has been, there has been a partnership between Covert Township and Palisades

| since the beginning. We look forward to that partnership continuing for another 20 years and

| longer. (W-5)

|

| Comment: Palisades is a great vehicle for industrial growth and growth in South Haven. At the

| present time during normal operations Palisades employees 600 people from their operations. 
Appendix A

October 2006 A-57 NUREG-1437, Supplement 27

And if you can imagine in your town, and I presume that most of you are from outside South |

Haven since I don’t recognize too many of you, if you have something that, a plant that |

employed 600 people and that were to close down there would be great economic impact on the |

area. So the nuclear plant right now, Palisades, is in a refueling outage where 900 more people |

come in to South Haven to work on the outage to repair things, to improve things. You can |

imagine what that does to the hotels, motels in South Have. It’s a great economic boost to |

South Haven. If you were to close Palisades down and I haven’t heard a good reason tonight |

for doing it, it would make South Haven a ghost town almost because there just wouldn’t be the |

jobs that are there now. (X-1) |

|

Comment: And I have, as I say I haven’t heard a word that says anything about a good reason |

to close Palisades down. So and we as a city council, oh by the way, I was mayor of South |

Haven for four years and while I was mayor we passed a resolution also endorsing the |

continuation of Palisades. (X-2) |

|

Comment: My name is Paul Harden. I’m the site vice president of Palisades Plant. And I’ll |

focus my comments on the purpose of the meeting and that’s the draft supplemental |

environmental impact statement. And I’d like to start off by commending the Nuclear Regulatory |

Commission on the scope and depth of that report. It’s very comprehensive and Nuclear |

Management Company agrees with the conclusions although we may have some comments |

that are minor that we’ll submit as well by the date none of which will affect the conclusions of |

the report. (EE-1) |

|

Comment: I’d like to spend a few minutes addressing the environmental impact of operating, |

continuing to operate the Palisades Nuclear Plant. But before I do that I’d like to recognize not |

all of us are ever going to agree whether nuclear power plants should exist. Not all of us are |

ever going to agree the public policy that this country has taken on how to deal with spent |

nuclear fuel. That’s okay. That doesn’t bother me. The fact that we have diverse people, |

diverse views and we have the freedom to speak our opinions is part of what makes this country |

great. (EE-2) |

|

Comment: What I would like to do is share a few facts. Some of the facts are the |

environmental responsibility is built into the design of nuclear power plants. There are multiple |

redundancies so that no single failures of whether it’s human failure or equipment failures can |

cause incidents that would be adverse to the environment. There’s environmental responsibility |

built into the way the plants are operated, the way they’re managed and the regulatory |

oversight. The nuclear industry is one of the more heavily regulated and industries that has |

additional oversight that there are out there. And the inspectors do a very good job of |

challenging everything we do. Another fact is that in addition to continuously monitoring |

radiation levels on the site and monitoring all the release pathways from the site we go beyond |

that to verify that we’re not having an adverse effect to the environment or the people that |
Appendix A

NUREG-1437, Supplement 27 A-58 October 2006

| surround the plant. We regularly sample soil. We sample fish. We sample fruits. We sample

| cows milks to verify that there are no low or trace levels of radioactive material that could have

| come from the plant. And we do that on a regular basis. Another fact is that the employees that

| work at the Palisades Nuclear Plant over 600 employees they’re also residents of the local

| areas. They raise their children here too and they have a deep respect and desire to keep the

| environment safe as well. They’re just as concerned about their children as everyone else. 

| (EE-3)

|

| Comment: Given that Consumers Energy and Nuclear Management Company are confident

| that we can operate Palisades Nuclear Plant and extend the license renewal period safely and

| with no adverse impact to the environment. That is why we are spending hundreds of millions

| of dollar each year as we proceed forward through the license renewal process upgrading the

| plant, changing the equipment. (EE-4)

|

| Comment: I heard some of the concerns in here with aging of equipment. In a nuclear power

| plant we are required to have what we call aging management programs. We do regularly

| change out components. Components that aren’t changed out get inspected or tested to verify

| that they are in good condition to continue to operate. And if they start to degrade or the testing

| shows that there is degradation we change out those components to keep them going. (EE-5)

|

| Comment: I’m not up here to change the mind of anyone who is against nuclear power. But I

| do want to get those facts out. We agree that, with the conclusions of the draft report that there

| are no significant or adverse impacts of operating the Palisades Nuclear Plant in the continued

| license renewal period. And if anyone would like to be educated on the facts or learn more

| about the plant I would be happy to discuss that with you. If you don’t trust talking to someone

| who works for the plant I’d encourage you to talk to the Nuclear Regulatory Commission

| because nuclear power can be a safe and viable entity. Everything we do in life has risks. It’s a

| matter of agreement whether those risks are worth endeavoring whether it’s a chemical plant, a

| coal plant or a nuclear plant. But for the purpose of this meeting the draft environmental impact

| statement we agree with its conclusions and we look forward to operating the plant in a

| continued operating period. (EE-6)

|

| Comment: I am in favor of continued use of the facility because:

| 1. It is a valuable, viable alternate energy source which, with proper use, conserves and

| protects the environment.

| 2. Manpower required for its continued use provide an economic boost in the winter months for

| the City of South Haven and its environs. While tourist dollars grow the local economy in

| summer, many local businesses benefit during the long winter months when Palisades

| maintenance plant workers come to the area to perform the bulk of plant maintenance during

| this time. (HH-1)

|
Appendix A

October 2006 A-59 NUREG-1437, Supplement 27

Comment: As a resident of Bangor (southwestern) Michigan, well writing the area of the |

Palisades Nuclear Generating Plant, I am writing in support of renewing the license for this plant |

for another 20 years. (LL-1) |

|

Comment: The plant has been a good neighbor. They routinely test their public warning |

system and I have never heard of any negative complaints about the operation or safety of this |

plant. (LL-2) |

|

Comment: I ask that you totally disregard the environmentalist, and other protesters, many of |

whom do not live in our community. Huxley, is his "brave New world, talked about "General |

Candle". The environmentalist have done great harm to our country and most American |

citizens by trying to stem the tide of change for the better. People have lost their jobs to protect |

to birds or fish. Millions pay exorbitant sums for gasoline, diesel, heating oil and natural Gas, |

because thanks to the activist, we are held hostage to foreign oil suppliers, because they have |

blocked drilling, refineries, pipe lines, etc. for years. Most of these protesters are misguided, |

liberals, with substantial assets and care very little for the public, but only for their own agenda. |

"General Candle sounds real good to some of them!" No source of energy is 100% safe. But |

Nuclear power generation has been good for our country, providing jobs and inexpensive |

power, which God knows we surely need more of. With your oversight, nuclear plants are not |

perfect, but they have an enviable safety record and the scare mongers and whiners should be |

ignored. (LL-3) |

|

Comment: This is our plant in our community and we do not want to pay higher prices just to |

please these environmentalists, especially when most of them do not even live here. I urge you |

to grant the Palisade nuclear generating Plant the 20 year license that is requested. (LL-4) |

|

Response: The comments are supportive of license renewal at Palisades and are general in |

nature. The comments do not provide new and significant information and will not be evaluated |

further. |

|

A.2.3 Comments in Support of Nuclear Power |

|

Comment: I knew about the plant when we bought the place. I wasn’t concerned a bit about |

the plant being there, and I’m still not concerned about it. I believe that nuclear power is one of |

the best answers we’ve got to getting power in this country. With all of these other things that |

have been named, they either don’t work fully or they’re more expensive and they’re harder on |

the environment. I personally am in favor of the nuclear power. And by the way, I’m also one |

that says thank god for the atomic bomb, because I was in the 77th infantry division and I saw |

the coast of Japan that we were supposed to hit. And the reason, one of the reasons I’m here |

today is because they dropped that bomb. And I’m not the least bit ashamed to say so. (K-1) |

|
Appendix A

NUREG-1437, Supplement 27 A-60 October 2006

| Comment: I agree that the US and the world certainly will need to continue to utilize Nuclear

| Power to reduce emissions and the reliance on foreign oil, and I am all for SAFE, NEW

| NUCLEAR PLANTS/TECHNOLOGY. (FF-1)

|

| Comment: I’m writing to express my opinion on the use nuclear power plants the United

| States. I believe we are putting our head in the sand like an ostrich by not using our nuclear

power for electricity for the benefit of our citizens of this country. We burn coal like our 18th |

| century ancestors, we burn natural gas that is running out that will be needed for home heating,

| when we have nuclear energy that is clean, cheap and an unending supply. (SS-1)

|

| Comment: Why do our leaders listen to activist like Kevin Kamps (who most likely got his

| information from the movie China Syndrome). What I am saying is every new territory our

| country has ventured into we have learned by doing not letting naysayers run our experts. I

| understand the country of Israel generates most if not all of their electricity with nuclear power. 

| Our technology not used at home. Look at the advancement in our nuclear submarines since

| they were put into service. We cannot advance in this field if we don’t enter into it. I believe all

| our electricity one day will be by nuclear power because we must, the problems of spent fuel

| rods will be figured out by scientists not by activist. (SS-2)

|

| Comment: What I’m saying is build all the new nuclear power plants the electricity companies

| need to build as that will benefit everyone. As for the Palisades Plant, let the experts make the

| decisions not the nuts on the street. (SS-3)

|

| Response: The comments support nuclear power, in general, and will not be evaluated further.

|

| A.2.4 Comments in Opposition to License Renewal at Palisades Nuclear Plant

|

| Comment: But another thing is, this coalition of ours, which is 25 group strong including

| Michigan Environmental Council, the biggest coalition of environmental groups in the State,

| 75 of them, 200,000 Michigan residents. The coalition’s still growing, and we plan on fighting

| this at every turn and that’s the factor that’s going to stop this from happening. (A-13)

|

| Comment: And I am convinced that because it’s of the geology, the problematic problems, the

| history, the track record at Palisades, the possibility of terrorism, the probability of increased

| nuclear waste problems, that it’s only a matter of time something’s going to happen there. And I

| don’t think the risk is worth it. Even though right now were in that, were in a crossroads. And

| you can take this day and live in this day forever. You could live here. But if after a disaster,

| you couldn’t. (C-7)

|

| Comment: And there’s so much to lose. It’s not just your lives, your children’s lives and the

| possibility of grandchildren, great grandchildren, but it’s a life in this area. It’s the soil. It’s our

| relationship with Canada. Do you think Canada would every forgive us for the fall out? Do you
Appendix A

October 2006 A-61 NUREG-1437, Supplement 27

think that we could ever restore the Great Lakes, our water table, if something happened there? |

And the, and the, the mounds of nuclear waste got into the Great Lakes that’s stored there? I |

don’t think you can get it back people. Not with radiation, and not with the huge contamination |

that an accident would cause. (C-8) |

|

Comment: Consequently, so I will leave this point for the time being and I continue that in this |

situation my recommendation is that, I request that no approval of operating license renewal be |

given unless all existing spent fuel is removed from the site and sent to a national central |

depository. (D-4) |

|

Comment: I recommend that any approval of operating license renewal of existing nuclear |

plants be in moratorium until the year 2015. (D-7) |

|

Comment: I appreciate the opportunity to speak. Maynard Kauffman speaking on behalf on |

Michigan Land Trustees. I live on a farm about ten miles straight east of here. And my |

comments are about alternatives. And what I want to do first is say I am opposed to the 20-year |

extension of the Palisades operating license. I think it’s a needless risk. And I’ll try to explain |

why. (P-2) |

|

Comment: So in that respect we do not have to take the chance even though it might be in |

your estimation small on re licensing this plant. This plant if relicensed could be in operation for |

60 years. I do not believe it was engineered to last 60 years and I don’t believe you can change |

all the components in that plant to make it really be safe for 60 years or even 50 years. (R-5) |

|

Comment: I’m a citizen of South Haven. I’m not affiliated with anyone. I’m here mainly to be |

educated about it. I, I’m blessed to live close to the beach and I’m on the beach every day and I |

see that plant every day and I’m, frankly I’m worried so I want to know what’s going on. What |

I’ve heard from our former mayor and, and some of the commissioners has all been economic |

based. It’s all about economy and jobs. And this touches me deeply because I’m a recently |

unemployed worker who was selling tropical plants and I lost my job from environmental impact |

from hurricanes. So I’m unemployed and I still stand opposed to it. I want to know what I’m |

seeing here more is public relations and not a lot of truth. (Y-1) |

|

Comment: But what I want to see happen is that economy take a backseat to ecology. If this |

is not ultimately safe for our citizens, if our citizens are breathing radioactive fumes, if there’s a |

potential for a major accident that wipes us all out there’s no need for an economy. I’d like to |

see economy take a backseat to ecology. I’d like better answers on, on the questions that are |

asked, a lot less lip service. I have a young child I want to see grow up in South Haven. I want |

him to grow up healthy. It’s a beautiful community. We’ll find ways to replace the economy. |

(Y-3) |

|
Appendix A

NUREG-1437, Supplement 27 A-62 October 2006

| Comment: I understand the need for economy and jobs. Let’s get that behind us and let’s look

| at the ecology. I think that’s most important. (Y-5)

|

| Comment: And just keeping this little plant open 20 more years and maybe it won’t blow

| maybe it will but it’s not looking at what we’re going to need in the future. That will be very

| different so let’s, let’s think about a new way. (BB-6)

|

| Comment: There’s a lot of problems there and, these aren’t being addressed. The, at one of

| the meetings earlier and I’ve been to all of these meetings now, this is before there were a lot of

| people here. Thank God there’s more people getting involved but maybe this is the last

| meeting. They were talking about the experimental use of sealant. And that wasn’t addressed. 

| There was other things that the NRC themselves wanted to address. And when I came to the

| meeting supposedly for that, those issues they switched locations and so they kept this, the

| public in the dark on that one. So where’s, and I, I don’t know the answers to those questions

| or if they were ever answered to the NRC’s specifications. But I know there’s real issues at

| Palisades. (DD-9)

|

| Comment: Well, what does a meltdown mean here. Okay, well, if you live in Covert, you know,

| you don’t have a chance to say goodby to anyone. If you live anywhere close to Palisades you,

| you’ll, you’ll, you’re gone. If you live downwind which could be in any direction but usually the

| wind comes from the Great Lakes. It comes from, from the west going east. (DD-11)

|

| Comment: There is much at stake with the prospect of 20 additional years of nuclear power

| and radioactive waste generation and the associated risks and serious consequences

| associated with the Palisades plant, which is already unfortunately sited right in the heart of an

| exceedingly environmentally valuable and sensitive dune and shoreland on Lake Michigan. 

| Part of the Great Lakes basin, Lake Michigan is an essential facet of a system that is invaluable

| from a planetary perspective, not only for its contribution to the water supply on the globe –

| approximately 20% of the world’s fresh surface water – but also for its rich and abundant fish

| and wildlife and the ecosystem services it provides to people, as well as supporting a primary

| economic engine for the nation. (GG-2)

|

| Comment: I oppose the license renewal because Palisades is an aging facility with a history of

| noncompliance, reactor pressure vessel embrittlement, radiation release, and other problems

| that have and will continue to affect the surrounding population beyond Covert Township,

| Michigan. Many of those affected in the surrounding area are of low socioeconomic status, as

| well as minorities, raising the issue of environmental justice. (KK-1)

|

| Comment: I oppose the renewal of the Palisades Nuclear Power Plant license for an additional

| twenty years. The plant is a danger to not only our precious natural resources in Michigan, but

| to countless people who are affected by its daily operation, and many more who would be

| affected should a disaster occur. (KK-10)
Appendix A

October 2006 A-63 NUREG-1437, Supplement 27

Comment: NRC writes (on page Roman numeral xvi of its draft EIS) that "...there are factors, |

in addition to license renewal, that will ultimately determine whether an existing nuclear power |

plant continues to operate beyond the period of the current [operating license]." We would agree |

with that. A catastrophic accident would do that in a hurry. Last October, had the 107 ton fully |

loaded high-level radioactive waste container dropped onto the waste storage pool floor, |

Palisades’ operations almost certainly would have ended for good. (MM-11) (NN-11) |

|

Comment: My wife and I grew up vacationing at Palisades Park. We recently purchased an |

old cottage and renovated it so our four children, 8 and under, will grow up with the same |

wonderful experiences at the lake. We understand nuclear power can be a viable option for |

clean and efficient power, but we strongly oppose the renewal of the Palisades Nuclear Power |

Plant license. (RR-1) |

|

Comment: There are far too many identified safety, security, environmental and health issues |

to overcome specific to the Palisades facility to warrant a license renewal. The age-related |

degradation, embrittlement of the reactor vessel, radioactive generation and storage issues, as |

well as the sensitive socio-economic impact of the community are just a few. (RR-2) |

|

Comment: We implore you to deny the license renewal for Palisades Nuclear Power Plant, |

listen to the voices of the people, and take a stand for future generations. This is an opportunity |

to do what is right and set a course for safe, healthy, efficient and renewable energy, rather than |

holding on to strings of a proven aged, unsafe and volatile facility. Please do the right thing and |

deny this application, for our kids and the future generations." (RR-4) |

|

Comment: Seek alternative solutions for a safe and clean future. (QQ-4) |

|

Response: The comments oppose license renewal at Palisades Nuclear Plant and are general |

in nature. The comments do not provide new and significant information and will not be |

evaluated further. |

|

A.2.5 General Comments in Opposition to Nuclear Power |

|

Comment: I want to say no matter where you stand on the nuclear issue, if you think Palisades |

is great and you like nuclear energy, or if you’re opposed to it, we’re all in the same boat, all of |

us that live here in this area. And that is that. What happens there is going to affect us. It’s not |

only going to affect us, but it’s going to affect our children’s children’s children. You might be |

the last person in your lineage if that thing blows because you’ll never have any, any offspring |

with normal DNA, if at all, you survive it, if at all, that you can reproduce. (C-5) |

|

Comment: What happened in Chernobyl was disastrous. Kevin Kamps, who is one of my |

good friends, brought children from Chernobyl over here. I worked on the U.S., U.S.S.R. |
Appendix A

NUREG-1437, Supplement 27 A-64 October 2006

| Reconciliation Project to stop the nuclearization and the cold war, and we, we were successful. 

| And when I see these children from Chernobyl whose beautiful souls with their sunken eyes,

| and they’re severely handicapped, and I see American kids who are bright and bouncing around

| and having fun, Corinne and I ran the Children’s Peace Camp and we had American children

| and Chernobyl kids. The, the contrast between the children was so immense, yet they’re all

| innocent beautiful little children. The only difference is Chernobyl blew and Palisades hasn’t

| yet. (C-6)

|

| Comment: It’s just hard for me to imagine that, that we’re all here in this room even talking

| about this. I think the humanity of, of this nuclear thing is, is not good. And if, and everyone in

| here is a human being and therefore we should all be able to define the meaning of humanity. 

| And to take a risk like this in my mind I, I don’t care how safe it is, you know, it’s, it’s still a risk

| and you people you’re here defending yourselves from a risk, a potential risk. So therefore

| you’re admitting that there could be a meltdown. So I, I just find this whole thing just, us being

| here talking about this is totally insane. (Z-1)

|

| Comment: We shouldn’t even, man should have never split the atom to begin with. It was a

| bad thing. It’s very bad. (Z-2)

|

| Comment: And I also concur with Mr. is it Hannan, who said these, how can we even be in this

| year of, of, of 2006 still being, trying to justify the manufacture of a waste that is absolutely lethal

| for hundreds and thousands of years. What are we going to do with it. Who, nobody wants it. 

| This is the substance of which we are having international, you know, traumas over right now

| with North Korea and a few years ago it was, you know, India, Pakistan and every, every nation

| on earth wants nuclear and we’re giving it to other nations. It’s absolutely preposterous. (AA-6)

|

| Comment: The process by which we are generating electricity is the same process that was

| used to make the atomic bomb that was dropped on, on Hiroshima and Nagasaki. So this is a

| technology of death make no mistake about it. We are made of better stuff than this. We are

| intelligent enough to create electricity in a manner that does not produce a waste. And to have

| the waste off of discussion for the environmental impact statement is absolutely scandalous. 

| (AA-7)

|

| Comment: In the early 80s I, I became concerned about nuclear issues in, in a broad way. 

| And I remember a film from that era which was called The Dark Circle documentary. And it,

| they interviewed lots of people in the nuclear industry both the weapons industry and the power

| industry. And what I remember from that is how intertwined they all are. That it, that you can’t

| really separate atoms for peace, atoms for industry from, from the weapons industry. And Gary

| Kartch said, you know, it’s, it’s about death. Do we choose death or do we choose life. It really

| is about that ultimately. (BB-1)

|
Appendix A

October 2006 A-65 NUREG-1437, Supplement 27

Comment: And in going to various meetings and conferences through the last 25 years I want |

to focus on just one thing which is I’ve heard a lot of whistle blowers speak. And their lives have |

been ruined. Now some of you may have seen the film about Karen Silkwood and maybe you |

thought that was over dramatized or not true or whatever. But I sat down with a women in her |

70s at at least three of these events who told me what happened to her. She went, and this is |

I’m, I’m moving to the inside here. She was an innocent young girl. She went to work for the |

industry and she noticed that some figures weren’t quite right. And so she thought she better |

tell her boss and she did and that was the beginning. Basically she was told you can either do |

the figures the way we want them or you can leave. And she realized either way she was a |

marked woman. And yes she did have to go underground. She, the, the act that protected |

people that came out I believe after Silkwood she, she, she literally had to go underground. |

This is, this a gramma tell me this. She, she was, she felt, she feels deliberately exposed. She |

was dying of bone cancer. Now this is just one woman speaking. I don’t think she was lying but |

I can’t prove this. But she’s only one of several that I’ve talked to who had their lives ruined in |

one way or another. Ann Harris at Lockspar [Watts Bar], part of TVA, Curtis Overall eight years |

ordeal, same place. Finally won on appeals. Wrongful termination. I, he was in tears, |

divorced, everything else. Ann Harris was run off the road. Interestingly enough it was Curtis |

Overall whose, who pointed out the flaws Lockspar [Watts Bar] which led to Cook very near us, |

D.C. Cook being shut down for three years because they had the same kind of system. And I |

remember hearing a guy in St. Joe talk about working at Cook and becoming a whistle blower |

and his life was ruined too. That’s very near us. People are threatened. They are called on the |

phone. They are run off the road. So knowing this I wonder if this isn’t just a charade. How |

many of you within the industry would have the guts if you, if you decided it was, there were |

things that weren’t quite right to say so in public. You’d, you’d pay a heavy price number one. |

(BB-2) |

|

Comment: So I guess I want to end by saying I don’t think you can have nuclear weapons and |

nuclear power, the Dark Circle and also have democracy. And I think that’s what we’re up |

against in this country right now if you want to look at, excuse me, the big picture. (BB-4) |

|

Comment: The NRC and power companies thus advocate for a dangerous source of |

electricity, nuclear power, calling it “clean” and “green” by appearing to discourage another |

harmful electricity source, one, however, that they plan to continue utilizing to the fullest extent |

possible... Further, nuclear power is not “carbon free,” as it relies heavily on the use of fossil |

fuels in the mining, milling, processing, transportation, management, and storage of its fuel and |

waste products. (GG-17) |

|

Response: The comments oppose nuclear power, in general, and will not be evaluated further. |
Appendix A

NUREG-1437, Supplement 27 A-66 October 2006

| A.2.6 Concerning Aquatic Ecology, Terrestrial Ecology, and Threatened and Endangered

| Species Issues

|

| Comment: I’ve seen frogs with ten arms. I’ve seen a lot of things from broken DNA. (DD-4)

|

| Comment: What it means that there is a huge area of contamination. It could go into Canada. 

| It could affect all of us in Michigan and Canadians. And as in the case of Chernobyl that year

| Meyer -- had the most insane bizarre food. I am sure in Michigan because of all our

| precipitation we had fallout. I had turnips, they got this big with a little narrow and then they

| bulged out again and they were rotten inside. I had cabbage that was huge and rotten inside. 

| That’s not normal. It’s never happened since. (DD-12)

|

| Comment: A license extension at Palisades increases the fragile status of numerous already

| threatened, endangered, or candidate species, from daily “routine” radiation releases and/or

| potential large-scale radiation releases. Species exposed to cumulative exposures from the

| radioactive discharges of a nuclear power plant may over time develop subtle genetic

| alterations that are not observable in the short term, but that could have large, subtle impacts

| within a population, not immediately apparent. This has significant implications for the

| threatened and endangered species of southwest Michigan. (GG-14)

|

| Comment: NMC/Consumers’ Environmental Report identifies numerous Federal and State of

| Michigan endangered, threatened, candidate or species of special concern – such as the

| eastern box turtle, lake sturgeon, lake herring, creek chub sucker, 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 sedges that either already live at

| or near the Palisades reactor or along its transmission lines, or very likely could in the future.

|

| Approving a license extension of 20 more years of reactor operations at Palisades increases the

| fragile status of these already threatened, endangered, or candidate species, from daily

| “routine” radiation releases and/or potential large-scale radiation releases. At minimum, NMC/

| Consumers must be required to establish a baseline for the status of the endangered species

| listed above and conduct appropriate monitoring to ensure that Palisades is not further

| endangering their health and viability. (GG-50)

|

| Comment: NMC/Consumers must be required to establish a baseline for the status of the

| endangered species and conduct appropriate monitoring to ensure that Palisades is not further

| endangering their health and viability. Approving a license extension of 20 more years of

| reactor operations at Palisades increases the fragile status of these already threatened,

| endangered, or candidate species, from daily “routine” radiation releases and/or potential large-

| scale radiation releases. (GG-65)

|
Appendix A

October 2006 A-67 NUREG-1437, Supplement 27

Response: The International Commission on Radiological Protection (ICRP) states that if man |

is adequately protected, then other living things are also likely to be sufficiently protected (ICRP |

1977, 1991). The International Atomic Energy Agency (IAEA 1992) and the National Council on |

Radiation Protection and Measurements (NCRP 1991) reported that a chronic dose rate of no |

greater than 10 mGy/day (1 rad/day) to the maximally exposed individual (MEI) in a population |

of aquatic organisms would ensure protection for the population. |

|

IAEA (1992) also concluded that chronic dose rates of 1 mGy/day (0.1 rad/day) or less do not |

appear to cause observable changes in terrestrial animal populations. Table 5-9, in the IAEA |

document, compares the estimated whole body dose to the biota to the IAEA chronic dose rate |

values for aquatic organisms and terrestrial animals. The cumulative effects of the current |

operating unit would result in dose rates significantly less than the NCRP and IAEA studies. |

The comment provides no new and significant information and will not be evaluated further. |

|

Comment: The license renewal does not involve any major construction or physical alteration |

of the project area. The Generic EIS and Draft Supplement 27 adequately address the |

concerns of the Department regarding fish and wildlife resources, as well as species protected |

by the Endangered Species Act. We concur with the preliminary conclusions of the |

U.S. Nuclear Regulatory Commission staff with respect to the impacts of continued operations |

on these resources and species. We have no comment on the adequacy of other resource |

discussions presented in the documents. (II-1) |

|

Response: The comment relates to aquatic ecology, terrestrial ecology, and threatened and |

endangered species issues covered in the SEIS. The comment provides no new and significant |

information and will not be evaluated further. |

|

Comment: Section 4.1, Cooling-System, Page 4-9. We are concerned about entrainment of |

fish and shellfish in early life stages. Under a U.S. EPA rule, codified in 40 CFR.125 (U.S. EPA |

Rule), Palisades Nuclear Plant is required to reduce its entrainment of fish and shellfish in early |

life stages. Under the U.S. EPA Rule, Palisades Nuclear Plant is required to choose one of five |

compliance alternatives to reduce entrainment and the compliance alternative must meet a |

regulatory performance standard. We understand that Palisades will comply with the U.S. EPA |

rule through conditions in a NPDES permit issued by the Michigan Department of Environmental |

Quality. However, we believe that the project proponents should have a proposed compliance |

alternative and regulatory performance standard for Palisades, because the project proponents |

must assess the feasibility of complying with the rule. Listing information would provide a |

comprehensive public disclosure of plans to reduce entrainment. Therefore, we request the |

project proponents to determine and disclose the proposed compliance alternative and |

performance standard that would most likely be proposed in the NPDES permit application for |

Palisades in the final SEIS. (UU-17) |

|
Appendix A

NUREG-1437, Supplement 27 A-68 October 2006

| Response: The final rule issued by the EPA on February 16, 2004, commonly referred to as

| the 316(b) Phase II regulations, establishes requirements to minimize adverse impacts on fish

| and shellfish from cooling-water intake structures at large power plants. Facilities have several

| compliance alternatives that meet the performance standards defined in the final rule. The

| alternatives include demonstrating that the existing cooling-water intake configuration provides

| adequate protection, selecting additional fish protection technologies (such as screens with fish

| return systems), and using restoration measures. Additional information regarding the rule can

| be found at http://www.epa.gov/waterscience/316b/. 

|

| Compliance with this rule is accomplished under implementation of the NPDES program. For

| Palisades, this program is administered by the State of Michigan Department of Environmental

| Quality (MDEQ). However, because Palisades employs a closed-cycle cooling system, as

| described in Section 2.1.3, and since 40 CFR 125.94(a)(1)(i) states that, “you may demonstrate

| to the Director that you have reduced, or will reduce, your flow commensurate with a closed-

| cycle recirculating system. In this case, you are deemed to have met the applicable

| performance standards and will not be required to demonstrate further that your facility meets

| the impingement mortality and entrainment performance standards specified in paragraph (b) of

| this section,” the NRC staff anticipates that Palisades would meet the performance standard of

| concern. Nevertheless, this final determination will be made by the MDEQ in its review of

| Palisades NPDES permit application. The NRC staff has determined that the impacts related to

| entrainment would be SMALL and no additional mitigation is warranted. However, if the MDEQ

| requires additional mitigation under the new regulations, the impact would be even further

| reduced. The comment provides no new and significant information and will not be evaluated

| further.

|

| Comment: Section 4.6, Threatened and Endangered Species, pages 4-32 to 4-35. We are

| concerned because the draft SEIS does not evaluate impacts on State-listed threatened and

| endangered species. The draft SEIS includes an evaluation of Federal and State-listed

| threatened and endangered species in the study area. However, the draft SEIS only evaluates

| impacts to Federal-listed threatened and endangered species. We believe that the final SEIS

| should include a more comprehensive evaluation of threatened and endangered species, by

| including an evaluation of impacts to State-listed species. (UU-18)

|

| Response: The Endangered Species Act [10 CFR 51.53(c)(3)(ii)(E)] requires the NRC to

| perform an assessment of impacts of a proposed action (license renewal) on Federally-listed

| threatened and endangered species in its SEIS. There is no Federal statutory requirement to

| specifically consider State-listed species in our analysis. However, the NRC staff does evaluate

| the impacts on all biota and their habitats from operation of the plant cooling system (Section

| 4.1) and continued operation of the transmission lines (Section 4.2). Potential impacts on

| aquatic and terrestrial species, regardless of their status as Federally-listed or State-listed

| species, were considered in this assessment; the conclusion reached in this assessment was

| that the impacts from continued operation of the cooling system and transmission system on all
Appendix A

October 2006 A-69 NUREG-1437, Supplement 27

biota and their habitats would be SMALL. Therefore, no additional actions were taken to further |

categorize or distinguish between Federally-listed and State-listed species. The comment |

provides no new and significant information and will not be evaluated further. |

|

A.2.7 Comments Concerning Surface-Water Quality, Hydrology, and Use Issues |

|

Comment: I’m concerned about Palisades because through the years, you know, growing up |

here in Michigan the last time I was in Lake Michigan was as a baby, when I was a baby my |

mother has a photo of me in the water. When I was growing up I went swimming quite a lot in |

Lake Michigan. I can remember drinking the water, swimming, enjoying it. I can remember how |

many people were on the beach. It was just glorious. And I can remember drinking the water |

and it was clean, sometimes it tasted a little fishy but, you know, it wasn’t a bad taste, you could |

drink it. You can’t drink it now. Since the, the building of the nuclear reactors the water quality |

has deteriorated. Last time I went swimming last year my daughter and my granddaughter, I |

have a little almost three-year-old granddaughter now, precious. They went swimming, and |

they both got stinging rashes. And I got a rash myself although I was only in the water for a |

couple of minutes. And we cannot drink the water; it’s got a bad, foul taste and I don’t know if |

this is because of the chlorine, bromine, and amine released or if it’s from other things. (DD-1). |

|

Response: Sections 2.2.2 and 2.2.3 discuss water use and water quality, respectively. |

Section 4.1 also discusses the impacts on surface-water quality, hydrology, and use resulting |

from the operation of the cooling system at Palisades as a Category 1 issue. Discharges of |

chlorine, bromine, and amine are regulated by the EPA and implemented through the NPDES |

program. The NRC staff has not identified any new and significant information during its |

environmental review process, which includes an evaluation of the Palisades NPDES permit |

and discussion with the MDEQ compliance office. Therefore, the NRC staff concludes that |

there would be no impacts of discharge of chlorine or other biocides during the renewal term |

beyond those discussed in the GEIS. The comment provides no new significant information |

and will not be evaluated further. |

|

Comment: There are questions regarding the status of the NPDES permit of Palisades to |

utilize and eventually discharge a compound, Betz Clam-Trol, to Lake Michigan to control |

mussel and clam mussel colonization in discharge and intake pipes. Reports posted by the |

Michigan Department of Environmental Quality (MDEQ) in 2000 and through 2004 indicated |

"continued non-compliance.” Subsequent updating of the reports now appears to indicate that |

the plant is and was in compliance with its permit. To further confuse the matter, MDEQ has |

stated that the original reports were erroneous. We ask that a full explanation be provided for |

this situation and how it will be considered in the re-licensing decision. The impact of 20 |

additional years of pollution improperly controlled under requirements of the National Pollutant |

Discharge Elimination System will adversely affect the water quality of nearby sources, |

including Lake Michigan. |
Appendix A

NUREG-1437, Supplement 27 A-70 October 2006

| In its “Ninth Biennial Report on Great Lakes Water Quality,” the International Joint Commission

| urged 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." The draft EIS must address how the NRC or the U.S. Environmental

| Protection Agency has met this obligation. (GG-42)

|

| Comment: The EIS should be revised to include how the NRC meets its obligations as

| described in the International Joint Commission’s (IJC) “Ninth Biennial Report on Great Lakes

| Water Quality.” In it, the IJC urged 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." (GG-63)

|

| Comment: Further, other toxic chemical discharges to Lake Michigan, such as Betz Clam-Trol,

| discharged via a National Pollutant Discharge Elimination System (NPDES) permit, require

| stricter controls and enforcement of violations, as part of any license extension application. 

| (GG-8)

|

| Comment: The impact of 20 additional years of pollution by non-radiological toxic chemicals

| 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 (EPA 2004). (KK-9)

|

| Comment: License renewal should not be granted to the Palisades Nuclear Power Plant,

| because (4) there is continued noncompliance of non-radiological persistent toxic chemicals to

| area water sources. (KK-5)

|

| Response: The NRC staff addressed the issue of the use of molluscicide Betz Clam-Trol and

| “continuing non-compliance” noted by the MDEQ in Section 2.2.3 of the SEIS, stating that in

| 2005 the MDEQ documented that the recurring noncompliance notices on the online database

| are erroneous, and that the facility is in compliance.

|

| In its response to the Ninth Biennial IJC Report, the EPA concluded that “The U.S. will continue

| to monitor nuclear generating stations to insure that toxic chemicals are not being used in large

| quantities and that radioactive forms of toxic chemicals are not being generated in sufficient

| amounts to cause significant impact on the Great Lakes ecosystem” (EPA 2006). The

| accumulation of contaminants is a Category 1 issue that has been evaluated in the GEIS. All

| effluent discharges are regulated under the provisions of the Clean Water Act and the

| implementing effluent guidelines, limitations, and standards established by the EPA and the

| States. Conditions of discharge for each plant are specified in its NPDES permit issued by the

| State or the EPA. The comment provides no new and significant information and will not be

| evaluated further.
Appendix A

October 2006 A-71 NUREG-1437, Supplement 27

A.2.8 Comments Concerning Human Health Issues |

|

Comment: Yesterday I received my copy of the Generic Environmental Impact Statement for |

License Renewal of Nuclear Plants Supplement 27 regarding the Palisades Nuclear Power |

Plant. Reading through both the manual and its cover letters, I see, despite the potential |

radioactive hazards, the NRC insists the environmental impacts of the Palisades Nuclear Power |

Plant and the radioactive materials about its reservation is always regarded as small throughout |

this report. (B-6) (TT-6) (O-1) |

|

Comment: I, responding I think to David Miller or whoever said that the consequences of the |

daily releases into the environment of radioactive nuclides is small, I don’t know what small |

means. I know cells are small. And I know that the newest report by the National Academy of |

Sciences has said that there is no safe threshold for radiation. Not one bit of it. So how do you |

determine, this is new information. You didn’t have that information when you licensed this |

plant 40 years ago. So this should be considered in your re-licensing process. It’s new |

information. Are you talking about a small person, or a small cell, you know? I’m a small |

person and I don’t want one of my small cells injured. So I think that information needs to be |

considered in this license application. So please look at that information. (G-1) |

|

Comment: My second question is to the health scientist. Is there any level of radiation where |

you cannot achieve an increase in incidents of cancer. It is my understanding that there is a |

linear relationship and there is no threshold between the incidents of cancer and your exposure |

to radiation, the lifetime. (R-2) |

|

Comment: The Palisades plant harms the environment and the health of its workers and |

surrounding residents from its discharges of radioactive and toxic substances to Lake Michigan, |

the air, and land. Routine radioactive discharges by nuclear power plants are incorrectly |

deemed legal and judged to be “safe” by the NRC and the nuclear power industry, contrary to a |

recent National Academy of Sciences report that confirms that there is no safe level of exposure |

to radiation. (GG-7) |

|

Comment: Nuclear reactors, including Palisades, are not ‘clean.” They emit harmful |

radioactivity into the environment on a daily basis and generate long-lasting radioactive wastes. |

(GG-18) |

|

Comment: The NRC also made a determination “that, although no standard exists that can be |

used to reach a conclusion as to the significance of the magnitude of the collective radiological |

effects attributable to any plant, these impacts are acceptable in that these impacts would not |

be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended |

operation under 10 CFR Part 54 should be eliminated.” This determination made by the NRC |
Appendix A

NUREG-1437, Supplement 27 A-72 October 2006

| is in direct conflict with a 2005 National Academy of Science report, which concluded that no

| dose of radiation, no matter how small, can be declared “safe.” (GG-25)

|

| Comment: The NRC has placed this issue outside the scope of the EIS for extending the

| license for Palisades. We strongly disagree.

|

| There are routine everyday discharges from nuclear power plants, deemed to be both explicitly

| “permissible” or “allowable,” and implicitly “safe” or “insignificant” by the NRC and the nuclear

| power industry. Prior to the advent of nuclear power, radioactive fission products, produced in

| nuclear reactors, were present in only exceedingly rare, trace amounts in isolated locations on

| earth. Over 300 different radioactive chemicals are currently created by nuclear chain reactions

| – and it takes hundreds of thousands to many millions of years for these new chemicals to

| return to a stable state. (GG-27)

|

| Comment: While concerns about the consequences of human exposure to ionizing radiation

| are not new, the 2005 National Academy of Science’s seventh Biological Effects of Ionizing

| Radiation (BEIR VII) report on “Health Risks from Exposure to Low Levels of Ionizing Radiation”

| has confirmed that there is no safe – level of exposure to radiation—that even very low doses

| can cause cancer and other maladies and that risks from low dose radiation are likely greater

| than previously thought. The implications of NAS’s recent findings require a thorough analysis

| by NRC in its EIS of the human health impacts of the radioactive substances released by

| Palisades. (GG-29)

|

| Comment: One time I sat on the beach and I had the sand in my fingers etcetera and there

| was a lot of gas coming out of Palisades that day and I was near the plant. I got real sick

| afterwards. It reminded me of when I was out at the nuclear test site the feelings I had

| afterwards being very tired and nauseous and just really dead tired. I’m a cancer survivor. I

| know what it’s like to go through that dark cloud. I’ve seen children from Chernobyl. (DD-2)

|

| Comment: I live on land where there’s pesticide use. I’m been a victim of that which is an

| essentially a cause of cancer not radiation but radiation does cause cancer too. (DD-3)

|

| Comment: Well, I wondered if I, I presume that you couldn’t calculate an increase number of

| cancers that would develop because of the increased exposure to radiation in the locality of this

| plant. And second the study you cited that was commissioned by the National Cancer Institute

| was a bonafide epidemiology study that, that really looked for a hot spot. (S-1)

|

| Response: The comments are noted. Radiation exposure to the public during the license

| renewal term is a Category 1 issue that was evaluated in the GEIS. 

|

| Radiation is only one of many agents with the potential for causing cancer, and cancer caused

| by radiation cannot be distinguished from cancer attributable to any other cause, such as
Appendix A

October 2006 A-73 NUREG-1437, Supplement 27

chemical carcinogens. The chances of getting cancer from a low dose of radiation is not known |

precisely because the few effects that may occur cannot be distinguished from normally |

occurring cancers. The normal chance of dying from cancer is about one in five. |

|

The actual amount of radiation any member of the public receives from activities at nuclear |

power facilities is so small that scientists have been unable to make empirically based estimates |

of radiation risk with any precision. There are many difficulties involved in designing research |

studies that can accurately measure the projected small increases in cancer cases that might |

be caused by low exposures to radiation when compared to the rate of cancer resulting from all |

other causes. In the absence of a clear answer, the U.S. Nuclear Regulatory Commission |

conservatively assumes that any amount of radiation may pose some risk for causing cancer or |

having some hereditary effect and that the risk is higher for higher radiation exposures. This is |

called a linear, no-threshold dose-response model and is used to describe the relationship |

between radiation dose and the occurrence of cancer. |

|

This model suggests that any increase in dose above background levels, no matter how |

small, results in an incremental increase in risk above existing levels of risk. Although the |

U.S. Nuclear Regulatory Commission has accepted this hypothesis as a “conservative” (i.e., |

cautious) model for determining radiation standards, the U.S. Nuclear Regulatory Commission, |

like other authoritative bodies, recognizes that this model will probably over-estimate radiation |

risk. The associations between radiation exposure and the development of cancer are mostly |

based on studies of populations exposed to relatively high levels of ionizing radiation (for |

instance, the Japanese atomic bomb survivors and the recipients of selected diagnostic or |

therapeutic medical procedures). |

|

Although radiation can cause cancers at high doses and high dose rates, currently there are no |

data to establish unequivocally the occurrence of cancer following exposures to doses below |

about 10 rem. The average annual dose to a member of the public from a nuclear power facility |

is in the range of less than 1/1000th rem (1 millirem) per year. At Palisades, the dose to a |

member of the public is much less than 1 mrem per year. This is compared to the 10 rem |

(10,000 millirem) discussed previously. At doses above 10 rem, a relationship between |

radiation and cancer can be observed. Although there is a statistical chance that radiation |

levels that small (i.e., less than 10 rem) could result in a cancer, it has not been possible to |

calculate with any certainty the probability of cancer induction from a dose this small. Because |

many agents cause cancer, it is often not possible to say conclusively whether the cancer was |

radiation-induced cancer. |

|

A number of studies have been performed to examine the health effects around nuclear power |

facilities. |

|
Appendix A

NUREG-1437, Supplement 27 A-74 October 2006

| C In 1990, at the request of Congress, the National Cancer Institute conducted a

| study (NCI 1990) of cancer mortality rates around 52 nuclear power plants and

| 10 other nuclear facilities including Palisades. The study covered the period

| from 1950 to 1984 and evaluated the change in mortality rates before and during

| facility operations. The study concluded there was no evidence that nuclear

| facilities may be linked causally with excess deaths from leukemia or from other

| cancers in populations living nearby.

|

| C Investigators from the University of Pittsburgh found no link between radiation

| released during the 1979 accident at the Three-Mile Island nuclear station and

| cancer deaths among nearby residents. Their study followed more than

| 32,000 people who lived within 8 km (5 mi) of the facility at the time of the

| accident.

|

| C In January 2001, the Connecticut Academy of Sciences and Engineering issued

| a report on a study around the Haddam Neck nuclear power plant in Connecticut

| and concluded that exposures to radionuclides were so low as to be negligible

| and found no meaningful associations to the cancers studied.

|

| C In 2001, the American Cancer Society concluded that, although reports about

| cancer clusters in some communities have raised public concern, studies show

| that clusters do not occur more often near nuclear plants than they do by chance

| elsewhere in the population. Likewise, there is no evidence linking the isotope

| strontium-90 with increases in breast cancer, prostate cancer, or childhood

| cancer rates.

|

| C In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that

| there are striking increases in cancer rates in southeastern Florida counties

| caused by increased radiation exposures from nuclear power plants. However,

| using the same data to reconstruct the calculations on which the claims were

| based, Florida officials did not identify unusually high rates of cancers in these

| counties compared with the rest of the state of Florida and the nation.

|

| C In 2000, the Illinois Public Health Department compared childhood cancer

| statistics for counties with nuclear power plants to similar counties without

| nuclear plants and found no statistically significant difference.

|

| In summary, there are no studies to date that are accepted by the nation’s leading scientific

| authorities that indicate a causative relationship between radiation dose from nuclear power

| facilities and cancer in the general public. The amount of radioactive material released from

| nuclear power facilities is well measured, well monitored, and known to be very small. 

|
Appendix A

October 2006 A-75 NUREG-1437, Supplement 27

In spring 2006, the National Research Council of the National Academies published, “Health |

Risks from Exposure to Low Levels of Ionizing Radiation, BEIR VII Phase 2.” A prepublication |

version of the report was made public in June 2005. The major conclusion of the report is that |

current scientific evidence is consistent with the hypothesis that there is a linear, no threshold |

dose response relationship between exposure to ionizing radiation and the development of |

cancer in humans. This conclusion is consistent with the system of radiological protection that |

the NRC uses to develop its regulations. Therefore, the NRC’s regulations continue to be |

adequately protective of public health and safety and the environment. None of the findings in |

the BEIR VII report warrant changes to the NRC regulations. The BEIR VII report does not |

conclude that there is no safe level of exposure to radiation; it does not address “safe versus |

not safe.” It does continue to support the conclusion that there is some amount of cancer risk |

associated with any amount of radiation exposure and that the risk increases with exposure and |

exposure rate. It does conclude that the risk of cancer induction at the dose levels in the NRC’s |

and EPA’s radiation standards is very small. Similar conclusions have been made in all of the |

associated BEIR reports since 1972 (BEIR I, III, and V); the BEIR VII report does not constitute |

new and significant information. |

|

The comments provide no new and significant information and will not be evaluated further. |

|

Comment: Historically, the NRC has relied on a 1990 National Cancer Institute (NCI) study to |

address cancer rates near nuclear power plants. However, this study is now outdated, not |

accounting for latency periods which could have developed into cancers since 1990. And it was |

essentially methodologically flawed from the start, as the only data considered by the NCI was |

from the county that each reactor is located in, and not other downwind and downstream |

populations potentially affected by radioactive releases of the plants. Further, there are a host |

of other diseases associated with radiation exposure that have not been assessed, such as |

thyroid disease, infertility, genetic damage and birth defects, heart disease, and immune system |

suppression, which require monitoring and attention. A baseline assessment, as well as regular |

monitoring, of cancer and other disease rates is warranted prior to consideration of Palisades’ |

proposal for a 20-year license extension. (GG-31) |

|

Comment: Effects on the health of populations surrounding Palisades and subject to |

downstream or downwind discharges must be studied and quantified. The implications of the |

National Academy of Science’s recent findings require a thorough analysis by the NRC in its |

EIS of the human health impacts of the radioactive substances released by Palisades. |

NMC/Consumers are obligated to provide the communities in the vicinity of the Palisades plant, |

with a monitoring program to provide them with independent information regarding radioactive |

discharges and releases. There is also a need to establish a baseline assessment of cancer |

and other disease rates, as well as a program of regular monitoring, prior to consideration of the |

proposal for a 20-year license extension. This should also include an evaluation of the potential |
Appendix A

NUREG-1437, Supplement 27 A-76 October 2006

| for the synergistic effects of chronic or catastrophic radiation releases combined with the toxic

| pesticides to which migrant field workers in the region have been exposed. (GG-54)

|

| Response: The comments propose monitoring the health of people living near Palisades. 

| The evaluation of health effects from exposure to radiation, both natural and man-made, is an

| ongoing activity involving public, private, and international institutions. International and

| national organizations such as the ICRP and NCRP provide consensus standards developed

| from recent and ongoing research.

|

| The NRC’s regulatory limits for effluent releases and subsequent dose to the public are based

| on the radiation protection recommendations of these organizations. The NRC provides

| oversight of all licensed commercial nuclear reactors to ensure that regulatory limits for

| radiological effluent releases and the resulting dose to the public from these releases are within

| the established limits. The regulations related to radiological effluents and dose to the public

| can be found in 40 CFR Part 190, 10 CFR Part 20, and 10 CFR Part 50, Appendix I.

|

| Gaseous and liquid effluent releases are monitored at Palisades to demonstrate that they are

| within regulatory limits. As stated in Section 2.2.7, the dose to the hypothetical MEI is less than

| 1 mrem. Health effects due to radiation exposure at this level are highly unlikely and would be

| indistinguishable from effects due to background radiation. The average dose from all sources

| of radiation, including the natural background, is approximately 360 mrem per year. Therefore,

| neither the NRC nor the licensees directly monitor the health of the people in the communities

| around nuclear power plants. As discussed in the response above, a number of studies have

| been performed to examine the health effects around nuclear power plants, including the NCI

| report (NCI 1990). The studies have concluded that there was no evidence to indicate that an

| excess occurrence of cancer resulted from living near nuclear power plants. The comments

| provide no new and significant information and will not be evaluated further.

|

| Comment: License renewal should not be granted to the Palisades Nuclear Power Plant,

| because (3) radiative effects are only considered within a 50-mile radius. (KK-4)

|

| Comment: The 50-mile radius considered in the impact assessment also fails to account for

| the movement of radiation with the wind. The radiation may expand and become less

| concentrated as it moves away from the epicenter (NRC 2006), but recent studies have shown

| that there is no safe level of ionizing radiation (NAS 2005). The effects beyond the radius

| cannot be ignored or discounted as negligible without serious ethical repercussions with this

| knowledge of toxicity of any level of radiation. (KK-8)

|

| Response: The comments question NRC staff’s use of a 50-mi radius for impact assessment

| of radiation exposure. As discussed in the responses above, the highest dose to members of

| the public from the Palisades plant would be much less than 1 mrem per year. The plant-

| related dose to a member of the public more than a very short distance (e.g., 1 mi) from the
Appendix A

October 2006 A-77 NUREG-1437, Supplement 27

plant would be even smaller. The background dose to a person living in the United States from |

all sources of radiation – cosmic, the earth, radon, building materials, medical procedures, and |

nuclear power plants – is approximately 360 mrem per year. Therefore, the NRC staff |

concludes that the use of a 50-mi radius for assessment of impact from radiation exposure is |

conservative and adequate. The comments provide no new and significant information and will |

not be evaluated further. |

|

Comment: Section 8.2.1, Coal-Fired Generation, page 8-17, under bullet point Human Health. |

Any dose estimate that would have the potential to fall in the risk range of 10-6 to 10-4 or greater |

needs to be specifically evaluated for potential regulatory requirements or risk impacts to the |

public health. This should be estimated conservatively using the data that is currently available |

or that can be logically extrapolated from currently available information. (UU-12) |

|

Response: While it is possible to estimate the dose from a coal-fired power plant, many |

assumptions would be required, including location and makeup of the affected population. For |

the basis of comparing alternatives, the NRC staff does not perform a complete assessment of |

impacts of the alternatives, but rather a qualitative, and if feasible, a quantitative comparison. |

Because the location of an alternative to Palisades and the surrounding population is purely |

speculative, an estimated dose would have little real meaning. The impacts on air quality and |

human health resulting from the operation of a coal-fired plant are discussed in general in the |

GEIS (NUREG-1437). The GEIS acknowledges that public health risks from emphysema and |

cancer would likely result from coal-fired power plant emissions of regulated pollutants and |

radionuclides. The comments provide no new and significant information and will not be |

evaluated further. |

|

A.2.9 Comments Concerning Socioeconomic Issues |

|

Comment: Financial benefits to Covert Township, host to Palisades nuclear power plant, are |

not evident and not expected with a license extension. The township consistently rates |

substantially below comparable county, State and national economic indicators in median |

household and per capita incomes and the draft EIS notes no improvements are expected by |

the license extension. (GG-12) |

|

Response: Per 10 CFR 51.53(c)(2), an applicant’s environmental report is not required to |

“include discussion of the economic costs and economic benefits of the proposed action or of |

alternatives to the proposed action . . . .” Section 4.4 of this SEIS discusses the socioeconomic |

impacts of plant operations as they relate to public services, aesthetics, housing, offsite |

landuse, cultural resources, and environmental justice. Financial benefits to the community are |

beyond the scope of the environmental review for license renewal. |

|
Appendix A

NUREG-1437, Supplement 27 A-78 October 2006

| The comment does not provide new and significant information and will not be evaluated

| further.

|

| Environmental Justice

|

| Comment: License renewal should not be granted to the Palisades Nuclear Power Plant,

| because (2) the risk of radiation to minority populations is underestimated using census-block

| grouping. (KK-3)

|

| Comment: Covert Township is one with high levels of minority populations and has many

| people who are of a low socioeconomic status. In the impact statement, these populations were

| taken into consideration, but large urban centers such as Battle Creek, Muskegon and Grand

| Rapids -where significant African American and Latin American communities live -were not

| considered. Because less than fifty percent of these cities were within the 50-mile radius, they

| were eliminated, and therefore significant risks to the minority populations were not fully

| documented." (KK-7)

|

| Response: The SEIS identifies the distribution of low-income populations within a 50-mi area

| of the plant at the block group level in order to assess whether license renewal may impact

| environmental justice. Low-income and minority populations, defined if block groups were

| found to have more than 50 percent of individuals below poverty level determined in the 2000

| Census, or if the number of individuals below the poverty level was more than 20 percentage

| points higher than the State average, were found in block groups in western Van Buren County,

| immediately to the west of Covert Township.

|

| To capture environmental impacts that could potentially impact the population as a whole, a

| 50-mi area around the plant is used, which is assumed to be the greatest geographic extent of

| any potential airborne releases from the plant during normal operations or during accidents. 

| The SEIS identifies the geographic distribution of low-income and minority populations within

| this 50-mi area at the block group level in order to provide a detailed characterization of low-

| income and minority groups potentially adversely impacted by the plant. Because the cities

| mentioned in the comment are beyond the 50-mi limit of the impact zone, they are not included

| in the analysis. Analyses of census data at the census block group level provides information

| for geographic areas of approximately 1000 people each, on average, and as such provides

| sufficient geographic detail to assess the impact of Palisades on low-income and minority

| populations.

|

| The comments do not provide any new and significant information and will not be evaluated

| further in the SEIS.

|

| Comment: Palisades has been considered a major contributor to Van Buren County’s property

| and municipal tax revenues, but the economic benefit to Covert Township has been
Appendix A

October 2006 A-79 NUREG-1437, Supplement 27

ambiguous. In fiscal year 2004, a total of $3.6 million in property taxes went to Covert |

Township and schools, with an additional $1.6 million to Van Buren County and schools. As |

host to the Palisades plant and benefactor of its tax revenue, it is reasonable to assume that |

Covert Township should at minimum be at economic parity with surrounding geographic |

household and per capita incomes. Despite the financial benefit such payments suggest, |

however, Covert Township consistently rates substantially below comparable county, State and |

national economic indicators in median household and per capita incomes. The EIS overlap of |

Geographic Distribution of Minority Populations (figure 4-1 on p. 4-29 of the NRC draft EIS) and |

Low-Income Populations (figure 4.2 on p. 4-30) shows a large area of Covert Township (and |

St. Joseph/Benton Harbor) to be both "high minority and low-income. Poverty persists in the |

Covert Township, a high minority and low-income community, despite the presence of the |

Palisades nuclear power plant for nearly four decades. |

|

Consumers Energy is described as the largest employer in Van Buren County, with 484 |

employees (draft EIS, Table 2-8). The draft EIS states that unemployment in the county "was |

moderately high at 7.2% in December 2004," but determines no "incremental change" in |

employment and personal income resulting from a Palisades license renewal --new employment |

opportunities are not projected to occur. |

|

Palisades’ Permanent Employee Residence Information by County and City (Table 2-3) lists |

employee residence totals as: South Haven (156), Bangor (14), Grand Junction (13), Paw Paw |

(12), Hartford (8), and Others (30). Unfortunately, residents of Covert Township that might be |

employed at Palisades are not specified in this information, raising the question as to whether or |

not Covert Township residents benefit at all from employment at the plant. |

|

A review of household income further shows a lack of positive benefit to Covert Township from |

Palisades. Per capita incomes in 2000 were $21,587 for the United States, $22,168 for |

Michigan, $17,878 for Van Buren County and $12,156 for Covert Township (U.S. Census |

Bureau, 2000 Census, in 1999 dollars). These figures reveal incomes for Covert Township that |

range from 45% and 33% consistently lower than the State of Michigan and Van Buren County |

respectively. |

|

Covert Township reported 14.3% of families with incomes less than $10,000, three times the |

rate of Van Buren County. There are over three times as many families below poverty level in |

Covert Township as in Van Buren County. Covert bears the burden of 34% of related children |

under 18 years of age in poverty compared to Van Buren’s 11%; related children under 5 years |

of age in poverty, 38% compared to Van Buren’s 17%; Covert families with female |

householders, no husband present, 48% compared to Van Buren’s 25%; related children under |

18 years of age for Covert at 57% compared to Van Buren’s 30%, and Covert related children |

under 5 years of age living below poverty level at 80% versus Van Buren’s at 48%. Covert |

reports 32% of individuals in poverty while Van Buren reports 11% of individuals living in |
Appendix A

NUREG-1437, Supplement 27 A-80 October 2006

| poverty. As unfortunate as Van Buren County poverty levels may be, Covert Township’s

| poverty is consistently two and three times worse. None of this data was provided whatsoever

| in the scope of the EIS socio-economic factors.

|

| Comments by local and county government and Chambers of Commerce officials at public

| hearings have extolled the benefits of new fire trucks and infrastructure improvements, and the

| EIS notes that Palisades’ property tax revenues are "used to fund local and county emergency

| management programs, public safety, local public schools, local government operations, local

| road maintenance, and the local library system," (page 2-58, of the draft EIS). Still, Covert

| Township experiences chronic poverty.

|

| NRC staff ultimately determined that the socio-economic impacts resulting from Palisades’

| license renewal would be "small", implying that the impacts "would not produce an incremental

| change in any of the impact measures used. Unfortunately, the draft EIS’s methodology

| neglected a comprehensive analysis of socio-economic conditions in Covert Township and Van

| Buren County, leaving out those conditions that did not support a positive benefit from the

| nuclear power plant.

|

| NMC/Consumers discounts potential impacts to Latin American migrant workers in southwest

| Michigan from an extension of Palisades’ license. NMC/Consumers’ Environmental Report

| (page 2-32) notes (inaccurately) that "Berrien and Van Buren Counties host moderate numbers

| of migrant workers." According to the U.S. Department of Agriculture, however, in 2004, 3,677

| and 6,733 temporary farm laborers (many of them Latino) were employed in Berrien and Van

| Buren Counties, respectively. These numbers, in addition to family members of the workers,

| represent populations as large as the county seats and even the biggest towns in these

| counties. Rather than characterizing the number of migrant workers, many of whom are Latino

| and of low income, as "moderate," a more accurate characterization relative to the populations

| of the host counties would be "large," and therefore worthy of significant consideration not only

| in NMC’s Environmental Report, but also in NRC’s draft EIS.

|

| The Latin American agricultural workforce of the Palisades area is also at disproportionate risk

| from both routine radioactive discharges, as well as catastrophic radiation releases, given this

| workforce’s complete reliance on agricultural sector employment. A large-scale radiation

| release from Palisades could seriously damage the region’s agricultural base. Even a “minor”

| accident at Palisades involving radiation release could significantly harm area agriculture, due

| to the stigma attached to radioactive contamination. In either scenario, the Latino migrant labor

| workforce would suffer disproportionate harm. There also has been no evaluation of the

| potential for the synergistic effects of chronic or catastrophic radiation releases combined with

| the toxic pesticides to which field workers have been exposed. In addition, there are no Spanish

| language emergency evacuation instructions and notifications prepared to serve the Spanish

| speaking Latino population within 50 miles of the Palisades reactor. (GG-23)

|
Appendix A

October 2006 A-81 NUREG-1437, Supplement 27

Comment: A comprehensive analysis of socio-economic conditions in Covert Township and |

Van Buren County must be conducted to encompass income disparities. NRC must account for |

the lack of positive benefit by Covert Township residents as a result of the presence of |

Palisades’ nuclear power plant and potential license extension. NRC must also direct |

NMC/Consumers to address the potential for disproportionate harm to the Latino migrant labor |

workforce from harm to the agricultural base from a radiation release. (GG-60) |

|

Comment: It is baffling NRC concludes that "offsite impacts from Palisades on minority and |

low-income populations would be SMALL (sic), and no special mitigation actions are |

warranted." (EIS, p. 4-31) Just three pages earlier, NRC admits that “[c]ensus block groups |

with a minority population . . . are located in Covert,” Palisades’ hometown. Figure 4-2 on |

p. 4-30 also identifies Covert’s predominantly African American population as low-income.” |

Why Covert’s African American community is still low-income after 38 years of substantial profit- |

making at Palisades is quite troubling. In addition, Covert’s community suffers the worst |

radiation doses from routine operations at Palisades, and would suffer the worst health impacts |

from accidental radiation releases. NRC even ignores the fact that Palisades’ tax contributions |

to its neighboring community in Covert are dwindling over time - shown in Nuclear Management |

Company’s 2005 Environmental Report -- so residents suffer worsening risks as the reactor |

deteriorates with age, while also receiving decreasing benefits such as tax income. (see |

http://www.astrongerkinship.com/ for a recent book about the African American history of |

Covert). (MM-8) (NN-8) |

|

Comment: NRC’s treatment - or lack thereof - of Palisades’ impact on the surrounding Latin |

American agricultural workforce is remarkably inconsistent and disconcerting. Regarding |

environmental interveners’ contention that this community would suffer disproportionately from |

routine and accidental radiation releases from the reactor, NRC staff agreed that the company’s |

license extension application does not sufficiently address the “adverse socio-economic impacts |

of a catastrophic radiation release...as they would be found among the low-income Latin |

American agricultural workforce of the Palisades area...” and that such a contention would not |

necessarily be out of scope. Likewise, NRC’s licensing board stated that interveners’ allegation |

of disproportionate impacts upon Latin American agricultural workers from an |

embrittlement/PTS core rupture might be pertinent and admissible in the proceeding to decide |

whether or not to grant Palisades 20 more years. Yet, the licensing board dismissed the |

contention, stating ‘no facts that would tend to show impacts falling disproportionately on this |

community have even been alleged.” (see pgs. 57-6 0 of the licensing board’s March 7, 2006 |

ruling dismissing this and all other intervener environmental contentions; also see the |

contention itself, at Aug. 8, 2005 on the “Palisades Watch” website). (MM-9) (NN-9) |

|

Comment: Isn’t it obvious that a catastrophic radiation release at Palisades would ruin nearby |

agriculture for years, decades, centuries, perhaps even forevermore? Who would eat cherries, |

blueberries, grapes, peaches, apples, or other agricultural products from west Michigan after a |
Appendix A

NUREG-1437, Supplement 27 A-82 October 2006

| large radiation release from Palisades? (see EIS, p. 2-54 and 55; Table 2-6 shows that nearly

| half of Van Buren County’s land base is devoted to agriculture!) Wiping out of agriculture would

| very likely impact the low-income, minority community of Latin American agricultural laborers

| more than any other segment of the surrounding population. Yet, despite the NRC staff’s and

| licensing board’s statements to the contrary, NRC now dismisses any notion of disproportionate

| impacts upon - or even the existence of - a Latin American agricultural workforce near

| Palisades, in the space of two sentences. NRC now treats these real people as invisible (EIS,

| p. 2-57), which represents an environmental justice violation by NRC itself. (MM-10) (NN-10)

|

| Response: Environmental justice is addressed in Section 4.4.6 of the SEIS, where the NRC

| staff concludes that offsite impacts from Palisades on minority and low-income populations are

| SMALL, and no special mitigation action is warranted. 

|

| Regarding radiological impacts during normal plant operation, the NRC concludes in Section 4.3

| that the radiation exposure to the general public is SMALL based on GEIS findings. The NRC

| has similar conclusions in Section 5.1 for the impact of postulated plant accidents at Palisades. 

| Given that these impacts are SMALL on the general population, there is no evidence to suggest

| that any minority or low-income population could be disproportionately affected by such impacts

| in a severe or adverse way.

|

| The comments provide no new and significant information and will not be evaluated further. 

|

| Historic and Archaeological Resources

|

| Comment: And I’d like to raise a point. In the back of the room, there’s a summary of the

| findings of this EIS and one of them referred to, it’s a contradiction with NRC’s own report. It

| said historic and archaeological impacts would be small, but right in the beginning of this report

| it says that they may be small, but could be moderate for historic and archaeologic resources. 

| And when you read the details in here, NRC actually verifies exactly what we raised last July

| 28th at this very podium and again during the licensing proceeding, but we got thrown out of

| that, that Native American sites very well could exist, very likely do exist, NRC is now saying

| that, at Palisades, but no site survey is going to be required. They can do 20 more years worth

| of routine radiation releases. If forced to build new dry cask pads that comply with safety

| regulations, that could be built right on top of a Native American archaeological site, burial

| grounds, village sites. It’s not exactly far fetched when NRC admits that there are 15 such sites

| within a mile of Palisades or its transmission lines, including one 0.3 miles away, which I believe

| is the Brandywine in Palisades Park, exactly what we pointed out here. So my question is, how

| in the world did we get booted out of the NRC licensing proceeding on that one? (A-11)

|

| Comment: NRC reports that 15 Native American archaeological sites have been identified by

| surveys within 1 mile of the Palisades site and its transmission lines, including a prehistoric

| village site. Another of the prehistoric sites is of “unknown type,” just 0.3 miles south of the
Appendix A

October 2006 A-83 NUREG-1437, Supplement 27

Palisades site, and a third is just outside Palisades’ eastern boundary. (EIS, pgs. 2-62 to 63) |

This validates the environmental contention, arbitrarily dismissed by the NRC licensing board on |

March 7, that 20 more years of routine radiation emissions, potential accidental radiation |

emissions, and plant expansions such as additional waste storage pads could do irreversible |

harm to as-yet unidentified Native American burial sites, village sites, etc. at Palisades. Why |

did the licensing board dismiss this contention when NRC admits in this EIS that it is an issue? |

(see http://www.nirs.org/reactorwatch/licensing/palisades.htm at Aug. 8 and 30, 2005 for these |

Native American impact contentions). NRC admits in its draft EIS that “[i]ntact archaeological |

sites could be present within the remaining undeveloped areas as well as in soils below the |

depth of ground disturbance in most areas of the [Palisades] site.” It admits “no archaeological |

field surveys have been conducted either at the Palisades site or for original transmission line |

construction or maintenance...[and] without accurate knowledge of the cultural resources |

present at the Palisades site, it must be assumed that power plant construction has the potential |

to adversely impact significant resources that may exist on the plant site.” Palisades’ own |

cultural resource assessment 25 years ago recommended that “an intensive survey be |

undertaken of the undisturbed portions of the site.” Despite all this, no extensive surveying was |

ever conducted. In its draft EIS, NRC simply brushes off the potentially disproportionate |

impacts upon Native American cultural resources and spiritual values that could occur with 20 |

additional years of operations at Palisades. The intensive site survey must be performed, in |

close and meaningful consultation with affected Native American tribes, before NRC even |

considers granting Palisades a license extension. NRC granting an extension without requiring |

such a survey would itself represent an environmental justice violation, not to a mention a |

potential violation of the American Indian Religious Freedom Act. (MM-7) (NN-7) |

|

Comment: Page Number 4-40, Line Number 19. Suggest adding new sentence at end stating |

that NMC and Consumers have procedures in place to require evaluation for archaeological |

resources if land-disturbing activities are planned in previously undisturbed areas. (OO-38) |

|

Comment: Page Number 4-42, Line Number 23-24. Suggest noting that NMC and Consumers |

have procedures in place to require evaluation for archaeological resources if land-disturbing |

activities are planned in previously undisturbed areas. (OO-40) |

|

Comment: In an email dated May 18, 2006, Kevin Kamps submitted comments on behalf of |

Nuclear Information & Resource Service, et al. regarding Native American resources at the site |

of the Palisades Nuclear Plant. His comments are summarized below, and the full text can be |

accessed on ADAMS at ML0615700220: |

|

“It is legally and morally incumbent upon the companies and Federal and State agencies |

involved that a comprehensive site survey of the Palisades property be required and performed, |

and that it be carried out in close consultation and cooperation with affected tribes on a legally |

sufficient, government to government basis. If Native American burial sites or other significant |
Appendix A

NUREG-1437, Supplement 27 A-84 October 2006

| sites are discovered during the comprehensive site survey, then appropriate actions must be

| taken to protect these sites against 20 more years of radiological and physical disruption and

| damage; All this, before a license extension can legally be granted for Palisades.

|

| It cannot be overly reinforced and re-emphasized that there should be meaningful consultations

| not only between the impacted tribes and the Palisades nuclear plant owner and operator, but

| also government to government consultations between tribes and relevant and involved Federal

| government regulators and agents, including NRC. A letter or a phone call does not constitute

| legally sufficient government to government consultation.” (PP-1)

|

| Response: The NRC staff carefully reviewed the records and found that the Atomic Energy

| Commission (AEC) met the compliance standard for historic preservation consideration when

| the AEC made its decision to issue the initial operating license for Palisades.

|

| The original regulations, implementing Section 106 of the National Historic Preservation Act

| (NHPA) (36 CFR Part 800), were promulgated in 1979, 7 years after the AEC granted the

| original license for operation of Palisades. The Advisory Council on Historic Preservation

| (ACHP) had no prescribed regulatory process for Federal agencies to demonstrate compliance

| with NHPA Section 106 responsibilities until 1979.

|

| As required by Section 106, in 1972 the AEC provided information on the proposed action for

| Palisades, including information on historic and archaeological resources and determinations, to

| the ACHP and the U.S. Department of the Interior (DOI) with a request for comment. In a letter

| dated March 9, 1972, the ACHP stated that the final environmental statement should contain

| evidence of contact with the Michigan State Historic Preservation Officer (SHPO) and a copy of

| his comments concerning the effect of the undertaking on historical and archaeological

| resources. On May 19, 1972, the SHPO office responded to the AEC that Palisades will not

| adversely affect known historical or archaeological resources of the State of Michigan. On

| April 7, 1972, the DOI stated that the existing plant should not directly affect any existing or

| proposed unit of the National Park System, nor any site eligible for registration as a national

| historic, natural, or environmental education landmark. The DOI went on to state that the final

| environmental statement should contain evidence of contact with the Michigan SHPO.

|

| NMC submitted an application for renewal on March 31, 2005, pursuant to 10 CFR Part 54. The

| NRC has established that, as part of the staff review of any nuclear power plant license renewal

| action, a site-specific SEIS to the GEIS, NUREG-1437, will be prepared under the provisions of

| 10 CFR Part 51, the NRC rules that implement NEPA. In accordance with 36 CFR 800.8(c), the

| SEIS includes an analysis of potential impacts on historic and archaeological resources. The

| NRC has determined that the area of potential effect (APE) for a license renewal action is the

| area at the power plant site and its immediate environs that may be impacted by post-license

| renewal land-disturbing operations or projected refurbishment activities associated with the

| proposed action. The APE may extend beyond the immediate environs in those instances
Appendix A

October 2006 A-85 NUREG-1437, Supplement 27

where post-license renewal land-disturbing operations or projected refurbishment activities, |

specifically related to license renewal, may potentially have an effect on known or proposed |

historic sites. This determination is made irrespective of ownership or control of the lands of |

interest. |

|

As stated in the ER, NMC does not plan to undertake major refurbishment activities for |

Palisades license renewal. Additionally, there are no plans to significantly alter current |

operations or engage in any substantive land-disturbing activities on the site or the associated |

transmission line corridors as part of the license renewal process. |

|

As stated in this SEIS, the NRC staff reviewed the applicant’s environmental review procedures |

for Palisades during the site audit. NMC has stated that these procedures are in place to |

ensure that any archaeological resources that may be present receive consideration and |

protection. The procedures require that an archaeological survey be undertaken for any |

construction and modification activities that involve all ground-disturbing activities in the owner- |

controlled area of NMC-operated nuclear facilities and to those activities, including, but not |

limited to, the construction or expansion of buildings, facilities, stations, parking lots, roads, or |

overhead or underground utility lines. In the event that items of potential historic significance |

are discovered during surveys, NMC and Consumers Energy would consult with the SHPO prior |

to proceeding. |

|

Additionally, the NRC staff reviewed the applicant’s excavation and trenching control |

procedures, which require that any planned excavation activities that occur at a depth greater |

than 6 in. within previously undisturbed land be reviewed by the NMC Environmental |

Coordinator. The Environmental Coordinator’s responsibilities (as defined in NMC’s |

Archaeological, Cultural and Historic Resources procedures) include reviewing excavation and |

trenching plans to determine if any known archaeological resources are located within the |

proposed ground disturbance area, assessing the potential importance of any archaeological |

resources discovered during construction, and coordinating with the SHPO when potentially |

culturally important resource discoveries are made. The procedures also include a list of the |

types of archaeological materials that could be encountered during construction. During the site |

audit, the NRC staff expressed concerns about the NMC procedures not requiring a qualified |

archaeologist to survey the proposed ground disturbance area for archaeological resources |

prior to construction. In addition, the NRC staff noted that the procedure did not specify the |

training, experience, or credential requirements for the site’s Environmental Coordinator to |

recognize archaeological materials or assess the potential significance of historic or |

archaeological resources. Subsequent to the NRC staff’s comments, the applicant revised and |

implemented its procedures in January 2006 (NMC 2006) to reflect these concerns. |

|

The preliminary draft of the SEIS contained language that reflected the procedures prior to their |

revision by the applicant. Upon receipt of the applicant’s revised procedures, the draft SEIS |
Appendix A

NUREG-1437, Supplement 27 A-86 October 2006

| was revised by the NRC staff to reflect updated information. In several portions of the draft

| (e.g., the Abstract and Sections 4.8.3 and 4.9), the original text was inadvertently retained. The

| SEIS has been revised to reflect this oversight.

|

| Comment: NRC staff, in the draft supplement to the Generic Environmental Impact Statement

| (GEIS), recommended that the Commission determine that the impacts of continued operation

| of Palisades were not significant enough to make its extended operation unreasonable. The

| document states further that: “This recommendation is based on (1) the analysis and findings in

| the GEIS; (2) the Environmental Report submitted by NMC; (3) consultation with Federal, State,

| and local agencies; (4) the NRC staff’s own independent review; and (5) the NRC staff’s

| consideration of public comments received during the scoping process.” Astoundingly, it is

| obvious that Native American tribes were not included in the consultation process for the

| development of the draft EIS for Palisades.

|

| The role of affected Federally recognized, as well as non-Federally recognized Native American

| tribes can best be described as unfairly and severely restricted throughout all aspects of the

| development of the EIS. Even though the re-licensing application from NMC was submitted to

| the NRC in March of 2005, it was not until four months later that eleven tribes in Michigan and

| Oklahoma were invited to participate (via one letter) in the license extension proceedings. A

| single letter to a Federally recognized tribe is not legally sufficient government-to-government

| consultation. However, other tribes that might be expected to have a substantial interest in

| proceedings involving Palisades relating to treaty rights and other related issues were left

| completely out of any part of the process, such as the Bay Mills Indian Community, the

| Keweenaw Bay Indian Community, the Sault Saint Marie Tribe of Chippewa Indians, all in

| Michigan’s Upper Peninsula, tribes in Wisconsin, the Sauk and Fox Tribes and others in

| Oklahoma, and the Kickapoo Tribe of Texas (which absorbed the Mascouten Tribe), all with

| ancestral ties to the Lake Michigan shoreline. In particular, there are concerns for the continued

| disregarding of sacred burial grounds and other artifacts of tribal groups that may be present on

| the site and possibly along electric transmission lines extending from the plant, as well as

| concerns from the tribes in safeguarding such species as the sturgeon that may be negatively

| impacted by continued operations at Palisades.

|

| Native American tribes are known to have traveled regularly throughout the dunes in West

| Michigan, hunting in them and using dune plants for food and medicinal purposes. Because of

| that, it is likely that villages or encampments, as well as burial sites, may well have been located

| on or in the vicinity of Palisades, especially given the presence of creeks just north and just

| south of the plant site and the heavily forested, large dunes of the property. This likelihood is

| confirmed in the draft EIS, on page 2-61 to page 2-62, where the NRC reports “Native

| American groups that inhabited the area during the historic period were predominantly the

| Potawatomi, Mascouten, Miami, and Ottawa. During the early historic period, their villages were

| situated on the edge of forested land, adjacent to prairies and convenient to streams or the

| lakeside; temporary winter camps were established in sheltered areas. By the beginning of the
Appendix A

October 2006 A-87 NUREG-1437, Supplement 27

nineteenth century, the Potawatomi had established 11 known villages in southern Michigan. |

Most were near the shorelines of Lake Michigan and Lake Erie, generally along the streams that |

flow into their waters.” Thus, Palisades has a significant potential for such Native American sites |

to be located on its property. |

|

Nuclear Management Company (NMC), however, gives scant attention to the interests of Native |

American tribes in its over 500 page Environmental Report, prepared as part of the re-licensing |

application process. Section 2.10, “Historic and Archaeological Resources,” of the report |

consists of four paragraphs, taking up less than two-thirds of one page (Page 2-46). In fact, the |

potential for Native American sites on the Palisades property is not explicitly mentioned at all. |

In its Environmental Report, NMC referenced a number of documents prepared as part of the |

original license application for Palisades that noted the absence of known archeological or |

historical resources on the site or in the vicinity to discount the potential for Native American |

artifacts to be impacted by the license extension application. |

|

The only specific documentation NMC provides in the Environmental Report to support its claim |

that there are no Native American artifacts, is a letter dated April 7, 1972 from the |

U.S. Department of the Interior (DOI) to the U.S. Atomic Energy Commission (the predecessor |

to today’s NRC), in terms of nuclear power plant regulation). In that letter, reproduced from |

Pages C-5 to C-9 of NMC’s Environmental Report, DOI states “It does not appear that the |

existing plant should directly affect any existing or proposed unit of the National Park System, |

nor any site eligible for registration as a national historic, natural or environmental education |

landmark; however, the final statement should contain evidence of consultation with the State |

Historic Preservation Officer concerning the effects of the power station on places on or being |

considered for nomination to the National Register of Historic Places.” However, the DOI |

statement does not seem to indicate that there was attention placed on locating Native |

American burial sites, former village sites, etc. located on the power plant site or along the |

transmission line corridors. |

|

Even though the Michigan State Historic Preservation Office (MSHPO) noted the possibility of |

unreported artifacts (see Page C-2, Cultural Resources Correspondence of NMC’s Environment |

Report), there has been no survey done by Consumers Power to confirm or dispute this claim |

and no actions taken by MSHPO officials to resolve the question, demonstrating a distinct lack |

of significance attached to protecting the interests of Native American tribes. In fact, NRC staff |

acknowledged in the draft EIS that no adequate surveys have ever been conducted at |

Palisades. Further, although the draft EIS document determined that the license extension for |

Palisades might pose a “moderate” impact on the interests of Native American tribes regarding |

archaeological or historical cultural resources, this initial determination was verbally deemed “a |

mistake” by NRC staff at the April 5, 2005 draft EIS public comment meeting in South Haven, |

Michigan. We ask for an explanation as to the reason for this “mistake” and justification for a |

significant downgrading of the impact level ascribed to Native American interests in such |
Appendix A

NUREG-1437, Supplement 27 A-88 October 2006

| cultural resources as burial sites from “moderate” in the draft EIS to “small” at the public

| meeting.

|

| Forty years ago, Native American tribes were seemingly ignored in decisions regarding the

| original placement and construction of the Palisades nuclear power plant, even though it was an

| intense and disruptive use on lands at one time occupied by a number of tribes along Lake

| Michigan, which is revered by all Native Americans of the region. It can only be concluded from

| this most recent lack of attention in the re-licensing process, that these tribes have once again

| been accorded neither legally sufficient notification nor appropriate involvement, which is

| especially negligent in respect to the Federally recognized tribes, which are sovereign entities

| and are legally entitled to have a government-to-government relationship with the United States.

|

| All Native American tribes and bands that could be expected to have an interest in the

| application by Palisades to operate an additional 20 years deserve both notification of this

| process, as well as the opportunity to share government-to-government decision making

| regarding the application, as allowed for under NEPA and other Federal laws. A comprehensive

| site wide survey should be performed on the entire Palisades property - as recommended by

| Palisades’ own cultural resource assessment subcontractor as described in the draft EIS - 

| carried out in close consultation with all affected tribes. If Native sites, such as burials, are

| found, then appropriate actions should be taken to protect them from damage, again, in close

| and meaningful consultation with affected tribes in order to ensure that NEPA, treaties, and the

| terms of other relevant Federal laws, such as the Native American Graves Protection and

| Repatriation Act and the National Historic Preservation Act, are met. (GG-22)

|

| Comment: Native American interests must be addressed. All Native American tribes and

| bands that could be expected to have an interest in the application by Palisades to operate an

| additional 20 years deserve both notification of this process, as well as the opportunity to share

| government-to-government decision making regarding the application, as allowed for under

| NEPA and other Federal laws. A comprehensive site wide survey should be performed on the

| entire Palisades property–as recommended by Palisades’ own cultural resource assessment

| subcontractor as described in the draft EIS - carried out in close consultation with all affected

| tribes. (GG-53)

|

| Response: For all Federal undertakings, Section 106 of the NHPA requires consultation

| between the lead Federal agency and the affected State Historic Preservation Office or Offices

| and all affected Native American tribes. Native American tribal governments are to be

| consulted on a government-to-government basis. The NRC has initiated this consultation by

| inviting the 11 Federally recognized tribes to participate in the license renewal process (see

| Appendix E). The NRC welcomes input from concerned Native American government leaders,

| elders, and citizens who wish to participate in the license renewal process. Government-to-

| government consultation is an ongoing process that is not limited to the issuance of this NEPA
Appendix A

October 2006 A-89 NUREG-1437, Supplement 27

document. Additionally, the NRC staff forwarded the draft SEIS to the 11 tribes for comments. |

To date, no response has been received from the Native American tribes. |

|

Comment: Page Number 2-61, Line Number 2. Suggest clarifying that there are no “known” |

historic and archaeological resources at the Palisades site. (OO-25) |

|

Response: The text has not been changed in the SEIS. This is an introductory sentence |

describing the topic that is to be covered in this section. The requested information follows in |

the main text. |

|

Comment: Page Number 4-40, Line Number 14. Suggest clarifying that Section 106 of the |

NHPA directs Federal agencies, and not the applicant, to contact Tribal Governments to take |

into account the effects of their undertakings on historic properties. (OO-37) |

|

Response: Issuance, or in this case, renewal, of the Federal license is the trigger for |

Section 106 of the NHPA. The NRC is the lead Federal agency that initiates government-to- |

government consultation. While the applicant is not responsible for contacting tribal |

governments, it is subject to compliance with the Section 106 process as a licensee of the NRC. |

The requested change has not been made in the SEIS because it implies the applicant has no |

obligation under Section 106 of the NHPA. Because the operation of Palisades requires a |

Federal license, the NRC, and by extension, the licensee, are bound to comply with |

Section 106. |

|

A.2.10 Comments Concerning Postulated Accidents |

|

Comment: In terms of reactor accidents, again I will point to NRC’s own numbers. They |

haven’t updated these since 1982, so of course the number of people has grown in this region, |

the economy has grown in this region, so these damages from a severe accident at Palisades |

would be much worse now than what’s given. But NRC calculated that a severe accident and |

catastrophic radiation release, and this was a 1982 report, a radiation release from Palisades |

would kill 11,000 people downwind, injure 7,000 people, and do over $50 billion in damages. |

That’s 1982 figures, so if you adjust for inflation, it’s over $100 billion now. And of course, if |

there’s a major radiation release from Palisades, that’s it for Michigan’s tourism, that’s it for its |

agriculture, and that’s the reason that our volunteer pro bono citizen’s effort to try to stop this |

20 year extension has been so determined and will continue to be so at every turn, because we |

care a lot about the future of this State. (A-10) |

|

Comment: And the last thing I’ll say is NRC said that, you know, this license renewal may be |

granted but there are other factors out there that may end up, you know, deciding whether or |

not this place will operate for 20 more years. I’d like to say, yeah, there really is. One would be |

a severe accident at Palisades that would kind of take care of it right away for all of us. (A-12) |
Appendix A

NUREG-1437, Supplement 27 A-90 October 2006

| Comment: My concern is a catastrophic event. And as this plant becomes older and older as

| we already heard the Big Rock plant up in Charlevoix has been closed and it hasn’t been

| generating electricity for some time. And as Mr. Kauffman said generating power by nuclear

| plants is not the cheapest way to generate energy. Now I came from Kalamazoo because we’re

| right downwind of what could happen if radiation was released from the Palisades Plant. It

| would devastating to Southern Michigan perhaps Northern Indiana. It could, if you look at the

| Chernobyl case and I would guess that all those government authorities there in the Ukraine

| were just 100 percent behind Chernobyl until they had their accident. (R-3)

|

| Comment: How horriffic if we in Michigan had a “Chernobyl” incident contaminating Lake

| Michigan and the surrounding area. What a disaster that would be. (FF-3)

|

| Response: Section 5.1.2 of the SEIS addresses severe accidents, and Section 5.2 addresses

| mitigation alternatives. The comments do not provide new and significant information and will

| not be evaluated further.

|

| Comment: The draft EIS prepared by the NRC unaccountably discounts the effects of global

| warming. There is considerable evidence that more extreme winds, as well more frequent and

| intense tornadoes — all of which global warming could cause — could make operation of

| Palisades more and more risky over time. (GG-11)

|

| Comment: Environmental impacts during severe emergencies at the Nuclear Plant

| (uncontrolled releases of radioactive elements) were not considered for comparison purposes

| with other non nuclear alternative sources of energy. Even though probabilistic, these impacts

| should be evaluated and mentioned in the report’s final summary conclusions. (JJ-4)

|

| Comment: Recognizing that the loss of power at the Palisades Substation could result in

| severe Plant accidents (core damage), we wonder if all feasible mitigation measures were

| considered in this regard I.e. adding a second circuit to the 345kV line connecting Covert Plant

| to the Substation. (JJ-5)

|

| Comment: Given the potential dire consequences of a major accident and radiation release at

| Palisades, how can NRC screen out “Severe Accident Mitigation Alternatives” because “the

| required extensive changes.. .would involve implementation costs known to exceed any

| possible benefit”? (EIS, p. 5-5) In 1982, in its CRAC-2 (Calculation of Reactor Accident

| Consequences) report, NRC calculated that a severe accident and catastrophic radiation

| release from Palisades would kill 11,000 people, injure 7,000, and do over $50 billion in

| damages. The population in the surrounding region has only grown since then (EIS, Table 2-7,

| p. 2-56), so casualty figures would be higher today. And adjusted for inflation, that property

| damage figure would top $100 billion, only $10 billion of which would be paid back by the

| nuclear power industry and its insurance companies (under the Price-Anderson Act, renewed in

| 2005, U.S. taxpayers would have to pay the rest, or else damages wouldn’t be compensated for
Appendix A

October 2006 A-91 NUREG-1437, Supplement 27

at all). A major radiation release at Palisades would ruin Michigan’s tourism and agriculture |

forever. How can NRC’s EIS” cost/benefit” analysis ignore its earlier CRAC-2 report? (MM-5) |

(NN-5) |

|

Response: In determining whether a severe accident mitigation alternative (SAMA) should be |

implemented, the licensee performed a cost-benefit analysis using a methodology consistent |

with the NRC Regulatory Analysis Technical Evaluation Handbook (NUREG/BR-0184). This |

analysis identifies and estimates the relevant values and impacts of a proposed change and |

provides a structured approach for balancing benefits and costs in determining whether |

implementation is justified. The Probabilistic Risk Assessment (PRA) is used within this |

analysis to evaluate the reduction in probabilities (core damage frequency) and consequences |

(population dose) that would be associated with implementation of each alternative. Use of the |

PRA in this manner is an essential and widely accepted part of the cost-benefit methodology, as |

described in Section 5.6 of NUREG/BR-0184. |

|

The study alluded to by the commenter (NUREG/CR-2239) was performed in 1982 using the |

CRAC-7 computer code to estimate offsite consequences, generic “siting source terms” to |

reflect the spectrum of accidents that could occur at boiling-water reactors or pressurized-water |

reactors, and “representative” probabilities to reflect the likelihood of each of these source |

terms. Rather than ignore the earlier report, the offsite consequence analyses performed in |

support of the SAMA analysis represents a reassessment of offsite consequences based on a |

later generation offsite consequence code (i.e., Melcor Accident Consequence Code System 2 |

(MACCS 2), and plant-specific (versus generic) source terms and source term probabilities. |

Thus, the plant- and site-specific consequence analyses performed for license renewal are |

considered an improvement over the earlier study. The comments provide no new and |

significant information and will not be evaluated further. |

|

Comment: Section 5.2.2, Estimate of Risk, page 5-6. It is stated that “The baseline core |

damage frequency (CDF) for the purpose of the SAMA [Severe Accident Mitigation Alternatives] |

evaluation is approximately 4.05 x 10-5 per year. This CDF is based on the risk assessment for |

internally-initiated events. NMC did not include the contribution to risk from external events |

within the Palisades risk estimates; however it did account for the potential risk reduction |

benefits associated with external events by increasing the estimated benefits for internal events |

by a factor of two.” |

|

The estimates for risks from both types of events should be evaluated and presented, along |

with a rationale for not basing risk decisions on the external events or including them in the |

considerations as necessary to get an accurate portrayal of the risk of the licensing renewal. |

(UU-7) |

|
Appendix A

NUREG-1437, Supplement 27 A-92 October 2006

| Response: Risk estimates for both internal and external events are presented and discussed

| in Section G.2 of Appendix G of the SEIS. The risk from external events at Palisades is lower

than the risk estimates from internal events (e.g., 3.31 x 10-5 per year for fire and 8.88 x 10-6 | for

seismic events, compared with 4.05 x 10-5 | per year for internal events). Nevertheless, potential

| SAMAs to further reduce external event risk were explored as part of the SAMA evaluation

| (see Sections G.2.2 and G.3.2). As described in Section G.6.2, the risk associated with

| external events was specifically accounted for in the risk calculations that were used to support

| the decision regarding potentially cost-beneficial SAMAs at Palisades. The comment provides

| no new and significant information and will not be evaluated further.

|

| A.2.11 Comments Concerning Uranium Fuel Cycle and Waste Management Issues

|

| Comment: My first concern, and more important I think, is in relation to the spent fuel. 

| Everybody know that right now the spent fuel is stored outside, next to the power plant. So this

| keeps accumulating and there is a possibility of, theoretically send it to a central, national

| central depository. But it was impossible in 40 years to obtain or to realize this central

| depository. And the reason for that is not political. It’s not because people are not doing their

| work. It’s just because they, they waste half their -- long, long time, I mean. You have to keep it

| under control, under storage for at least 10,000 years. So nobody can guarantee that even the

| more stable place can guarantee that. So this is, if we continue doing that we are going to keep

| this material in that place forever. That’s what we have to understand. I mean, this is a fact. 

| What, what, why we are scared? Because we are increasing the possibilities of an

| uncontrolled releases of radioactive material. The plant has a bigger accident and can have

| uncontrolled releases, but this other thing we’re allowing here can also prove to have accidents

| by sabotage, by error, human error, by many things that, one important thing in life is

| imagination. So with a little bit of imagination, we, we can figure out that this is not way to go. It

| is not the way to go. (D-3)

|

| Comment: Okay. And my second concern is related a little with the first. The analogy that is

| used at Palisade has been following -- first. Through the use of a large amount of spent fuel

| waste, which is highly radioactive and this toxicity for a long time, 10,000 years. Second, the

| waste contains plutonium which if enriched could be used in the manufacture of atomic bombs. 

| Third, it is a low efficient use of the fuel, uranium. If continuing with this old technology, the

| amount of the available uranium in nature could be exhausted in a short time. The Nuclear

| Power Industry is in the process of producing a new generation of reactors. General Electric

| Company, Western Electric Company, Westinghouse Electric Company are doing that using full

| fuel recycling. These reactors that could be approved by 2015 will not have the above

| mentioned drawbacks of the old reactor technology. The spent fuel, the spent fuel in this

| reactors would be reduced in amount and would require shorter time in storage, 400 years. 

| Therefore a Central depository could be readily found. It would use the energy content in the

| fuel much more efficiently. The uranium available in nature could last for many centuries. The

| plutonium in the waste is not usable for the manufacture of weapons. (D-6)
Appendix A

October 2006 A-93 NUREG-1437, Supplement 27

Comment: NRC must provide a detailed explanation to the public as to the ultimate disposition |

of the wastes stored currently on the Palisades plant site, as well as the 290 additional tons |

expected as part of 20 additional years of operation. |

|

The proposed national repository for high-level wastes from nuclear power plants, Yucca |

Mountain, Nevada, is not expected to open until at least 2020, and is likely to be delayed |

beyond that date. Further, by law, the repository can only store 70,000 metric tons, which will |

not include the additional wastes generated at Palisades during a license extension. (GG-55) |

|

Comment: Section 6.1, The Uranium Fuel Cycle, page 6-3. Under the bullet point for Off-site |

radiologial impacts (individual effects from other than disposal of spent fuel and high level waste |

disposal), no consideration appears to be given to the potential long-term storage of the spent |

fuel and high-level waste materials on site until such time-as a permanent facility is finally |

licensed and begins to accept. these materials for disposal. A reference to other sections that |

this evaluation may have been included in should be provided here as well as in other sections, |

or if this evaluation has not been adequately conducted, the issue needs to be considered and |

an appropriate evaluation conducted. (UU-8) |

|

Comment: Section 6.1, The Uranium Fuel Cycle, page 6-8, under the bullet point for On-Site |

Spent Fuel. A more thorough evaluation for the volume of spent fuel expected to be generated |

during the additional licensed time needs to be provided, along with more-specific information |

as to site specific circumstances that.may impair or improve the risk values for potential |

exposures to this spent fuel storage. (UU-9) |

|

Response: Onsite storage of spent nuclear fuel is a Category 1 issue. The safety and |

environmental effects of long-term storage of spent fuel onsite have been evaluated by the |

NRC, and, as set forth in the Waste Confidence Rule at 10 CFR 51.23 (available at |

http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/part051-0023.html), the NRC |

generically determined that “if necessary, spent fuel generated in any reactor can be stored |

safely and without significant environmental impacts for at least 30 years beyond the licensed |

life for operation (which may include the term of a revised or renewed license) of that reactor at |

its spent fuel storage basin or at either onsite or offsite independent spent fuel storage |

installations. Further, the Commission believes there is reasonable assurance that at least one |

mined geologic repository will be available within the first quarter of the twenty-first century and |

sufficient repository capacity will be available within 30 years beyond the licensed life for |

operation of any reactor to dispose of the commercial high-level waste and spent fuel originating |

in any such reactor and generated up to that time.” Section 6.1 provides the information |

available regarding the status of the application for a high-level waste repository. The |

comments do not provide new and significant information and will not be evaluated further. |

|
Appendix A

NUREG-1437, Supplement 27 A-94 October 2006

| Comment: Palisades license extension will increase the amount of high-level waste on the

| Lake Michigan shoreline and the number of dangerous barge shipments of high-level

| radioactive waste on Lake Michigan. Palisades will generate approximately 290 more tons of

| high-level radioactive wastes in 20 additional years with no national repository likely to be

| established to receive the wastes. The U.S. Department of Energy’s plan for transporting high-

| level radioactive wastes generated by the plant’s operation, involves barging up to 125 or more

| giant rail-sized containers of the wastes from Palisades to the Port of Muskegon, up along the

| Lake Michigan shoreline. The slightest leakage of even a small amount of this waste could not

| only threaten Lake Michigan as a source of drinking water for ten million people, but also cause

| a host of other irrevocable impacts on the lake’s fish, wildlife, people, and economy. (HH-5)

|

| Response: Transportation of spent fuel was evaluated in the GEIS and was determined to be a

| Category 1 issue. The comment provides no new and significant information and will not be

| evaluated further. 

|

| Comment: The Barnwell, South Carolina “low” level radioactive waste dump, which has

| accepted shipments from Palisades for decades, will close its doors to wastes from Michigan in

| 2008. Neither NMC in its Environmental Report, nor NRC in its draft EIS, have explained how

| Palisades will deal with the “low” level radioactive wastes when Barnwell closes, such as

| establishing storage installations for “low” level radioactive wastes on the plant site. What NRC

| and the nuclear industry term “low” level radioactive wastes contain many of the same radio-

| nuclides as high-level radioactive waste, only less concentrated. Some “low” level radioactive

| waste can even deliver a lethal dose of radiation at close enough range in as little as

| 20 minutes. “low” level radioactive waste management at Palisades is a significant health,

| safety, and environmental issue that requires is largely unaddressed by NMC and NRC in the

| license extension application and requires specific consideration. (HH-39)

|

| Response: Low-level waste storage and disposal were evaluated in the GEIS and were

| determined to be Category 1 issues. The impact was determined to be SMALL. The

| Commission is confident that all nuclear waste generated will be handled, stored, and disposed

| of in a manner that assures public health and safety. The comment provides no new and

| significant information and will not be evaluated further. 

|

| Comment: According to Dr. Arjun Makhijani, Director of the Institute for Energy and

| Environmental Research, uranium mining and milling inflicts some of the worst human health

| impacts of the entire uranium fuel chain. This is due to the careless handling of the radioactive

| materials involved, and dumping of waste materials upon the surface of the land, where they

| can be dispersed in air and water. Because of this, the Navajo Indian Tribe in the Southwestern

| United States-the largest Indian Tribe in the country-has officially banned the mining, milling, or

| processing of uranium upon its reservation territory.

|
Appendix A

October 2006 A-95 NUREG-1437, Supplement 27

NRC’s draft EIS does not address such negative environmental impacts of the nuclear fuel |

chain. A full cost accounting of the uranium fuel chain’s negative impacts on health and the |

environment is required to properly evaluate Palisades’ twenty-year license extension request. |

(HH-47) |

|

Response: The comment is related to the uranium fuel cycle and waste management issues. |

Uranium fuel cycle and waste management issues were evaluated in the GEIS and were |

determined to be Category 1 issues. The Commission is confident that all nuclear waste |

generated will be handled, stored, and disposed of in a manner that assures public health and |

safety. The NRC has specific regulations for releases of radioactive materials from the uranium |

fuel cycle to the environment. The comments provide no new and significant information and |

will not be evaluated further. |

|

Comment: Section 2.1.4.1, Liquid Waste Processing Systems and Effluent Controls, |

Page 2-12. The draft SEIS does not provide quantitative details about the planned modification |

of the liquid radioactive waste processing system. The draft-SEIS states that NMC is planning |

to replace the current system, which is based on evaporation, to a system using resins for ion |

exchange. The draft SEIS does not provide quantitative details about the estimated change in |

collection efficiency between the two systems. This information should be provided in the final |

SEIS. (UU-16) |

|

Response: The information provided in the draft SEIS in Section 2.1.4.1 regarding planned |

modification of the liquid radioactive waste processing system has been updated to reflect that |

NMC completed its modification in December 2005. The NRC staff evaluated the modification |

in Section 2.1.4.1 qualitatively rather than providing quantitative details, because the |

requirements of 10 CFR Part 20 and Part 50, Appendix I for effluent controls are based on |

radioactive releases and resulting doses rather than collection efficiencies of the plant’s system, |

e.g., if a batch of liquid waste did not meet release requirements, it could be recycled through |

the resin bed and sampled again until it met such requirements. In addition, changes or |

modifications to facilities and equipment at operating nuclear plants are regulated under the |

requirements contained in 10 CFR Part 50 for operating reactors; any such modifications at |

Palisades would have been done in accordance with those requirements. However, the NRC |

staff also notes that similar systems have been employed at other nuclear reactors, such as |

Nine Mile Point and D.C. Cook, and have shown releases well within regulatory limits. On this |

basis, the NRC staff expects that the equipment modification would not change the applicant's |

ability to process liquid radioactive waste much, and that releases would continue to remain |

within regulatory limits. |

|

The comment does not provide any new and significant information and will not be evaluated |

further. |

|
Appendix A

NUREG-1437, Supplement 27 A-96 October 2006

| A.2.12 Comments Concerning Alternative Energy Sources

|

| Comment: My question is, in this regard, is that we are reading this report or your final result is

| administered by you and it’s only, is going to say, well, that Palisades can continue. I mean, the

| fact that Palisades can continue operation is not unreasonable. And I understand that you are

| stressing that result. But on the side, you are taking position on alternative solutions that I read

| and I don’t think is enough education in your point. Because the fact is that wind is flying. We

| are having wind all over the world and in here too. So I guess you missed the point in this. And

| I don’t understand why you, you are so concerned on our selecting alternatives if we know

| about the alternatives. And really, you are not doing a good job and the guys are going to really

| make the decisions, went through the final decision. (D-1)

|

| Comment: But when I turn to the alternative energy sources, which should be pursued at the

| Palisades Plant site, their impacts are often referred to as large. Which all considering, they

| would be, taking into account the enormity of the electrical power the plant puts on the grid, for

| alternatives to equal out in their current forms at this site. A rather particular assumption

| bracketing both the plant and the NRC’s positions well, yet ignoring the simple fact that if all the

| resources used to continue operation of this plant were put into renewables and other forms of

| electrical generation throughout the State, it would turn the argument on its head. (B-7) (O-2)

| (TT-7)

|

| Comment: And sooner or later human beings probably are going to make some errors. And

| with a gas-fired plant, right across the road you can -- facilities, as the Palisades Nuclear Power

| Plant that I kind of wondered, why in the world don’t we go to a plant already on line there,

| already ready to deliver, as opposed to the aging Palisades Nuclear Power Plant. (E-2)

|

| Comment: Secondly, I heard that solar and acreage. And it’s my understanding that solar is

| very commonly mounted on rooftops and walls in cities, which also reduces transmission loss,

| etc., that comes from centralized nuclear plants scattered around and have this great

| transmission loss over their process of getting the electricity to where it is needed. (F-2)

|

| Comment: Now, we do want to say that one of the important points, and the word I haven’t

| heard, is sustainable. We have not talked sustainable power and energy. And in the 21st

| century and beyond, we need sustainable power, not the fossil fuel which nuclear is also. 

| There’s a limit to uranium involved, so it’s about time that we began to think for our great great

| grandchildren. And we have, anybody else? This little guy’s going to help us here. This is an

| adaptation of the Raging Grannies presentations that they have given all across the country in

| various ways. (F-3)

|

| Comment: And this, heard a lot about alternate forms of generating electricity. And I’ve read

| quite a bit about it and nothing I have read has convinced me there is a better way. I’m local,
Appendix A

October 2006 A-97 NUREG-1437, Supplement 27

sometimes a lot of these people from far away come in and tell us how we’re supposed to do |

things. I don’t particularly appreciate that either. (K-4) |

|

Comment: My hope is that by the time the current license expires in 2011 that nuclear power |

should be replaced by wind power and by a lot more conservation and more efficient use of |

electrical energy. That is possible. I’ll come back to that. (P-3) |

|

Comment: Also it’s [wind power] cheaper. Currently as according to my latest figures and I’ve |

been doing a lot of reading on this, wind energy is sold for four cents a kilowatt power or less |

sometimes when it’s under long term contract to where as I understand the cost of nuclear |

energy is about three times higher than that. So we the taxpayers, the ratepayers are paying so |

somebody else can make money. And it’s not necessary. Let me explain. (P-4) |

|

Comment: In any case wind power is really growing worldwide. It’s growing at the rate of |

30 percent per year. Most of this is happening in Europe and in Europe Germany is in the lead |

with I believe at this point 14,600 megawatts of electricity from wind. They seem to know how to |

do it. So I suggest to the people at the NRC or to the, to the management company that they |

should go to Germany and ask and say we don’t know how to make wind power work here |

maybe you could tell us how to do it. (P-7) |

|

Comment: And incidently wind generators and their, their towers can be reused and recycled |

over and over again so that they have that advantage as well. And they provide the jobs that |

you’re so concerned about in this community. (P-10) |

|

Comment: Finally I have to say that according to the GEIS again Consumers Energy has |

decided they didn’t want to deal with what they call DSM and for you who haven’t read the book |

DSM mean demand supply management. In other words giving advise to the consumer to use |

less energy to get complex for, you know, all of the things that could save energy. Oodles of it. |

They chose not to do that. Why? Well, it might be very costly or this or that. Now come on. |

This would be a way of trying to sort of curtail the need for licensing this plant in a risky way for |

another 20 years. Any relevance has said that we could do with 50 percent less electricity if we |

used it intelligently and if we conserved. (P-12) |

|

Comment: So I, I believe that we would be far better to spend our money on safer distributing |

energy sources like wind power particularly in Michigan. My wife and I just came back from |

California. Even a State like Wyoming has tremendous numbers of wind generating plants now. |

Wyoming has tremendous amounts of coal. They have tremendous amounts of oil yet they are |

going to wind generation. And you look out across this nation the idea that you, you cannot |

have distributed types of energy production is insane in my view point. So let’s invest in |

alternative energy sources. (R-4) |

|
Appendix A

NUREG-1437, Supplement 27 A-98 October 2006

| Comment: So if this money were diverted to the renewables and the technology to wind and

| solar you would and perhaps let’s pretend that the, the information in the environmental impact

| statement is correct for a minute but as submitted by the, in the EIS, that, that wind turbines

| need X amount of acreage and all this and they can only produce X amount of megawatts

| etcetera. If you take even a minuet amount of the money that is given to the nuclear industry

| just as a given and divert that to renewables and, and improve the technology of the renewables

| this would absolutely not be an issue. (AA-5)

|

| Comment: So let’s look for alternatives. We need a whole new way of living. We can get

| along with a lot less of this, look at this. Lights on all night. You go to the cities they’re, and

| frankly we’re going to, we’re running out of oil, we’re running out of natural gas, we’re running

| out of a lot of stuff. We’re going to have to think about doing things a different way guys. 

| (BB-5)

|

| Comment: I think that the premiss is upside down where they consider the, another 20 years

| of, of Palisades operating as, environmentally a small issue and they consider alternatives as a

| great impact. I think it’s opposite actually. (DD-7)

|

| Comment: The analysis of alternatives to extending the license for Palisades was flawed and

| biased. Renewable energy sources such as wind power and solar power, as well as

| alternatives such as energy efficiency and conservation, are not given credible consideration in

| the EIS. NMC/Consumers and the NRC reveal a bias in favor of fossil fuel and nuclear power

| by presenting only those two sources favorably and by downplaying the potential for energy

| efficiency, energy conservation, and renewable sources of electricity. (GG-10)

| Comment: The drive for re-licensing of the nation’s nuclear power plants started as early as

| 1982, with research on aging of nuclear reactors, and began in earnest in 1991 when the NRC

| published safety requirements for renewal. Currently, re-licensing plans are moving more

| rapidly as proponents attempt to take advantage of the nation’s current energy crisis. Extended

| and new nuclear power generation is now being promoted as a “clean” alternative to the use of

| fossil fuels, which are now universally acknowledged as contributing to global warming. Many

| utilities that own nuclear power plants, however, including Consumers Energy, also own coal-

| burning plants. Consumers Power, in particular, generates a sizable share of its electricity from

| the burning of fossil fuels. (GG-16)

|

| Comment: In the draft EIS, Section 7.0, “Alternatives to the Proposed Action,” renewable

| energy sources such as wind power and solar power, as well as alternatives such as energy

| efficiency and conservation, are not given credible consideration. Polluting electricity sources

| such as fossil fuels are cited by NMC/Consumers as the only realistic alternatives to approval of

| a 20-year license extension at Palisades. This is not surprising, as nearly three-quarters of

| Consumers’ electricity generation (in 2002) comes from fossil fuel facilities. But the choice is

| not just between nuclear power and coal as sources for electricity generation. NMC/Consumers

| reveal a bias in favor of fossil fuel and nuclear power use by presenting only those two sources
Appendix A

October 2006 A-99 NUREG-1437, Supplement 27

favorably in their Environmental Report, and by downplaying the potential for energy efficiency, |

energy conservation, and renewable sources of electricity. NRC echoes this as well in its draft |

EIS. (GG-43) |

|

Comment: Renewables, efficiency and conservation are not only available, reliable, safe, |

clean and affordable options for electricity generation and savings, but also a source for |

tremendous job growth and cost savings. Using simple energy efficient techniques, Michigan |

citizens and businesses could easily reduce the State’s energy demand by 1%, the energy used |

by 40,000 homes. In the State of Michigan there is currently 19,250 megawatts of generating |

capacity. Palisades generates 798 megawatts, or 4% of the power generation in the State of |

Michigan. Wind power potential in Michigan, according to the DOE, is 16,000 megawatts, or |

twenty fold the mega-wattage of Palisades, and could be a viable replacement for the energy |

that Palisades provides. In fact, wind power is the fastest growing new source of electricity in |

the United States, relative to all other sources. (GG-44) |

|

Comment: There are also many examples of new efforts underway in Michigan to move |

forward with renewable energy, with the deployment by Mackinaw Power of modern, large |

capacity wind turbines on the northern tip of Michigan’s lower peninsula, plans to deploy more |

wind turbines on the Lake Michigan shoreline of west Michigan, and advances in solar electricity |

by United Solar Ovonics in Troy, Michigan (which manufactures solar electricity generating |

roofing shingles). President Bush visited the headquarters of United Solar Ovonics earlier this |

year to promote promising renewable energy technologies. |

|

It is especially significant that on April 6, 2006, Michigan Governor Jennifer Granholm signed |

Executive Directive No. 2006 - 2, which charges the Michigan Public Service Commission to |

prepare an “Energy Plan for the State of Michigan” by December 31, 2006. The directive calls |

for the development of a renewable portfolio standard that “establishes targets for the share of |

this State’s energy consumption derived from renewable energy sources” and initiates the |

“appropriate use and application of energy efficiency, alternative energy technology, and |

renewable energy technologies.... consistent with the goal of assuring reliable, safe, clean and |

affordable energy.” This puts the State of Michigan in a favorable position to promptly substitute |

clean energy sources for those with adverse impacts, such as nuclear power, as it moves into |

the forefront of renewable energy technology. (GG-46) |

|

Comment: NRC must revise its analysis of energy alternatives. Full and objective |

consideration must be afforded the options of renewable energy and efficiency. NRC must also |

provide a thorough cost accounting of the uranium fuel chain’s negative impacts on health and |

the environment. (GG-62) |

|

Comment: I agree with Don Williams, retired Hope College chemistry professor that, “not only |

should Palisades’ life be extended, but another reactor...added”, and to paraphrase, NRC needs |
Appendix A

NUREG-1437, Supplement 27 A-100 October 2006

| to plan for decommissioning the current reactor, replacing it with a more advanced, safer, more

| economical Generation III plant. (HH-3)

|

| Comment: The considered Environmental Impacts were not weighed as required to perform an

| overall impact evaluation. In other words, not all environmental impacts have the same effect.

|

| Renewable (sustainable) energy sources should be given extra points when compared with

| energy sources of lower availability. Wind and Solar sources are renewable energy sources. 

| The Standard Nuclear Plant, using Light Water Cooled Reactor, is a source of limited

| availability. New types of Nuclear Reactors, using advanced fuel cycle or a fast neutron reactor

| would be of longer availability.

|

| Nuclear Power alternatives using advanced fuel cycles would decrease the amount of long term

| hazard of nuclear waste. Is this point being considered in the comparison of Nuclear Plants?

| Is the impact on Proliferation of radioactive materials in the World being considered to evaluate

| the Nuclear Plants? The standard Nuclear Plant using 5% enriched Uranium has technology

| and materials that could be used for the manufacture of the plutonium bomb.

|

| Between the alternatives to be considered to obtain an “equivalent” electric generation we

| believe that the following should be maintained as technically feasible:

| -Hydro-Pump storage (not considered in the GEIS)

| -Demand side Load Management (considered but disregarded)

| I.e. the introduction of smart electric meters

| -Wind Power (considered in GEIS Page 8-45, but disregarded)

| -Solar Power (considered in GEIS Page 8-45, but disregarded)

| -Co-generation (not considered in GEIS)

|

| Are the CO2 atmospheric emissions for the different energy sources being considered in the

| evaluation of alternatives? (JJ-7)

|

| Comment: Of course, there are many other adverse environmental impacts 20 more years of

| operations at Palisades would cause. But in addition to all the negatives about Palisades, there

| are positive alternatives: energy efficiency, wind power, solar power, and biomass could be

| offered as alternatives to 20 more years of nuclear power and radioactive waste generation. 

| But NRC shrugs off such notions in its draft EIS. (MM-12) (NN-12)

|

| Comment: There are a number of energy efficient alternatives that are more viable for the

| area. Overlooking the interests of the people and clearly identified health concerns in the

| interest of plant self-preservation are actions from a bygone era. (RR-3)

|

| Response: NRC’s requirements to consider the environmental impacts of various alternatives

| are based on NEPA. The purpose of NEPA is to ensure that relevant agencies examine and
Appendix A

October 2006 A-101 NUREG-1437, Supplement 27

disclose the potential environmental impacts of their actions before taking the action. NEPA is a |

procedural statute that does not dictate a decision based on relative environmental impacts. |

Furthermore, the NRC has no authority or regulatory control over the ultimate selection of future |

energy alternatives. Likewise, the NRC cannot ensure that environmentally superior energy |

alternatives are used in the future. The NRC makes its decision whether or not to renew the |

license based on safety and environmental considerations. The final decision on whether or not |

to continue operating the nuclear plant will be made by the utility, State, and Federal (non-NRC) |

decision makers. This final decision will be based on economics, energy reliability goals, and |

other objectives over which the other entities may have jurisdiction. Moreover, given the |

absence of the NRC’s authority in the general area of energy planning, the NRC’s identification |

of a superior alternative does not guarantee that such an alternative will be used. |

|

Comment: I was wondering on this assessment of wind and solar, granted Michigan doesn’t |

have sunshine every day like the Western states. Solar really isn’t feasible here as an |

alternate. But what about the wind? You’re saying it’s, it’s a large concern because it takes a |

lot of land. How much of power for Palisades is sold out of State? What percent of the power is |

sold out of State? Well, this, this, this all comes together because if you’re taking this and |

you’re saying 143,000 acres, but if Palisades, like D.C. Cook, sells most of its energy out of |

State, that’s really not a proportionate summation. One other thing, please. This is, this is |

important. What are you basing on, what size wind generators are you basing this summation |

on? The small little ones, or the ones that they’re using now, the big ones that Consumers |

Energy’s investing in to replace the nuclear? Palisades is up for sale. They want it off their |

hands. They were investing in green energy and it’s working. So I wonder about this. (C-1) |

|

Comment: But I would like to know, technically, all right, how you came to this summary and |

the size of the wind generators you took into account in this summary, et cetera, et cetera, et |

cetera. The whole detail. (C-3) |

|

Comment: I asked how much is sold out of State, and what size wind, what size wind |

generators? What, what is the size in your analysis, what size, what size wind generators are |

you saying would take that much acreage? And how much of Palisades power is sold out of |

State? (C-4) |

|

Comment: Several things. Number one, I’m concerned that the kinds of answers we’re |

hearing, I, I feel are very questionable. For instance, wind power in itself, you don’t measure |

that by acreage because farmers are finding a very successful business for them to put the wind |

farms along their lot lines. And so it’s a very definite advantage environmentally in that respect, |

and I didn’t hear that kind of that thing in your report. (F-1) |

|

Comment: And I have a question for Dr. Miller and ask if you really want to stand by those |

figures that you cited on wind energy 125,000 acres for I presume the kind of megawatts the |
Appendix A

NUREG-1437, Supplement 27 A-102 October 2006

| plant currently produces. If you, if you, if you do the calculations here I know there’s been

| machines that put out four megawatts each and there could be, you know, maybe you’d need

| about 200 of them or so to do that and that would be about 500 acres per machine. And that

| makes it look as if wind is really impossible but it’s not. And I think there’s a fallacy in there. 

| (P-1)

|

| Comment: Palisades sits on 432 acre site of which 80 acres is developed or I presumed used. 

| That leaves 200 to 300 acres of land which could be available for wind turbines. If you figure

| four acres per turbine and they’re really large, this would be a four megawatt turbine and they

| exist, you would need or you would have room for about 50 large wind turbines. They could be

| erected on the site, more land could be rented for farmers down the line along the transmission

| line too. But even these 200 megawatts that would be produced here by wind is not negligible. 

| That’s one fourth as much roughly as the current nuclear plant provides. (P-5)

|

| Comment: Now on page of the GEIS on page 845 I understand that wind power had been

| considered and rejected for a number of reasons. One of which is that it said could be

| intermittent and there’s sense in which you could say that but I, I have a wind generator next to

| my house, nearby, and I say that wind power isn’t seasonal. Because in this season it hasn’t

| quit running for weeks and weeks. So it’s not just intermittent but it might be seasonal. So

| certain other seasons might require a different mix of energy to keep the customers going. So

| that’s one of the problems I have here. It isn’t simply intermittent. It’s seasonal. (P-6)

|

| Comment: I want to suggest that there are three paragraphs on page 8-45 of this GEIS dealing

| with wind power and together the three paragraphs includes so many distortions, falsehoods or

| simple stupidity that I think if this is a kind of an indication of what’s in this book it’s bad news

| because this is not going to fly. (P-8)

|

| Comment: The way this is put down here is to sort of make wind a non starter. And it’s not

| true because as I just said it is growing worldwide and it could here too if people were to take a

| different kind of attitude. (P-9)

|

| Comment: There, I already mentioned in my comment earlier that it does not require 500 acres

| for a single wind generator and if the large ones, you know, the, the way the GEIS puts it you

| really have a system here where they say you need 500 acres or well actually they say 150,000

| acres in order to provide 1000 megawatts. I’ve been on wind farms and many of you have seen

| them. They’re not one per 500 acres. This is either a big mistake by somebody that should

| have known better or it’s a blatant distortion. As I suspect the latter because they don’t want to

| deal with wind power they’d rather deal with nuclear because that’s the business that they’re in

| both for the commercial and governmental agency. So I, I worry about this. (P-11)

|

| Comment: So my point is that I think the, the put down of wind energy in this book is so blatant

| that I suspect I have to say I’m afraid I lose, I think that the nuclear regulatory commission loses
Appendix A

October 2006 A-103 NUREG-1437, Supplement 27

credibility by people who know something about this. And that’s a serious thing because I don’t |

want to live in a society where governmental agencies lose credibility because they’re supposed |

to be responsible. (P-13) |

|

Comment: NRC staff’s assertion in the draft EIS that such wind power expansion would have a |

large negative impact due to the large surface area of land it would require is incorrect, and |

ignores the fact that small-scale family farmers could benefit from the placement of wind |

turbines on their fields. These farmers could either benefit from the lease payments from wind |

power companies for use of their land’s “windshed,” or could work towards owning their own |

wind turbines on their own land, and thus receive the full income from wind powered electricity |

generation. Wind turbines would not preclude the farmers’ continued use of fields for |

agricultural crop or livestock production. Wind power could serve as a valuable source of |

income for farming families, complementing their agricultural livelihood, while also providing |

safe, clean, reliable, and inexpensive electricity for the region. (GG-45) |

|

Response: The SEIS has been revised to incorporate the latest information on wind power |

technology. The National Renewable Energy Laboratory estimates that the footprint of a |

1.5-MW wind turbine (the largest land-based turbine currently available) is between 0.25 and |

0.5 acres. The spacing between turbines would be at an interval of 5 to 10 turbine rotor |

diameters (a rotor diameter for a 1.5-MW wind turbine is assumed to be approximately 200 ft). |

It is estimated that 524 1.5-MW turbines would be needed, in areas with a wind class of Class 3 |

or higher, to produce 786 MW(e). The total acreage for a wind farm of 524 turbines in optimal |

wind conditions would be in excess of 2000 acres. Approximately 262 acres of those would be |

dedicated to the footprint. The remaining acreage could be available for other uses (e.g., |

farming, grazing). |

|

The comments also speak to the attractiveness of wind or solar energy versus nuclear power. |

The SEIS’s discussion on alternatives is only intended to disclose the potential environmental |

impacts of each feasible alternative. The final decision on whether or not to continue operating |

the nuclear plant will be made by the utility, State, and Federal (non-NRC) decision makers. |

This final decision will be based on economics, energy reliability goals, and other objectives |

over which the other entities may have jurisdiction. Moreover, given the absence of the NRC’s |

authority in the general area of energy planning, the NRC’s identification of a superior |

alternative does not guarantee that such an alternative will be used. |

|

Comment: I have two questions involving the last point on the board there. That includes, |

well, yes I guess, all of, and when you consider those solar and wind power would that be like a |

centralized like field of windmills and–sun panels. I’m worried about like the environmental |

effects. Is that moderate or large considering that it would be all in one place? (T-1) |

|
Appendix A

NUREG-1437, Supplement 27 A-104 October 2006

| Response: The factor that elevates the impacts of renewable energy alternatives to

| MODERATE and LARGE is that you are evaluating the impacts at a baseload capacity. Many

| of the renewable energy alternatives are very effective at small capacity levels (i.e., under

| 100 MW(e)). When those alternatives are expanded to meet baseload needs, the potential for

| environmental impacts becomes very large because of the scale of the project and the need for

| that baseload capacity to reach the same users of energy from the current Palisades plant. 

| These impacts are evaluated based on centralized or proximate arrays of windmills or sun

| panels.

|

| Comment: Section 8.2.3, Nuclear Power Generation, page 8-34. The changes in power

| production would provide a difference in potential risk to the public and needs to be specified,

| rather than merely referenced, to provide a clearer understanding of the risk determination in

| this section of the document. (UU-13)

|

| Response: As stated in Section 8.2.3, the impacts shown in Table S-3 (of 10 CFR 51.51) are

| for a 1000-MW(e) reactor and would need to be adjusted to reflect the replacement of

| 786 MW(e) generated by Palisades. For the basis of comparing alternatives, the NRC staff

| assumes that a hypothetical plant would produce the same amount of power currently

| generated by Palisades; the risk associated with this hypothetical plant is not expected to

| exceed that of the current plant at Palisades. Therefore, the comment provides no new and

| significant information and will not be evaluated further.

|

| A.2.13 Comments Concerning Monitoring Issues

|

| Comment: Although radiation monitoring occurs at reactor sites, it only provides information on

| levels of discharges emitted or released. It does not provide specific information about where

| the radioactive materials end up, or if they contribute to radiation levels in plants, fish, and

| wildlife as well as body burdens of local and downwind or downstream residents. The Nuclear

| Regulatory Commission relies upon self-reporting and computer modeling from reactor

| operators to track radioactive releases and their projected dispersion. A significant portion of

| the environmental monitoring data is extrapolated – or virtual, not real. (GG-28)

|

| Comment: NMC/Consumers should be required to provide the communities in the vicinity of

| the Palisades plant, with a monitoring program to supply independent information regarding

| radioactive discharges and releases. These communities are currently dependent upon the

| operators of Palisades to provide notification of radiological releases. Establishment of an

| independent program would give evidence of NMC/Consumers’ interest in and commitment to

| ensuring the health of its surrounding communities. (GG-30)

|

| Response: The NRC requires licensees to report plant discharges and results of

| environmental monitoring around their plants to ensure that potential impacts are detected and
Appendix A

October 2006 A-105 NUREG-1437, Supplement 27

reviewed. Licensees must also participate in an interlaboratory comparison program that |

provides an independent check of the accuracy and precision of environmental measurements. |

In annual reports, licensees identify the amount of liquid and airborne radioactive effluents |

discharged from plants and the associated doses. Licensees also must report environmental |

radioactivity levels around their plants annually. These reports, available to the public, provide |

the results of the sampling of ingestion sources such as milk, fish, invertebrates, and broad leaf |

vegetation. Radiological environmental monitoring program reports have not shown any |

significant elevation in radiological contamination of foodstuffs from surrounding farms. The |

applicant’s effluent and environmental radiological monitoring programs are regularly inspected |

by health physics experts from the NRC’s Region III office. In additional, the Michigan |

Department of Environmental Quality conducts an environmental radiological monitoring |

program in the areas around Palisades. The comments provide no new information and will not |

be evaluated further. |

|

Comment: Section 2.2.7, Radiological Impacts, pages 2-49, 2-50. The references to the |

environmental standards need to be more complete citations, including title of the rule or |

regulation along with the basic standard for comparison provided consistently. All of the |

environmental standards that could be used for comparison should be used, including 40 CFR |

61 Radionuclide National Emission Standards for Hazardous Air Pollutants values. This will |

reduce the time needed to look up these citations and verify values that are cited in the text. |

(UU-2) |

|

Response: As stated in Section 2.2.7, “the limits for all radiological releases are specified in |

the Offsite Dose Calculation Model (ODCM) (NMC 2004a), and these limits are designed to |

meet Federal standards and requirements. The primary radiological standards applicable to |

Palisades are contained in 10 CFR Part 20, 40 CFR Part 190, and 10 CFR Part 50, Appendix I.” |

Additional text has been added to reference Section 3.8.1.1 “Regulatory Requirements” of the |

GEIS, which provides a summary and specific numerical dose limits associated with these |

standards and requirements. Complete citations for these standards are provided in the |

reference section of Chapter 2. |

|

Regarding the comment to include 40 CFR Part 61, the EPA rescinded Subpart I as it applies to |

power reactors on September 5, 1995 (60 FR 46206), based on the reasoning that “the |

regulatory program established by the NRC pursuant to the Atomic Energy Act provides an |

ample margin of safety to protect the public health.” No change was made to the SEIS as a |

result of this comment. |

|

Comment: Section 2.2.7, Radiological Impacts, page 2-49. We are concerned about the level |

of information provided in the draft supplemental environmental impact statement (SEIS) on |

direct and cumulative radiological impacts. According to the draft SEIS, Nuclear Management |

Company, LLC (NMC), the applicant for the operating license, has conducted a radiological |
Appendix A

NUREG-1437, Supplement 27 A-106 October 2006

| environmental monitoring program (REMP) around the Palisades site since 1971. Through this

| program, NMC has monitored and documented radiological impacts to workers, the public, and

| the environment. The draft SEIS states: The REMP includes monitoring of the waterborne

| environment (ground water, surface water, and sediments), ingestion pathways (milk, fish and

| vegetation), direct radiation (gamma dose at thermoluminescent dosimeter [TLD] locations), and

| atmospheric environment (airborne radioiodine, particulates, gross beta, and gamma). 

| [Page 2-49]

|

| The draft SEIS cites two annual reports which summarizes information from the REMP, but the

| draft SEIS does not contain this summary information itself. Summarized quantitative

| information about-radiation and exposure pathways in the environment is relevant in

| determining radiological impacts from the continued operation of Palisades. We are unable to

| make such a determination from the draft-SEIS as it is written. In addition, the draft SEIS lacks

| a comprehensive assessment of cumulative radiological impacts, since it does not include

| quantitative information about the D.C. Cook Nuclear Plant, located about 28 -miles south-

| southwest of Palisades on Lake Michigan’s shores. Therefore, we suggest that the final SEIS

| include(1) current annual summary information from the REMP and (2) a quantitative

| cumulative impact assessment of radiological impacts which accounts for impacts from the

| D.C. Cook Nuclear Plant. (UU-3)

|

| Response: Radiological impacts of normal operations were considered and evaluated in the

| GEIS, and the generic conclusion was reached that these impacts were SMALL. Therefore, this

| is a Category 1 issue. In the supplements to the GEIS, such as this supplement for Palisades,

| the NRC staff determines if any new and significant information is available that would change

| that generic conclusion. No such new and significant information was identified. The text, as it

| is written in Section 2.2.7 summarizes the results of the radiological environmental monitoring

| program (REMP), as documented in the annual reports. More detailed information about the

| REMP and its findings can be found in the annual Radiological Environmental Operating

| Reports referenced in Section 2.2.7. These reports are available to the public through the NRC

| electronic reading room at http://www.nrc.gov/reading-rm/adams.html. In preparing the SEIS,

| the NRC staff summarizes and incorporates by reference such reports unless a unique call for

| specific data is required.

|

| Section 4.8.3 of the SEIS has been revised to include clarifications about how the cumulative

| impacts analyses do consider the impacts from the D.C. Cook Nuclear Power Plant. The doses

| due to releases from D.C. Cook on receptors near the Palisades have not been quantified but

| they would be essentially zero considering the distance between the two plants; that is, the MEI

| dose given in Section 2.2.7 would not change. Therefore, the MEI dose given in Section 2.2.7

| would be bounding for any offsite individual in the vicinity of Palisades. As discussed in

| Section 2.2.7, the MEI dose is a small fraction of the applicable regulatory limit of 25 mrem per

| year in 40 CFR Part 190. The comment provides no new and significant information and will not

| be evaluated further.
Appendix A

October 2006 A-107 NUREG-1437, Supplement 27

Comment: Section 2.2.7, Radiological Impacts, pages 2-49, 2-50. Providing the estimated |

total effective dose equivalents (TEDEs) for comparisons helps in providing the public with |

additional assurances that doses are monitored and do meet the As Low As Reasonably |

Achievable (ALARA) principals of the U.S. Nuclear Regulatory Commission (NRC). (UU-4) |

|

Response: The estimated total effective dose equivalents (TEDEs) are provided in |

Section 2.2.7 of the SEIS and are compared to the EPA’s 10 CFR Part 190 dose limit of 25 |

mrem per year as follows: “Over this 5-year period, the maximum annual TEDE for the MEI was |

estimated to be 7.53 × 10-3 mrem with an annual average TEDE of 3.73 × 10-3 mrem. These |

doses represent approximately 0.03 percent and 0.015 percent of the 25-mrem limit, |

respectively.” The explanation of how these doses compare to the 25 mrem limit (0.03 and |

0.015 percent, respectively) helps in providing additional assurance that doses are monitored |

and do meet the ALARA principles, i.e., the relevant data was provided to show an appreciation |

for the magnitude of difference between the TEDEs and corresponding limit. |

|

Comment: Section 4.8.3, Cumulative Radiological Impacts, page 4-38; 4-39. Information or |

procedures used to generate values to support the assertions in this section need to be |

provided in a clearer manner to reduce the possibility of misunderstandings and the reasoning |

on procedures to reach these conclusions. (UU-6) |

|

Response: For aditional clarity, the discussion of Cumulative Radiological Impact in Section |

4.8.3 of the SEIS has been revised in response to this comment. |

|

A.2.14 Comments Concerning Decommissioning Issues |

|

Comment: Section 7.1, Decommissioning, 7-2, under bullet point Radiation Doses. As the |

GEIS is based on a forty-year licensing period, an extension of this period would have an |

impact that needs to be quantified and reported. This information should have been included |

specifically in the draft SEIS as part of the risk that would be associated with the license |

extension. The specific methodology needs to be provided and explained. (UU-10) |

|

Response: Environmental impacts from the activities associated with the decommissioning of |

any reactor before or at the end of an initial or renewed license are evaluated in the GEIS |

(NUREG-1437) and in NUREG-0586, Generic Environmental Impact Statement for |

Decommissioning Nuclear Facilities, Supplement 1, Regarding the Decommissioning of Nuclear |

Power Reactors, published in 2002. The findings from these two documents are used to |

support the findings in the SEIS by the use of tiering. Tiering is a process by which agencies |

eliminate repetitive discussions and focus on actual issues ripe for discussion. The effect of |

license renewal on the impacts of decommissioning are stated in Chapter 7 of this SEIS. The |

radiation doses to the public during the period of extended opeation are expected to be well |

below applicable regulatory limits, and the occupational dose during the time the plant |
Appendix A

NUREG-1437, Supplement 27 A-108 October 2006

| undergoes decommissioning would be expected to increase only slightly. The comment

| provides no new and significant information and will not be evaluated further.

|

| A.2.15 Comments Concerning Global Warming

|

| Comment: A majority of scientists throughout the world now believe that increased emissions

| of carbon dioxide since the Industrial Revolution are enhancing the greenhouse effect of the

| atmosphere that surrounds the earth, and causing a warming that will cause dangerous effects

| to the earth’s climate and inhabitants - global warming. The NRC confirms it as well, in its

| analysis of impacts of alternatives that might be more appropriate options than extending the

| license for Palisades, as it concludes that the impacts of substituting coal plants for Palisades

| would be a “large” impact, due to their contribution to global warming.

|

| A one-degree Celsius warming of the earth’s surface may seem insignificant, but it is not. The

| temperature of the earth’s surface greatly affects our climate in many ways. In particular, a

| warmer planetary climate means more rain, flooding, and snow in various regions, earlier spring

| arrivals, hurricanes, heat waves, drought and fires in some places, frigid cold in others.

|

| The effects are already seen in Michigan, where water in the Great Lakes is warming. 

| According to Dr. Natalia Andronova, research scientist at the Department of Atmospheric,

| Oceanic, and Space Sciences at the University of Michigan in a May 7, 2006 interview with the

| Ann Arbor News, “Measurements of the near-surface temperature over the northern part of

| Lake Michigan and southern part of Lake Huron showed that for both lakes the period from

| 2000 to 2005 was warmer by at least two degrees Celsius than the period from 1981 to 1985.”

| An increase of Lake Michigan water temperatures may eventually affect Palisades’ operation,

| since the condenser within the plant requires cooler water to operate efficiently. During a heat

| wave in the late 1990s, reactors on the U.S. side of Lake Ontario shut down because the water

| temperature was too high to efficiently cool the reactor and generate steam for electricity

| production. During the extreme heat wave in France in recent years, nuclear reactors released

| so much superheated water to rivers that fish kills occurred; operators had to hose down the

| exterior of reactors as an emergency measure to provide additional cooling at the same time.

|

| In the recent interview, Dr. Andronova also noted conditions particular relevant to re-licensing of

| Palisades. She commented that “it is becoming windier over the Great Lakes. The extreme

| winds increased from the one period to the next by more than 3 meters per second.” More

| extreme winds, as well more frequent and intense tornadoes – all of which global warming could

| cause – could make operation of Palisades more and more risky over time. For example,

| documents received by the Nuclear Information and Information Resource from NRC during a

| Freedom of Information Act request regarding the October 2005 “near-drop” of a storage cask

| into the irradiated nuclear fuel pool at Palisades revealed that on extremely windy days,

| Palisades is prohibited from lifting loaded dry casks from the pool, as the high winds make

| crane operations too dangerous.
Appendix A

October 2006 A-109 NUREG-1437, Supplement 27

The potential danger presented by tornadoes to reactors was clearly shown in 1998, when a |

tornado struck the Davis-Besse nuclear plant in Ohio, knocking out the off-site electricity supply; |

the emergency back up diesel generators also malfunctioned. If not for extreme efforts by staff, |

the plant could have lost coolant, leading to a meltdown. An increase in severe weather due to |

global climate destabilization in the region could well increase risks at Palisades. Far from |

being a solution to global warming, nuclear power could become unacceptably dangerous and |

unreliable due to global warming. |

|

The draft EIS prepared by the NRC unaccountably discounts the effects of global warming, |

noting that its effects cannot be predicted. We assert that there is sufficient information |

currently available that should be investigated and considered regarding the impacts of changes |

in weather that may occur in a 20-year extension to Palisades’ license. This must also include |

an analysis of the increased potential for an electrical station loss of power that could lead to |

loss of cooling in the reactor core and waste storage pool, with the potential for core meltdown |

and waste pool fires, with consequent catastrophic large-scale radiation releases to the |

environment. The warming of the cooling water supply from Lake Michigan must also be |

considered in regards to the efficiency and safety of Palisades continued operation till 2031. |

(GG-49) |

|

Comment: NRC must assess and consider as part of the EIS, the information currently |

available regarding the impacts of global warming to the region. This must also include an |

analysis of the increased potential for an electrical station loss of power that could lead to loss |

of cooling in the reactor core and waste storage pool, with the potential for core meltdown and |

waste pool fires, with consequent catastrophic large-scale radiation releases to the |

environment. The warming of the cooling water supply from Lake Michigan must also be |

considered in regards to the efficiency and safety of Palisades continued operation till 2031. |

(GG-64) |

|

Response: While climate change is a legitimate concern, the specific impacts of climate |

change within a particular region are still highly speculative, and are, therefore, beyond the |

scope of a NEPA review for reactor license renewal. The comments do not provide new and |

significant information and will not be evaluated further. |

|

A.2.16 Comments Concerning Editorial Issues |

|

Comment: Page Number 2-4, Line Number 22. Suggest that text specifically state the Covert |

Generating Station is owned and operated independently of Palisades. (OO-1) |

|

Comment: Page Number 2-5, Line Number 1. Replace “40-ac” with “400-ac” (See ER p 2-1). |

(OO-2) |

|
Appendix A

NUREG-1437, Supplement 27 A-110 October 2006

| Comment: Page Number 2-12, Line Number 4-12. The new Radwaste system became

| operational in December 2005. Change “NMC is planning to modify...” to “NMC has modified...” 

| Remove 2 sentences describing old radwaste system. Change “The system NMC plans to

| install relies...” to “The system relies...” (OO-3)

|

| Comment: Page Number 2-12, Line Number 14. Change “The equipment NMC plans to

| install...” to “The equipment NMC has installed...” (OO-4)

|

| Comment: Page Number 2-14, Line Number 39-40. Change to “Sanitary waste is sent to three

| onsite septic systems.” (See DSEIS Figure 2-3). (OO-5)

|

| Comment: Page Number 2-19, Line Number 1-2. Change “plant area” to “protected area.” 

| (OO-6)

|

| Comment: Page Number 2-19, Line Number 18. Change “OLs” to “OL” (OO-7)

|

| Comment: Page Number 2-22, Line Number 25. The NPDES Permit (corrected copy of

| 11/8/04 submitted to NRC in letter dated 12/8/04) requires outfall observations five times per

| week. Suggest changing last word from “day” to “week.” (OO-8)

|

| Comment: Page Number 2-23, Line Number 5. Suggest adding third sentence to the

| paragraph which states, ”Clam-Trol treatments are no longer required to be recorded in

| Palisades’ DMRs, but monitoring during Clam-Trol treatments is performed in accordance with

| the NPDES permit.” (OO-9)

|

| Comment: Page Number 2-23, Line Number 8-9. Revise sentence to state, “Temperature

| data collection at monitoring point 001A is conducted in accordance with the NPDES permit.” 

| As written, sentence implies, incorrectly, that monitoring was not conducted prior to 2005. 

| (OO-10)

|

| Comment: Page Number 2-24, Line Number 7. Correct name of facility is the “Benton Harbor-

| St. Joseph Wastewater Plant.” (OO-12)

|

| Comment: Page Number 2-25, Line Number 27. Wind class differs from wind class given on

| DSEIS p. 8-45 line 21. (OO-13)

|

| Comment: Page Number 2-26, Line Number 16. Change “2350" to A2500." The rated

| capacity of the diesel generators is 2500kw per FSAR Section 8.4. (OO-14)

|

| Comment: Page Number 2-49, Line Number 35. Change “NMC performed an assessment...”

| to “NMC performs an annual assessment...” (OO-15)

|
Appendix A

October 2006 A-111 NUREG-1437, Supplement 27

Comment: Page Number 2-51, Table 2-3. Suggest adding footnote “Figures may not add due |

to rounding” (OO-16) |

|

Comment: Page Number 2-52, Line Number 34-35. Fire protection services are provided by |

the Covert Township Fire Department and the South Haven Fire Department. (OO-17) |

|

Comment: Page Number 2-54, Line Number 19. Change “Table 2.6" to Table 2-6" (OO-18) |

|

Comment: Page Number 2-55, Line Number 23-25. Stated building heights are not correct. |

Suggest either deleting heights or replacing with the following approximate values: turbine |

building-94 ft; containment building-192 ft; auxiliary building-108 ft; cooling tower pump house- |

35 ft; two cooling towers-65 ft; and feedwater purity building-58 ft. These are approximate |

heights above grade as the buildings would be seen from the west. (OO-19) |

|

Comment: Page Number 2-57, Line Number 23. Value “27,488” appears to be an error. |

“27,488" does not represent 39% of Van Buren County’s 16,977 employed in 2002, as stated. |

(OO-20) |

|

Comment: Page Number 2-57, Line Number 36-38. Appears that “Van Buren County” should |

be one of the two counties referenced (instead of both sets of figures being attributed to Berrien |

County). (OO-21) |

|

Comment: Page Number 2-58, Line Number 25-27. Taxes are also paid to Lake Michigan |

College and the Michigan State Education Tax (See ER, p. 2-40) (OO-22) |

|

Comment: Page Number 2-58, Line Number 34. According to Table 2-9, taxes paid to Covert |

Township averaged 58 percent of tax revenues. The word “spent” should be deleted from this |

sentence. (See DEIS Table 2-9, p. 2-60). (OO-23) |

|

Comment: Page Number 2-58, Line Number 35. According to Table 2-9, taxes paid to Covert |

School District averaged 32 percent of total property taxes. (See DEIS Table 2-9, p. 2-60). |

(OO-24) |

|

Comment: Page Number 2-63, Line Number 10. Approximately 80 acres of the site are |

developed or maintained (See DEIS p. 2-4 line 29). (OO-26) |

|

Comment: Page Number 2-63, Line Number 12-13. Replace existing sentence with, “Most of |

these facilities are located along the main and north access roads.” (OO-27) |

|

Comment: Page Number 2-63, Line Number 19. Suggest changing “former” to “pre- |

operational:” (OO-28) |
Appendix A

NUREG-1437, Supplement 27 A-112 October 2006

| Comment: Page Number 2-68, Line Number 13. Change “Straminea” to “Pitcheri” (OO-29).

|

| Comment: Page Number 4-24, Line Number 11. No “Table 2-10" exists; should be changed to

| “Table 2-9.” (See DSEIS p. 2-60) (OO-30)

|

| Comment: Page Number 4-24, Line Number 13. Taxes paid to Covert Township averaged 58

| percent of tax revenues spent in the county (See DSEIS Table 2-9, p. 2-60.) (OO-31)

|

| Comment: Page Number 4-24, Line Number 14. The Covert School District received an

| average of $2.7 million annually from Consumers over the 3-year period (See DSEIS Table 2-9,

| p. 2-60) (OO-32)

|

| Comment: Page Number 4-24, Line Number 21. VBCO & VBCISD received 3-5 percent of

| revenues from Consumers (See DEIS Table 2-9, p. 2-60) (OO-33)

|

| Comment: Page Number 4-26, Line Number 11 &15. Suggest rewording “The applicant has

| stated that these procedures are in place...” and replacing with “These procedures are in

| place...” (OO-34)

|

| Comment: Page Number 4-27, Line Number 8. Change to “(1) no major...” (OO-35)

|

| Comment: Page Number 4-37, Line Number 23. Line should read, ”...Palisades’ NPDES

| permit...” (OO-36)

|

| Comment: Page Number 4-41, Line Number 1. According to cited study, groundwater flow

| velocity is from the east-southeast to west-northwest at approximately 23ft/yr. This would

| indicate a westward flow. (OO-39)

|

| Comment: Page Number 5-5, Line Number 34. Change “its” to “it.” (OO-41)

|

| Comment: Page Number 5-8, Line Number 11. % Contribution column does not add to 100%. 

| Suggest adding footnote, “Figures may not add due to rounding.” (OO-43)

|

| Comment: Page Number 5-6, Line Number 10. “CP 1996” is not in ER reference list-remove

| reference here; “CP 1995” and “CP 1996” are not in DSEIS Chapter 5 reference list. (OO-42)

|

| Comment: Page Number 5-9, Line Number 32. “NRC 2004” is not in the Chapter 5 reference

| list. No reference is cited for NUREG/BR-0058. NMC 2005a is not in Chapter 5 reference list. 

| (OO-44)

| Comment: Page Number 5-9, Line Number 29. Reference should be NRC 1997b, and

| reference should be added to Chapter 5 reference list. (OO-45)

|
Appendix A

October 2006 A-113 NUREG-1437, Supplement 27

Comment: Page Number 5-10, Line Number 1. “NRC 2004” is not in the Chapter 5 reference |

list. No reference is cited for NUREG/BR-0058. (OO-46) |

|

Comment: Page Number 5-10, Line Number 27. NMC 2005a is not in the Chapter 5 reference |

list. (OO-47) |

|

Comment: Page Number 5-10, Line Number 36. NMC 2005b, NMC 2005c are not in the |

Chapter 5 reference list. (OO-48) |

|

Comment: Page Number 8-4, Line Number 6. There are no threatened or endangered aquatic |

species known at Palisades; suggest removing “including threatened and endangered species.” |

(See DSEIS page 2-32) (OO-49) |

|

Comment: Page Number 8-4, Line Number 29. Palisades has three onsite sanitary drain fields |

(see DSEIS Figure 2-3). (OO-50) |

|

Comment: Page Number 8-5, Line Number 28. “Covert County” should be either “Covert |

Township” or “Van Buren County.” (OO-51) |

|

Comment: Page Number 8-7, Line Number 17-31. Annual Energy Outlook 2006 is now |

available. Suggest updating paragraph to reflect latest information from DOE. (OO-52) |

|

Comment: Page Number 8-34, Line Number 4-6. Suggest noting that the AP1000 design is |

now certified also. See NRC website for references. (OO-53) |

|

Comment: Page Number 8-45, Line Number 21. Wind class differs from wind class given on |

DSEIS p. 2-25, line 27. (OO-54) |

|

Comment: Page Number 8-53 & 8-54, Heading. Table numbers should be Table 8-8. |

(OO-55) |

|

Comment: Page Number 9-1, Line number 7. “NMC” should be replaced with “the plant |

owner” (OO-56) |

|

Comment: Page Number E-3, Line Number 8. The South Carolina Radioactive Waste License |

for Delivery was reissued for 2006. Authorization information is as follows: Number 0006-21- |

06; Issue Date: 01/09/2006; Expiration Date: 12/31/2006. (OO-57) |

|

Comment: Page Number E-3, Line Number 10. The Tennessee Radioactive Waste License |

for Delivery was reissued for 2006. Authorization information is as follows: Number T-MI003- |

L06; Issue Date: 01/01/2006; Expiration Date: 12/31/2006. (OO-58) |
Appendix A

NUREG-1437, Supplement 27 A-114 October 2006

Comment: Page Number G-2, Line Number 39. Change “is 1.0 x 10-7” to “is about 1.0 x 10-7 | ”. 

| Also change “NMC 2005a” to “NMC 2005b”. (OO-59)

|

| Comment: Page Number G-4, Line Number 28. Column does not add to 100%. Suggest

| adding footnote, “Figures may not add due to rounding.” (OO-60)

|

| Comment: Section 2.1.4.2, Gaseous Waste Processing Systems and Effluent Controls,

| Page 2-12, second paragraph. Citations of dose values should include the dose value, in

| addition to the citation, to make the values clearer. (UU-1)

|

| Response: The comments are noted, and wording in the identified sections of the SEIS have

| been changed to reflect this information, where appropriate.

|

| Comment: Section 8.2.3.1, Closed-Cycle Cooling System, page 8-39, under bullet point

| Waste. Waste impacts need to be specified, rather than merely referenced, to provide a clearer

| understanding of the risk determination made in this section of the document. (UU-14)

|

| Comment: Section 8.2.3.1, Closed-Cycle Cooling System, page 8-40, under bullet point

| Human Health. Human-health impacts need to be specified, rather than merely referenced, to

| provide a clearer understanding of the risk determination in this section of the document. 

| (UU-15)

|

| Response: As a supplement, this SEIS relies on tiering from the GEIS (NUREG-1437) and

| does not need to repeat all analysis and conclusions presented in the GEIS. The SEIS relies to

| a great degree on impact analyses presented in the GEIS by the use of a process called tiering. 

| Tiering was promulgated by the Council on Environmental Quality in 1978 in 40 CFR Part

| 1502.20. Appropriate sections of the GEIS are referenced, when necessary. Human health

| impacts are presented in 10 CFR Part 51, Appendix B, Table B-1. For ease of review, this table

| can be found at http://www.nrc.gov/reading-rm/doc-collections/cfr/part051/part051-appb.html. 

| More detailed information on this topic can be found in Volumes 1 and 2 of the GEIS, which are

| available at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/ sr1437/v1 and

| http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/v2, respectively. The

| comments do not provide any new and significant information; therefore, no changes were

| made to the SEIS text.

|

| Comment: Page Number 2-23, Line Number 13. Suggest defining “several” by stating the

| number of spills cited within the last five years. (OO-11)

|

|
Appendix A

October 2006 A-115 NUREG-1437, Supplement 27

Comment: Section 4.2.2, Electromagnetic Fields-Chronic Effects, page 4-17. We commend |

NRC for providing the reference to the National Institute of Environmental Health Sciences |

results and recommendations on chronic exposures to electromagnetic fields. This will provide |

the public with valuable information on these types of exposures (UU-5) |

|

Response: The comments are editorial in nature, and no changes were made to the SEIS as a |

result of these comments. |

|

Comment: Section 8.1, No Action Alternative, page 8-5, under the bullet point Human Health. |

The value representing the cited percent value should be specifically provided in addition to the |

citation. This will reduce unnecessary additional research by readers, except for value |

verifications, and potential misunderstandings or confusion as to the actual value(s) being |

specified. (UU-11) |

|

Response: The assessment of Human Health impacts in Section 8.1 was qualitative and |

incorporated summaries of conclusions reached in Chapter 4. Therefore, no specific values |

were cited. The comment will not result in modification of the SEIS text. |

|

A.2.17 Issues Outside the Scope of the Environmental Review for License Renewal: |

Safeguards and Security; Cask Incident; Dry Cask Storage, Waste Confidence |

Rule, Spent Fuel; Aging Management; Allegations Process; Cost-Benefit |

Analysis; Energy Policy; and Emergency Preparedness and Response |

|

Safeguards and Security |

|

Comment: What I wondered is, the basis like sabotaging where taking account can be – in this |

way too. And if you have done that, because this, my contention is [it] is a new issue. They’re |

not the same like previous plan. (D-2) |

|

Comment: I’m curious as to where Homeland Security and terrorism falls in this environmental |

impact. (Q-1) |

|

Comment: The SEIS (Supplemental Environmental Impact Statement) report should |

acknowledge that there has been changes in our government strategy since the original |

issuance of Palisades OL, particularly regarding sabotage and/or terrorism. Therefore |

additional analysis are required for OL Renewal. We believe that additional Severe Accident |

Mitigation Alternatives (SAMAs) regarding this issue should be considered for Palisades |

Operation License Renewal. (JJ-2) |

|

Response: Section 5.1.2 discusses the impacts of severe accidents including sabotage. The |

GEIS findings state that compliance with the NRC regulatory requirements under 10 CFR Part |
Appendix A

NUREG-1437, Supplement 27 A-116 October 2006

| 73 provide reasonable assurance that the risk from sabotage is SMALL. Even if such events

| were to occur, the Commission would expect that resultant core damage and radiological

| releases would be no worse than those expected from internally initiated events. Based on the

| above, the commission concludes that the risk from sabotage and beyond design basis

| earthquakes at existing nuclear power plants is small and additionally, that the risks form other

| external events, are adequately addressed by a generic consideration of internally initiated

| severe accidents.

|

| Comment: One time I was sitting on the deck of my cottage, which is right on the shores of

| Lake Michigan, a stone’s throw from the, from the plant and of course, this was after 9/11 and a

| no-fly zone was instituted. And all of a sudden a Japanese zero comes zooming down the lake

| shore there about 50 feet over the water. It of course flew right over the plant on its way up to

| an old plane show someplace up north along Michigan. And I thought to myself well, how easy

| it would be for somebody, a plane to come on, and you know, I was really surprised that the

| accident report didn’t include sabotage and other things along that line. So that’s, that’s kind of

| a problem. I’m a boater, and I boat past the plant many times from South Haven down to

| Palisades Park where the cottage is. And now it’s not a no fly zone, but a no boat zone. The

| parameters of the property are 3/4's of a mile. And I looked at my boat and I said, boy, those

| casks are so easy. They’re right, right over there. So I think that somehow or another we need

| to entrust the issues of, of license renewal for just 20 years because we’re really looking,

| according to what I read, 10,000 years down the pike. (E-1)

|

| Comment: My last thing, in yesterday’s New York Times, I don’t know if you all saw it, but

| maybe some of you from the NRC might get red ears when you read this article, because it is,

| after consulting with the industry, the Nuclear Regulatory Commission weakened security

| regulations it had proposed for reactors, government auditors said in a report to be released

| Tuesday. This is a GAO report. The audits said the process, quote, created the appearance

| that the changes were made based on what the industry considered reasonable and feasible,

| feasible to defend against rather than assessment of the terrorist threat itself. The report, by the

| Government Accounting Office, stopped short of saying that the Commission had made

| changes, quote, based solely on industry views. This cozy relationship between the NRC and

| the industry is what really bothers all of us. (G-4)

|

| Comment: There is strong evidence that suggest security measures at Palisades are not

| adequate. Recent reports, including one in March of 2006 by the Government Accountability

| Office, call into question the ability and motivation of the NRC and nuclear power industry to

| take the necessary steps to ensure that the nation’s nuclear power plants have instituted the

| most stringent security measures to protect against terrorist attacks. (GG-4)

|

| Comment: The NRC has placed this issue outside the scope of the EIS for extending the

| license for Palisades. We strongly disagree and assert that the decision to allow Palisades to
Appendix A

October 2006 A-117 NUREG-1437, Supplement 27

operate an additional 20 years in a much higher risk condition mandates extensive involvement |

by the public. |

|

Maintaining the security of the Palisades plant is a high priority concern since the events of |

September 11, 2001. That threat is real and imminent, as nuclear power plants were |

considered to be potential targets by the terrorists who carried out 9/11, according to the report |

of the 9/11 June 30, 2006 Commission. The Commission report notes that several of the |

terrorists had given indications that a nuclear power plant near New York City was a considered |

target for an airplane attack, due to the large population that would be affected by a release of |

radioactivity. That did not happen, reportedly, because the terrorists appeared to have |

concluded that it would have been difficult to control the effects of a release of radioactivity. |

But, the fact that it was considered means that each and every nuclear power plant in the U.S., |

including Palisades, should be regarded as a potential target for terrorism and security |

measures must be the most stringent available to address this threat. In fact, reactors such as |

Palisades are likely more at risk of terrorist attack than certain other reactors, as it is situated on |

the shoreline of Lake Michigan, the source of drinking water for the region. |

|

Both the NRC and nuclear power companies assert that the events of 9/11 stimulated additional |

security at plants. However, numerous reports following 9/11 suggest otherwise, including a |

2002 report by the Project on Government Oversight (POGO) referencing the plight of |

overworked and fatigued security guards at the plants during the year following 9/11, and |

numerous high-profile media accounts of risky gaps in security. |

|

An October 3, 2002 Kalamazoo Gazette article, “Palisades incident leads to reassessment,” |

describes a security response lapse due to Palisades’ failure to follow proper procedures, |

leading to a communications breakdown. When three cars approached Palisades on the eve of |

the first anniversary of the 9/11/01 attacks, Palisades mistakenly phoned the local police rather |

than the county 911 system, leading to a 45 minute delay before State police arrived on the |

scene. By that time, the suspicious cars were long gone. |

|

An October 20, 2002 New York Times article, “Guards at Nuclear Plants Say They Feel |

Swamped by a Deluge of Overtime,” described an emotional breakdown by an armed security |

guard at Palisades with “unescorted access” to vital areas of the plant after she had been |

forced to work 72 hour work weeks for months on end. If guards complained about their fatigue, |

they faced the loss of their job, or forced psychiatric evaluations. Apparently, as reported by |

POGO, some nuclear utilities chose to nearly double current guards’ duty time in order to avoid |

the added costs of training and providing benefits for newly hired guards. |

|

In March of 2006, an independent nonpartisan investigatory Federal agency, the Government |

Accountability Office (GAO), issued a report that demonstrates that there is much yet to be done |

to protect the nation from terrorist threats to nuclear power plants. The report, Efforts Made to |
Appendix A

NUREG-1437, Supplement 27 A-118 October 2006

| Upgrade Security, but the Nuclear Regulatory Commission’s Design Basis Threat Process

| Should be Improved (GAOBO6B388), assessed the NRC’s current efforts and found evidence

| that suggested the nuclear industry attempted to avoid strengthening security to avoid costs. It

| also noted slow progress in conducting mock attacks or force-on-force exercises to test safety

| at plants, as well as egregious examples of security lapses in the small number of mock attacks

| that NRC has carried out to date.

|

| NRC’S process for determining risk to nuclear power plants was flawed and undercut by the

| nuclear power industry

|

| The recent GAO report was done to review the process that the NRC used to revise the Design

| Basis Threat (DBT) that was in place for nuclear power plants prior to 9/11. The DBT is a

| description of the threats that might be anticipated from terrorist activities and is used to

| recommend appropriate security efforts at plants. The GAO also looked at what nuclear plants

| were doing to meet the threats, and the results of mock attacks, called “force-on-force”

| inspections, to test security efforts, carried out by NRC staff.

|

| Trained “threat assessment” staff within the NRC used intelligence information that provided

| information on the capabilities of terrorists and recommended that the DBT be changed to

| accommodate a larger suite of threats. After sending out the revised DBT for review by nuclear

| power plant industry officials and groups, however, the NRC changed their recommendations

| for revising the DBT to reflect nuclear industry concerns about what was “reasonable and

| feasible” to defend against.

|

| Judgment calls were made on most likely threats

|

| Much of the threat assessment analysis involved a review of a limited amount of information

| (not much was available specific to nuclear power plants) as well as personal judgment by NRC

| staff to predict what might be used in a terrorist attack against nuclear power plants. For

| example, the staff considered whether to increase the number of potential attackers in the DBT,

| based on knowing the number of attackers in other incidents. Staff did not, however,

| recommend increasing the number of attackers in the DBT because they assumed that a large

| number of attackers would be more likely to be caught before they could carry out an attack – a

| judgment call. NRC staff concluded that an attack similar to 9/11 would not focus on a single

| nuclear power plant and that since an attack from the air was not an option used often by

| terrorists, did not recommend that scenario to be included in the DBT. Staff did assess the

| possibilities of an attack from water, but concluded that a bomb transported by water would

| necessarily be of smaller size, because it would need to be carried on a boat. (This

| assessment would not apply to a facility on Lake Michigan, as boats of quite large size could

| approach Palisades; in addition, it is plausible that speedboats could have the ability to launch

| an attack on Palisades before plant security defenses could react.

|
Appendix A

October 2006 A-119 NUREG-1437, Supplement 27

Undue influence by the nuclear industry changed NRC recommendations. |

|

The GAO report, in its review of the revisions to the DBT, noted that because the nuclear |

industry had the opportunity to review the draft DBT, the changes that were made to the draft |

appeared to reflect concerns by the nuclear industry over the high cost of some increased |

security measures, suggesting undue influence by the industry. For example, industry |

representatives protested the inclusion of certain weapons in the DBT, saying that one would |

render the ballistic shielding of the plants obsolete and that another would be too costly. The |

industry argued as well that protecting against the use of certain weapons by terrorists was the |

responsibility of the U.S. Federal government, namely, the Department of Defense. |

|

The industry also opposed the inclusion of a threat of an attack from inside the plant, from an |

“active violent insider,” saying there were no cost effective ways of avoiding this scenario. NRC |

staff made changes to the draft DBT that appeared to be influenced by the industry comments. |

When the draft DBT was presented to NRC commissioners, even more changes were made |

based on industry objections, for example, allowing plants to use a “human reliability program” |

to reduce the potential for an insider situation. The commissioners also removed some |

weapons from the list recommended by staff that plants would have to defend against that |

would have added to the cost of increasing security, as well as voting to decrease the maximum |

amount of weight of equipment, weapons, and explosives an attacker might carry, downgrading |

the level of security required at plants. The GAO report concluded that some of the changes |

suggested by commissioners and included as part of the DBT, were made due to judgment, |

rather than specific criteria. |

|

Few mock attacks carried out to date |

|

The GAO report noted that as of November 2005, the NRC had only conducted mock attacks, |

or force-on-force demonstrations at 20 of the 65 nuclear plant locations (with 103 reactors) in |

the U.S. The GAO reviewed documents from inspections and force-on-force demonstrations as |

well as observing a number of force-on-force demonstrations. Its review of 18 baseline |

inspection reports and demonstrations noted problems, including an intrusion detection failure |

at one site: |

|

! Notice of demonstration dates were given 8 to 12 weeks in advance, and daytime and |

nighttime exercises were generally convened at the same times at each event, leading |

to a lack of unpredictability in the exercises. |

! There were instances where advance information about attack scenarios had |

inadvertently been provided to plant personnel. |

! The quality of feedback from NRC personnel to plants after an inspection varied. For |

example, not all potential problems were discussed by NRC with plant officials after each |

demonstration. |
Appendix A

NUREG-1437, Supplement 27 A-120 October 2006

| ! Alarms failed to activate; some did not function properly.

| ! Gaps in patrols were observed.

| ! Not all personnel entering protected areas within the plant were searched (for example,

| a security officer did not examine objects that set off the metal detector).

| ! Some security officers were inadequately trained for a terrorist attack (lack of physical

| stress preparedness, training inappropriate to threat).

| ! Security officers in one location were noted as inattentive at their posts.

| ! A vehicle barrier system was improperly and ineffectively placed at one plant location.

|

| Accountability to the public on security is non-existent

|

| The need to keep classified certain sensitive information about measures taken at potential

| targets of terrorism is understandable, but those who live in the vicinity of Palisades, as well as

| those throughout the region who might be affected by a terrorist attack directed at Palisades,

| must be assured in no uncertain terms by the NRC, Palisades, and elected leaders that every

| measure has been instituted that will provide safety and peace of mind to the public. It is

| disturbing to note that keeping back information on the plants has even broader implications. In

| March 2004, for example, the NRC decided not to publicize results of problems related to

| security at plants, as well as enforcement information relating to actions taken by the NRC

| against the reactor licensees for violations of safety regulations. This appears to be taking

| advantage of the heightened attention and concern for security at nuclear power plants to limit

| information about unsafe operations that should be readily available to members of the public.

|

| If a force on force demonstration has not been conducted at Palisades, it should be conducted

| as soon as possible. Classified results of the demonstration should then be directly

| communicated to the region’s U.S. Congressional representatives and senators, as well as the

| Governor and Attorney General of the State of Michigan, for their thorough review and approval

| and reporting back to the public. To truly secure the Palisades nuclear power plant and dry

| cask storage, the following security safeguards, if not instituted already, would need to be in

| place.

|

| ! Sufficient cameras and patrols;

| ! Delay measures, such as fences outside buildings and entrances that would delay

| potential attackers;

| ! Bullet resistant structures in the protected areas of the plant site;

| ! Adequate and specific training for security officers;

| ! Several levels of intrusion detection systems (Needed especially by Palisades to protect

| against intrusion from potential attackers that may enter from Van Buren State Park,

| adjacent to the plant site);

| ! Vehicle barrier systems to prevent vehicles with bombs from entering the site;

| ! Anti-aircraft capability, and;
Appendix A

October 2006 A-121 NUREG-1437, Supplement 27

! Shore patrol equipped with stationary weaponry capable of preventing an offshore |

assault. |

|

While some of these safeguards may appear excessive, they are necessary to secure the |

facility. Unfortunately, some of these measures have significant civil liberties ramifications for |

the communities surround Palisades, therefore we request that the NRC address how this will |

be handled in a 20-year license extension in the draft EIS. |

|

Palisades must also ensure that its irradiated nuclear fuel storage pools are safeguarded from |

terrorist activities. A study released in April 2005 by the National Academy of Sciences shows |

that the cooling pools at nuclear reactors, which store 10 to 30 times more radioactive material |

than that contained in the reactor core, are at risk from attacks by terrorists. According to the |

study, the cooling ponds could be severely damaged by crashing aircraft, high-powered |

weapons or explosives, releasing large quantities of radioactive material into the environment. |

(GG-19) |

|

Comment: Security issues at Palisades must be addressed immediately. If a mock attack or |

force on force demonstration has not been conducted at Palisades, it should be conducted as |

soon as possible. Classified results of the demonstration should then be directly communicated |

to the region’s U.S. Congressional representatives and senators, as well as the Governor and |

Attorney General of the State of Michigan, for their thorough review and approval and reporting |

back to the public. The following security safeguards, if not instituted already, must be put in |

place immediately: |

|

! Sufficient cameras and patrols; |

! Delay measures, such as fences outside buildings and entrances that would delay |

potential attackers; |

! Bullet resistant structures in the protected areas of the plant site; |

! Adequate and specific training for security officers; |

! Several levels of intrusion detection systems (Needed especially by Palisades to protect |

against intrusion from potential attackers that may enter from Van Buren State Park, |

adjacent to the plant site.); |

! Vehicle barrier systems to prevent vehicles with bombs from entering the site; |

! Anti-aircraft capability, and; |

! Shore patrol equipped with stationary weaponry capable of preventing an offshore |

assault. |

|

NRC and Palisades must also ensure that the plants irradiated nuclear fuel storage pools are |

safeguarded from terrorist activities as well as address civil liberties ramifications of increased |

security to the host and surrounding communities of Palisades. (GG-52) |

|
Appendix A

NUREG-1437, Supplement 27 A-122 October 2006

| Comment: Security measures and supervision requirements for the on-site storage of the

| spent fuel. It is clear that the amount of on-site storage, dry stored, spent fuel will increase

| during the renewal term as long as there is no final off-site storage facility provided by the

| Federal Government. Therefore there would be additional security measures and supervision

| requirements to take care of the status of the on-site dry storage of spent fuel for an

| indeterminate period of time. Security measures would be: locate the dry storage facility at a

| place, guarded, hidden and less vulnerable to terrorist activity. I.e. The fact that the South

| Haven Municipal Airport is within 6 mile distance from Palisades, could imply the need to move

| the location of that Airport. Supervision requirements are related to continuous monitoring and

| accounting of the spent fuel during offsite storage. This activity could be an important part of

| the Palisades renewal term. All these impacts should be considered for OL extension

| alternative. (JJ-1)

|

| Response: Security issues such as safeguards planning are not tied to a license renewal

| action but are considered to be issues that need to be dealt with constantly as a part of the

| current (and renewed) operating license. Security issues are periodically reviewed and updated

| at every operating plant. These reviews continue throughout the period of an operating license,

| whether original or renewed. If issues related to security are discovered at a nuclear plant, they

| are addressed immediately, and any necessary changes reviewed and incorporated under the

| operating license.

|

| Since 9/11, the NRC and other Federal agencies have heightened vigilance and implemented

| initiatives to evaluate and respond to possible threats posed by terrorists, including the use of

| aircraft against commercial nuclear power facilities and independent spent fuel storage

| installations. The NRC routinely assesses threats and other information provided by other

| Federal agencies and sources. The NRC also ensures that licensees meet appropriate

| security-level requirements. While security issues are legitimate matters of concern, they will

| continue to be addressed through the ongoing regulatory process as a current and generic

| regulatory issue that affects all nuclear facilities and many of the activities conducted at nuclear

| facilities. The issue of security and risk from malevolent acts at nuclear power facilities is not

| unique to facilities that have requested a renewal to their licenses. The comments are outside

| the scope of the license renewal review as set forth in 10 CFR Part 51 and Part 54; therefore,

| they will not be evaluated further.

|

| Cask Incident

|

| Comment: How many of you here heard about the near drop of the fully loaded dry cask at

| Palisades last October? I have a question for folks at NRC. When we were having the hearing

| in early November in this, down the block here, how come that wasn’t brought to our attention? 

| I mean, our, if we have any credibility left in the NRC and in the company, if we had any trust

| left in the company and in this government agency that’s supposed to protect our health and
Appendix A

October 2006 A-123 NUREG-1437, Supplement 27

well being and our environment and our safety, it’s gone. It’s absolutely gone. And NRC’s |

response in the press is, it was not a reportable incident. (A-3) |

|

Comment: The potential consequences, according to NRC’s own documents of that incident, if |

the cask had dropped into the pool and damaged the pool and drained away the water, there |

could have been a radioactive inferno in the waste. And thousands to tens of thousands of |

people could have died downwind. Those are NRC’s own numbers. I’m not making this stuff |

up. So it just is a real betrayal of the public to have on our part, to have taken part in good faith |

and at that very moment be kept in the dark about something as significant as that. So the |

outrage we’ll try to control to an extent, but it’s, it’s deep burning at this point in the local |

community. (A-4) |

|

Comment: This is the NRC inspectors writing. Therefore, the on scene inspectors concluded |

that working outside the bounds of the approved work package and manipulating the brake |

release on the crane represented an increase in the risk of a load drop, the load being the fully |

loaded cask on the crane. This increase in risk is directly associated with the reactor safety |

cornerstone objective of the spent fuel cooling system as a radiological barrier. What does that |

mean? The pool water could have drained away. What happens then? The waste catches on |

fire. What happens then? (A-14) |

|

Comment: Talk about this crane hanging up. I’ve been around machinery enough to know that |

there’s things like that do happen, and that things can be secured and there’s no danger from |

them. (K-3) |

|

Comment: And what I thought I would really focus on because it really caused quite a stir |

earlier today and I think it deserves as much attention from the public as it can get because the |

public deserves to know about it was the incident last October involving the cask that was stuck |

on a crane above the pool at Palisades. And I just wanted to read some passages from NRC |

documents from Palisades documents that reveal the serious nature of that incident. So I’ll start |

with something I read earlier. The NRC inspectors concluded that working outside the bounds |

of a work package on a crane with a suspended load that if dropped would damage the spent |

fuel pool warranted a safety significance determination. Had the load dropped the spent fuel |

pool could have sustained severe damage. The inspectors concluded working outside the |

bounds of the approved work package and manipulating the break release represented an |

increase in the risk of a load drop. This increase in risk is directly associated with the reactor |

safety cornerstone objective of the spent fuel, spent fuel cooling system as a radiological |

barrier. And what that last sentence means is if the cask which weighed 107 tons had fallen |

into the pool it would have cracked the floor of the pool, drained away the water which cools the |

waste in the pool. And in a matter of time, some hours, the waste would catch on fire and it |

would be a large scale radiation release perhaps worse than Chernobyl. So what were the |

potentially catastrophic consequences had the cask dropped. And again this is from an NRC |
Appendix A

NUREG-1437, Supplement 27 A-124 October 2006

| report entitled Technical Study of Spent Fuel Pool Accident Risk published in February of 2001. 

| The analysis exclusively considered drops severe enough to catastrophically damage the spent

| fuel pool so that pool cooling water inventory would be lost rapidly and it would be impossible to

| refill the pool using onsite or offsite resources. There is no possibility of mitigating the damage

| only preventing it in the first place. The staff assumes the catastrophic heavy load drop creating

| a large cooling water leakage path in the pool would lead directly to a zirconium fire. Zirconium

| is the metal cladding around the fuel rods. It’s, it’s a combustible material, highly combustible. 

| The time from a load drop until a fire varies depending on fuel age, burn up and configuration. 

| The dose rates in the pool area before any zirconium fire are tens of thousands of rem per hour

| making any recovery actions very difficult. Tens of thousands of rems per hour would deliver a

| lethal dose of radiation to someone close to that in a matter of minutes. And that’s what

| happened to the firefighters at Chernobyl. They received deadly doses of radiation in a very

| short period of time. They died two weeks later because their red blood cells stopped

| reproducing. I’m reading directly from the NRC again. Based on discussions with NRC staff

| structural engineers it is assumed that only spent fuel casks are heavy enough to

| catastrophically damage the pool if dropped. In fact NRC has reported, “the possibility of a

| zirconium fire leading to a large fission product release cannot be ruled out even many years

| after final shutdown of a reactor.” Palisades is an operating reactor so the waste in the pool is

| thermally hot, it’s radioactively hot. All the more likely to lead to worst case end results. So this

| is a quote from a study done by Robert Alvarez and others in 2003 and it was about pool fires. 

| This is the quote: “Spent fuel recently discharged from a reactor could heat up relatively rapidly

| to temperatures at which the zurcolode fuel cladding could catch fire and the fuel’s volatile

| fission products including 30 year half life, cesium 137 would be released. The fire could well

| spread to older spent fuel. The long term land contamination consequences of such an event

| could be significantly worse than those from Chernobyl.” Another quote from that same report,

| “The damage that can be done by a large release of fission products was demonstrated by the

| April 1996 Chernobyl accident. More than 100,000 residents from 187 settlements were

| permanently evacuated because of contamination by cesium 137. Strict radiation dose control

| measures were imposed. The total area of this radiation control zone is huge equal to half the

| area of the State of New Jersey. During the following decade the population of this area

| declined by almost half because of migration to areas of lower contamination”. From the

| Alvarez study. (CC-1)

|

| Comment: And so we found out about this cask incident by a fluke because a number of us

| attended an unrelated NRC technical meeting where a piece of it was mentioned. But we

| understood what it could mean and so we followed up. And we did a Freedom of Information

| Act request which NRC informed us would take two to four weeks to get back to us. Well, it

| took two months to reach us. And in the meantime we found out all that we could and we found

| the tables in that earlier report I read from about spent fuel waste fires and the casualty figures

| downwind were quite remarkable. The NRC’s own numbers again 20,000 to 44,000 cancer

| deaths over time downwind out to a distance of 500 miles away from a pool fire. That was at

| 2001 NCR study. So we finally got the FOIA, this was after the Detroit Free Press exposed the
Appendix A

October 2006 A-125 NUREG-1437, Supplement 27

incident in that front page article. We only received a partial FOIA response at this point. And |

the, the document that I read from earlier was the quarterly inspection report from the NRC. |

That was the first public document of that incident. But the details that came out in the FOIA |

were quite interesting. The precursors that led to the incident. Here’s, here’s a quote from an |

internal Palisades mia copa done by the inspection crew that inappropriately handled the crane. |

Well, I’d like to encourage everybody to go over to that table in the back corner and get their |

own copy of this thing and read it because it’s worth it. (CC-2) |

|

Comment: So this is, this is the company’s workers who made the mistake that could have |

overridden the emergency brake. That’s the whole point. They shouldn’t have handled the |

crane because they didn’t understand the crane. We failed to consider the severity of the |

consequences if our troubleshooting caused the load to slip or fall into the spent fuel pool. This |

is why we set up an event response organization to, to allow an open forum with full |

consideration of how these activities will affect the plant and the health and safety of the public. |

This is the company saying this. The NRC earlier said that the risk of a load drop was |

increased because of this inappropriate handling. So I’ll just, please do pick up a copy. The |

precursors of the event that led to this thing, the false setting of the emergency brake were due |

to the fact that Palisades lacks knowledge of the crane. They have to bring in the crane |

company to help them operate the crane. The crane company representative who came last |

August to set the emergency brake had to get to vacation. He was in a hurry. So instead of |

setting the emergency brake correctly with three checks on the emergency brake he did one |

check. And he set it wrong that time. He thought he set it at 175 foot pounds. He actually set it |

at 140. So that was one precursor. He had to go home on vacation. And the other one was |

that Palisades doesn’t know how to handle the crane. The people that did know how to handle |

it have left the company. And one of the amazing admissions by the company is that there may |

be other aspects of operations where we also lack full knowledge not just this crane. (CC-3) |

|

Comment: And I think this, this incidents of the crane that was just mentioned that’s another |

incident I believe that was not reported to the NRC. And I believe that Palisades asked for an |

exemption that they don’t want to report things any more. (DD-6) |

|

Comment: the Palisades -- crane break down on October 11th. 55 hour shutdown with a |

110 casks containing spent fuel assemblies partially suspended broke in the air fell partly |

submerged over the fuel pool. The fuel pool went well beyond its original design capacity with |

fuel assemblies going back to the 70s. I gather from the Tribune article all the brakes froze |

because plant personnel did not set the emergency brake properly just before leaving for his |

vacation. How big a rem stream would this situation be giving off. How many rems the article |

certainly didn’t say. Did the whole fuel pool area must have had, must have had to been |

decontaminated. How much did it receive. All that spent fuel at risk should that cask have |

dropped down onto decades where for spent fuel assemblies it would have caused a fire |

making for an accident much worse than Chernobyl. The article also pointed out this incident |
Appendix A

NUREG-1437, Supplement 27 A-126 October 2006

| was considered of low significance by the NRC within its quarterly report. Quite a change from

| the NRC in the early 90s when dry storage cask storage was initiated at Palisades hearing the

| operators 30 violations for everything from cracked pipes to mishandled drop fuel assembly

| rods into its reactor vessel. Did they ever find the two pounds of missing fuel. To Palisades

| Conversation Group this incident further demonstrates the aged long time ineffectiveness of

| both the equipment and the personnel at the Palisades Plant right along with the current NRC

| not handing out violations for such – This must have been some long term radiation being

| released for over two days within the flow through area. Were procedures fumbled, could not

| get their crane to budge for days because one brake froze and all the brakes shut down for

| 55 hours. What were the plant personnel doing scratching their heads. A further explanation of

| partly suspended a 110 pound metal inner cask leaves me with cause for concern as it did

| others, was not made clear in the article. Just insistent that everything was okay. Just what is

| the shielding of a bare metal cask, that neutron thermal shielding that they’re in the cask at the

| time. (O-8) (TT-13) 

|

| Comment: In October 2005, crane handling errors led to a 107 ton NUHOMS transfer cask

| fully loaded with high-level radioactive waste dangling for 55 hours above the storage pool. 

| Reports confirmed that the risk of a heavy load drop had been increased due to improper

| emergency brake manipulation during the incident. NRC reported that, had the load dropped,

| severe damage to the pool could have resulted. A separate NRC report, “Technical Study of

| Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants,” (NUREG-1738,

| Feb. 2001) revealed that a heavy load drop can cause the cooling water to drain away. The

| densely-packed waste in the pool could then overheat, spontaneously combust, and ignite a

| waste fire causing catastrophic radiation release. NRC concluded that up to tens of thousands

| of people could die from cancer over time, downwind of such an accident.. Despite similar

| crane problems years earlier at its Big Rock Point nuclear power plant in northern Michigan,

| failure to communicate “lessons learned” within the nuclear utility contributed to repeating the

| same dangerous errors at Palisades. (GG-35)

|

| Comment: How can NRC approve a license extension for Palisades when Consumers Energy

| and Nuclear Management Company nearly dropped a 107 ton nuclear waste container into the

| storage pool in October 2005? Such a drop could have punched a hole in the pool floor,

| draining away the cooling water, leading to a waste fire and radioactive inferno. Tens of

| thousands of people could have died from radiation-induced cancer downwind. The company

| cannot safely handle its radioactive wastes with its present workforce, a situation that can only

| get worse as experienced personnel leave the plant or are laid off as plant owner Consumers

| Energy tries to sell Palisades, and as plant operator Nuclear Management Company has

| already been told it will not be retained in the future. Instead of protecting the public health and

| safety and environment against such hazards as the near-drop of such a heavy load into the

| vulnerable waste pool, NRC helped the company keep the public in the dark about the incident

| for months! (MM-3) (NN-3)

|
Appendix A

October 2006 A-127 NUREG-1437, Supplement 27

Response: The NRC resident inspectors at Palisades identified a finding of very low safety |

significance and an associated noncited violation when plant personnel performed activities |

outside the scope of the work package used to inspect the spent fuel pool crane on October 11, |

2005. While raising a dry fuel storage (DFS) cask from the spent fuel pool following loading of |

the cask, the emergency brake on the crane engaged. The engaged emergency brake stopped |

movement of the load, resulting in suspension of the load partially out of the pool. During |

troubleshooting activities, the workers exceeded the bounds of the approved work package by |

manipulating the brake release. This finding represented a violation of the license by |

performing work contrary to requirements specified by NUREG-0612. Corrective actions |

include reinforcing site standards for procedural adherence as well as successfully lowering the |

DFS cask. The licensee entered the item in the Corrective Action program. The safety |

significance of the finding was dominated by the extremely low probability of the brakes failing. |

The actions by the worker did not result in any load motion. Both crane brakes remained fully |

set, either of which could have supported the full load of the cask. While such action by the |

licensee represented an increase in the risk of load drop from a human performance |

perspective, the NRC estimates that with both brakes engaged, such action would not have |

significantly increased the likelihood of a load drop because of the reliability and independence |

of the brake mechanisms. Nevertheless, the NRC noted the procedure violation, and remains |

observant of the licensee’s activities in repairing, maintaining, and other general crane |

operations. The licensee complied with requirements for reporting the event to the NRC. The |

NRC documented the event in the next inspection report, which was issued in January 2006. At |

the time of the event, public interest was not anticipated. The event was not discussed at the |

November hearing because it is outside the scope of license renewal. |

|

The comments are outside the scope of the license renewal review as set forth in 10 CFR |

Part 51 and Part 54; therefore, they will not be evaluated further. |

|

Dry Cask Storage, Waste Confidence Rule, Spent Fuel |

|

Comment: What I’d like to address in regards to this proceeding today is radioactive waste, |

speak of the devil, and reactor accidents. The NRC says in its Nuclear Waste Confidence |

decision that a repository for commercial irradiated fuel will open by 2025. And it’s appropriate |

to bring this up because the Bush Administration yesterday introduced a bill to get rid of any |

remaining impediments to opening Yucca Mountain. That means public health protections and |

safety regulations, that kind of thing. Just get rid of those. But the problem is that Yucca’s in |

complete disarray. The last date DOE gave for its opening is 2012. They won’t give dates |

anymore. They won’t give cost estimates any more. It used to be $60 billion, but they won’t |

give that kind of prediction. So the State of Nevada’s challenging this NRC Waste Confidence |

decision in Federal court. So how NRC can dismiss this issue at Palisades is just really beyond |

me, especially given the irony that Palisades license is up in 2011, and that’s the very year that |

Yucca will be full. Will have reached its legal limit long before it opens because there will be |
Appendix A

NUREG-1437, Supplement 27 A-128 October 2006

| that much commercial waste in the country, 63,000 tons of it. Quite a bit of that at Palisades, its

| fair share. (A-5)

|

| Comment: So from 2011 to 2031 all waste made at Palisades would be excess to Yucca’s

| capacity. So it would continue to sit at Palisades with nowhere to go, unless a second

| repository’s opened, this time in the east. So would that be in Michigan or Wisconsin perhaps? 

| (A-6)

|

| Comment: So it needs to be pointed out that Palisades’ current dry cask storage pads are in

| violation of NRC regulations. We raised this during the NRC licensing proceeding on this

| extension and were rejected. But our expert witness on this matter is none other than Dr. Ross

| Landsman from NRC region three, whose job it was to inspect those pads and the casks on

| them. And he warned NRC since 1993 that the cask close to the lake, the pad close to the lake

| is in violation of safety regulations, specifically earthquake regulations. If there’s an earthquake,

| the -- could open up, the lake could pour in, and one of those casks or more than one, could

| end up in the lake under water. And what could that mean? If water infiltrates the cask there’s

| enough fissile material inside to sustain a nuclear chain reaction. So we could have a nuclear

| reaction in Lake Michigan. (A-7)

|

| Comment: In another scenario, the sand could open up in an earthquake and casks could be

| buried under the sand. Overheating could occur. The cask could be damaged. Radioactivity

| could escape. And it would be a matter of time before it hit the lake. NRC now says in another

| Orwellian twist that Dr. Landsman’s allegations against the newer pad built in 2004, also that it

| violates earthquake regulations are under review. Those allegations are under review. They

| have been for years. The incredible thing is that while under review, the storage pad is used for

| storing waste. More and more waste as time goes on. The cask dangle that happened last

| October, was a part of that campaign to move dry casks to that newer pad, seven of them. 

| (A-8)

|

| Comment: So we’ve got two pads at Palisades, both in violation of NRC’s safety regulations,

| and just yesterday we filed an emergency petition to the NRC to enforce its own regulations and

| stop storing waste on those pads. So the question is, where is Palisades going to store 20

| more years worth of waste? (A-9)

|

| Comment: A cut rate move Consumer’s Energy Company took when their fuel pool was filled

| to maximum capacity. Well passed its original design capacity threatening a shut down of the

| plant. Breaking another promise made when the plant was first built, that no highly

| contaminated radioactive materials would be on the plant site outside of its high level

| containment structure. For purposes other than refueling and eventual removal of spent fuel

| assemblies to a national repository. (B-2) (TT-2)

|
Appendix A

October 2006 A-129 NUREG-1437, Supplement 27

Comment: What my real concern here is the fact that the GEIS report does not take into |

consideration of dry cask storage or other highly radioactive contaminated things such as the |

former steam generators on site. Many would argue the Palisades reservation is already a |

defacto high level nuclear waste dump. Which to their, our Palisades Conversion Group and |

my viewing of this issue, a large impact on this fragile lake shore environment. (B-8) (O-3) |

(TT-8) |

|

Comment: And yes, dry cask storage casks piling up on site. I’m sure we’ll all hear about |

Yucca Mountain or the Goshutes, Skull Valley Indian Reservation taking all of this off our hands |

for the umpteenth time in the last 20 years. There are now over 20 to 30 dry casks on site. Will |

anyone here give us an exact number? Or are you going to just dodge the question again, |

insisting it’s a Federal issue, none of this re-licensing businesses concern. This is a local |

community concern for we will have to live with and care take all of this waste for generations to |

come. In ‘93 we were told these experimental cut waste storage casks would be gone in 1998, |

time and time again by Mark Savage the plant’s spokesperson. Now we’re told by the NRC, |

they’re licensed to store – Well you know, you literally could go on for years because this thing |

has and it keeps piling up a good record for anybody that really takes a look at it. (B-11) (O-6) |

(TT-11) |

|

Comment: Mark Savage if he was still here can well attest that I’ve been a gadfly at Palisades |

for 20 years now. And, thank you, I don’t plan to be for another 20. It astounds me that this |

proceeding can go on like a runaway train in light of the fact that the industry has been allowed |

to run for 50 years with no high level waste facility, guaranteed or otherwise. Different things |

about Yucca Mountain are interesting in that they have gone on and approved almost |

everything that the opponents have suggested, seismic, water leaking into the -- underneath it, |

and other things. And then most recently, we hear that the original loading of it, if it were carried |

out would cause overheating and make --, if they were to use it, to have that capacity. And if it |

had opened 10 years ago when it was supposed to, that capacity wouldn’t have taken care of |

what waste we had at that point anyway. So now it’s, maybe a quarter of what we have, if they |

were to use it. And if they don’t use it and the Indian Reservation is brought up as an |

alternative, it’s, it will be interesting to see how the EIS has arranged for that. Maybe there’s an |

-- under it like the Mississippi River for all we know. That sure would be a mess. (L-1) |

|

Comment: On April 4th the Squaw Valley Reservation will be approved for above ground |

storage but with Yucca Mountain’s inability to take this slated cask off the Goshute’s hands, |

there will not be move in either nuclear waste storage site for all the waste piling up at |

Palisades now much less that all the additional waste produced during the 20 year relicensing |

period. All for a little electricity now. Decades perhaps centuries of radioactive waste for the |

local citizenry to look at. (O-7) (TT-12) |

|
Appendix A

NUREG-1437, Supplement 27 A-130 October 2006

| Comment: Have you factored into your considerations the impact of an earthquake. And the

| reason I ask that is that, well, we don’t have earthquakes here really. The largest earthquake in

| the continental United States occurred in the Midwest in the early 19th century. That could

| happen again. Have you taken that into consideration–in your computations. And that’s in

| regards to both the reactor as well as those waste storage containers that are sitting there on

| the shore of Lake Michigan. (S-2)

|

| Comment: I would like a quick question as to what sort of seismic event did you assume in this

| calculation. In other words on a Richter scale. And second why wouldn’t you include the waste

| or the spent rod storage in this calculation because I don’t think we can count on, on Yucca

| Mountain coming online because as I understand it there have been some conflicting

| information that’s been presented on the Yucca Mountain situation and that might not be

| approved for many years. Well, I guess I don’t understand how you can say it’s 15,000 years

| for this part of the Midwest because new information suggests that it’s a rebound of the land –

| (S-3)

|

| Comment: There was a gentleman asked a really profound question why the dry cask things

| weren’t affiliated or weren’t in with the seismic analogy. And to me that seems more important

| than the deteriorating radioactive, see and I don’t even know the terminology, so forgive me.

| (Y-2)

|

| Comment: The waste generated, dry casking it there and not having a home for it worries me. 

| 20 years from now what’s that going to be like or where are we going to be with, how much

| more waste will they produce in those 20 years. And right now from what I’ve read and again

| I’m naive so I’m here to be educated but we don’t have a home or a place to put this waste

| that’s one of the most toxic substances on the plant from what I understand. It’s sitting

| 150 yards from our precious resource the lake. Why that doesn’t trouble more people I don’t

| know. (Y-4)

|

| Comment: I think that Palisades was burgeoning nuclear waste which is a problem, unstable

| geological strata, the singing sands, the shifting sands, freezing and thawing conditions on the

| casks. Cask number four which is surrounded by other casks has bad welds, could crack. 

| (DD-8)

|

| Comment: Palisades’ high-level radioactive waste storage facility is defective and risky,

| situated on the Lake Michigan shoreline. There are numerous incidents dating from the

| installation of the waste storage facility to the present that demonstrate the risks associated with

| the dry cask storage containers, as well as their problematic placement on a high risk erosion

| stretch of the shoreline, on pads not adequately designed to be stable during events such as

| earthquakes. (GG-6)

|

|
Appendix A

October 2006 A-131 NUREG-1437, Supplement 27

Comment: Lake Michigan dunes constitute a series of dynamic environmental settings, from |

bare beach shorelines, to “growing dunes” or lightly vegetated foredunes, fragile interdunal |

wetlands and ponds, and finally to mature, forested “oldest” dune hills. Vegetation -- grasses, |

bushes, and trees -- is an essential key to the stability of the dunes. When dune vegetation is |

disturbed by footpaths or other activities, high winds and storms can widen a small stretch of |

bare sand into an increasingly wide swath or “blowout.” Blowouts, areas of blowing and |

unstable sands, in dunes in the vicinity of Palisades’ dry cask storage system could threaten the |

integrity of the dry cask storage waste system, by clogging vents in the casks, and causing the |

wastes to overheat, which could lead to an explosion. Left unattended, large blowouts in the |

dunes surrounding the casks could possibly decrease the stability of the pads on which the |

casks are situated. This issue must be addressed in the EIS. Palisades must, at minimum, be |

required to monitor the dunes for potential blowouts and ensure that the dunes are consistently |

vegetated and stable. (GG-20) |

|

Comment: Michigan has had a lengthy history of earthquake activity, dating back to the first |

several historically recorded quakes, in 1811 and 1812, originating from the New Madrid fault, |

centered in New Madrid, Missouri. These quakes registered at 8.0 or higher on the Richter |

scale. Additional quakes were felt in a variety of locations throughout Michigan in the later |

1800s. The largest earthquake experienced in Michigan was in 1947. With a magnitude of 4.6, |

it was felt throughout southern Michigan, affecting an area of 50,000 square miles. A quake |

originating in south central Illinois in 1968 extended approximately 580,000 square miles and |

was felt throughout southern Michigan. The last earthquake in Michigan registered 3.5 and was |

centered in Lansing in 1994. |

|

The New Madrid zone has produced the country’s largest earthquake and is considered the |

country’s most seismically active region east of the Rocky Mountains. The United States |

Geological Survey (USGS) has given the New Madrid fault a 25 to 40% probability of having an |

earthquake of 6.0 or greater in the next 50 years (USGS Fact Sheet FS-131-02). Movement |

has already been noted and described in a June 2005 Nature article describing the results of a |

University of Memphis study that detected a half-inch shift in the fault from 2000 to 2005. |

|

The potential for earthquake activity to damage Palisades’ outdoor dry cask storage pads, upon |

which the casks have been placed, warrants rigorous consideration, which unfortunately, is not |

in evidence in the draft EIS. Concerns regarding the impacts of an earthquake that might cause |

disruptive movement to the waste storage facilities at Palisades surfaced as early as 1994, from |

within the NRC. Dr. Ross Landsman, Nuclear Safety Engineer and Palisades Dry Cask Storage |

Inspector, questioned the adequacy of requirements associated with earthquake activity for |

Palisades’ dry cask storage facility in a letter to the chairman of the NRC. In his letter, |

Dr. Landsman voiced his concerns, “Actually, it’s the consequences that might occur from an |

earthquake that I’m concerned about. The casks can either fall into Lake Michigan or be buried |

in the loose sand because of liquefaction [soil taking on liquid characteristics]. This event might |
Appendix A

NUREG-1437, Supplement 27 A-132 October 2006

| be in the public’s mind in view of what just happened in Southern California. It is apparent to

| me that NMSS [NRC’s Office of Nuclear Material Safety and Safeguards] doesn’t realize the

| catastrophic consequences of their continued reliance on their current ideology.”

|

| In a September 15, 2005 affidavit, Dr. Landsman further describes his concerns regarding the

| ability of the storage pads to withstand movement due to earthquakes, asserting that both the

| older pad nearer Lake Michigan and the newer one further inland, are in violation of NRC

| earthquake regulations, 10 CFR ‘ 72.212(b)(2)(i)(B), which require 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. . . .” 

| Dr. Landsman noted that Palisades’ analysts and engineers apparently failed to acknowledge

| the differences in elevation between the plant and pad sites in their design of the storage

| facility. This led to mistakes in the calculations made to determine the potential movement of

| the pads due to an earthquake. Dr. Landsman noted the violation after inspecting the new

| storage pad in 2004 and warned that it was not safe, but his concerns were not addressed and

| casks have nonetheless been allowed by NRC to be placed on the pad right up to the present.

|

| The implications of damage to the casks from an earthquake are significant. Wastes in casks

| covered in or buried by sand, could overheat, causing severe damage to the irradiated nuclear

| fuel assemblies and making future storage, handling, transport, and management more

| dangerous. Overheated radioactive wastes could damage the dry storage casks, leading to

| leakage of radioactivity into the environment. Emergency responders could be at risk from any

| damage to the radiation shielding measures on the casks.

|

| The dangers of nuclear waste cask submersion underwater are two fold. First, radioactivity

| could leak from the cask into the water. Leakage of even a fraction of a cask’s contents into

| Lake Michigan could endanger the source of drinking water for ten million people. Second,

| enough fissile uranium-235 and plutonium is present in the high-level radioactive waste inside

| the casks, that water, with its neutron moderating properties, could actually cause a nuclear

| chain reaction to take place within the cask. This would complicate emergency responses, as

| potentially fatal radiation doses could be emitted from within the cask.

|

| There is undoubtedly an elevated probability of a strong earthquake originating from the New

| Madrid fault in the next 50 years, and the potential for it to extend to southwest Michigan. 

| Because of that, it is imperative that the question of the safety of the concrete pads and the

| 29 storage casks of high-level wastes be resolved to the satisfaction of citizens of the region. 

| (GG-21)

|

| Comment: The NRC also concludes that any impacts from high-level waste and irradiated fuel

| disposal from a license extension (even acknowledging the uncertainties about the proposed

| Yucca Mountain repository) would not be sufficiently large to require the NEPA conclusion, for
Appendix A

October 2006 A-133 NUREG-1437, Supplement 27

any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. |

(GG-26) |

|

Comment: The NRC has placed the issue of waste generation and storage outside the scope |

of the EIS for extending the license for Palisades. We strongly disagree. |

|

The Palisades nuclear power plant has generated, on average, 14.5 tons [U.S. Dept. of |

Energy’s Feb. 2002 Final EIS for Yucca Mountain. Appendix A. Tables A-7 and A-8] per year |

of high-level radioactive waste. The Nuclear Waste Policy Act was amended in 1982 to allow |

the NRC to approve interim storage of high-level radioactive waste in dry cask storage facilities |

in a “generic licensing” without studies specific to each plant site or Environmental Impact |

Statements. In 1993, several tons of wastes that were accumulating in the Palisade plant’s |

overfull irradiated fuel pools were moved into massive concrete and steel storage casks on |

concrete pads on the plant site. (GG-32) |

|

Comment: Inexplicably, the extremely dangerous radioactive wastes from Palisades, that will |

remain dangerous for tens to hundreds of thousands of years, were deliberately placed within a |

high-risk erosion zone, which is highly unstable, dynamic and risky. Currently, around 20 of a |

total of 29 casks, weighing 132 tons each, are situated approximately 150 yards from Lake |

Michigan, sitting atop loose sand dozens of feet thick. Thus, the casks, and the concrete pad |

upon which they sit, are not anchored to bedrock. This stretch of Lake Michigan’s southwest |

shoreline is known to have the ability to recede in an exceptionally short time frame. The high- |

risk erosion zone requires 30-year construction setbacks that range from 55 ft. to 140 ft. and |

60-year setbacks that range from 115 ft. to 260 ft. (GG-33) |

|

Comment: One of the waste storage cask systems at Palisades, the “VSC-24,” (Ventilated |

storage cask containing 24 pressurized water reactor irradiated nuclear fuel assemblies) utilizes |

passive ventilation to keep the waste at the appropriate temperature. The vents on this type of |

cask need regular cleaning so they will not clog from blowing dune sand, debris, or snow. This |

cask is also not considered transportable, like some casks, and as such, wastes contained |

within them will need to be unloaded and transferred into shipping containers, when or if |

transport occurs. But even though Consumers Energy and the NRC testified in Federal court |

that the casks could be safely unloaded, there have been numerous problems. When weld |

defects were detected in the fourth VSC-24 cask to be loaded in 1994, for example, it was found |

that there were critical questions about how to handle the procedure. This defective cask has |

yet to be unloaded, twelve years later. |

|

To further complicate the unloading problems of Palisades’ casks, the configuration of the dry |

casks currently stored on the older pad nearer Lake Michigan is such that those casks furthest |

back cannot be moved or unloaded until all other casks in front of them have been moved out of |
Appendix A

NUREG-1437, Supplement 27 A-134 October 2006

| the way first. Thus, casks that cannot be unloaded on the shore side of the pads will effectively

| halt unloading of the casks behind them.

|

| There have been other accidents and incidents with the VSC-24 system. While a VSC-24 cask

| was being welded shut at the Wisconsin Point Beach nuclear power plant in 1996, a spark from

| the welding caused a hydrogen gas explosion that tilted the lid of the cask (3 tons of metal)

| several inches ajar; this incident occurred on the edge of the waste storage pool, threatening to

| damage the pool and unleash a potentially catastrophic radiological accident. Additional weld

| defects have been detected in other casks at Palisades and at other plant sites.

|

| On February 6, 1997, Mary P. Sinclair Ph.D. co-chair of Don’t Waste Michigan, wrote to

| Dr. Shirley Jackson, Chair U.S. Nuclear Regulatory Commission and reviewed this history in

| great detail with documentation and references for each point made. In her letter to

| Dr. Jackson, Dr. Sinclair wrote the following:

|

| “ . . . Attorney General Frank Kelley petitioned for an injunction in May 1993, against the loading

| of these casks in the Western Michigan Federal Court at Grand Rapids. (Case No. 4:93

| CV 67). Consumers Power Co.’s response to the Court was that the company would unload the

| casks and place the nuclear waste back in the spent fuel pool if the Court should rule against

| them and, therefore, an injunction to prevent loading was unnecessary. A supporting position

| for the utility’s action was filed by Charles Haughney of the NRC, in which he assured Judge

| Robert Holmes Bell that Consumers was able to do this by simply reversing the process of

| loading, if the Court so ordered. This demonstrates that, not only did Consumers Power Co.

| mislead the Judge, perhaps out of ignorance, about Consumers’ ability to unload these casks,

| but more importantly, Charles Haughney of the NRC pledged the Agency’s credibility in support

| of this position. His statement is signed, “Pursuant to 28 U.S.C. sec. 1746, I declare under

| penalty of perjury that the foregoing is true and correct.” (Executed and signed on May 5,

| 1993). Judge Bell, of course, could hardly grant an injunction under those circumstances. This

| is one of many instances in which the judgment of the staff was flagrantly in error, and helped to

| compound the problems that have later developed. [pp. 3-4, Requests that Commission review

| 2.206 petition filed on 950919 & amended on 960930 by Lake Michigan Federation & Don’t

| Waste Michigan, Sinclair MP. Accession Number: 9704090248, Docket Number: 

| 05000255,07200007, Microform Address: 92410:204-92410:211] A hard copy of this letter is

| being provided by Don’t Waste Michigan to be entered in its entirety into the record as part of

| comments being submitted on this draft EIS. There are additional comments in the letter, which

| also pertain to this EIS process.

|

| The Wisconsin explosion led to a three year hiatus in the loading of VSC-24 casks nationwide,

| in order to improve safety procedures. Palisades was the first plant in the country to begin

| loading VSC-24s again, in June, 1999. However, mistakes were made yet again. A welding

| crew accidentally ignited flammable hydrogen gas being vented off a loaded VSC-24. But it

| failed to notify the next welding crew coming on shift to replace them. The new crew also 
Appendix A

October 2006 A-135 NUREG-1437, Supplement 27

ignited the leaking hydrogen gas, representing a breakdown of safety protocols, risking a repeat |

of the Wisconsin explosion. |

|

During the June, 1999 dry cask loading campaign, Palisades also loaded irradiated fuel that had |

not yet thermally cooled and radioactively decayed in the underwater storage pool for the |

required minimum of five years. This represented a violation of the technical specifications for |

the casks, and thus NRC safety regulations. Also in June 1999, a fire at Palisades in an office |

trailer storing paper records on the dry cask storage installation destroyed records on the most |

recent, and earlier, accidents. (GG-34) |

|

Comment: In 1982, with the passage of the Nuclear Waste Policy Act, the U.S. Department of |

Energy (DOE) was given the responsibility for finding a permanent site to build and operate a |

repository for all of the wastes accumulating at the reactors across the country. Original plans |

were for the repository to begin accepting irradiated nuclear fuel in 1998, but it has been pushed |

back until 2020, according to the most-recent predictions made by Energy Secretary Samuel |

Bodman. In 2002, Congress voted to allow DOE to apply for a license from NRC to construct |

and operate a repository at Yucca Mountain in Nevada. The opening of the repository is |

uncertain: the State of Nevada has actively opposed the plan, and raised legitimate questions |

about the suitability of the site; DOE does not have full funding for construction and operations, |

and recently, a Federal appeals court found that the impact of the project must be evaluated for |

longer than the 10,000 years currently considered. Even if the Yucca site were to open in 2020, |

DOE has projected in its 2002 Final EIS for Yucca that it would take 24 to 38 years to transport |

wastes to Yucca from reactors across the U.S., including Palisades. Thus, even if Yucca |

opened in 2020, it would take until 2044 or even until 2058 for the wastes generated before |

2010 at Palisades to be moved to Yucca Mountain, Nevada. Because of this, existing wastes |

from Palisades are likely to remain on the Lake Michigan shoreline indefinitely. (GG-36) |

Comment: Yucca Mountain is limited by law to store 70,000 metric tons of nuclear waste. Only |

90%, or 63,000 metric tons, of that can come from commercial nuclear reactors. 63,000 metric |

tons is approximately the amount of nuclear waste that will be stored on-site at reactors around |

the country by 2010. A 2004 analysis by the Environmental Working Group found that the 26 |

reactors at nuclear power plants re-licensed between 2000 and 2004 will produce an additional |

9,000 metric tons of high-level nuclear waste over the 20-year period of their license extensions. |

Eighteen more reactors at nine power plants with license extensions pending would add another |

6,600 metric tons of waste, for a total of 15,600 additional metric tons. Wastes produced at |

Palisades for 20 additional years-- 290 additional tons of irradiated nuclear fuel --will likely be |

stored indefinitely in the same manner as the other Palisades wastes that have been produced |

to date, resulting in a massive assemblage of concrete and steel silos extending along the high |

risk erosion zone on Lake Michigan, as well as a packed storage pool within the Palisades |

plant. (GG-37) |

|

|
Appendix A

NUREG-1437, Supplement 27 A-136 October 2006

| Comment: The DOE has estimated that transporting the waste from the plants to Yucca

| Mountain would require more than 53,000 truck shipments to Yucca over 24 years or about

| 2,200 per year. If rail is the primary means of transporting the waste, and DOE has stated that it

| prefers rail, the proposed action would require more than 10,700 cross-country shipments over

| 24 years, or about 450 per year (Halstead 2002). Re-licensing to date has added about 5,700

| more truck shipments, or 1,050 rail shipments to that total.

|

| The Department of Energy declared in April 2004 that rail shipment to Nevada is the preferred

| mode of transportation for high-level nuclear waste. Barge shipments are being considered

| under this option because 17 nuclear power plants, including Palisades, have no rail access, yet

| could connect to rail lines via barges.

|

| For Palisades, DOE has proposed barging up to 125 giant rail-sized containers of high-level

| radioactive waste from Palisades to the Port of Muskegon, up the Lake Michigan shoreline. 

| DOE’s estimate of 125 shipments may very well be an underestimate, in that DOE assumed

| Palisades would only get a 10-year license extension, while NRC’s practice to date has been to

| approve every request for a 20-year license extension. Thus, an additional 10 years worth of

| waste generation would mean that many more barge shipments between Palisades and

| Muskegon.

|

| The barging of 125 or more shipments of high-level radioactive waste is very risky. Any

| submersion of the casks in water, could stimulate the fissile uranium-235 and plutonium, both

| present in the high-level waste, to cause a nuclear chain reaction. The slightest leakage of

| even a small amount of this waste could not only threaten Lake Michigan as a source of

| drinking water for ten million people, but also cause a host of other irrevocable impacts on the

| lake’s fish, wildlife, people, and economy. (HH-38)

|

| Comment: Barging of high-level radioactive wastes in Lake Michigan must be removed as a

| transportation option. The barging of 125 or more shipments of high-level radioactive waste on

| Lake Michigan is simply too risky. Any submersion of the casks containing the wastes in water,

| could stimulate the fissile uranium-235 and plutonium, both present in the high-level waste, to

| cause a nuclear chain reaction. The slightest leakage of even a small amount of this waste

| could not only threaten Lake Michigan as a source of drinking water for ten million people, but

| also cause a host of other irrevocable impacts on the lake’s fish, wildlife, people, and economy. 

| (GG-57)

|

| Comment: The safety of the concrete pads and the storage casks of high-level wastes must be

| resolved to the satisfaction of citizens of the region. The potential for earthquake activity to

| damage Palisades’ outdoor dry cask storage pads, upon which the casks have been placed,

| warrants rigorous consideration, which unfortunately, is not in evidence in the EIS. Further,

| blowouts, areas of blowing and unstable sands, in dunes in the vicinity of Palisades’ dry cask

| storage system could threaten the integrity of the dry cask storage waste system, by clogging
Appendix A

October 2006 A-137 NUREG-1437, Supplement 27

vents in the casks, and causing the wastes to overheat, which could lead to an explosion. |

Palisades must be required to monitor the dunes for potential blowouts and ensure that the |

dunes are consistently vegetated and stable. (GG-61) |

|

Comment: The spent fuel during the renewal term, while in on-site storage, would have |

discharges of radioactive elements and neutrons that by collision with the surrounding natural |

molecules could generate additional radioactive elements. These discharges should be added |

to the atmospheric emissions and ground discharges of the Plant to verify overall compliance |

with the EPA and NRC regulations. (JJ-3) |

|

Comment: License renewal should not be granted to the Palisades Nuclear Power Plant, |

because (1) both of the dry cask storage pads at Palisades are in violation of Nuclear |

Regulatory Commission’s earthquake regulations. (KK-2) |

|

Comment: Potential amplification of earthquakes through soil-structure interaction, and soil |

liquefaction potential or other soil instability due to vibratory ground motion are of great concern, |

especially considering the geological nature of sand increasing the likelihood of sand |

avalanches (Landsman 2005). The violation of the Nuclear Regulatory Commission’s own |

standards in storage of radioactive material must be followed. (KK-6) |

|

Comment: The NRC says in its “Nuclear Waste Confidence Decision” that a repository, or |

permanent dump, for commercial irradiated nuclear fuel will open by 2025. But the only site |

under consideration for such a dump - Yucca Mountain, Nevada - is in remarkable disarray. |

Due to the site’s scientifically unsuitable geology, as well as legal, political, and popular |

resistance and skyrocketing costs, the dump’s opening has been delayed from 1998 to 2010, |

then 2012. Now the U.S. Dept. of Energy won’t even hazard a guess as to when the dump will |

open, if ever, and at what cost. In addition, the State of Nevada, adamantly opposed to |

becoming the country’s atomic sacrifice area, has filed Federal lawsuits against the proposal at |

every turn. One of them challenges NRC’s “Waste Confidence Decision” directly. NRC is |

supposed to be the objective judge of whether or not Yucca Mountain should be opened, but if |

NRC sticks to its arbitrary 2025 deadline, its bias in favor of approving the dump at Yucca |

Mountain, despite its defects and dangers, is obvious. Even if Yucca does open someday, it |

could only accommodate commercial wastes generated before 2011, due to its capacity limit |

under the Nuclear Waste Policy Act for only 63,000 tons of commercial irradiated fuel. That |

much will have been generated in the U.S. by the end of 2010. Thus, any waste generated at |

Palisades during its license extension from 2011 to 2031 could not legally go to Yucca |

Mountain, even if the ever-more-doubtful dump opens.How can the NRC approve 20 more |

years of waste generation and storage on the Lake Michigan shoreline when there is nowhere |

for those wastes to go? How can NRC declare such an essential issue to environmental and |

public health and safety to be “out of scope” during this environmental impact proceeding? The |
Appendix A

NUREG-1437, Supplement 27 A-138 October 2006

| ongoing generation of nuclear waste at Palisades must be stopped as soon as possible. 

| (MM-1) (NN-1)

|

| Comment: Palisades’ dry cask storage installations - outdoor “parking lots” for gigantic 150 ton

| concrete and steel silos filled with high-level radioactive waste - are in violation of NRC’s own

| earthquake safety regulations. Dr. Ross Landsman, now retired NRC dry cask storage

| inspector for the Midwest region, has warned for well over a decade that the 13 year old

| concrete cask pad just 150 yards from Lake Michigan could fail during an earthquake, resulting

| in casks being buried under sand or being dumped into Lake Michigan. Burial could result in

| the irradiated fuel overheating, damaging the containers, and releasing radioactivity. 

| Underwater submersion could result in a nuclear chain reaction in the fissile materials still

| present in the waste. Even the two year old pad further inland is in violation of NRC earthquake

| regulations. Despite claiming these alleged violations are “under review,” NRC has allowed

| Palisades to continue loading casks onto these unsafe pads. How can NRC allow Palisades to

| generate 20 more years’ worth of waste, when even its current storage facilities violate NRC

| safety regulations? (see http://www.nirs.org/reactorwatchllicensinglpalisades.htm at Sept. 15,

| 2005 and at Feb. 17, 1994 for more information) (MM-2) (NN-2)

|

| Comment: I am also concerned about the safe disposal of the spent fuel rods. Over the next

| 25 years, more rods will be used and where will they be stored? Is there a safe place to store

| this nuclear waste or will they be stock piled here along our precious resource Lake Michigan? 

| (QQ-3)

|

| Response: Onsite storage of spent nuclear fuel is a Category 1 issue. The safety and

| environmental effects of long-term storage of spent fuel onsite has been evaluated by the NRC,

| and, as set forth in the Waste Confidence Rule, the NRC generically determined that such

| storage can be accomplished without significant environmental impact. In the Waste

| Confidence Rule, the Commission determined that spent fuel can be stored onsite for at least

| 30 years beyond the licensed operating life, which may include the term of a renewed license. 

| The NRC has a certification process for casks, regulated by 10 CFR Part 72. Such wastes are

| under continual licensing control. Siting of a waste repository is a separate regulatory action

| involving DOE. A geologic repository is not expected to be ready before 2010 (GEIS). In the

| interim, onsite spent fuel storage in pools and in dry cask storage facilities continues in

| accordance with NRC regulations. Consequently, the comments do not provide new and

| significant information and will not result in modification of the SEIS text.

|

| Aging Management

|

| Comment: I have seen construction of and then finished [nuclear] plants during tours. The

| plants then new and impressive, then again many years later aging, much obsolete, often highly

| contaminated equipment, malfunctioning devices such as the reactor containment hatch door

| inoperable for some time while I was de-conning when Consumers Energy operated the plant. 
Appendix A

October 2006 A-139 NUREG-1437, Supplement 27

Things get old, dilapidated with time especially when they are neglected. I’m sorry, my glasses, |

I have to back off to read here. Things get old, dilapidated with time, especially when they are |

neglected, worn out, under the influence of radiation, outdated or used up such as the Palisades |

plant’s fuel pool, now double racked. Steam generators replaced highly contaminated previous |

units within their own mortuary on the plant site. Along with approximately 30 V.S.C. 24 and |

34 dry storage casks in use for above ground spent fuel assembly storage, also on site. (B-1) |

(TT-1) |

|

Comment: After 38 years of operation, Palisades Nuclear Power Plant and its reservation is |

showing its age and effects of embrittlement. Its pressure reactor vessel being protected with |

old, many cycled fuel assemblies, a case in point. Years now, no vessel replacement or further |

shielding in sight. Or 2007 says the NRC, 2011 say others. 2014 say Palisades’ lawyers. This |

should have been replaced ten years ago. As P.R. spokesman Mark Savage told the local |

press back in 1993 when the problem surfaced during an interview with the South Haven Daily |

Tribune. Once they finally got to admit, there was a metal condition called embrittlement |

affecting the reactor. (B-3) (TT-3) |

|

Comment: More to the point potential in fact should things not go as designed or planned or |

promised which over the last 38 years time and time again have been broken. With an |

additional 20 years worth of above ground dry storage cask along with other contaminated |

equipment which is sure to be replaced should this plant be pushed so far past its original |

design capacity which it already has by years now. Counter to the GEIS’s insistence that no |

changes to the plant need to take place in the additional 20 years. (B-9) (O-4) (TT-9) |

|

Comment: Isn’t the reactor head soon to be replaced? In July perhaps? The pressure reactor |

vessel long in question operated in such a patchwork method since embrittlement was |

discovered more than ten years ago. How long before it’s replaced? Annealiated as once |

promised in court or a neutron thermal shield installed? Or the reactor replaced? (B-10) (O-5) |

(TT-10) |

|

Comment: And it was only built for a certain amount of time. The engineers that designed that |

place built it, they thought it would last that long, and the licensing is, is beyond that point. I |

believe that so far these band-aids have, people have been very lucky that we haven’t had |

accidents with stuck valves, leaking coolant, all accidents that have happened at Palisades over |

and over again, they’ve always been able to fix it in time. (C-9) |

|

Comment: My second concern is regarding the equipment refurbishing, refurbishing of our |

equipment. I have low opinions. A plant with 40 years is ready for a good refurbishing. You |

can tell that, you have done a wonderful job, but I don’t believe it. And your report, the NRC is |

saying that they considered, I don’t know, I don’t think, this is requested by the licensee, but the |
Appendix A

NUREG-1437, Supplement 27 A-140 October 2006

| NRC I don’t know really, what he’s, he’s going to do, but it doesn’t look like he’s going to

| request. (D-5)

|

Comment: | Now the other thing is the issue of embrittlement, and the question was have you 

| considered an accident based on the fact that Palisades is quite embrittled. When Palisades

| was licensed 40 years ago, the issue of embrittlement I don’t think was considered because you

| didn’t really know that that’s what was happening or would happen. So in my understanding,

| this is, if there is an accident, the result, as a result of embrittlement, it would be a beyond

| design accident, if that’s the correct terminology. So that’s an accident that you’re not

| considering, but that’s new information since this plant was re-licensed 40 years ago. So I think

| you need to look at what would happen if there is an accident as a result of embrittlement, since

| you didn’t know that when you licensed this plant 40 years ago. (G-2)

|

| Comment: It’s my recollection that Big Rock went, went into service about 1959 or 60 about

| 11 years before Palisades. And it’s my recollection that Big Rock has not been running really

| as a power plant for some number of years here now. And it’s got a lot of trouble. So that

| means that if you go ahead and, and renew this you’ll be, this reactor will be far exceeding the

| line time of the Big Rock Plant in terms of production. (R-1)

|

| Comment: The biggest issue I’ve heard about and this is not disputed, this is fact. Is that it is

| embrittled. In a layman’s terms I’ll try to explain to you what embrittlement is. When a nuclear

| reactor has, of the, the design at Palisades is, had so many reactions through the years it gets

| like little finger holes in it, lots of little holes from all this stress and these reactions. Cooling,

| heating, cooling heating and the near misses they’ve had. And after you get this, these holes in

| the, in the design structure it becomes embrittled which means that if there was a stuck value,

| broken coolant pipes, lots of things could happen to cause a meltdown, okay, and then it starts

| heating up. And they cool, they had to cool it real fast. So they flood it with water. If the plant

| is embrittled as Palisades is it’s like taking a really hot glass coffee pot and immersing it in cold

| water. Bang. That’s what accurate embrittlement is and that’s what I’ve hear would, would be

| the most probable thing that would happen to cause a meltdown. (DD-10)

|

| Comment: I feel it is in the best interests of the public for safety issues, to close Palisades

| down and certainly NOT RENEW THE LICENSE with that aging reactor and all the surrounding

| safety issues as a result. (FF-2)

|

| Comment: Aging and extended operation increase the risk of accidents at Palisades. The

| longer Palisades operates, the more embrittled its reactor pressure vessel becomes, increasing

| the risk for Pressurized Thermal Shock, a condition caused by any number of system

| malfunctions which can result in a severe, sudden overcooling of the reactor pressure vessel. 

| This can lead to a loss-of-coolant accident, meltdown, and catastrophic release of radiation to

| the entire Great Lakes basin. (GG-9)

|
Appendix A

October 2006 A-141 NUREG-1437, Supplement 27

Comment: A top concern directly related to the re-licensing of Palisades for 20 additional |

years, is the aging of the plant, in particular embrittlement, or the gradual weakening of the |

reactor pressure vessel (RPV) from decades of bombardment by neutrons emitted by the |

nuclear chain reaction in the core. It is generally acknowledged that the reactor pressure vessel |

at Palisades is one of the most embrittled in the nation. The longer Palisades operates, the |

more embrittled its RPV becomes, increasing the risk for Pressurized Thermal Shock (PTS), a |

condition caused by any number of system malfunctions which can result in a severe, sudden |

overcooling of the reactor pressure vessel. This, combined with the intense pressurization in a |

pressurized water reactor, can stress the RPV such that its walls could crack or rupture, leading |

to a loss-of-coolant accident, meltdown, and catastrophic release of radiation to the entire Great |

Lakes basin. |

|

Age-related failure of Palisades’ systems could initiate the sequence of events that leads to |

PTS. Examples of aging systems at Palisades are evident in this short list of recent incidents: |

|

1. Alert Declared Due to Loss of Shutdown Cooling (Event # 39699 March 25, 2003) |

2. Failure of the Control Rod Drive Mechanism (see PNO-III-04-010 August 11, 2004) |

3. Reactor Manually Tripped Due to Fire in 2B Condensate Pump (Event# 41002 August 31, |

2004) |

4. Relief Requests for Reactor Vessel Head Penetration problems (NMC Request 10/4/04) |

5. Reactor Vessel Head Nozzle Cracking - Through Wall Cracks (Degraded Condition |

10/17/2004) |

6. Manual Reactor Trip/Main Condenser Vacuum (Event # 41319) |

7. Emergency Declared on Primary Coolant System Integrity ( Event # 41681) |

8. Control Rod Stuck in Reactor Core (Event #42569 May 11, 2006) |

|

The embrittlement at Palisades, the unresolved risks of PTS, and the ever-increasing likelihood |

of the failure of the RPV as Palisades ages warrant special environmental considerations. This |

type of accident is considered one that goes beyond the design of the reactor. NRC has not, |

however, included the issue in the EIS nor incorporated it in “Beyond Maximum Credible |

Accident” scenarios for Palisades as a potential accident. Further, NMC in its Environmental |

Report, has declined to undertake major refurbishment for Palisades’ license renewal, despite |

Consumers Energy’s earlier pledge to “anneal” (super-heat) the reactor pressure vessel. This |

super-heating theoretically can bring back ductility or flexibility to the metal, thus reducing |

potential for PTS. Annealing has never been performed in the U.S., however, and thus raises |

concerns itself as an experimental procedure. |

|

Please include for the record the Adobe PDF document entitled “Palisades Nuclear Plant Yearly |

Capacity Factors” & “Palisades Plant - Record of Transients or Operational Cycles” for |

Occurrence #1 dated 1/11/1972 through Occurrence # 126 dated 1/9/2005. This is a record |
Appendix A

NUREG-1437, Supplement 27 A-142 October 2006

| which has major implications for embrittlement and the Reactor Pressure Vessel at Palisades. 

| A hard copy will be sent. Please enter it into the record.

|

| Age-related deterioration also increases the likelihood of unintentional leaks, as plant systems,

| structures and components wear out and fail. Palisades’ age-related degradation means

| increasing amounts of radioactivity will be “routinely” released over time. Plans for addressing

| embrittlement and other aging issues at Palisades are not provided in NMC’s Environmental

| Report or in the EIS. Any discussion of 20 additional years of operation at Palisades

| necessitates a specific plan for addressing embrittlement and aging issues.

|

| The most recent NRC report on a potential accident at Palisades, done in 1982, (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; adjusting for inflation, property damage could

| exceed $100 billion expressed in year 2005 dollars). The above CRAC - 2 report did not take

| into account a “Beyond Maximum Credible Accident” scenario. We request the EIS provide

| assessment of the consequences of a “Beyond Maximum Credible Accident” as Palisades’

| embrittlement status increases the likelihood of such an accident. (GG-40)

|

| Comment: NRC must require Palisades to develop and implement a specific plan for

| addressing embrittlement and aging issues. Plans for addressing embrittlement at Palisades

| are not provided in by NMC or in the EIS. Any discussion of 20 additional years of operation at

| Palisades necessitates such a plan to address the aging of plant structures and components. 

| We request the EIS provide assessment of the consequences of a “Beyond Maximum Credible

| Accident” as Palisades’ embrittlement status increases the likelihood of such an accident. 

| (GG-58)

|

| Comment: The fact that in the Application for renewal the Licensee states that no refurbishing

| will be performed prior to extended term operation is of our outmost concern. We believe that

| after 40 years of operations, a thorough refurbishing should be mandatory to insure a safe Plant

| operation during the extended term. (JJ-6)

|

| Comment: Due to deterioration and degradation, old reactors are more likely to experience

| accidents than younger reactors. At 39 years, Palisades is one of the oldest operating reactors

| in the U.S., and has been considered a “nuclear lemon” since it began operations in the first

| place. The risk of a severe accident at this “geriatric” reactor is reason enough to close it down

| in 2011 at the end of its current license. (MM-4) (NN-4)

|

| Comment: By NRC’s own reckoning, Palisades has one of the most embrittled reactor

| pressure vessels in the U.S. Consumers Energy and Nuclear Management Company admitted
Appendix A

October 2006 A-143 NUREG-1437, Supplement 27

in November, 2005 that in 2014, Palisades will surpass NRC embrittlement criteria. In fact, |

Palisades has surpassed NRC’s limits on embrittlement a number of times - the earliest in 1981, |

just ten years into operations - only to see NRC weaken its standards, allowing Palisades to |

continue operating. Embrittlement makes the risks of “pressurized thermal shock” (PTS) too |

great to keep operating this reactor. During an emergency, PTS could fracture Palisades’ |

reactor pressure vessel like a hot glass under cold water. Since such a fracture is a ‘beyond |

design basis” accident, there is no countermeasure to prevent a melt down. Operating |

Palisades till 2031 risks a Chernobyl on the Lake Michigan shoreline, a risk that only grows |

worse with time. (see environmental interveners’ contentions and supporting documents at |

http:/Avww.nirs.org/reactorwatch/icensinglpalisades.htm at 1993, 2004, Aug. 8 and Sept. 16, |

2005.) (MM-6) (NN-6) |

|

Comment: The NRC officials avoided detailed answers to questions regarding the safety of the |

aging reactor. When questioned about renewing the license for an additional 20 years beyond |

2011, (exceeding the original lifespan of Palisades of 40 years), the NRC officials once again |

avoided the issue of safety. |

|

Given the poor track record of safety at Palisades along with present conditions of the |

reactor—how can we expect Palisades to be a source of safe and efficient power for the next |

25 years? (QQ-2) |

|

Response: The principal safety concerns associated with license renewal are related to the |

aging of structures, systems, and components important to the continued safe operation of the |

facility. When the plants were designed, certain assumptions were made about the length of |

time each plant would be operated. During the safety review for license renewal, the NRC must |

determine whether aging effects will be adequately managed so the original design |

assumptions will continue to be valid throughout the period of extended operation, or verify that |

any aging effects will be adequately managed. For all aspects of operation, there are existing |

regulatory requirements governing a plant that offer reasonable assurance of adequate |

protection if its license were renewed. The comments are noted. The NRC’s environmental |

review is confined to environmental matters relevant to the extended period of operation |

requested by the applicant. Safety matters related to aging are outside the scope of this review. |

An NRC safety review for the license renewal period is conducted separately. The comments |

provide no new and significant information and will not be evaluated further. |

|

Allegations Process |

|

Comment: One of the biggest complaints from plant critics is the operators have been less |

than forthcoming when problems surface. Make excuses, rosy predictions they know will never |

come to pass. Or lie to anyone listening when the information might or will be perceived as |

contentious, placing public trust in jeopardy. (B-4) (TT-4) |
Appendix A

NUREG-1437, Supplement 27 A-144 October 2006

| Comment: Finally, I am in agreement with the Kalamazoo Gazette article, April 2, that “it would

| be smart of the NRC to provide prompt reporting of even allegedly minor incidents.” (HH-2)

|

| Comment: I know someone that worked inside of Palisades. He said he wouldn’t work in the

| Michigan anymore. He works in another State. I won’t mention his name. I won’t mention what

| State he works at, although the NRC and other people have tried to find out. He told me that

| Palisades is the most likely to blow of all the nuclear reactors in the United States. He said it’s a

| well known fact in the nuclear industry. And I said well why, you know, like at DC Cook I know

| that for ten years they operated with a cooling system that wouldn’t function in the case of a

| melt down. I said are they trying to cover something up at Palisades? He says no, it’s just the

| way they run things. He says they don’t report things. He says there’s so much that goes on

| that people don’t know about. He says the NRC doesn’t know about it, and I don’t know what

| he was talking about. I tried to get more information out of him. He wouldn’t talk, but that

| bothers me. And I think that a lot people are in the dark and I’m one of them. And I come here. 

| I take time out of my life, and like Kevin and other people, we’re doing this without any monetary

| reward. We’re using our own gas money which is expensive and everything else, and I hope

| somehow that something I’m saying makes a difference, you know. That something is going,

| that somehow that something I say or write or do is going to forestall a big disaster. And I don’t

| know if it, if it means anything at all. I don’t know if everything I say is futile, if anybody’s

| listening, if anybody cares. But I know that if it blew, then your little plant that’s full of holes, if it

| blew, that people would understand what I’m talking about because you can’t get it back. An

| acceptable risk, as far as you’re dealing with something this big, if you can shut it down, go to

| natural gas, Consumers Energy is already --, then do it. Why not. (C-10)

|

| Comment: I know a man who worked at Palisades and he’s still in the nuclear industry he’s got

| a real high job in the nuclear industry. And he told me that it’s well known quote un quote, is

| what he said it’s well know within the nuclear industry that Palisades is the most likely to blow of

| all the nuclear power plants in the United States at this time. And I asked him well why is that. I

| said is it, are they covering something up like they did at DC Cook which for ten years they

| covered up the fact that they had a non functioning coolant system. Or if they had a meltdown

| they could not have, they could not have stopped the meltdown. And only by the grace of God

| we have not had a meltdown yet. Well, they covered that up and as people have mentioned the

| whistle blower got in trouble for that. And now he said no he says Palisades they don’t cover

| things up he says they just don’t report it. (DD-5)

|

| Response: Allegations or safety concerns reported to the NRC are handled under the

| allegations program as described in NUREG/BR-0240, Rev. 3, “Reporting Safety Concerns to

| the NRC.” The comments are outside the scope of the license renewal environmental review

| and will not be evaluated further.

|

|
Appendix A

October 2006 A-145 NUREG-1437, Supplement 27

Cost-Benefit Analysis |

|

Comment: A 20-year extension for Palisades will be costly. Ratepayers and (by default) |

taxpayers are to pay for maintenance of the waste generated by the utilities. The fifty year old |

Price-Anderson Act requires taxpayers to pay for any major accident or terrorist incident at |

nuclear power plants over a cap of merely $11 billion paid for by the nuclear utilities and their |

insurance companies for accidents or terrorist incidents at the plant, a liability that could run into |

many hundreds of billions of dollars. This liability protection is a unique subsidy provided to the |

nuclear power industry, at taxpayer expense. (GG-13) |

|

Response: The Commission determined that an applicant for license renewal need not provide |

an analysis of the economic costs or ecnomic benefits of the proposed or alternative actions. |

The comment is outside the scope of the license renewal environmental review as set forth in |

10 CFR Part 51 and Part 54 and will not be evaluated further. |

|

Energy Policy |

|

Comment: And forgive me for not having the information with me, the facts and figures at the |

moment, but the information I have been reading indicates that nuclear industry has received |

more government subsidies during its lifetime than any other industry. It’s well over 50 percent |

of all of the tax incentives, breaks, guaranteed loans, supplementing catastrophic insurance for |

the industry etcetera. (AA-1) |

|

Comment: The amount of money that the taxpayers are paying out of their tax, taxes to the |

industry on top of these high electric rates that they’re having to pay monthly rates is absolutely |

extraordinary. If people knew that and if that was, if that was analyzed down to a level and |

given to them so they could see it they would be absolutely appalled. (AA-2) |

|

Comment: And the renewable, the percentage of, of money going to renewal is something like |

11 percent of all the money and the nuclear industry gets well, well over 50 percent as I say. |

(AA-3) |

|

Comment: Now in the, and the media has, you know, made some, had been reporting a large |

subsidy and tax incentives to the oil industry and everybody is appalled over that. The nuclear |

industry has them by a mile. (AA-4) |

|

Comment: Decommissioning, or the closing and dismantling of nuclear power plants, ranges |

from $280-$612 million for each plant, ultimately paid for by utility customers. DOE’s latest cost |

prediction for the Yucca site for high-level radioactive waste generated up to the year 2010 is |

$58 billion. Energy Secretary Bodman has recently admitted, however, that DOE has no total |

price tag predictions for the project and the State of Nevada predicts the cost will top |
Appendix A

NUREG-1437, Supplement 27 A-146 October 2006

| $100 billion. Ratepayers who receive electricity from nuclear reactors pay a Nuclear Waste Fee

| on their electricity bills. Several billion dollars of the Fund have already been spent at Yucca;

| about $20 billion remains in the Fund, far short of DOE’s now underestimate of $58 billion for

| Yucca. The shortfall will have to be paid, yet again, by US taxpayers, many of whom have

| already paid as ratepayers. (GG-48)

|

| Response: The NRC makes its decision whether or not to renew the license based on safety

| and environmental considerations. The final decision on whether or not to continue operating

| the nuclear plant will be made by the utility, State, and Federal (non-NRC) decision makers. 

| This final decision may be based on economics, energy reliability goals, and other objectives

| over which the other entities may have jurisdiction. The comments are outside the scope of the

| license renewal review and will not be evaluated further.

|

| Emergency Response and Preparedness 

|

| Comment: Emergency responders in the 50-mile zone around the Palisades nuclear reactor

| are likely to be inadequately trained and inadequately equipped to respond to a major

| radioactivity release during an accident or attack at the Palisades plant. Covert Township does

| not have the staffing, equipment, training or preparedness for a major radiological emergency,

| the risk of which increases with 20 additional years of operation at Palisades, as the plant ages.

|

| Other communities within the 50-mile zone are mostly rural, and maintain only volunteer fire

| departments, which have even less equipment and training than Covert Township. 

| Radiation monitors and radiation-protective gear are unheard of, or in limited supply. Isolation

| wards for radioactively contaminated victims – the patients themselves posing a hazard to

| emergency medical technicians, doctors, and nurses -- are limited as well at hospitals within 50

| miles of Palisades

|

| NMC/Consumers are obligated to demonstrate how the communities that surround its facility

| are equipped for such a risk referenced in NRC’s 1982 report, of a catastrophic radiation

| release, as well as ensuring that the plant’s current Radiological Emergency Response Plan

| projects 20 years forward and incorporates population trends and development, highway

| construction projects, transitory populations of migrant workers, and provisions for bi-lingual

| notifications and dissemination of information. (GG-41)

|

| Comment: NMC/Consumers must demonstrate how the communities that surround its facility

| are equipped for a catastrophic radiation release. The plant’s current Radiological Emergency

| Response Plan is inadequate and must be revised to project 20 years forward and incorporate

| population trends and development, highway construction projects, transitory populations of

| migrant workers, and provisions for bi-lingual notifications and dissemination of information. 

| This requires Spanish language emergency evacuation instructions and notifications prepared

| to serve the Spanish speaking Latino population. (GG-59)
Appendix A

October 2006 A-147 NUREG-1437, Supplement 27

Response: The Commission considered the need for a review of emergency planning issues in |

the context of license renewal during its rulemaking proceedings on 10 CFR Part 54, which |

included public notice and comment. As discussed in the Statement of Consideration for |

rulemaking (56 FR 64966), the programs for emergency preparedness at nuclear power |

facilities apply to all nuclear power facility licensees and require the specified levels of |

protection from each licensee regardless of plant design, construction, or license date. |

Requirements related to emergency planning are in the regulations at 10 CFR 50.47 and |

Appendix E to 10 CFR Part 50. These requirements apply to all operating licenses and will |

continue to apply to facilities with renewed licenses. Through its standards and required |

exercises, the Commission reviews existing emergency preparedness plans throughout the life |

of any facility, keeping up with changing demographics and other site-related factors. |

Therefore, the Commission has determined that there is no need for a special review of |

emergency planning issues in the context of an environmental review for license renewal. |

|

The comments are outside the scope of the license renewal review; therefore, they will not be |

evaluated further. |

|

|
Appendix A

NUREG-1437, Supplement 27 A-148 October 2006

| A.3 References

|

| International Atomic Energy Agency (IAEA). 1992. Effects of Ionizing Radiation on Plants and

| Animals at Levels Implied by Current Radiation Protection Standards. Technical Report Series

| No. 332. Vienna, Austria. 

|

| International Commission on Radiological Protection (ICRP). 1977. Recommendations of the

| International Commission on Radiological Protection. ICRP Publication 26, Pergamon Press,

| New York. 

|

| International Commission on Radiological Protection (ICRP). 1991. 1990 Recommendations of

| the International Commission on Radiological Protection. ICRP Publication 60, Pergamon

| Press, New York. 

|

| National Cancer Institute (NCI). 1990. Cancer Populations Living Near Nuclear Facilities, NIH

| Publication No. 98-814. July.

|

| National Council on Radiation Protection and Measurements (NCRP). 1991. Effects of Ionizing

| Radiation on Aquatic Organisms. NCRP Report No. 109, Bethesda, Maryland.

|

| Nuclear Management Company, LLC (NMC). 2006. Personal communication with attachments

| from J. Holthaus, Environmental, Nuclear Management Company, LLC, Covert, Michigan, to

| B. Pham, U.S. Nuclear Regulatory Commission, Rockville, Maryland. Subject: “Palisades

| Cultural Resources Procedures.” Attachment 1: “Archaeological, Cultural and Historic

| Resources,” FP-RP-ENV-01; Attachment 2: “Palisades Cultural Resources,” LM-330. 

| (January 24, 2006).

|

| U.S. Environmental Protection Agency. 2006. “U.S. Response to Recommendation in the

| IJO’s 9th Biennial Report on Great Lake Water Quality.” Available URL: 

| http://www.epa.gov/glnpo/glwqa/ijc9th/index.html.

|
Appendix A

October 2006 A-149 NUREG-1437, Supplement 27

A.4 Public Meeting Transcript Excerpts |

|

Excerpts of Transcripts of the Afternoon Public Meeting on April 5, 2006, in South Haven, |

Michigan |

|

[Introduction by Mr. Cameron] |

[Presentation by Ms. Franovich] |

[Presentation by Mr. Bo Pham] |

|

MR. CAMERON: Yes. Let's see if we have questions on the process before we get into the |

substantive findings of the EIS. And we just need to make sure that we save time to get your |

questions on that, but any questions on the license renewal process at this point? Yes, let me |

get you with this microphone here. |

|

MS. CAREY: Well, as a mother of four boys and a teacher of fourth graders, I usually talk pretty |

loud, but I wanted to ask you, the hour before the meeting, in other words, the pre-meeting |

availability of all these nice people to answer questions. Is that new in the process or has that |

gone on from the beginning? |

|

MR. CAMERON: Okay, good question. Bo? The informal open house that we do, traditionally |

do before |

the -- |

|

MR. PHAM: That has -- |

|

MR. CAMERON: -- the meeting. |

|

MR. PHAM: Yes. Both the scoping meeting and our draft meetings we have traditionally have |

held one hour before and after, before the formal presentations itself as an open house. |

|

MS. CAREY: I think my question about it is that in order to get the issue, I may have a question |

and issue that I really want answered, but I want other people to hear it too because I need |

everybody's input. And if it's done on this private discussion before and after the meeting, it |

means that the other people that are hear don't get a chance to hear my very important |

question. |

|

MR. CAMERON: And that's, I think, Rani would tell you, would urge you to, to also ask the |

question here so that everybody else can hear it. It's not, the open house is meant to give |

people an opportunity to informally talk to the NRC's staff, and it's not meant to foreclose any |

questions or comments from coming up in this session. Right, Rani? |

|
Appendix A

NUREG-1437, Supplement 27 A-150 October 2006

| MS. CAREY: Thank you.

|

| MR. CAMERON: Okay. Yes, sir? And we have a question back there, but, and please

| introduce yourself too.

|

| MS. CAREY: Oh, I was Corinne, oh, go ahead.

|

| MR. CAMERON: Go ahead, sir.

|

| MR. LOWE: Yes, this is Corinne Carey.

|

| MR. CAMERON: Thank you.

|

| MR. LOWE: And I'm Chester Lowe. Both from Grand Rapids, Michigan. I wanted to know

| what the, or whether or not there are any local residents from South Haven here that had any

| input or any kind of part for the environmental review process, and what happens here in the

| community. In other words, are there any representatives of South Haven area, or even this

| area of Michigan? In the, as part of a team for part of the process of this? Also, about the

| socioeconomic factor. I wanted to know more about that.

|

| MR. CAMERON: Okay. We'll, we'll hold off on the socioeconomic and go back to that after you

| hear Dave Miller's presentation on that. And in terms of local residents and local government

| being, being part of the process, I think Bo and/or Rani are going to tell you about the fact that

| we did have local residents who spoke at the scoping meeting and I think that Bo, and you

| elaborate on this, in terms of how we work with local government here in terms of the process,

| okay?

|

MR. PHAM: Yes. During the scoping process, when we had the meeting here in July 28th | last

| year, we basically, we asked everybody that if they were interested and they registered at the

| meeting, and we had the address and contact information, we have been keeping everyone on

| our expanded mailing list. If there any correspondence that we have been sending out

| regarding the license renewal issues, everyone should have been getting, so and when we

| published the Draft Impact Statement, we also mailed a copy to everyone on that. 

|

| Now as far as the people are showing up here today, I couldn’t tell you who specifically is from

| the community, but that, the process carries on from here on to and that if you register, and

| that's one point I, I kind of wanted to follow-up onto. If you're here and you haven't registered I

| ask that you please do so, so that we can have your information so that we continue to keep

| you informed of the whole process here.

|

| MR. CAMERON: Good, good point. And we're going to go here, and then we'll go over to you. 

| And if apropos of Corinne's question about the informal open house, we'll be here after the
Appendix A

October 2006 A-151 NUREG-1437, Supplement 27

A-1

meeting too if anybody wants to get more information on a point or a question to talk to the NRC |

staff after the formal part of the meeting is over. And, Kevin? |

|

MR. KAMPS: My name is Kevin Kamps. I work for Nuclear Information and Resource Service, |

but I'm from Kalamazoo. And my question, Bo, has to do with the schedule that you went |

through. My question is what is the breakneck speed up there all about? I mean, back in |

July 28th, we requested an extension to the scoping period and I don't even think we got an |

answer on that. We sure didn't get an extension, but we didn't get an answer even. And so my |

question is if you really want public input on this stuff, then, and I know you're going to say, well, |

the Commission told us to and maybe even, well, Congress told us to beyond that but, this, this |

breakneck speed, this sprint is just, you know, kind of, the writing's on the wall, I would have to |

say. |

|

MR. CAMERON: And Bo, in terms of a couple of points as, you know, the basis for the, for the |

schedule, perhaps something that you might not know is what did we do with Kevin's request, |

which I remember, I think, from the last scoping meeting. Not that it matters that I remember, |

but what we did with that. Kevin, I don't know if implied in your question you're formally, or at |

least at this meeting, requesting that the comment period be held open. If you are, we'll want to |

get that on the record. |

|

MR. KAMPS: I would like to make that request. I'd like to ask for another three months on the |

comment period -- |

|

MR. PHAM: Okay -- |

|

MR. KAMPS: -- for meaningful public input. |

|

MR. PHAM: Let me -- |

|

MR. CAMERON: Okay. |

|

MR. PHAM: Let me have Bob take on the first part of the question and whether we responded |

to your request. I remember hearing about that, but Bob was the, the Environmental PM at the |

time. And now, Bob? |

|

MR. SCHAAF: Right. Kevin, we did respond to that request and I can get you the accession |

number for the letter. I thought it had been addressed, actually, to you. It may have been |

misdirected in responding, but we did, we did address that, that request. And I'll make a note to |

get that accession number for you. |

|

MR. CAMERON: Okay. Great. That's Bob Schaaf. Thank you, Bob, and -- |
Appendix A

NUREG-1437, Supplement 27 A-152 October 2006

A-2

| MR. SCHAAF: I, I, as, as far as the schedule and, and the timing and the amount of time for

| comments, you know, the gist of our response both for, for the scoping period and I guess it

| would be a similar answer to your question regarding comments on the draft, is that the

| Commission has, has a number of, of goals that, that we work towards, one of which is

| openness to the public and involving the public in our process. We also have goals regarding,

| you know, efficient operation, conduct of, of the public's business. 

|

| And the Commission has determined that these time frames are reasonable time frames for

| balancing those, those goals that, particularly in the case of, actually in the case of the comment

| on the draft period. Our regulations stipulate a 45 day comment period and include

| opportunities for the public to request 15 day extensions. And by default, when we started the

| license renewal process, we, we went ahead and added on essentially two 15 day extensions to

| the, the, the regulatory requirement for a 45 day comment period. So there has already been

| some allowance for additional time, nearly double the, the required time frame for that response,

| for folks to provide responses.

|

| MR. CAMERON: Okay. And we're going to go on to one last question before, and see if we

| can revisit these issues, but we'll go to you. Then I just want to give Kevin a follow-up.

|

| MR. KAMPS: Well, just to respond to that. I mean, our efforts as local concerned citizens

| regarding this very dangerously deteriorated plant have involved the NRC licensing process,

| performed pro bono by us through completely volunteer efforts on a grass roots level. And so

| this thing is going on at the same time as that licensing process, which we're still engaged in

| because we've appealed the licensing board's ruling against us. So I think the Commission's

| regulations are unreasonable.

|

| MR. CAMERON: Okay. And that is on record, Kevin, as is your request. And let's go right here

| and then we'll go on. Yes, ma'am?

|

| MS. ELZERMAN: My name is Mary Ann Elzerman, and I am a Physicist for the Department of

| Environmental Quality. And I want to assure all of you that we have had two people, two

| physicists, in this process of the environmental and the technical review ever since it started. 

| And the state is very aware of what's going on and we do comment on all of the publications

| that come from the NRC.

|

| MR. CAMERON: Great. Thank you State of Michigan, Department of Environmental Quality. 

| Thank you very much. Let's, do you have a quick process question sir, before we go on? And

| also please introduce yourself.

|

| MR. PICCIUCA: My name is Sebastian Picciuca, and I live in, within 50 miles of the plant. Did,

| you said 45 days, it's only 43 at the bottom, one of the upper ones was only 30, like 3, 25. What

| was the 45 days?
Appendix A

October 2006 A-153 NUREG-1437, Supplement 27

MR. PHAM: It was, it's 45 days from the publishing of our Draft Environmental Impact |

Statement and the recognition of it by the EPA, and as published in the Federal Registered |

Notice. So that's the 45 days, and actually they, May 18th -- |

|

MR. PICOIUCA: So when's the 45 days? |

|

MR. PHAM: It, it should have been from February 24th, which is the date that the EPA issued |

the Federal Registered Notice. So 45 days from February 24th, but actually when I'd put up the |

schedule, May 18th built in a little cushion just in case. We could even make the 45 days. So |

you actually have more than 45 days. |

|

MR. CAMERON: Okay. Thank you. Ken, let's go to you. |

|

MR. RICHARD: I'm Ken Richard. |

|

MR. CAMERON: Well, Ken, what I wanted to do is, is get Dave on with his substantive findings |

and then we'll go to you first after he's done with that for your question. Because I think it may |

relate more to that, I don't know. And we do have the socioeconomic in the parking lot, so to |

speak too. So we didn't forget that, Chester. It is Chester, right? |

|

MR. LOWE: Right. |

|

MR. CAMERON: All right. Dave? Dave Miller. |

|

[Presentation by Mr. Dave Miller] |

|

MR. CAMERON: Let's go for questions. Okay, Bo, do you want to clarify something? |

|

MR. PHAM: Yes. I want to just take a quick moment just to pause here and make sure that |

Chester was satisfied with our addressing of the socioeconomic. We looked at factors like |

housing, the infrastructure and land use for the area, and we did not find anything that was, that |

negatively impacted the environment. |

|

MR. CAMERON: And let me just see if Chester has a follow-up on that. Chester, do you have |

more things that you want to ask about the socioeconomic analysis. |

|

MR. LOWE: Not about the socioeconomic. Mainly about the sociological impact. |

|

MR. CAMERON: Okay. Let me go to Ken, and then we'll go to this young, Nancy? Kathy. All |

right. All right. So are you guys ready to answer questions? Okay. Okay, Ken, please |

introduce yourself to us. |
Appendix A

NUREG-1437, Supplement 27 A-154 October 2006

| MR. RICHARD: I'm Ken Richards. I live three miles from the plant and I've been following this

| issue probably since the plant's inception. And the first question I have is about the process

| here. We've, I've been talking with a lot of local people. There's a lot of folks who really think

| this license is already done. It's already been issued. I was wondering if you would clear that

| up. I'm reading in the manual and I come across, or it sounds like it's trying to justify the license

| that is already done. And other places I see, it's not going to be, the decision won't be made

| until 2007. There's still another meeting in Washington, D.C. in December. When does this

| license get issued?

|

| MR. CAMERON: Okay. And what I'd like you to do Bo, is to not only talk about what remains to

| be done on the Environmental Impact Statement, but please tell people going back go Rani's

| initial presentation all the different parts that need to come together before there is a decision

| and what time frame. I think starting off, the bottom line is is there has been no decision yet. 

| And Bo with that, can you explain --

|

| MR. PHAM: Yeah.

|

| MR. CAMERON: -- to the audience what this is all about?

|

| MR. PHAM: Yeah. Definitely I want to reiterate that there has been no --

|

| AUDIENCE MEMBER: Louder.

|

| MR. PHAM: Okay. It was off. Can you hear me now? Okay. Yeah, I definitely want to

| reiterate that no decision has been made and there's no finality on this decision. What we're

| here today, what we're here to do today is to take your comments regarding the environmental

| review process. And if you look at this screen up there, the process of license renewal breaks

| down into two paths basically. One is the safety review, and Juan Ayala is the Project Manager

| for that path. And I am here for the environmental review process. And we're not complete with

| that, you know, so basically towards, at the end there what you're going to have is a complete

| review from both paths and that, those two, you know, when the Commission comes to a

| decision based on those two paths, is the finality of the review and that's when the Commission

| will decide whether a license is renewed.

|

| MR. CAMERON: Okay. 

|

| MR. PHAM: Does that answer your question?

|

| MR. CAMERON: Let's just, Rani, do you want to, hold on a minute Ken. Just let me see if Rani

| wants to add anything to that for your benefit.

|
Appendix A

October 2006 A-155 NUREG-1437, Supplement 27

MS. FRANOVICH: The final Safety Evaluation Report, which is the culmination of the Staff's |

safety review, here, that is expected to be issued in October of this year. Once we issue the |

Safety Evaluation Report, it will go to the ACRS for their independent review. And once they've |

completed their review, they'll have some recommendations for the Commission directly. The |

NRC decision on whether to issue a new license here, is when Juan? What's the ETA for the |

new licenses? 22 months from the time that we get the license in hand. So 22 months from |

March, I guess it will be January of '07. January of '07 is when we are supposed to -- |

|

MR. RICHARD: Is that the old original, one of the, and one of the decommission -- |

|

MR. CAMERON: Ken, we need to get you on the record, so I'm going to give you a follow-up, |

and then I'm going to go to Kathryn. And then we'll go over to you. And that estimated time for |

the decision, is the decision on whether to renew the license? |

|

MS. FRANOVICH: Correct. |

|

MR. CAMERON: Okay. Do you have one follow-up? |

|

MR. RICHARD: No, I've got quite a few. I was going to wait for the two hour session. |

|

MR. CAMERON: Okay. All right. Let me go to Kathryn. |

|

MS. BARNES: Yeah. These questions are for Mr. Miller. You are, your degree is in |

Environmental? |

|

DR. MILLER: Engineering. |

|

MS. BARNES: Engineering. Have you worked with wind technology? |

|

DR. MILLER: Well, members of my team have. Oh, sorry, yes. I am the team lead as I -- |

|

MS. BARNES: Okay. |

|

DR. MILLER: -- wanted to point out. We had another ten other experts in their various subject |

matter experts. |

|

MS. BARNES: Okay. |

|

DR. MILLER: For instance, when I, when I actually do a subject matter expert, mine's hydrology |

ground water, water resources, because that's where my discipline is. So we bring the |

appropriate expertise to the subject matter. |
Appendix A

NUREG-1437, Supplement 27 A-156 October 2006

C-1

C-2

C-3

| MS. BARNES: I was wondering on this assessment of wind and solar, granted Michigan

| doesn't have sunshine every day like the Western states. Solar really isn't feasible here as an

| alternate. But what about the wind? You're saying it's, it's a large concern because it takes a

| lot of land. How much of power for Palisades is sold out of state? What percent of the power is

| sold out of state?

|

| DR. MILLER: I'd like to address the wind, the wind point first and then I can ask others to

| address that.

|

| MS. BARNES: Okay. Well, this, this --

|

| DR. MILLER: But, may I address the wind part of it?

|

| MS. BARNES: Well, this, this, this all comes together because if you're taking this and you're

| saying 143,000 acres, but if Palisades, like DC Cook, sells most of its energy out of state, that's

| really not a proportionate summation.

|

| DR. MILLER: I, I think I understand your question. I think I understand your question.

|

| MR. CAMERON: -- please.

|

| MS. BARNES: And also I was wondering --

|

| MR. CAMERON: Kathryn, let me --

|

| MS. BARNES: One other thing, please. This is, this is important. What are you basing on,

| what size wind generators are you basing this summation on? The small little ones, or the ones

| that they're using now, the big ones that Consumers Energy's investing in to replace the

| nuclear? Palisades is up for sale. They want it off their hands. They were investing in green

| energy and it's working. So I wonder about this. 

|

| And also, this whole summation. It's all, you're all under the premise on this whole review that

| there's, nothing's going to happen. That there's no accidents. But there's things that happen all

| the time. So this, you're, you're, you're process, I think is defective. 

|

| MR. CAMERON: And Kathryn --

|

| MS. BARNES: But I would like to know, technically, all right, how you came to this summary

| and the size of the wind generators you took into account in this summary, et cetera, et cetera,

| et cetera. The whole detail.

|
Appendix A

October 2006 A-157 NUREG-1437, Supplement 27

MR. CAMERON: And if you could just, we appreciate your comments and we want to hear |

them. |

|

MS. BARNES: I'd like some answers. |

|

MR. CAMERON: But if you could just hold your comments until the comment period and we'll |

try to get you some answers to your question. And I just want to make sure that Dave gets a |

chance to answer the question about the analysis. And Bo you indicated you understand where |

Kathryn's going with the amount of power generated, shipped out of state. Why don't we let |

Dave talk about how that analysis was done on wind, and then you can tie that going out of |

state thing in, I think -- |

|

DR. MILLER: Sure. |

|

MR. CAMERON: -- would be good. |

|

DR. MILLER: Well, regarding, and I realize it is a complex issue, and that's why we do look at |

combinations of alternatives. And the details that are fairly significant would be difficult to get |

into completely here, but they are laid out both in the GEIS and then supplemental information |

in the supplement. |

|

But to answer the basic question about the kind of wind generation capacity that's considered, |

it's not a single specific design. It's basically a design that uses current efficiencies ranging |

between about 25 to 35 percent efficiencies that, that would gather roughly 25 to 35 percent of |

the energy available in the wind, in that wind field at any single time. And so that, and then you |

look at the size of area that you need to support that amount of wind and you scale it by the 25 |

to 35 percent value, and that's how you come up with the acreage required for the wind |

replacement of the base level. |

|

MS. BARNES: So you're -- |

|

MR. CAMERON: And its size, and Kathryn, I'm sorry, we need to get everybody on the |

transcript. And also, although I apologize for this, we can give so much of an answer now to the |

questions, and then we might have to talk to you after the meeting because we do want to hear |

your comments also. So let's go with the questions that you have on the floor, and I think that, |

did we answer? You did have a question about the size of the wind turbines that are used. |

Steve, can you say anything about that? |

|

DR. MILLER: Yes. The analysis, the alternative analysis assumes that Palisades is producing |

780 megawatts of electricity right now. And so we're trying, in all of our alternatives we try to |

baseline that as the replacement amount of energy that needs to be, that needs to be provided. |
Appendix A

NUREG-1437, Supplement 27 A-158 October 2006

D-1

| So based on that the scale of the wind farm or, you know, other sources, in the particular case

| of wind and solar, the amount of land use that's required for, to produce that capacity is going to

| have a greater impact. And that's why we, you know, we're not saying that wind power in

| general has a large effect on the environment. We're just comparing to what we have today. 

| And so that's the basis of our comparison and analysis.

|

| MR. CAMERON: Okay. And you can please talk to Kathryn after the meeting with more details

| on this. And I'm going to go to this gentleman over there, and then Corinne, and we're going to

| go on to the SAMA issue. Okay? Yes sir? And please introduce yourself.

|

| MR. DAL MONTE: My name is DalMonte, and I am the President of -- Now my, my question is,

| in this regard, is that we are reading this report or your final result is administered by you and it's

| only, is going to say, well, that Palisades can continue. I mean, the fact that Palisades can

| continue operation is not unreasonable. And I understand that you are stressing that result. 

| But on the side, you are taking position on alternative solutions that I read and I don't think is

| enough education in your point. Because the fact is that wind is flying. We are having wind all

| over the world and in here too. So I guess you missed the point in this. And I don't understand

| why you, you are so concerned on our selecting alternatives if we know about the alternatives. 

| And really, you are not doing a good job and the guys are going to really make the decisions,

| went through the final decision. Okay, thank you.

|

| MR. CAMERON: Mr. Dal Monte, thank you for that. And we are going to hear from you later

| on. I think that the question there that we could provide some information on is why do we do

| the alternatives analysis. Can you put that in perspective for us Bo?

|

| MR. PHAM: Yeah, let me try to frame that. You know, like I said before, we take a baseline of

| what we're trying to replace, the energy source that we're trying to replace, which is the

| Palisades Nuclear Plant that's there right now. We're not, if you can try to look at it as not

| comparing wind power versus nuclear power versus anything else. We're looking what, what

| the potential environmental impact of each of those alternatives is going to result in. So that's

| what our analysis is. 

|

| We're not here, and we don't, the NRC doesn't have the jurisdiction really to make the energy

| policy of what, you know, what comes out of Palisades and what other different sources of

| energy. And so what we're here, and you know, I'm trying to, I guess, define the scope of what

| we look at is really, all these different alternatives and not comparing them and making the

| judgment of whether one is better than the other. We're just simply stating that this is what the

| environmental impact is going to be with wind power, with the nuclear power plant, or with solar

| power, or with other alternatives as well.

|

| MR. CAMERON: And Rani, do you want to add to that?

|
Appendix A

October 2006 A-159 NUREG-1437, Supplement 27

MS. FRANOVICH: I just want to add something. You know, you're, you're looking at a nuclear |

power plant. It's already built. It's already operating today. So the impact of its continued |

operation is quite different from the impact of closing that facility, building a wind farm of large |

components that would harvest the wind energy, or another site that would have solar panels to |

harvest the energy of the sun. The environment associated with building those new sites is |

larger, it's a larger impact to the environment than continuing to run a facility that's already built |

and operating now. So on a logical level, that time makes sense. |

|

MR. CAMERON: Okay. We're going to go to this gentleman. |

|

MR. HENKEL: I'm Don Henkel. |

|

MR. CAMERON: Yes, we usually -- |

|

MR. HENKEL: I'm still Don Henkel. Point of information. I understand there's some hundred |

and some odd nuclear power plants throughout the United States. How many of those have |

applied for renewal licenses? And of those who have successfully applied for a renewal |

license, how many have been approved and how many have been disapproved? |

|

MS. FRANOVICH: Okay. That's a good question. |

|

MR. CAMERON: And Rani, please, put that in the context too in terms of our process about |

rejection of applications, et cetera, et cetera. Thank you sir. |

|

MS. FRANOVICH: There are 103 operating reactors across the country. We haven't quite |

gotten halfway through the fleet. I'd say 47 or 48 or so, thus far, have applied for renewal. And |

this is reactor units, not necessarily sites. There have been a couple that we've returned |

because the information in the application was not adequate or sufficient for the Staff to begin |

and complete its review. |

|

For those that we did not return, we requested additional information and it depends on really |

the quality of the original submittal will dictate how many requests for additional information the |

NRC needs to put out there. But for the plant that I managed back a few years ago, there were |

273 requests for additional information. So the Staff does not grant renewal for every |

application it receives because it's a pro forma review. The Staff will continue to get the |

information it needs to complete its review, and will not be satisfied until that information is |

received. |

|

So when we issue our Safety Evaluation Reports, a number of times there are still open items |

that the Staff is not satisfied with. We do not issue a final Safety Evaluation Report and brief the |

ACRS on our work until the Staff is satisfied. |
Appendix A

NUREG-1437, Supplement 27 A-160 October 2006

F-1

F-2

| So the answer is we're roughly halfway through the fleet. We've returned a couple of

| applications for sufficiency issues. For the rest, we gathered more information than we received

| to insure we were satisfied with the information to complete our review.

|

| MR. CAMERON: In terms of the number of licenses we've renewed though?

|

| MS. FRANOVICH: I don't have the specific number off the top of my head, but I'm saying 40,

| I'm thinking 48, 49 --

|

| MR. CAMERON: 39.

|

| MS. FRANOVICH: 39 per unit.

|

| MR. CAMERON: All right. And Corinne, you had a question?

|

| MS. CAREY: Yes. Several things. Number one, I'm concerned that the kinds of answers we're

| hearing, I, I feel are very questionable. For instance, wind power in itself, you don't measure

| that by acreage because farmers are finding a very successful business for them to put the wind

| farms along their lot lines. And so it's a very definite advantage environmentally in that respect,

| and I didn't hear that kind of that thing in your report. 

|

| Secondly, I heard that solar and acreage. And it's my understanding that solar is very

| commonly mounted on rooftops and walls in cities, which also reduces the transmission loss, et

| cetera, that comes from centralized nuclear plants scattered around and have this great

| transmission loss over their process of getting the electricity to where it's needed. And there

| was a third point, and I can't think of it right now.

|

| MS. FRANOVICH: Did you have a question?

|

| MR. CAMERON: And no, I think Corinne is, I think the comment we have of what Corinne is

| saying is that there may, comments like she just made and like we're going to hear tonight, and

| I'm sure from Kathryn, for example, on wind power are all the things that we need to hear to

| consider in finalizing our report. And Dave Miller did a summary of the report and didn't get into

| every detail where that type of thing may be coming out. And I'm going to go to this lady back

| here for a question, and then I think we need to go on to SAMAS. If we have time to come back

| to you, Kathryn, we will. But we really need to get to the next presentation. Yes ma'am?

|

| MS. HIRT: I'm Alice Hirt. And I do not really need to ask a question right now, but I want to

| respond to Ms. Franovich. Is that what your name? I, I feel that you respond to the question

| about the impact of other technologies on the environment with a very subjective answer. And I

| sort of resent you making that sort of sweeping statement. I don't believe that you are an expert

| on all other technologies and for you to say that new other sources, say wind and so forth,
Appendix A

October 2006 A-161 NUREG-1437, Supplement 27

C-4

would have a greater impact on the environment than keeping Palisades going, I, that is |

certainly not my estimation, and I don't believe that that was really your place to make that sort |

of a sweeping comment. |

|

MR. CAMERON: Okay. And the, Alice, what we have in the report, and Rani is the Section |

Chief for the environmental section that does these, there's details in there that arrives at that |

conclusion as Mr. Miller presented. And he may have done that before you, I don't know if you |

were here for his presentation, but that is the conclusion. And indeed people will, can and will |

disagree with that, and we want people to tell us if they disagree with it and tell us why they |

disagree with it basically. And Rani, do you want to add anything else at this point? It wasn't -- |

|

MS. FRANOVICH: She's entitled to her -- |

|

MR. CAMERON: -- a question. |

|

MS. FRANOVICH: -- view and I appreciate her expression of it. I, I'm not an expert. You're |

absolutely right. What I was doing was explaining the Staff's conclusions on the analysis that |

was performed by the experts. |

|

MR. CAMERON: Which was done by the experts. |

|

MS. FRANOVICH: Correct. |

|

MR. CAMERON: Okay. And I'm sorry that we can't go back for second questions here. |

|

MS. BARNES: I didn't have my first one answered. I asked questions and no one answered |

them. |

|

MR. CAMERON: They tried their best to answer the question Kathryn. |

|

MS. BARNES: I asked how much is sold out of state and what size wind, what size wind |

generators. |

|

MR. CAMERON: Okay. That's two questions. How much is sold out of state and what is the |

size of the turbine? That's, that's true Kathryn. |

|

MS. BARNES: No. What, what is the size in your analysis, what size, what size wind |

generators are you saying would take that much acreage? And how much of Palisades power |

is sold out of state? Those are two questions I asked they will not answer. |

|

MR. CAMERON: You want to do this one? Okay. Exactly right. |
Appendix A

NUREG-1437, Supplement 27 A-162 October 2006

| MR. PHAM: Only can answer the first one. I do not have the numbers to provide for you

| regarding how much power is sold out from Palisades. That's, the NRC doesn't have any say in

| that, in that decision actually. Your second question regarding the, what size turbine, I believe

| we look at the predominant research that's out there based on the Department of Energy and

| other bodies. The National Academy of Sciences, for example, and take a look, and we use,

| we don't use specific models or types of turbines. We look at the general baseline efficiency of

| what wind turbines, the best and the worst of what the wind turbines can do right now.

|

| MR. CAMERON: Okay. And if anybody does have the information on the amount of power sold

| out of state, if they can give Kathryn after the meeting, please, please do that. And, yes sir?

|

| AUDIENCE MEMBER: I'm, I'm, my only questions is why was oil in the same category with

| solar and wind? That's, in the alternative, it was listed with the alternatives.

|

| MR. CAMERON: And the answer to that question? And is it going to be Bo or Dave?

|

| MR. PHAM: I would say that there was no connotation or nothing meant by it. Yeah, it's just

| one of the alternatives that we looked at.

|

| MR. CAMERON: Okay. 

|

| MR. SCHAAF: I can, I can --

|

| MR. CAMERON: All right. Bob Schaaf on that one.

|

| MR. SCHAAF: What we look at in the alternatives analysis is, NEPA requires us to evaluate

| and assess the impacts of alternatives to the proposed action. The proposed action here is for

| the plant to continue operating for an additional 20 years. At the very least, we need to look at

| what's called the no action alternative, which would be not renewing the license and identify

| those impacts. The NRC has decided from a practical standpoint, if the plant does not continue

| to operate, something will need to be done to replace the generation lost when that plant

| ceases operation. That may be a new base load power generating facility. It may be

| purchasing power from outside of the service area. That may be renewable alternatives. It may

| be a new, large, base load power generating station.

|

| When we do these alternatives' analyses, we look at the infrastructure that is in place in the

| vicinity of the site to look for what are the likely alternatives that we do a detailed analysis on. 

| You have a gas fired plant just across the freeway from the Palisades site. So there is

| infrastructure in place to deliver natural gas which would allow you to install and construct a

| large base load gas-fired generating station. There's a rail line in the vicinity of the site, which

| would allow you to bring in coal to construct a coal-fired generating station. Although I believe

| in this case we didn't look at placing the coal-fired plant at the site. We looked at placing it
Appendix A

October 2006 A-163 NUREG-1437, Supplement 27

somewhere else in the service territory because of the sensitivity of the dunes area. We also |

looked at new nuclear construction because there is interest in the industry in constructing new |

nuclear generating stations. |

|

Under other alternatives, the reason oil is in with the wind and the solar and the conservation, is |

because these are alternatives that we looked at in less detail because we didn't consider them |

to be the likely alternatives for replacing loss generation if the license was not renewed. There's |

not infrastructure in place necessarily to bring an oil, plus there are other uses for oil in |

transportation and in the chemical industry. That's why it's in there. |

|

We're not saying that it's equivalent to some of these renewable sources that we considered, |

the wind, the solar. The reasons that the wind and solar aren't looked at in, in as great a detail |

frankly, is that we're talking about replacing a large base load generating station that is |

expected to operate for roughly 90 percent of the time. Wind won't generally do that. Solar |

won't generally do that. And so we consider those alternatives, and we discuss the impacts of |

those alternatives, but we don't view them in the same level of detail. |

|

MR. CAMERON: Okay. |

|

MR. SCHAAF: I guess that's, that's why it's in there. |

|

MR. CAMERON: Thank you. That's very helpful. |

|

MR. SCHAAF: And that's kind of a concise discussion on that. |

|

MR. CAMERON: That's very helpful. We really, I'm sorry, we really do need to move on to Bob |

Palla. |

|

MR. SCHAAF: And I'm available to discuss that after, after the meeting is over. |

|

MR. CAMERON: Yes. I think that gentleman and a bunch of people might want to talk to you |

about that, Bob. Thank you Dave, Bob, Bo. And we're going to go to Bob Palla. And then we'll |

be back to Bo for some final comments here. These are accidents, the accident analysis. |

|

[Presentation by Mr. Bob Palla] |

|

MR. CAMERON: Okay. Thank you Bob. And that's all laid out in the Draft Environmental |

Impact Statement. Anybody have any questions on this SAMA aspect? |

|

AUDIENCE MEMBER: Are they detailed in the EIS? |

|
Appendix A

NUREG-1437, Supplement 27 A-164 October 2006

D-2

| MR. CAMERON: Yes they are.

|

| MR. PALLA: In the supplement. Chapter five is a summary, Appendix G is a detailed

| accounting.

|

| AUDIENCE MEMBER: The ones that were not approved are detailed also?

|

| MR. PALLA: The entire set is described there. And then which ones were deemed to be cost

| beneficial, and which ones are being further evaluated, that's all spelled out specifically.

|

| MR. CAMERON: Thank you. Mr. Dal Monte?

|

| MR. DAL MONTE: What I wondered is, the basis like sabotaging where taking account can be -

| - in this way too. And if you have done that, because this, my contention is is a new issue. 

| They're not the same like previous plan.

|

| MR. CAMERON: Bob, I think this is a question that we get in terms of seismic, what are the

| subjects that are included within the scope of SAMA procedures.

|

| MR. PALLA: Well, let me say what is included. The short answer is sabotage is not included

| within the risk profile that we do this, the SAMA analysis for. What we include is internally

| initiated events, fires within the plant, internal floods, seismic events, high wind events, things

| that we can analyze basically. When it comes to sabotage, even if we wanted to include it, it

| defies quantification and really systematic analysis. So that, that would be one deterrent to, to

| try and include it here, is that it just is very difficult to quantify the frequency of these events. 

|

| Now Rani Franovich mentioned at the beginning, this is, these issues are being addressed as

| part of the current situation with the plant. We're not done with that work yet. This is still in

| progress. Plants are, have beefed up their security arrangements and are looking further at

| mitigation strategies within the plant to deal with things like aircraft impact. This is all not being

| forgotten. But we're looking at it now. It's not really tied into license renewal. And it was not

| part of this evaluation.

|

| MR. CAMERON: Okay. Thank you. And let's have one more question right here on SAMA,

| and then Bo if you could conclude and then we can go and hear what people have to tell us. 

| Yes ma'am?

|

| MS. MCFADDEN: I'm Jean McFadden. I'm a social worker. I'm assuming that the SAMA

| discussion doesn't relate to the embrittlement of the aging reactor.

|

| MR. PALLA: That's correct.

|
Appendix A

October 2006 A-165 NUREG-1437, Supplement 27

MS. MCFADDEN: Okay. |

|

MR. PALLA: That would be determined to be acceptable as part of the, as the safety review |

did. |

|

MS. MCFADDEN: So, so then, looking at this other report on emergency finding and |

preparedness, are you confident in the ability of FEMA, after seeing Hurricane Katrina, to come |

in and manage an emergency here in Van Buren County? |

|

MR. CAMERON: And can we just, this, this is an important issue, obviously, emergency |

planning. And can you just, Rani or Bo, can someone just lay out what the responsibilities are |

for emergency planning NRC, local government, FEMA, and we may need to talk to you further |

about that, but can you do that? |

|

MR. PHAM: Yes. |

|

MR. CAMERON: All right. |

|

MR. PHAM: The, basically, the NRC, our jurisdiction as far as emergency planning is to make |

sure that the personnel on site are protected from the dose, dosage in the case of emergencies. |

Now in the case with outside of the, offsite, that's something that we coordinate with FEMA, |

local authorities and everything. I can't, I can't answer your question regarding do I have |

confidence in FEMA to do it. |

|

MS. MC FADDEN: Why not? |

|

MR. CAMERON: Okay. Rani, do you want to try to address this, and we'll just hear from the |

State of Michigan before we go on. But can we do, can we tell people what FEMA's |

responsibility is vis a vis local government and the NRC, at least tell them that? |

|

MS. FRANOVICH: Yes. And we're experts more in the license renewal arena, so we don't |

have people at this meeting who can really speak to you on the details of, of, you know, the |

NRC's coordination with FEMA and local and state officials. |

|

But I can tell you that licensees periodically conduct drills, and the NRC participates. So does |

FEMA, so do state and local officials. And after the drills there is a debriefing, there is a look at |

lessons learned, so that is where the NRC is engaged. We really can't comment, it wouldn't be |

even appropriate for us to comment on FEMA's capabilities. But I can tell you that our |

jurisdiction is, does the site have an emergency plan? Do they exercise that plan on a periodic |

basis? And does that involve coordination with other stake holders, state and local officials and |

-- |
Appendix A

NUREG-1437, Supplement 27 A-166 October 2006

| MR. CAMERON: And I think we're going to hear from the, from the people who have direct

| responsibility, Jean, right now, with the state. Can you explain that please?

|

| MS. ELZERMAN: The State of Michigan is very proactive in doing their own emergency

| planning. The state police, Emergency Management Division and Homeland Security are in

| charge as lead agency for the State of Michigan for any emergency. During a radiological

| emergency, we, the Department of Environmental Quality Radiological Protection, will step in

| and be their counterpart for the radiological part. In no way will we let FEMA take over. Our

| state will run the emergency until the very end. Thank you.

|

| MR. CAMERON: Okay. Thank you for that. And Bo, can you summarize so we can on and --

|

| MR. PHAM: Yes. Thank you for that comment, by the way. So turning on to our conclusions,

| we found that the impacts of the license renewal in all areas were small. We also concluded the

| alternative actions that we discussed in some subsequent discussions after Dr. Miller's

| presentation, including the no action alternatives, may have moderate to large environmental

| effects in some impact categories. 

|

| Based on these results, our preliminary recommendation is the adverse environmental impacts

| of license renewal is not so large that it would be unreasonable to forward the planning decision

| makers to leave that as an option. 

|

| This slide is a quick recap of our current status. The Draft, like I said before, the Draft

Environmental Impact Statement was issued on February 14th | . To go back to the question

earlier about the 45 day period, the February 14th | date is actually the date that the NRC issued

| or published our Environmental Impact, our Draft. Publicly it's not legitimate or it's not available

| to the public, per se, until the EPA recognizes it, checks it in the system, and publishes a

Federal Registered Notice. And that was done on February 24th | . 

|

| Now by regulations we are required to give a minimum of 45 days for comments from the time

of issuance of the Draft, and we actually built in a 75 day period from the February 24th | date. 

And like I said, even with that we have a little cushion for May 18th | . So once again the comment

period end date is going to be May 18th | , and then we expect to issue the final impact statement

| sometime in October of this year.

|

| This slide identifies me as your primary point of contact with the NRC for the preparation of the

| Environmental Impact Statement. It also identifies where the documents related to our review

| may be found in the local area. Palisades' Draft Environmental Impact Statement is available at

| the South Haven Memorial Library. All documents related to the review are also available at the

| NRC's website, www.nrc.gov. 

|
Appendix A

October 2006 A-167 NUREG-1437, Supplement 27

And in addition, as you came in you were asked to fill out a registration card. If you did and you |

included your address on there, we will mail a copy of the draft and a final, final impact |

statement to you. If you did not fill out a card, I do encourage you that you do. And if you need |

to know how to do it, please contact, Cristina, could you raise your hand please? Cristina |

Guerrero will be out at the registration desk and they'll be able to give you the cards for the |

registration. |

|

In addition to providing comments at this meeting, there are other ways that you can submit |

comments to, for our environmental review process. You can provide written comments to the |

Chief of our Rules and Directives Branch, at the address on the screen there. You could also |

make comments in person if you happen to be in Rockville, Maryland. We've also established, |

to make it easier, we've also established an e-mail address that you can write to us at |

palisadeseis@nrc.gov, there at the bottom. |

|

This concludes my remarks and thanks again. Once again, thank you for taking the time to |

come this afternoon. And I suppose we can take a few more questions. |

|

MR. CAMERON: Well, let's, I think what we're going to do is move on to the comments now, |

but I would just ask the NRC staff, you heard questions, concerns. After the meeting, if there's |

a possibility of talking to people. For example, we heard Kathryn, Corinne, others on, and Alice |

Hirt about the analysis of alternatives. You might want to talk to them, and I don't want to forget |

that Chester had some issues on sociological, so Dave I know you have a colleague with you. I |

don't know how much you can divide your time, but you might want to talk to them after the |

meeting. |

|

And with that, we're going to go to hear from you. And we have to start with, three |

governmental folks. And we're going to start with Mary Ann Middaugh first, and then we're |

going to go to John Tapper, and then to Nancy Ann Whaley. Mary Ann, could you come up? |

And then after we hear from those three, we're going to go to Kevin Kamps, Ken Richards, and |

Don Henkel. Yes, please. And I guess that in order for this to really be heard, you're going to |

have to -- |

|

MS. MIDDAUGH: I'm pretty good at that. |

|

MR. CAMERON: -- speak in. Good, good, thank you. |

|

MS. MIDDAUGH: Politicians always want to be heard. My name is Mary Ann Middaugh. And |

the people of southwest Michigan voted to have me represent them in the Michigan legislature |

for six years, the maximum allowed under our Constitution. I served as Chair of the House |

Energy and Technology Committee when the electric restructuring was passed. |

|
Appendix A

NUREG-1437, Supplement 27 A-168 October 2006

H-1 | During our hearings and other deliberations, it was clear that Michigan needs nuclear energy

| and Michigan needs the Palisades plant as it generates enough power for 500,000 of

| Michigan's residents. Because Michigan is a peninsula, we're limited in the amount of energy,

| we can't come across where the lakes are, limited in the amount of energy we can import from

| contiguous areas. 

|

| Our committee looked at the environmental and safety record of this plant and the record of how

| the Nuclear Management Company dealt with any problems that arose. The record is excellent

| on both counts. And we, as elected officials, were kept apprised of all activities at the plant. 

|

| I've had an opportunity to review the NRC's draft environmental report and want to commend

| you on a very thorough job you have done. Your conclusion that Palisades has not added

| anything harmful to the environment, has protected the endangered Pitcher's Thistle, monitors

| fish, water and crops monthly in the surrounding areas, and has kept reports and permits

| current with Michigan Department of Environmental Quality matches our findings.

|

| Palisades employs about 600 individuals with a payroll of about $60 million. We very much

| need the jobs that Palisades provides to this area. These employees are not only responsible

| while at work, they are also a very real asset to this area of the state. They are involved in their

| churches, schools, families and communities.

|

| Palisades is also a good corporate neighbor. They pay a great deal of taxes to area

| governments, and are very supportive of the community and work together to make this area of

| the state a good place to live and raise a family. This is evident from the numerous letters and

| resolutions of support of re-licensing of this plant from area governmental bodies. I add my

| voice of support for re-licensure of this environmentally friendly electric generating plant. Thank

| you.

|

| MR. CAMERON: Thank you very much, Mary Ann. We're going to go now to Mr. Tapper. And

| Mr. Tapper is a member of the Van Buren County Board of Commissioners. Mr. Tapper?

|

| MR. TAPPER: Thank you.

|

| MR. CAMERON: Your welcome.

|

| MR. TAPPER: I'll make a quick comment because when I first talked with you earlier on, you

| elaborated five minutes. But I understand my five minutes started about ten minutes ago. Is

| that correct?

|

| MR. CAMERON: No. I think we'll start it right now.

|
Appendix A

October 2006 A-169 NUREG-1437, Supplement 27

I-1

MR. TAPPER: Okay. Well, I'd like to tell you a little bit about myself, because I have been |

around Van Buren County all my life. I'm four 18's plus nine in age. I live in the house I was |

born in. And since '57, we've had a summer home along Lake Michigan between South Haven |

and the Palisades plant. And actually, with being around all these years, I had the opportunity |

to be in the County Board of Commissioners 30 years, well, I've served over 38 years, since '52. |

And actually, I remember when Palisades was in the thinking stage, because Consumer had us |

go down to Benton Harbor. We got on a DC-3 and flew up to Charlevoix to look at what they |

had up there prior to our resolution. And we did have a resolution way back then. Now I do |

have a resolution that we approved on March 22nd of '05, and I would really like to read it to you. |

|

Report of the Administrative Affairs Committee. I'm a Board of Commissioners. I hope |

everybody can hear me. Okay, thanks. |

|

Whereas, Palisades has been in operation since 1971, safely providing electricity to Consumer |

Energy customers for those 34 years, and; |

|

Whereas, based on Palisades' continued improved performance, particularly over the past four |

years since Nuclear Management Company has been operating Palisades, Consumers Energy |

has increased confidence in the plant's safety, reliability and predictability, and; |

|

Whereas, to that end, Consumers Energy announced last summer that it would seek a license |

renewing for Palisades. Nuclear Management Company will apply for a 20-year license renewal |

on behalf of the Consumers Energy next month with the U.S. Nuclear Regulatory Commission. |

When approved, Palisades' license will be renewed through the year 2031, and; |

|

Whereas, this means continued employment to the residents of Van Buren County who operate |

and maintain the plant, continued tax revenue from the plant that are, revenues that are shared |

by various governments, hospitals, schools, county government, government throughout the |

region. And this really is continued support for the emergency management activities and |

continued employment paychecks that bolster your local economy. |

|

Now therefore it be resolved that the Van Buren County Board of Commissioners support |

Consumers Energy in their application process. |

|

This was approved March 22nd, '05 and signed by all seven commissioners. And really our |

livelihood since this plant has been here, has certainly helped. Helped schools particularly, and |

not just the Covert region. Thank you. |

|

MR. CAMERON: Okay. Thank you Commissioner Tapper. And if you want us to attach a copy |

of the resolution to the transcript -- |

|
Appendix A

NUREG-1437, Supplement 27 A-170 October 2006

J-1

J-2

J-3

J-4

| MR. TAPPER: Sure.

|

| MR. CAMERON: -- we can do that.

|

| MR. TAPPER: Okay.

|

| MR. CAMERON: All right. Thank you very much. And now we're going to go to Nancy Ann

| Whaley who's Geneva Township Supervisor.

|

| MS. WHALEY: Hello. I'm Nancy Ann Whaley from Geneva Township. And I, like Mr. Tapper,

| live on the same land that I was born and raised on. 

|

| Geneva Township is located directly east of South Haven Township and it corners with Colbert

| Township on our southwest corner and their northeast corner. We are in the 10 mile range of

| the speaker system that gives us the alert warnings. And our western three tiers of sections are

| located in that siren system of Palisades. 

|

| I never realized until I became a board member of Geneva Township in 1987 and became

| acquainted with the operations and effects at Palisades Nuclear Plant on the structure and

| economic well being of Geneva Township, as well as the surrounding area. Palisades plant and

| people continuing support of our communities, organizations and businesses through usage,

| involvement and monetary support enhancing the overall community health and welfare.

|

| Many Palisades personnel live in Geneva Township and are tax payers which benefits Geneva

| Township, South Haven Area Emergency Services, Lake Michigan College, South Haven and

| Bangor Public Schools, Van Buren County Intermediate School District, South Haven Hospital,

| South Haven Senior Services and Van Buren County.

|

| Being a South Haven Area Emergency Services Authority Board Member, I have watched as

| Palisades has contributed much to our fire and ambulance service in the way of training,

| equipment and support. This joint effort for the safety of our citizens and Palisades' personnel

| is a tribute to working together to make our community what it is today.

|

| Over the years, we have been privileged to reports by Palisades' personnel at our Township

| board meetings, keeping us informed on happenings, new procedures, updating of siren

| warning system and just being available to answer questions that arise in our public settings.

|

| The seminars presented by Palisades' personnel to provide exposure for the local

| municipalities, businesses and industry to review the plant and safety procedures that are in

| place, as well as having contact personnel for our comments and questions is indeed beneficial. 

| Mark Savage, Palisades' employee as well as property owner in Geneva Township, is always

| available to review any concerns that arise.
Appendix A

October 2006 A-171 NUREG-1437, Supplement 27

J-5

J-6

At the April 12th 2005 board meeting, the Geneva Township Board unanimously voted to support |

the license renewal by resolution which was presented to Mark Savage at that meeting. It is my |

strong belief that the negative personal and economic impact that all of us will feel if the |

operating license for Palisades is not extended will be a loss of great magnitude to this |

community. I'm asking your full support for the 20 year renewal of the licensing for Palisades. |

|

The resolution that was passed at the Geneva Township Board on April 12th, 2005 reads: |

|

Whereas, Palisades Nuclear Plant has been in operation since December of 1971 safety |

providing, safely providing electricity to Consumers Energy customers for those 34 years, and |

based on Palisades continued improved performance, particularly over the past four years since |

Nuclear Management Company has been operating Palisades, Consumers Energy has |

increased confidence in the plant's safety, reliability and predictability, and to that end, CMS |

Energy announced last September that they would seek a license renewal for Palisades. |

|

Nuclear Management Company will apply for the 20 year license renewal on behalf of |

Consumers Energy next month with the U.S. Nuclear Regulatory Commission. When approved, |

Palisades license will be renewed through the year 2031, and this means that the residents of |

Geneva Township and surrounding areas are receiving continued employment for those who |

operate and maintain the plant, continued tax revenues from the plant that are shared by the |

various governments, hospitals and schools throughout the region, continued support for energy |

management activities, and continued employee paychecks that bolster local economies, and to |

date, the NRC has approved 30 license renewals for generating stations and is reviewing |

applications for 10 others, and there are 103 operating nuclear plants in the United States that |

generate approximately 20 percent of the nations' electricity. |

|

Therefore, be it resolved that the Geneva Township Board of Trustees supports Palisades' |

efforts in the application for a 20 year renewal of the operating license and their efforts to |

continue the enhancement of economic conditions in our area. This resolution was presented |

and supported by all Geneva Township board members. Thank you. |

|

MR. CAMERON: Thank you very much, Nancy Ann. I realize that a lot of you that took the time |

to do a prepared written statement for us, and we really appreciate that. We are going to try to |

move through this so that we get to everybody, so if you are going to be longer than five to |

seven minutes, if you could just try to summarize and we will put the prepared statement on the |

record too. And that's not directed at you Nancy. You were right on time. But I just wanted to |

say that. |

|

And now we're going to Kevin Kamps from Nuclear Information Resource Service. And Kevin, |

you have a long history here so, please tell us about that too. |

|
Appendix A

NUREG-1437, Supplement 27 A-172 October 2006

A-3

A-4

A-5

A-6

A-7

| MR. KAMPS: My name is Kevin Kamps, and I work for Nuclear Information and Resource

| Service in Washington, D.C. But I'm from Kalamazoo, Michigan and I'm still a board member of

| Don't Waste Michigan representing the Kalamazoo chapter.

|

| How many of you here heard about the near drop of the fully loaded dry cask at Palisades last

| October? I have a question for folks at NRC. When we were having the hearing in early

| November in this, down the block here, how come that wasn't brought to our attention? I mean,

| our, if we have any credibility left in the NRC and in the company, if we had any trust left in the

| company and in this government agency that's supposed to protect our health and well being

| and our environment and our safety, it's gone. It's absolutely gone. And NRC's response in the

| press is, it was not a reportable incident.

|

| The potential consequences, according to NRC's own documents of that incident, if the cask

| had dropped into the pool and damaged the pool and drained away the water, there could have

| been a radioactive inferno in the waste. And thousands to tens of thousands of people could

| have died downwind. Those are NRC's own numbers. I'm not making this stuff up. So it just is

| a real betrayal of the public to have on our part, to have taken part in good faith and at that very

| moment be kept in the dark about something as significant as that. So the outrage we'll try to

| control to an extent, but it's, it's deep burning at this point in the local community.

|

| What I'd like to address in regards to this proceeding today is radioactive waste, speak of the

| devil, and reactor accidents. The NRC says in its Nuclear Waste Confidence decision that a

| repository for commercial irradiated fuel will open by 2025. 

|

| And it's appropriate to bring this up because the Bush Administration yesterday introduced a bill

| to get rid of any remaining impediments to opening Yucca Mountain. That means public health

| protections and safety regulations, that kind of thing. Just get rid of those. But the problem is

| that Yucca's in complete disarray. The last date DOE gave for its opening is 2012. They won't

| give dates anymore. They won't give cost estimates any more. It used to be $60 billion, but

| they won't give that kind of prediction.

|

| So the state of Nevada's challenging this NRC Waste Confidence decision in Federal court. So

| how NRC can dismiss this issue at Palisades is just really beyond me, especially given the irony

| that Palisades license is up in 2011, and that's the very year that Yucca will be full. Will have

| reached its legal limit long before it opens because there will be that much commercial waste in

| the country, 63,000 tons of it. Quite a bit of that at Palisades, its fair share.

|

| So from 2011 to 2031 all waste made at Palisades would be excess to Yucca's capacity. So it

| would continue to sit at Palisades with nowhere to go, unless a second repository's opened, this

| time in the east. So would that be in Michigan or Wisconsin perhaps? So it needs to be pointed

| out that Palisades' current dry cask storage pads are in violation of NRC regulations. We raised

| this during the NRC licensing proceeding on this extension and were rejected. But our expert
Appendix A

October 2006 A-173 NUREG-1437, Supplement 27

A-8

A-9

A-10

A-11

witness on this matter is none other than Dr. Ross Landsman from NRC region three, whose job |

it was to inspect those pads and the casks on them. And he warned NRC since 1993 that the |

cask close to the lake, the pad close to the lake is in violation of safety regulations, specifically |

earthquake regulations. If there's an earthquake, the -- could open up, the lake could pour in, |

and one of those casks or more than one, could end up in the lake under water. And what |

could that mean? If water infiltrates the cask there's enough fissile material inside to sustain a |

nuclear chain reaction. So we could have a nuclear reaction in Lake Michigan. |

|

In another scenario, the sand could open up in an earthquake and casks could be buried under |

the sand. Overheating could occur. The cask could be damaged. Radioactivity could escape. |

And it would be a matter of time before it hit the lake. NRC now says in another Orwellian twist |

that Dr. Landsman's allegations against the newer pad built in 2004, also that it violates |

earthquake regulations are under review. Those allegations are under review. They have been |

for years. The incredible thing is that while under review, the storage pad is used for storing |

waste. More and more waste as time goes on. The cask dangle that happened last October, |

was a part of that campaign to move dry casks to that newer pad, seven of them. |

|

So we've got two pads at Palisades, both in violation of NRC's safety regulations, and just |

yesterday we filed an emergency petition to the NRC to enforce its own regulations and stop |

storing waste on those pads. So the question is, where is Palisades going to store 20 more |

years worth of waste? |

|

In terms of reactor accidents, again I will point to NRC's own numbers. They haven't updated |

these since 1982, so of course the number of people has grown in this region, the economy has |

grown in this region, so these damages from a severe accident at Palisades would be much |

worse now than what's given. But NRC calculated that a severe accident and catastrophic |

radiation release, and this was a 1982 report, a radiation release from Palisades would kill |

11,000 people downwind, injure 7,000 people, and do over $50 billion in damages. That's 1982 |

figures, so if you adjust for inflation, it's over $100 billion now. And of course, if there's a major |

radiation release from Palisades, that's it for Michigan's tourism, that's it for its agriculture, and |

that's the reason that our volunteer pro bono citizen's effort to try to stop this 20 year extension |

has been so determined and will continue to be so at every turn, because we care a lot about |

the future of this state. |

|

AUDIENCE MEMBER: And our homes and our families. |

|

MR. KAMPS: Amen. And I'd like to raise a point. In the back of the room, there's a summary of |

the findings of this EIS and one of them referred to, it's a contradiction with NRC's own report. It |

said historic and archaeological impacts would be small, but right in the beginning of this report |

it says that they may be small, but could be moderate for historic and archaeologic resources. |

|
Appendix A

NUREG-1437, Supplement 27 A-174 October 2006

A-12

A-13

| And when you read the details in here, NRC actually verifies exactly what we raised last July

28th | at this very podium and again during the licensing proceeding, but we got thrown out of

| that, that Native American sites very well could exist, very likely do exist, NRC is now saying

| that, at Palisades, but no site survey is going to be required. They can do 20 more years worth

| of routine radiation releases. If forced to build new dry cask pads that comply with safety

| regulations, that could be built right on top of a Native American archaeological site, burial

| grounds, village sites. It's not exactly far fetched when NRC admits that there are 15 such sites

| within a mile of Palisades or its transmission lines, including one 0.3 miles away, which I believe

| is the Brandywine in Palisades Park, exactly what we pointed out here.

|

| So my question is, how in the world did we get booted out of the NRC licensing proceeding on

| that one? But --

|

| MR. CAMERON: Kevin, can I ask you to --

|

| MR. KAMPS: Yes.

|

| MR. CAMERON: -- give a summary of this? Thank you.

|

| MR. KAMPS: Yeah. Instead of five or seven minutes, of course, I could go on for five or seven

| days about this stuff. But I'm glad that there's a good turnout today and I look forward to

| hearing other concerned local citizens. 

|

| And the last thing I'll say is NRC said that, you know, this license renewal may be granted but

| there are other factors out there that may end up, you know, deciding whether or not this place

| will operate for 20 more years. I'd like to say, yeah, there really is. One would be a severe

| accident at Palisades that would kind of take care of it right away for all of us. 

|

| But another thing is, this coalition of ours, which is 25 group strong including Michigan

| Environmental Council, the biggest coalition of environmental groups in the state, 75 of them,

| 200,000 Michigan residents. The coalition's still growing, and we plan on fighting this at every

| turn and that's the factor that's going to stop this from happening. Thank you.

|

| MR. CAMERON: Okay, thank you. Thank you Kevin. Ken, could we have you come up and

| talk to us?

|

| MR. RICHARD: Hello. My name is Ken Richards, and I've been a resident of South Haven my

| whole life. 

|

| AUDIENCE MEMBER: We can't hear you.

|

| AUDIENCE MEMBER: Use the mike.
Appendix A

October 2006 A-175 NUREG-1437, Supplement 27

B-1

B-2

B-3

MR. RICHARD: My name is Kenneth Richards, and I've been a citizen here in South Haven |

pretty much my whole life. And back when Palisades first went into dry cask storage in the |

early '90's, we formed a group called Palisades Conversion Group because, basically what |

they're doing out there is they're boiling water to make electricity and as Ralph Nader said, |

there's a lot of ways to boil water and make electricity. |

|

So, having worked in two occupations within the nuclear field, laborer for J.A. Jones |

Construction Company in '71, '72 on the Donald C. Cook Nuclear Power Plant, then at the |

Palisades Nuclear Power Plant, Decon-Tech for Essential Services Company -- |

|

AUDIENCE MEMBER: Louder. |

|

AUDIENCE MEMBER: We can't hear you. |

|

MR. RICHARD: -- during a refueling outage in the '90's, I have seen construction of and then |

finished plants during tours. The plants then new and impressive, then again many years later |

aging, much obsolete, often highly contaminated equipment, malfunctioning devices such as the |

reactor containment hatch door inoperable for some time while I was de-conning when |

Consumers Energy operated the plant. |

|

Things get old, dilapidated with time especially when they are neglected. I'm sorry, my glasses, |

I have to back off to read here. Things get old, dilapidated with time, especially when they are |

neglected, worn out, under the influence of radiation, outdated or used up such as the Palisades |

plant's fuel pool, now double racked. Steam generators replaced highly contaminated previous |

units within their own mortuary on the plant site. Along with approximately 30 V.S.C. 24 and 34 |

dry storage casks in use for above ground spent fuel assembly storage, also on site. |

|

A cut rate move Consumers Energy Company took when their fuel pool was filled to maximum |

capacity. Well passed its original design capacity threatening a shut down of the plant. |

Breaking another promise made when the plant was first built, that no highly contaminated |

radioactive materials would be on the plant site outside of its high level containment structure. |

For purposes other than refueling and eventual removal of spent fuel assemblies to a national |

depository. |

|

After 38 years of operation, Palisades Nuclear Power Plant and its reservation is showing its |

age and effects of embrittlement. Its pressure reactor vessel being protected with old, many |

cycled fuel assemblies, a case in point. Years now, no vessel replacement or further shielding |

in sight. Or 2007 says the NRC, 2011 say others. 2014 say Palisades' lawyers. This should |

have been replaced ten years ago. As P.R. spokesman Mark Savage told the local press back |

in 1993 when the problem surfaced during an interview with the South Haven Daily Tribune. |
Appendix A

NUREG-1437, Supplement 27 A-176 October 2006

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B-5

B-6

B-7

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B-9

| Once they finally got to admit, there was a metal condition called embrittlement affecting the

| reactor.

|

| One of the biggest complaints from plant critics is the operators have been less than

| forthcoming when problems surface. Make excuses, rosy predictions they know will never

| come to pass. Or lie to anyone listening when the information might or will be perceived as

| contentious, placing public trust in jeopardy.

|

| Much of the same thing can be said of the NRC during these current rounds of scoping

| meetings concerning the re-licensing endeavor. Long time followers of this issue have seen or

| heard it all from a very different NRC under past presidential administrations. The difference

| between now and say, the early 90's, cannot be denied. This is a very business friendly NRC,

| not public or environmentally friendly.

|

| Yesterday I received my copy of the Generic Environmental Impact Statement for License

| Renewal of Nuclear Plants Supplement 27 regarding the Palisades Nuclear Power Plant. 

| Reading through both the manual and its cover letters, I see, despite the potential radioactive

| hazards, the NRC insists the environmental impacts of the Palisades Nuclear Power Plant and

| the radioactive materials about its reservation is always regarded as small throughout this

| report. But when I turn to the alternative energy sources, which should be pursued at the

| Palisades Plant site, their impacts are often referred to as large. Which all considering, they

| would be, taking into account the enormity of the electrical power the plant puts on the grid, for

| alternatives to equal out in their current forms at this site.

|

| A rather particular assumption bracketing both the plant and the NRC's positions well, yet

| ignoring the simple fact that if all the resources used to continue operation of this plant were put

| into renewables and other forms of electrical generation throughout the state, it would turn the

| argument on its head.

|

| What my real concern here is the fact that the GEIS report does not take into consideration of

| dry cask storage or other highly radioactive contaminated things such as the former steam

| generators on site. Many would argue the Palisades reservation is already a defacto high level

| nuclear waste dump. Which to their, our Palisades Conversion Group and my viewing of this

| issue, a large impact on this fragile lake shore environment. More to the point, potential impact

| should things not go as planned or designed or promised, which over the last 38 years, time

| and time again have been broken.

|

| With an additional 20 years worth of above ground dry cask storage, along with other

| contaminated equipment, which is sure to be replaced should this plant be pushed so far past

| its original design capacity, which it already has by years now. Counter to the GEIS's insistence

| that no changes to the plant need to take place in the additional 20 years.

|
Appendix A

October 2006 A-177 NUREG-1437, Supplement 27

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B-11

Isn't the reactor head soon to be replaced? In July perhaps? The pressure reactor vessel long |

in question operated in such a patchwork method since embrittlement was discovered more |

than ten years ago. How long before it's replaced? Annealiated as once promised in court or a |

neutron thermal shield installed? Or the reactor replaced? |

|

And yes, dry cask storage casks piling up on site. I'm sure we'll all hear about Yucca Mountain |

or the Goshutes, Skull Valley Indian Reservation taking all of this off our hands for the |

umpteenth time in the last 20 years. There are now over 20 to 30 dry casks on site. Will |

anyone here give us an exact number? Or are you going to just dodge the question again, |

insisting it's a Federal issue, none of this re-licensing businesses concern. |

|

This is a local community concern for we will have to live with and care take all of this waste for |

generations to come. In '93 we were told these experimental, cut-rate dry storage casks would |

be gone in '98, time and time again by Mark Savage, the plant spokesman. |

|

Now we're told by the NRC, they're licensed to store -- |

|

MR. CAMERON: Ken, I'm going to have to, I'm going to have to ask you to summarize. I'm |

sorry, Ken, we can attach your full statement to the record. |

|

AUDIENCE MEMBER: Go on for years. |

|

MR. RICHARD: Well, you know, you literally could go on for years because this thing has and it |

keeps piling up a good record for anybody that really takes a look at it. |

|

MR. CAMERON: Okay. Thank you. Thank you very much. Is Mr. Henkel, is it -- |

|

MR. RICHARD: Do I hand these to him? |

|

MR. CAMERON: Yes. Why don't you do that and we'll make sure that we get a copy of them |

as a formal comment for our purposes. But they will be attached to the transcript. So Mr. |

Henkel, do you want to still talk to us? |

|

MR. HENKEL: My name is Don Henkel. I've had a cottage at Palisades Park Country Club for |

about 40 years. We're probably about the closest of anybody to the nuclear power plant. |

Before 9/11 I had many opportunities to walk in front of the power plant, to enjoy the beach |

area, et cetera. Our park is 100 years old so, both our cottage and myself and the park have |

preceded the nuclear power plant by a long period of time. |

|
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NUREG-1437, Supplement 27 A-178 October 2006

E-1

E-2

| I am convinced that the way of producing electrical power in this country needs a great deal of

| attention. There's no doubt in my mind that coal burning and so on adds a great deal of

| pollutants that nuclear energy does not incur. But that's as long as the genie is in the bottle. 

|

| And for many years now I've heard on Saturday morning the sirens go off and this rather

| metered voice, terrible voice comes over, this is a test, this is only a test. And then at the end of

| that there's a cow-lunk, like somebody's dropped a hammer or something like that on the floor. 

| And I don't think too much about it because I've experienced this for many, many years. But

| upon occasion I think, well, what if it were not a test. And that's of course when the genie

| comes out of the bottle. 

|

| One time I was sitting on the deck of my cottage, which is right on the shores of Lake Michigan,

| a stone's throw from the, from the plant and of course, this was after 9/11 and a no-fly zone was

| instituted. And all of a sudden a Japanese zero comes zooming down the lake shore there

| about 50 feet over the water. It of course flew right over the plant on its way up to an old plane

| show someplace up north along Michigan. 

|

| And I thought to myself well, how easy it would be for somebody, a plane to come on, and you

| know, I was really surprised that the accident report didn't include sabotage and other things

| along that line. So that's, that's kind of a problem. I'm a boater, and I boat past the plant many

| times from South Haven down to Palisades Park where the cottage is. And now it's not a no fly

| zone, but a no boat zone. The parameters of the property are 3/4's of a mile. And I looked at

| my boat and I said, boy, those casks are so easy. They're right,, right over there. So I think that

| somehow or another we need to entrust the issues of, of license renewal for just 20 years

| because we're really looking, according to what I read, 10,000 years down the pike. 

|

| And sooner or later human beings probably are going to make some errors. And with a gas-

| fired plant, right across the road you can -- facilities, as the Palisades Nuclear Power Plant that I

| kind of wondered, why in the world don't we go to a plant already on line there, already ready to

| deliver, as opposed to the aging Palisades Nuclear Power Plant. Thank you very much.

|

| MR. CAMERON: Okay. Thank you Mr. Henkel. I'll, I am going to ask Viktoria Mitlyng who is

| one of our Public Affairs Officers from Region three to just summarize what the NRC's stance is,

| I guess, on the crane drop. And do you want to talk to us for a little bit up there Viktoria?

|

| MS. MITLYNG: Good afternoon everyone. Can you hear me? Yes? My name is Viktoria

| Mitlyng, and I'm Public Affairs Officer for the NRC. From my accent you could probably tell I'm

| not a native to this country. Originally, I'm from Kiev which is about 40 miles from Chernobyl. 

|

| One of the reasons that I work for Nuclear Regulatory Commission is because I can stand here

| and tell you what happened. In my former country, I couldn't do that. So when Kevin was
Appendix A

October 2006 A-179 NUREG-1437, Supplement 27

talking about the NRC losing credibility because the public wasn't informed about the crane |

incident, it got me a little riled. My job is not to get riled, but I was. |

|

The inspection reports that include information about all the findings at the plant are publicly |

available. There was so much information in our inspection reports produced by Resident |

Inspectors, by Specialists, that it is impossible at a meeting to come for us and give you a |

summary of what happened. It's not an expectation we can meet. Other we literally would |

spend our time sitting here and telling you, telling you what happened, or our Resident |

Inspectors instead of inspecting the plant. That's not possible. |

|

So I'm hoping that if you're interested in what's going on at the plant, you can take a look at the |

reports that are publicly available. You can call me anytime and I will let you know what is going |

on and any information that you want provided about what the NRC is doing. |

|

Now about the cask. I'm not going take long. I'm just going to say that the cask was secured in |

place. It was not an issue of the cask being about to get dropped. It was a procedural error. |

And that's why the NRC wrote it up, is because the operators were not supposed to manipulate |

the grade according to their own procedures, and they didn't. I have a picture of the cask if |

anybody's interested in taking a look at it. And it is not about to drop, to drop and cause a |

nuclear disaster. |

|

So the very real issues that people are bringing up here that we want to hear about, however, |

there are certain things that I really wanted to respond to and one of them is public confidence |

and openness. The information is out there. And our job is to protect public health and safety, |

and we take it very seriously. I take it seriously for personal reasons, because, you know, half |

of my family is gone from leukemia, cancer, et cetera. So I would not stand here and tell you |

anything that's not true because it would be like, you know, shooting myself. There would be no |

reason for me to be in this country. And people I work with I trust. So that's what I wanted to |

say. If you want to talk to me further or you want to hear Russian jokes, come and talk to me |

after the meeting. |

|

MR. CAMERON: Okay. I don't want to get to, I don't want to get into a long running discussion |

because we have to hear from, from people on this. Okay? We heard Kevin's viewpoint. We |

heard from the NRC, which I thought was important on this recent event to hear that. |

|

MR. KAMPS: I just got a quote from the very document that Viktoria encouraged me to read. |

|

MR. CAMERON: Okay. |

|

MR. KAMPS: That -- from the NRC. It took several months to get, but I've got it right here. I'd |

love to read from it. |
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NUREG-1437, Supplement 27 A-180 October 2006

A-14

| MR. CAMERON: Well, let's go through the rest of these people, Kevin, and hear from them. 

| And Kevin is here with a report from the NRC. If people want --

|

| MR. KAMPS: Yeah, I'll just read it real quick. It'll take me 10 seconds. This is an NRC

| inspection report that Viktoria encouraged me to read.

|

| MR. CAMERON: Kevin, if you, and this, again, is something that is, you know, we don't know

| what the context is. If you have 10 seconds, let's go 10 seconds from this. I just want to keep --

|

| MR. KAMPS: What is the context? The context is the very incident she just described.

|

| MR. CAMERON: Go ahead.

|

| MR. KAMPS: The NRC Quarterly Inspection Report.

|

| MR. CAMERON: Okay.

|

| MR. KAMPS: Coming out many months after the incident occurred, so we're just supposed to

| wait I guess. If we wait long enough, that's okay.

|

| MR. CAMERON: Okay. Kevin, go ahead.

|

| MR. KAMPS: Well, got this through 4F everybody. This is the NRC inspectors writing. 

| Therefore, the on scene inspectors concluded that working outside the bounds of the approved

| work package and manipulating the brake release on the crane represented an increase in the

| risk of a load drop, the load being the fully loaded cask on the crane. This increase in risk is

| directly associated with the reactor safety cornerstone objective of the spent fuel cooling system

| as a radiological barrier. What does that mean? The pool water could have drained away. 

| What happens then? The waste catches on fire. What happens then?

|

| MR. CAMERON: Kevin, Kevin, you read, you read from that. Okay? And I don't, you know,

| obviously it is an important issue. The report, you guys can do this later, okay? The report is

| there for people to read, and Kevin read from one part of it. Viktoria gave a summary of it,

| okay? And John who's our resident, I don't know if there's a bottom line you want to add to this,

| but I just want to conclude it.

|

| MR. ELLEGOOD: Yeah, I'd like to conclude this, and we can talk afterwards. We wrote that

| because you cannot up and manipulate equipment without the proper procedures in place,

| without the right management oversight understanding what you're doing, without

| understanding the consequences of what you're doing. In this case, the worker went up there. 

| Prior to going up there he had been briefed. It had been discussed. I have been in the

| meetings that they would not manipulate any components on the crane. It was to be an
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October 2006 A-181 NUREG-1437, Supplement 27

D-3

inspection of the crane to understand exactly why the brake engaged, understand if there was |

any damage at all done to the crane, and understand what they needed to do to proceed to |

lower the load safely. |

|

The individual up there in communication with an off site vendor decided to manipulate |

components of the crane and he simply should not have. It's very tough to quantify the change |

in risk when you've got an individual going up there. I have no idea how far he might have |

gone, how much he might have slipped. I judge that was an increase in risk. However, at all |

times there were two brakes fully engaged on that crane. Either one of those could support the |

full load. Looking through the documentation as to brake failures in cranes, it's about one every |

10,000 events for a single brake, probably more than that. Therefore, with two brakes you've |

figured out is about one to the minus eight. With the guy manipulating it, there's an increase in |

risk. I don't know exactly how much. Maybe a couple of words of magnitude. One in a million |

chance. We took it seriously. We wrote a non-cited violation, and we remained observant of |

the licensee's activities in repairing cranes, maintaining cranes, and in crane operations. |

|

MR. CAMERON: Okay. Thank you very much John, at the plant. And we're going to go back |

to license renewal now, and we know that there's concerns about these issues so it's important |

to discuss them. We're going to go to Mr. Dal Monte right now, and then to Mr. Mitchell, and |

then to Michael Martin. Mr. Dal Monte, do you want to come up? All right. |

|

MR. DAL MONTE: Good afternoon. I am a resident of the South Haven area. I, we select this |

area for the end of our life. So I retired. I was working in Chicago, and then I came here. And |

now I have a little time to go overseas. My profession is an Electrical Engineer. I am from |

Illinois, and today we covered some of my concerns regarding the operating license renewal of |

Palisades Nuclear Power Plant. |

|

My first concern, and more important I think, is in relation to the spent fuel. Everybody know |

that right now the spent fuel is stored outside, next to the power plant. So this keeps |

accumulating and there is a possibility of, theoretically send it to a central, national central |

depository. But it was impossible in 40 years to obtain or to realize this central depository. And |

the reason for that is not political. It's not because people are not doing their work. It's just |

because they, they waste half their -- long, long time, I mean. You have to keep it under |

control, under storage for at least 10,000 years. So nobody can guarantee that even the more |

stable place can guarantee that. So this is, if we continue doing that we are going to keep this |

material in that place forever. That's what we have to understand. I mean, this is a fact. |

|

What, what, why we are scared? Because we are increasing the possibilities of an uncontrolled |

releases of radioactive material. The plant has a bigger accident and can have uncontrolled |

releases, but this other thing we're allowing here can also prove to have accidents by sabotage, |
Appendix A

NUREG-1437, Supplement 27 A-182 October 2006

D-4

D-5

D-6

| by error, human error, by many things that, one important thing in life is imagination. So with a

| little bit of imagination, we, we can figure out that this is not way to go. It is not the way to go. 

|

| Consequently, so I will leave this point for the time being and I continue that in this situation my

| recommendation is that, I request that no approval of operating license renewal be given unless

| all existing spent fuel is removed from the site and sent to a national central depository.

|

| My second concern is regarding the equipment refurbishing, refurbishing of our equipment. I

| have low opinions. A plant with 40 years is ready for a good refurbishing. You can tell that, you

| have done a wonderful job, but I don't believe it. And your report, the NRC is saying that they

| considered, I don't know, I don't think, this is requested by the licensee, but the NRC I don't

| know really, what he's, he's going to do, but it doesn't look like he's going to request --

|

| MR. CAMERON: Mr. Dal Monte, you've raised two very important points, but I have to ask you

| to summarize now. Do you have another important point to tell us?

|

| MR. DAL MONTE: Yeah. 

|

| MR. CAMERON: And if you could just state that and then we'll have to go on --

|

| MR. DAL MONTE: Sure.

|

| MR. CAMERON: -- to the next person. Thank you.

|

| MR. DAL MONTE: Okay. And my second concern is related a little with the first. The analogy

| that is used at Palisade has been following -- first. Through the use of a large amount of spent

| fuel waste, which is highly radioactive and this toxicity for a long time, 10,000 years. 

|

| Second, the waste contains plutonium which if enriched could be used in the manufacture of

| atomic bombs. Third, it is a low efficient use of the fuel, uranium. If continuing with this old

| technology, the amount of the available uranium in nature could be exhausted in a short time.

|

| The Nuclear Power Industry is in the process of producing a new generation of reactors. 

| General Electric Company, Western Electric Company, Westinghouse Electric Company are

| doing that using full fuel recycling. These reactors that could be approved by 2015 will not have

| the above mentioned drawbacks of the old reactor technology.

|

| The spent fuel, the spent fuel in this reactors would be reduced in amount and would require

| shorter time in storage, 400 years. Therefore a Central depository could be readily found. It

| would use the energy content in the fuel much more efficiently. The uranium available in nature

| could last for many centuries. The plutonium in the waste is not usable for manufacture of

| weapons.
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October 2006 A-183 NUREG-1437, Supplement 27

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K-1

K-2

K-3

K-4

MR. CAMERON: Thank you. Mr. Dal Monte, I'm going to have to ask you to -- |

|

MR. DAL MONTE: But, I, I would just to say in regard to this concern, I recommend that any |

approval of operating license renewal of existing nuclear plants be in moratorium until the year |

2015. Thank you for your, for your time. |

|

MR. CAMERON: Thank you Mr. Dal Monte. Thank you very much. Do we have a Mr. |

Mitchell? Lewis Mitchell? Mr. Mitchell, oops, are you okay? All right. This is Mr. Lewis |

Mitchell. |

|

MR. MITCHELL: Thank you. |

|

MR. CAMERON: Your welcome. |

|

MR. MITCHELL: My name is Lewis Mitchell. I'm a native of South Haven. We were gone for |

about 30 years and moved back. I'm retired from this, weekly newspaper publisher. We sold |

our paper in Illinois and moved back home and found a place out by Bangor, which is directly |

east of Palisade plant. |

|

I knew about the plant when we bought the place. I wasn't concerned a bit about the plant |

being there, and I'm still not concerned about it. I believe that nuclear power is one of the best |

answers we've got to getting power in this country. With all of these other things that have been |

named, they either don't work fully or they're more expensive and they're harder on the |

environment. I personally am in favor of the nuclear power. And by the way, I'm also one that |

says thank god for the atomic bomb, because I was in the 77th infantry division and I saw the |

coast of Japan that we were supposed to hit. And the reason, one of the reasons I'm here |

today is because they dropped that bomb. And I'm not the least bit ashamed to say so. |

|

Heard a lot of ifs today. If this, if that, if the other thing, and having been in the newspaper |

business, I'm a little more inclined to rely on some facts. Not if this happens or if that happens. |

I've never been in the plant. I've heard people talk about the condition of it. I've never been out |

there, so I do not know anything about the condition of that plant, whether it's good, bad, brittle |

or whatever. I'll leave that up to the people that know, the people that are experts. I think the |

NRC has a whole staff of experts and I'd rather trust them than somebody that's not on the site |

making inspections and so forth. |

|

Talk about this crane hanging up. I've been around machinery enough to know that there's |

things like that do happen, and that things can be secured and there's no danger from them. |

|

And this, heard a lot about alternate forms of generating electricity. And I've read quite a bit |

about it and nothing I have read has convinced me there is a better way. I'm local, sometimes a |
Appendix A

NUREG-1437, Supplement 27 A-184 October 2006

K-5

L-1

| lot of these people from far away come in and tell us how we're supposed to do things. I don't

| particularly appreciate that either. In my opinion, Palisades is safe and I want to see that

| license renewed.

|

| MR. CAMERON: Okay. Thank you very much Mr. Mitchell. Thank you. We're going to go to

| Mr. Martin, and then Mr. Norm Knight and Mr. Milan. Mr. Martin?

|

| MR. MARTIN: Mark Savage if he was still here can well attest that I've been a gadfly at

| Palisades for 20 years now. And, thank you, I don't plan to be for another 20. It astounds me

| that this proceeding can go on like a runaway train in light of the fact that the industry has been

| allowed to run for 50 years with no high level waste facility, guaranteed or otherwise. Different

| things about Yucca Mountain are interesting in that they have gone on and approved almost

| everything that the opponents have suggested, seismic, water leaking into the -- underneath it,

| and other things. And then most recently, we hear that the original loading of it, if it were carried

| out would cause overheating and make --, if they were to use it, to have that capacity. And if it

| had opened 10 years ago when it was supposed to, that capacity wouldn't have taken care of

| what waste we had at that point anyway. So now it's, maybe a quarter of what we have, if they

| were to use it. And if they don't use it and the Indian Reservation is brought up as an

| alternative, it's, it will be interesting to see how the EIS has arranged for that. Maybe there's an

| -- under it like the Mississippi River for all we know. That sure would be a mess. 

|

| And the next part of what I have to say, it's interesting when you go west on the old Route 66

| area, we see all the old barns painted with the taverns, and Missouri taverns and Arkansas, and

| so forth. And it seems back in the early 70's, Oklahoma Power Company decided they were

| going nuclear. And when they did this, there was a local woman a few miles away who decided

| that this would not happen and she decided to intervene. She mortgaged her farm, sold her

| nursing home, and we had quite an interesting intervention on that. 

|

| And at the time I worked for a newsman who had been a part of the Manhattan project and went

| around the country with a brief case locked to his wrist. Had a lot of secrets in it, I imagine. 

| And after that he became an oil well person, drilled a lot of wells. And at the time I was working

| with him during the intervention and on his newspaper, he candidly admitted to me that he had

| drilled a well on the side of this Black Fox Nuclear Plant that they wanted to install just east of

| Tulsa. And when he drilled this well, it went so far until all of a sudden they were drilling into

| nothing. And they kept adding more divisions to the well, and it still struck nothing. And finally,

| they just hooked the drill point to a cable and they never did find bottom there. That was where

| the August nuclear industry was going to put its nuclear plant. 

|

| And you've heard of these places where the ground gives away in Florida and stuff. Here's one

| that could have taken the whole nuclear plant. And as it finally turned out the plant was turned

| down. They didn't really need that power to begin with. And it's kind of a situation where we're

| talking about that if we conserved a little bit, we could do without Palisades as well. Thank you.
Appendix A

October 2006 A-185 NUREG-1437, Supplement 27

M-1

MR. CAMERON: Okay. Thank you Mr. Martin. Is Mr. Knight here? Yes, Mr. Knight. |

|

MR. KNIGHT: Thank you. |

|

MR. CAMERON: You're welcome. |

|

MR. KNIGHT: I am Norm Knight. I'm from Kalamazoo, Michigan. I've probably been involved |

with nuclear power more than anybody else in this room. I was involved with the first, dropping |

the first bomb on Okinawa, not on Okinawa, but from Okinawa to Hiroshima, and three days |

later on the second one over in Nagasaki. So that I knew these pilots, Mr. Tibbets and Mr. |

Sweeney on a personal basis and was involved with that for some time. |

|

However, I was released from the Marine Corps and was involved with the studying about |

nuclear power about that time, and took my training at Edgewood Arsenal in Maryland under a |

fellow by the name of -- Joe Stillwell, the general from the far east. Since that time I've been |

involved with pharmaceuticals. I was an Upjohn person. I'm a chemist involved with chemistry. |

And I can remember one of our -- tests for sodium was to go ahead and mix it with uranium |

oxide. And then you wait to sodium urinate. Well, that was okay, fine. |

|

But I've been a proponent, and I'd like to thank Mr. Mark Savage for the wonderful job that he's |

done over there at Palisades. And in the winter time, I also winter out in Arizona. At that point |

I'm about 20 miles from the Palo Verde Nuclear Power Plant, which is the largest one in the |

country. It supplies most of the electricity for Phoenix. I have some pictures which I forwarded |

to Mark Savage, and have some of them here, which involves replacement of the steam |

generators. These came up, these were too large to come through the Panama Canal, so they |

shipped them around South America and up through Mexico, and from there they were |

transported by fazoli trains up to the Palo Verde Nuclear Power Plant. And I still think nuclear |

power is the way to go. I think today, approximately 70 percent of the power that's distributed in |

France is by nuclear power. Why we can't go ahead and listen to these people even if we can't |

speak French. But, I would like to thank everybody here. I enjoyed your program very much. |

And I'm a proponent of nuclear power, still. Thank you. |

|

MR. CAMERON: Okay. Thank you Mr. Knight. Mr. Milan? Corinne? Can you just point that at |

you? |

|

MS. CAREY: Great. We'll do that. In fact, while the other people involved in my presentation |

come |

up -- |

|

AUDIENCE MEMBER: Can't hear you. |

|
Appendix A

NUREG-1437, Supplement 27 A-186 October 2006

F-3

| MS. CAREY: Oh, well, I, just a minute.

|

| MR. CAMERON: And Corinne, it's fine to do a little theater, but we do need to watch the time.

|

| MS. CAREY: Yeah. Oh, yes. We will. Yes.

|

| MR. CAMERON: All right.

|

| MS. CAREY: If the other people involved in my presentation will come up please. The Raging

| Grannies? And we've invited a few grandpa's in the meantime also.

|

| MR. CAMERON: All right.

|

| MS. CAREY: Yeah.

|

| MR. CAMERON: Here we go.

|

| MS. CAREY: All right. Okay. Now, we do want to say that one of the important points, and the

| word I haven't heard, is sustainable. We have not talked sustainable power and energy. And in

the 21st | century and beyond, we need sustainable power, not the fossil fuel which nuclear is

| also. There's a limit to uranium involved, so it's about time that we began to think for our great

| great grandchildren. And we have, anybody else? This little guy's going to help us here. This

| is an adaptation of the Raging Grannies presentations that they have given all across the

| country in various ways.

|

| Oh, give me a home, where the rivers don't foam, and the squirrels and the chipmunks can play. 

| Where lakes all have fish, you can put on your dish, and the skies are not smoggy and gray. 

| Home, home, on the earth, you're beauty's beginning to fade. We've got to act fast, our -- won't

| last, our home you just can't throw away. 

|

| There's nuclear waste, are inclined to escape, and into the ground they are dumped. We don't

| want PCB's, in the birds and the bees, and dioxins on our babies rumps.

|

| Oh, give me a home, safe inside the ozone, there is danger in those cosmic rays. Oceans up to

| our necks, from the greenhouse effect, please don't wash all this beauty away.

|

| And I know that's a silly, superfluous approach. Thank you. I do want to encourage people to

| find out that radioactive releases from nuclear power plants in the Great Lakes basin, what are

| the dangers. There are copies of this at that table, and other things. If there's more than one,

| you are free to take it.

|
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October 2006 A-187 NUREG-1437, Supplement 27

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C-6

On this table are some other things also. In fact, this gives you quite an interesting map. Some |

other things, including those thick books, like the one I got from Bruce. Now Bruce is the |

nuclear facility, I've heard it's the world's biggest. They have, is it nine or 11, reactors in their |

complex, 50 miles from Michigan. Right across from the thumb on the little pinky finger that |

sticks out of Canada there. And that is their Yucca Mountain in progress. |

|

Luckily, the wind doesn't very often blow to, on us from the east, so we usually don't concern |

ourselves with the fact that there, we could be downwind from that. We are downwind. I'm from |

Grand Rapids, and we are downwind from Palisades obviously. 50 miles was the intervener |

zone. It goes through Jennison, so I wasn't able to be one of the interveners. I'm another 10 |

miles in, but that's not far enough if a dangle drops, or any of the kinds of things that can |

happen in a Chernobyl situation. I would suggest that particularly you pick up one of these. It |

gives you several interesting articles, including the one that's current about the British report on |

finding, they call it the Queen's --. Depleted uranium measured in Britain's atmosphere. If it's |

measured in Britain's, what about the U.S. Who's going to do that? Who makes those studies? |

Who's going to pay for that? The taxpayers? The nuclear plants? The NRC? How do we |

know what's going on? I understand one of the problems in our intervener court, court suit is |

that we don't have specific data from Palisades. Well, who's going to pay for that? Taxpayers? |

Nuclear plants? Not likely. |

|

Another thing back there at this table is the summary report. And not only is it several pages |

long, it's based upon U.S. Nuclear Regulatory Commission Freedom of Information Act |

response documents, and so on. But you can have your very own picture of the cask. So it's |

back there on the top, stack back there. |

|

I was, I have an encore ready if you'd like. |

|

MR. CAMERON: I heard, I heard no. I heard yes. But thank you. Thank you very much |

Corinne. Kathryn, Kathryn Barnes? And we're running a little bit late over here, but we'll be |

done soon. |

|

MS. BARNES: I want to say no matter where you stand on the nuclear issue, if you think |

Palisades is great and you like nuclear energy, or if you're opposed to it, we're all in the same |

boat, all of us that live here in this area. And that is that. What happens there is going to affect |

us. It's not only going to affect us, but it's going to affect our children's children's children. You |

might be the last person in your lineage if that thing blows because you'll never have any, any |

offspring with normal DNA, if at all, you survive it. If at all, that you can reproduce. |

|

What happened in Chernobyl was disastrous. Kevin Kamps, who is one of my good friends, |

brought children from Chernobyl over here. I worked on the U.S., U.S.S.R. Reconciliation |

Project to stop the nuclearization and the cold war, and we, we were successful. And when I |
Appendix A

NUREG-1437, Supplement 27 A-188 October 2006

C-7

C-8

C-9

C-10

| see these children from Chernobyl whose beautiful souls with their sunken eyes, and they're

| severely handicapped, and I see American kids who are bright and bouncing around and having

| fun, Corinne and I ran the Children's Peace Camp and we had American children and

| Chernobyl kids. The, the contrast between the children was so immense, yet they're all

| innocent beautiful little children. The only difference is Chernobyl blew and Palisades hasn't

| yet. 

|

| And I am convinced that because it's of the geology, the problematic problems, the history, the

| track record at Palisades, the possibility of terrorism, the probability of increased nuclear waste

| problems, that it's only a matter of time something's going to happen there. And I don't think the

| risk is worth it. Even though right now were in that, were in a crossroads. And you can take this

| day and live in this day forever. You could live here. But if after a disaster, you couldn't. 

|

| And there's so much to lose. It's not just your lives, your children's lives and the possibility of

| grandchildren, great grandchildren, but it's a life in this area. It's the soil. It's our relationship

| with Canada. Do you think Canada would every forgive us for the fall out? Do you think that we

| could ever restore the Great Lakes, our water table, if something happened there? And the,

| and the, the mounds of nuclear waste got into the Great Lakes that's stored there? I don't think

| you can get it back people. Not with radiation, and not with the huge contamination that an

| accident would cause. 

|

| And it was only built for a certain amount of time. The engineers that designed that place built

| it, they thought it would last that long, and the licensing is, is beyond that point. I believe that so

| far these band-aids have, people have been very lucky that we haven't had accidents with stuck

| valves, leaking coolant, all accidents that have happened at Palisades over and over again,

| they've always been able to fix it in time. 

|

| I know someone that worked inside of Palisades. He said he wouldn't work in the Michigan

| anymore. He works in another state. I won't mention his name. I won't mention what state he

| works at, although the NRC and other people have tried to find out. He told me that Palisades

| is the most likely to blow of all the nuclear reactors in the United States. He said it's a well

| known fact in the nuclear industry. And I said well why, you know, like at DC Cook I know that

| for ten years they operated with a cooling system that wouldn't function in the case of a melt

| down. I said are they trying to cover something up at Palisades? He says no, it's just the way

| they run things. He says they don't report things. He says there's so much that goes on that

| people don't know about. He says the NRC doesn't know about it, and I don't know what he

| was talking about. I tried to get more information out of him. He wouldn't talk, but that bothers

| me. 

|

| And I think that a lot people are in the dark and I'm one of them. And I come here. I take time

| out of my life, and like Kevin and other people, we're doing this without any monetary reward. 

| We're using our own gas money which is expensive and everything else, and I hope somehow
Appendix A

October 2006 A-189 NUREG-1437, Supplement 27

G-1

G-2

G-3

that something I'm saying makes a difference, you know. That something is going, that |

somehow that something I say or write or do is going to forestall a big disaster. And I don't |

know if it, if it means anything at all. I don't know if everything I say is futile, if anybody's |

listening, if anybody cares. But I know that if it blew, then your little plant that's full of holes, if it |

blew, that people would understand what I'm talking about because you can't get it back. An |

acceptable risk, as far as you're dealing with something this big, if you can shut it down, go to |

natural gas, Consumers Energy is already --, then do it. Why not. |

|

MR. CAMERON: Okay. Thank you Kathryn. We have two final speakers. Alice Hirt, could you |

join us, and then we're going to go to Paul Harden. And then we're going to ask Rani to just |

adjourn the meeting. Here's Alice Hirt. |

|

MS. HIRT: Thank you. I'm going to be very brief. I, responding I think to David Miller or |

whoever said that the consequences of the daily releases into the environment of radioactive |

nuclides is small, I don't know what small means. I know cells are small. And I know that the |

newest report by the National Academy of Sciences has said that there is no safe threshold for |

radiation. Not one bit of it. So how do you determine, this is new information. You didn't have |

that information when you licensed this plant 40 years ago. So this should be considered in |

your re-licensing process. It's new information. Are you talking about a small person, or a small |

cell, you know? I'm a small person and I don't want one of my small cells injured. So I think |

that information needs to be considered in this license application. So please look at that |

information. |

|

Now the other thing is the issue of embrittlement, and the question was have you considered an |

accident based on the fact that Palisades is quite embrittled. When Palisades was licensed |

40 years ago, the issue of embrittlement I don't think was considered because you didn't really |

know that that's what was happening or would happen. So in my understanding, this is, if there |

is an accident, the result, as a result of embrittlement, it would be a beyond design accident, if |

that's the correct terminology. So that's an accident that you're not considering, but that's new |

information since this plant was re-licensed 40 years ago. So I think you need to look at what |

would happen if there is an accident as a result of embrittlement, since you didn't know that |

when you licensed this plant 40 years ago. |

|

My last thing, in yesterday's New York Times, I don't know if you all saw it, but maybe some of |

you from the NRC might get red ears when you read this article, because it is, after consulting |

with the industry, the Nuclear Regulatory Commission weakened security regulations it had |

proposed for reactors, government auditors said in a report to be released Tuesday. This is a |

GAO report. The audits said the process, quote, created the appearance that the changes were |

made based on what the industry considered reasonable and feasible, feasible to defend |

against rather than assessment of the terrorist threat itself. The report, by the Government |

Accounting Office, stopped short of saying that the Commission had made changes, quote, |
Appendix A

NUREG-1437, Supplement 27 A-190 October 2006

N-1

N-2

| based solely on industry views. This cozy relationship between the NRC and the industry is

| what really bothers all of us. 

|

| MR. CAMERON: Okay. Thank you Alice. I would just ask Juan if you want to talk to Alice

| afterwards about the embrittlement issue. And Dave, I think the Draft Environmental Impact

| Statement might address the -- 7 report that Alice mentioned to us. So if you could talk to her

| about that. 

|

| And finally, I think Corinne or someone put a copy of a Wednesday New York Times article on

| the table over there that talks about a hearing, a Congressional hearing yesterday that provides

| further amplification on what you mentioned. Okay.

|

| Let's go to our final speaker. This is Mr. Paul Harden, who's the site Vice President at

| Palisades.

|

| MR. HARDEN: As Chip mentioned, my name is Paul Harden. I'm the site Vice President at

| Palisades. I'm also a Nuclear Engineer, so I happen to understand the topics and the issues

| and discussion here very, very well as we discuss them.

|

| First, I'd like to focus my comments on the purpose of the meeting, the Draft Supplemental

| Environmental Impact Statement. And I'd like to commend the NRC on the scope and depth of

| the report. It's very comprehensive and a lot went into it. A lot of views have gone into it. 

| Nuclear Management Company will also have comments on it. Our preliminary review showed,

| has come up with no issues of significance, but as we complete the review we will also submit

| our comments.

|

| Before I address a few of the facts, I'd like to talk about regarding environmental impact to

| operating the plant, I'd first like to state that not everyone in the public is ever going to agree on

| whether nuclear power is a good or bad thing. Not everyone in the public is ever going to agree

| whether the method that this country has chosen to store fuel is a good or bad thing. The

| diversity of the people, the diversity of the views, and our freedom to express them, that's part of

| what makes this country great. So I think it's okay that there are differing views out there. But I

| would like to address a few facts regarding the environmental impact of operating Palisades

| Nuclear Plant.

|

| Environmental responsibility is built in to the design, the operation, the management and the

| regulation of nuclear power plants. There are multiple redundancies. There are multiple levels

| of safety. There's defense in depth, and there's a regulatory agency that's very, very intrusive

| into how we do business to insure that environmental responsibility. 

|

| The employees at the plant, they're also residents. We raise our children, my baby in the back

| of the room, here in South Haven and we have a vested interest in also insuring that the plant is
Appendix A

October 2006 A-191 NUREG-1437, Supplement 27

N-3

environmentally responsible. We continuously monitor radiation levels at the plant. We |

continuously monitor the release paths from the plant. That's not all we do. We go on to verify |

it. We sample soil. We sample fruits. We sample fish. We sample water from surrounding |

areas as an additional validation that we are maintaining the environment safe. |

|

And there are multiple regulatory agencies, not just the Nuclear Regulatory Commission. |

There's Environmental Protection Agency, and there's the Michigan Department of |

Environmental Quality all of which enforce strict regulations and review what we do at the |

Palisades Nuclear Plant to insure that we are safe to the environment. |

|

Consumers Energy and Nuclear Management Company are convinced that Palisades can be |

operated safely with minimal impact or adverse impact to the environment. That's why we're |

investing millions of dollars in the plant in upgrading the plant and the equipment today as we |

proceed forward with our license renewal process. |

|

We're satisfied the continued operation of this plant is an environmentally responsible decision, |

and I'm also quite gratified that the Draft Supplemental Environmental Impact Statement has |

come to that conclusion. And we look forward to a long and prosperous operation and a very |

safe and environmentally sound manner at the Palisades Nuclear Plant. |

|

MR. CAMERON: Okay. Thank you very much Mr. Harden. I'm going to ask Rani Franovich to |

just -- |

|

MS. FRANOVICH: Are there any more comments? |

|

MR. CAMERON: No. |

|

MS. FRANOVICH: Okay. |

|

MR. CAMERON: We're good. |

|

MS. FRANOVICH: I just wanted to again thank you all for coming to our meeting. I mentioned |

at the beginning of the meeting, and I really mean it. Your comments, your participation is really |

important to our process. It helps us to insure that we didn't miss anything. So thank you for |

your input. |

|

Excerpts of Transcripts of the Evening Public Meeting on April 5, 2006, in South Haven, |

Michigan |

|

[Introduction by Mr. Cameron] |

[Presentation by Ms. Franovich] |
Appendix A

NUREG-1437, Supplement 27 A-192 October 2006

| [Presentation by Mr. Bo Pham]

|

| MR. CAMERON: Okay. Thank you, thank you both. Thanks, Rani.

|

| Are there any questions on the review process with the NRC? And please just introduce

| yourself too.

|

| MS. BARNES: My name is Kathryn Barnes. I have a question. You mentioned biocides. I was

| wondering what biocides are used at Palisades and for what purpose.

|

| MR. PHAM: I don't have the, I just gave that as an example. I would have to probably get back

| to you on that on the specific biocides. But that's just an example of, you know, things that are

| released and the known release into bodies of water if any that we document in the generic

| environmental impact statement. 

|

| I do not have, I don't have the specific on that right now.

|

| MR. CAMERON: And Kathryn, if we have more information we'll get that to you. John.

|

| MR. ELLEGOOD: Just real quick, a lot of licensees use some sort of biocide to limit the growth

| of clams in service water systems. Palisades is no exception to this in terms of biocides that

| would be used --

|

| MR. CAMERON: Thank you.

|

| MS. BARNES: Do you know what it is.

|

| MR. CAMERON: Now what --

|

| MS. BARNES: I, I was wondering what kind, what kind of chemical components --

|

| MR. ELLEGOOD: I'd have to get back to you --

|

| MS. BARNES: Hydrocarbons or?

|

| MR. ELLEGOOD: We'll get back to you.

|

| MR. CAMERON: We'll find out specifically for you. Process, did you have something, you

| don't, okay.

|

| MR. SCHAAF: I don't have the specifics off the top of my head but we, that's one of the things

| we, we did talk about in the supplement. It, it'll be identified in the supplement to the GEIS and
Appendix A

October 2006 A-193 NUREG-1437, Supplement 27

also those are, those releases are permitted by the State of Michigan and, and the permit |

includes conditions on which materials are, are able to be released. And at what, what |

concentrations. |

|

MR. CAMERON: And if Kathryn wants to see the specifics she can find that in the draft |

environmental impact statement. |

|

MR. SCHAAF: The permit is available in our document management system. The utilities are |

required to submit a copy of, of their permit when it's renewed. These permits are renewed on |

a, on a five year basis. |

|

So we can identify the accession number in our document management system if you're |

interested in that information. |

|

MR. CAMERON: Okay. Thank you very much. Process questions? Yeah, and. |

|

MR. RICHARDS: One of the things, Ken Richards, one of the things I was looking through the |

manual for was the plant's original decommissioning date. I found decommissioning dates in |

there but I've always been curious what was the original decommissioning date for the |

Palisades Plant. |

|

When it was first built we were told 20, 25 years. |

|

MR. CAMERON: Right. |

|

MR. RICHARDS; They'd be building another plant after that. They even worked on it, and it's |

been like 38 years and now they want to go another 20 years with this. But I'm wondering what |

was the original decommission date. And I've been all through this thing -- |

|

MR. CAMERON: Okay. We're going to try and see if we know that. |

|

MR. PHAM: I don't have, I don't know what the intention was for the original decommissioning |

date. However, as Rani said in her part of the presentation that when the NRC licenses a |

nuclear power plant the, the life of the license is for 40 years -- |

|

MR. RICHARDS: 40 from that? |

|

MR. PHAM: Yes. And that's, that's also based on economic reasons not on plant aging. |

|

MR. RICHARDS: Well, what does that -- |

|
Appendix A

NUREG-1437, Supplement 27 A-194 October 2006

| MR. CAMERON: Okay. Can we, we need to get everybody on the transcript. Could we follow

| up on this.

|

| MR. RICHARDS: Well, when did they issue a 40 year permit? Because I remember back in the

| late 60s, early 70s they were talking 20, 25 years. Now they're saying 40.

|

| MR. CAMERON: And I think the very simple answer is when we, when we gave this license to

| Palisades originally what was the length of the license time.

|

| MR. PHAM: The, 2011 is the --

|

| MR. CAMERON: Okay. Carry on.

|

| MR. RICHARDS: That's the current -- 

|

| MR. CAMERON: All right.

|

| MR. PHAM: We haven't, we have --

|

| MR. CAMERON: Let's, let's, do you have anything else then?

|

| MS. FRANOVICH: That's, that's the length of the license. Now maybe the utility at time has

| talked about closing before the license ends. Maybe that's the information he has.

|

| MR. CAMERON: Okay.

|

| MS. FRANOVICH: And that would be their decision, it would be a business decision.

|

| MR. CAMERON: Yes, sir and please introduce yourself.

|

| MR. ADAMS: Duane Adams. My question is what was the design during the 60s when, when

| this was on the planning books. You design a piece of equipment to last a certain period of

| time. 

|

| What was that in that original document and is it in this document that you just issued? 

| Because normally the plants are built to last a certain period of time much like cars are.

|

| MR. CAMERON: All right.

|

| MR. PHAM: I think the answer to that would be that when the plant, the plant was, I don't, I don't

| think this plant was specifically designed with components lasting a certain period of amount of

| time.
Appendix A

October 2006 A-195 NUREG-1437, Supplement 27

Everything that the NRC does basically is to ensure the health and safety of the public and so |

we had ongoing safety programs to ensure that the plants are operated safely. |

|

And part of that is the equipment managing process in which we look at the safety equipment |

and make sure they're operating and, and they're going to be sustainable throughout the life of |

the plant. |

|

MR. ADAMS: But there are certain components you cannot look at. |

|

MR. CAMERON: Okay, sir, sir. We need to get all comments on the record and maybe Rani |

can provide a little bit more on that question. |

|

MS. FRANOVICH: Yeah, with the, with the license being for 40 years the utility may have |

purchased certain components that may have a life of 40 years or less in which case they |

replace or refurbish those components to ensure that they perform their intended functions |

during the extended period of operation. |

|

MR. CAMERON: Okay. |

|

MR. ADAMS: All the components have -- |

|

MS. FRANOVICH: No. |

|

MR. CAMERON: Sir. |

|

MS. FRANOVICH: No. |

|

MR. CAMERON: Sir, we need to get you, you know, on the transcript so. |

|

MS. FRANOVICH: Those that may have a design life for 40 years or less may be replaced or |

refurbished to ensure that their intended functions are performed. That's what we inspect. |

|

MR. CAMERON: Okay. Thank you. Let's go to one other question here and then go to, to the |

draft EIS. |

|

Yes, sir. |

|

MR. HANNON: My name is Robert Hannon. I just want to, I, I think what the gentleman is |

getting at is I'd like to ask the engineer, there was an engineer over here. The major |

components of that plant I think what the guy was trying to get at is anything that's built like that |

the critical stages of when it's break, it's break in point and when it ages. |
Appendix A

NUREG-1437, Supplement 27 A-196 October 2006

| And I'd just like to know from the engineer if, if indeed that is, that's correct. Just a yes or no

| would be fine.

|

| MR. CAMERON: And the question is whether the critical point is the break in period and then in,

| as it gets --

|

| MR. HANNON: As it --

|

| MR. CAMERON: -- to its end of its useful life --

|

| MR. HANNON: Yeah.

|

| MR. CAMERON: -- aging.

|

| MR. HANNON: Exactly.

|

| MR. CAMERON: All right. John.

|

| MR. ELLEGOOD: What you're thinking of is with components you typically have a infant

| mortality and, and 

| a life mortality of the component when it fails.

|

| At the power plants they do routine inspection surveillance as preventive maintenance activities

| on components a lot of predictive maintenance to determine if that particular component is

| nearing it's end of life and try to replace it for pro actively before it fails.

|

| As part of the license renewal process there was an extensive evaluation of the aging

| management programs to make sure that they were in place and licensing was doing additional

| inspections above and beyond what they had historically been doing to find out those types of

| issues.

|

| For example a pipe a certain wall thickness eventually is going to erode, make sure they have a

| process in plan to determine the remaining wall thickness and replace that pipe if necessary.

|

| So the answer becomes they had an ongoing program and the license renewal process adds

| additional inspection activities and aging management activities to replace components before

| they fail.

|

| MR. CAMERON: Thank you very much, John. 

|

| We're going to go to Dr. Dave Miller to talk about the findings in the draft environmental impact

| statement now. And then we'll go back to your questions.
Appendix A

October 2006 A-197 NUREG-1437, Supplement 27

[Presentation by Mr. Dave Miller] |

|

MR. CAMERON: We're going to get a bunch of questions so if you could just -- |

|

DR. MILLER: Oh -- |

|

MR. CAMERON: Maybe we won't get a bunch but we'll get some questions -- |

|

MR. PHAM: Chip, I just wanted to follow up with Kathy on her question and, and we verified in |

our document that the State of Michigan does license Palisades to, to use Chlorine, Bromine |

and Amine as far as their permit for biocides. |

|

MR. CAMERON: And if you could when after the meeting why don't you point out where that is |

to her so she can see the content. But let's go, thank you, Bo. |

|

Let's go to see if there is questions on the, the analysis on the presentation you just heard. Any, |

any questions on, on that. Yes. And just please introduce yourself to us. |

|

MS. MORGAN: My name is Jeanise Morgan. I was wondering what does it take to get denied |

or, you know, the license denied. And has this group ever done that? |

|

MR. CAMERON: Okay, good, thanks Denise. |

|

MS. MORGAN: Jeanise with a J. |

|

MR. CAMERON: Jeanise, I'm sorry. Jeanise, two questions is what does it take for a denial. |

That means all the different parts of the analysis and what is our history in terms of denial, how |

do we modify applications that come in. |

|

Bo, do you want to start us off on that? |

|

MR. PHAM: Yeah, the first part of that question what does it take to deny a request is basically |

the standard that I had, that I put up before is we look at the environmental impact to see if it's |

large enough to the point where it would be unreasonable for us to leave -- as an option. |

|

Now that sounds like a very subjective measure I realize that but it's, it goes back to for example |

the hypothetical example that Dave used on the fishery on the lake for example. |

|

MS. MORGAN: Can you give me a real example of one that you denied? |

|

MR. CAMERON: Let him, let him get there and we'll go to that. |
Appendix A

NUREG-1437, Supplement 27 A-198 October 2006

| MR. PHAM: So that's the answer to the first part --

|

| MR. CAMERON: That's why it's, it's not a complete answer in the sense that that's only the one

| part of the review the environmental part of the review.

|

| MS. MORGAN: I understand that but I just want an example have you ever --

|

| MR. PHAM: From a, yeah, from an environmental perspective if a resource is impacted to the

| point where it cannot be sustained is the general answer on that, okay.

|

| MS. MORGAN: Is that --

|

| MR. PHAM: The second part of, the second part of your question has it ever been denied. No,

| the NRC has never denied. We have, we have returned applications to applicants because of

| lacking of information or inadequate formatting of the information that they provided us. I

| remember, the process isn't a go no go process. 

|

| The applicant submits their application. We review it for consistency with our standards and if it

| contains the adequate information that's required per regulation.

|

| Now if it doesn't to the point where it's not, it's not quite at the, you know, at the effort where we

| should be putting the effort into doing the review without adequate information then we will

| return it to the applicant and have them look at it again or review it for quality of purpose prior to

| trying to, to trying to submit such a document.

|

| MR. CAMERON: And Rani, do you have anything to add to that for Jenise?

|

| MS. FRANOVICH: Did that answer your question or are you satisfied with that answer?

|

| MS. MORGAN: I was hoping for a good example of one you might have stopped because it just

| seems to me there would be one that would need to be shut down. 

|

| MS. FRANOVICH: Okay.

|

| MS. MORGAN: And I'm sure you have a lot of years under your belt to say that there would be

| one that was just so bad it shut down.

|

| MS. FRANOVICH: Well, to tell you the truth when applicant comes to the NRC with a license

| renewal application they have advanced invested a substantial amount of time and money in

| putting together their application to demonstrate to the NRC that that plant will be safe to

| operate and will not adversely impact the environment.

|
Appendix A

October 2006 A-199 NUREG-1437, Supplement 27

P-1

If an applicant cannot do that then they will probably decide not to apply for license renewal |

because it's costly endeavor. |

|

So if an applicant feels they cannot demonstrate that to the NRC they will not pursue license |

renewal. |

|

MR. CAMERON: Okay. That, I think might give Jeanise an idea of why a lot of the applications |

end up being granted -- |

|

MS. FRANOVICH: The applications will be typically accepted by the NRC we have returned |

applications that we felt were not adequate or sufficient for us to conduct our review. |

|

MS. MORGAN: But 100 percent of those have been okayed then? 100 percent? |

|

MS. FRANOVICH: Well, when we, when we get the application we review it. We typically will |

ask a number, a large number of additional questions. When I was project manager for license |

renewal for Catawba and McGuire we had 273 requests for additional information. |

|

So the application comes, the staff looks at it. The staff almost always is not satisfied with that |

which is in the application. So we engage with the, with the applicant to get more information so |

we're satisfied that continued operation of the plant will be safe. |

|

MS. MORGAN: I guess it's just hard to believe that never one has never been, you know, |

denied like that. |

|

MR. CAMERON: Okay. |

|

MS. BARNES: Wasn't there two -- |

|

MR. CAMERON: We're going to go, Kathryn please just don't just speak out we need to try to |

get people in turn -- |

|

MS. BARNES: I think -- |

|

MR. CAMERON: -- and get them on the record and we're going to go to this gentleman over |

here. Please introduce yourself, sir. |

|

MR. KAUFFMAN: Maynard Kauffman. And I have a question for Dr. Miller and ask if you really |

want to stand by those figures that you cited on wind energy 125,000 acres for I presume the |

kind of megawatts the plant currently produces. |

|
Appendix A

NUREG-1437, Supplement 27 A-200 October 2006

Q-1

| If you, if you, if you do the calculations here I know there's been machines that put out four

| megawatts each and there could be, you know, maybe you'd need about 200 of them or so to

| do that and that would be about 500 acres per machine. And that makes it look as if wind is

| really impossible but it's not. And I think there's a fallacy in there.

|

| MR. CAMERON: Okay. Dave, do you want to address that and we're going to go to, to another

| questioner.

|

| DR. MILLER: Yes. The, the information I provided to you is in the generic environmental impact

| statement and you'll see that in the references.

|

| And I would encourage you to provide us as a part of you comments any additional updated

| information that you might have on that because that is exactly the kind of thing we would look

| at.

|

| MR. KAUFFMAN: All right, I appreciate that.

|

| MR. CAMERON: Thank you, thank you Maynard. Yes, ma'am.

|

| MS. ADAMS: My name is Sandra Adams and I'm curious as to where Homeland Security and

| terrorism falls in this environmental impact. Are you going to discuss that tonight or are you

| going to discuss that later?

|

| MR. PHAM: Security is part of an ongoing review process at the plants. So emergency

| preparedness and security are part of the everyday items that we look at at the NRC. And there

| are processes in place that look at the adequacy of the security of the plant. So therefore it's

| not part of the license renewal process. So we look at more than aging management of

| equipment. And in our case our team looks at the environmental impacts of it.

|

| And so no we will not address that tonight because it's beyond the scope of --

|

| MR. CAMERON: And as Bo pointed out and I think Rani did in her presentation it's considered

| an everyday issue that we need to look at. Yes.

|

| MS. ELLIGIN: My name is Mary Ann Elligin. I'm with the Michigan Department of Environmental

| Quality and to answer, was it Jeneane,

|

| MS. MORGAN: Jeanise.

|

| MS. ELLIGIN: Jeanise's question we had Big Rock Point out just a couple years ago. They

| went through this study prior to putting it down to the NRC and submitting it and they decided

| they could no longer operate under this kind of condition.
Appendix A

October 2006 A-201 NUREG-1437, Supplement 27

And so the plants themselves are wise enough not to pay to go through the NRC process and to |

take themselves off. |

|

MS. MORGAN: Yeah, I knew about that. |

|

MR. CAMERON: Okay. Thank you, thank you very much. Let's go over here. Yes. |

|

MS. TIDWELL: Hi, I'm Carol Tidwell. I just have a question about the Argonne National Lab. Is |

that related to the government? Is it part of the government -- |

|

DR. MILLER: Argonne National Laboratory is one of a number of national laboratories. The, the |

structure is such that the Department of Energy owns our facilities but we are operated under |

contract to the government by the University of Chicago. |

|

Other labs are operated by other consortiums typically universities but sometimes they're |

corporations of some sort. |

|

MS. TIDWELL: So is there, is there a private not connected to the government agency that |

reviews these plans/ |

|

MR. PHAM: Yes, actually we are using a contractor Earthtech that is doing the review for one of |

other plants as well. |

|

MR. CAMERON: And you might want to note that whenever, for any contractor that we use to |

help us with this there is a specific conflict of interest review that has to take place to make sure |

there's no conflicts between who is doing it and the work they're doing. So is that right, Bo? |

|

MR. PHAM: Yes. The answer is yes we are using commercial contractors. |

|

MR. CAMERON: Okay. Did you want to add anything, Rani? |

|

MS. FRANOVICH: I just wanted to affirm what you said, Chip. We cannot use a contractor that |

is for example engaged in doing work for the very applicant that has requested license renewal. |

|

MR. CAMERON: Okay. Let's to Mr. Hannan and then Kathryn. |

|

MR. HANNAN: I, you mentioned the amounts of radiation that are admitted or released annually |

was small. Does radiation accumulate in the body over time? And has anybody ever tested |

people who live in Covert medically to see the amounts of radiation that, that are in their |

bodies? |

|
Appendix A

NUREG-1437, Supplement 27 A-202 October 2006

| MR. CAMERON: Okay. Two, two good questions. And one of them is the accumulation and

| the second one is whether there has ever been a health study done --

|

| MR. HANNAN: Yes.

|

| MR. CAMERON: -- on, on radiation here.

|

| MR. PHAM: I'm going to try to answer this man and Rich can help me in the back there. 

|

| But to answer the question yes radiation does accumulate in the body. The amount of radiation

| released from the plant is in our definition per the EPA standard. We don't look at specifically at

| the content but at the dose that's received from the population and that's the standard we're,

| we're looking at.

|

| The second part of your question I believe you were asking is anybody looking, looked at the

| accumulation, Rich, which could you provide additional information on that.

|

| MR. CAMERON: Okay.

|

| MR. EMCH: Yes, I'll be happy to. My name is Richard Emch and I'm a health physicist and I

| work for the U.S. Nuclear Regulatory Commission.

|

| To get back to the first question, sir, about, about accumulation in the body. Yes, there is, there

| is some chance of accumulation in the body. And in fact there are certain radio nuclides that

| you have in your body all the time no matter how far away from a nuclear power plant you live,

| okay.

|

| In addition to that though I wanted to point out the dose models that are used where we

| calculate doses and let's say you receive a certain amount of -- or something like that from the

| plant the dose models that we calculate have what we call a 50 year dose commitment. 

|

| In other words we're saying when we calculate the dose we're saying the dose that you're going

| to receive from this amount of radioactive material, we're, we're estimating what that dose is

| going to be over a 50 year period.

|

| We're assigning it all in the one year but it's estimated over a 50 year period.

|

| The second question I believe was about health effects about monitoring of heath effects.

|

| MR. CAMERON: And whether there's ever been a study of health effects in Covert --

|
Appendix A

October 2006 A-203 NUREG-1437, Supplement 27

MR. EMCH: In 1990 the, the Congress commissioned the National Cancer Institute to do an |

evaluation of, of available data about cancer incidents around nuclear power plants. And then |

they also looked at control, what we call control counts and Palisades was one of the plants that |

they looked at. |

|

And the conclusion was that they saw no increased incidents, no, no evidence of increased |

incidents of cancer from living near a nuclear power plant. And that includes Palisades. |

|

Beyond that what I would like to point out and I'll give you an example of why that's the case. |

|

Earlier Dave said that the doses from, were very small. In reality the doses are less than 100th |

of one milligram per year maximum dose for an individual living or working near a power plant. |

|

For usefulness of comparison the standards, the EPA standard is 25 milligram per year from the |

entire fuel cycle. The, if you go to the dentist and get dental X-rays you're probably looking at 5 |

to 20 milligram. You take a cross country flight you're probably looking at 2 to 5 milligram. Just |

by being an inhabitant of planet earth you're getting in the neighborhood of 300 milligram a year |

from all sources including radon. |

|

So you can see that the doses, the difference in doses here we're talking this much versus this |

much. |

|

That's, that kind of thing is not going to show up in health studies. And so as far as I know |

there's been nothing specific done in Covert. |

|

Now we did talk to the state agencies to, to the State of Michigan about this and they indicated |

that they were aware of no problem. So we did look at that as well. |

|

MR. CAMERON: Great, thank you. Kathryn. Let me get you this microphone. |

|

MS. BARNES: Yeah, two things. First of all I believe that there was a couple of the reactors in |

the State of Maine. The Yankee Row and another one that were trying to get re licensed and |

they were denied a re licensing. And also I have heard, read that the level for nuclear power |

plant workers is higher as if they're super human. In other words their level for milligrams per |

year is higher than an average person. |

|

And I also read that the, the standards for how much, how many milligrams per year a person |

can have was increased. And I wonder how that's justifiable. I don't believe there their |

physiological beings are any different than anybody else's. So two things. |

|

MS. FRANOVICH: Actually I counted three. |
Appendix A

NUREG-1437, Supplement 27 A-204 October 2006

| MR. CAMERON: Okay. And the first one in terms of --

|

| MS. FRANOVICH: Yankee Row and --

|

| MR. CAMERON: -- Yankee --

|

| MS. FRANOVICH: Yankee Row was considering license renewal back in the early to mid 90s

| before we actually even finished our rule and realized that they really could not demonstrate

| that the plant could be run safely. It didn't generate a large number of megawatts.

|

| And so they made a business decision to not go through license renewal. In fact I think they

| actually shut down and are decommissioning.

|

| As far as Maine Yankee goes they did not ever file for license renewal either. They also

| decided to shut down the plant. It was a business decision. They did not produce a lot of

| electricity to, either. And so they decided to shut down and they are decommission those, that

| plant.

|

| So no those plants never did come in for renewal. One of them I know did consider it and

| decided for economic reasons not to.

|

| The second question or second comment.

|

| MR. CAMERON: Question is the standards for the radiation doses that workers at a plant can

| get, are --

|

| MS. FRANOVICH: It's a different standard --

|

| MR. CAMERON: -- higher than the standard for the general public is, is what Kathryn was

| saying --

|

| MS. FRANOVICH: I believe that's the case --

|

| MR. CAMERON: -- is that, is that true and why. Do you want Rich to do it or do you want to do

| it?

|

| MS. FRANOVICH: I'm going to let Rich comment on that but I think she also made an assertion

| that they receive higher levels than the general public.

|

| MS. BARNES: No, that the level was increased for the general public --

|

| MS. FRANOVICH: The standard was increased.
Appendix A

October 2006 A-205 NUREG-1437, Supplement 27

MS. BARNES: Yes. |

|

MS. FRANOVICH: Okay, Rich. |

|

MR. CAMERON: Okay. We got an answer over here, Kathryn. Richard. |

|

MR. EMCH: Okay. I'm a little confused. I'm going to try it and if I don't quite get it you let me |

know, okay. |

|

I am not aware of any increase in radiation standards for either members of the public or for |

occupational workers ever. I, I don't ever remember seeing that. Occupational workers are |

limited by Part 20 to five rem, I was talking earlier about millirem. Now I'm takimg rem, five rem |

per year for an occupational exposure limitation. |

|

And as I said before the 10CFR, I'm sorry 40CFR190 which is the EPA regulations, we have a |

set of regulations ourselves but they're, but they're supposed implement the, the EPA |

regulations. |

|

The EPA regulations are, must be less than 25 millirem to any member of the public from the |

entire fuel cycle and that includes Palisades or, you know, if another plant was nearby it would |

be both plants are included. |

|

Did I cover what you were asking? I'm not sure I did but. |

|

MR. CAMERON: Why are they higher? |

|

MS. BARNES: So there is, there is a different standard, there's a different standard? |

|

MR. EMCH: There's a different standard for members of the public and for -- |

|

MS. BARNES: Right. |

|

MR. EMCH: -- occupational, for workers yes. |

|

MS. BARNES: Right. They're stand, they can tolerate supposedly more radiation than average |

people. |

|

MR. EMCH: Actually in fact biologically no. They're just very healthy members of the public, |

okay. And, and in fact a member of the public could get five rem and you would probably see |

no, no health impact on them either, okay. |

|
Appendix A

NUREG-1437, Supplement 27 A-206 October 2006

R-1

R-2

| But the belief is because the worker makes a conscious decision to work at the plant and, and

| undergo whatever risk there is just like working at, if you're a fireman or a, or a policeman or

| whatever there's certain risks inherent with your job.

|

| But occupational worker like at the plant makes a decision that he's going to incur those risks,

| okay. The plant does a good job of trying to make sure that he gets a very low dose.

|

| When we're talking about members of the public that's a different story. You folks aren't

| volunteering for anything in terms of radiation exposure so that's why the standard is so much

| lower for members of the public.

|

| MR. CAMERON: Okay. Thank you. And I just want to go the State of Michigan to add anything

| that she wants to on this. We're going to take a couple more questions and then we're going to

| go to Bob Palla so we can hear about the severe accident aspect. Go ahead.

|

| AUDIENCE: I just want to back Rich up. As a radiation worker I have protective clothing and I

| also have other protective features that we have available to us. These are not available to the

| public. So politically we have determined that the public needs a lower dose because you are

| not aware of what you can do to help your dose. And you're not aware of that you're getting the

| dose.

|

| So the State of Michigan chose an even lower one than the DPH standard and we have our own

| administrative limits for our public.

|

| MR. CAMERON: Okay. Thank you. Thank you very much. Let's go over here and then Ken

| and then Maureen. Go ahead.

|

| MR. ADAMS: Wade Adams. I have a couple of questions actually. One goes to the lady over

| here. It's my recollection that Big Rock went, went into service about 1959 or 60 about 11 years

| before Palisades. And it's my recollection that Big Rock has not been running really as a power

| plant for some number of years here now. And it's got a lot of trouble.

|

| So that means that if you go ahead and, and renew this you'll be, this reactor will be far

| exceeding the line time of the Big Rock Plant in terms of production.

|

| My second question is to the health scientist. Is there any level of radiation where you cannot

| achieve an increase in incidents of cancer. 

|

| It is my understanding that there is a linear relationship and there is no threshold between the

| incidents of cancer and your exposure to radiation, the lifetime.

|
Appendix A

October 2006 A-207 NUREG-1437, Supplement 27

MR. CAMERON: All right. I don't know what we can say about the Big Rock comparison to, to |

this plant. I don't think we'll be able to say anything about that. |

|

But, Rich, can you talk about the, the, you know, the linear no dose threshold and maybe you |

can go up there and do that and then we're going to go to this young lady here and over here |

and then we'll go back to a presentation. |

|

MR. EMCH: It wasn't actually part of what I was supposed to answer but I think you're, you're |

assumption is correct, sir, if the, if the, if Palisades is granted a renewed license I'm sure they |

will operate longer than Big Rock Point did. |

|

MR. CAMERON: Can -- |

|

MR. EMCH: I'm sorry, can you not hear me? |

|

MR. CAMERON: We want to go to the -- |

|

MR. EMCH: To what I'm really up here for? |

|

MR. CAMERON: Yeah. |

|

MR. EMCH: Okay. Fair enough, all right. Yes, sir, you are correct. And in fact the NRC does |

stand by what's called the linear non threshold theory. You've seen it probably in a number of |

places. It was mostly recently reconfirmed in something called the BIER 7 report which I earlier |

today somebody mentioned to us. |

|

And basically this theory is that there is, that there is some but there is no actual threshold that |

this is some amount of risk associated with any amount of exposure. Okay, very simplistically, |

okay. |

|

What I was, and, and the NRC follows that, that theory as do most of the, the low radiation |

protection community does. And, and that's part of why the, the, those limits that I was talking |

about for the public are as low as they are. |

|

Earlier when I said that there was I think I think I mentioned something about no recorded or no |

health effects below five rems or something like that I was talking about things that had been |

reported or things that had been found in the studies. |

|

But again back to the very basic philosophy. The NRC's philosophy, the NRC's theory our, our |

regulations are based on the concept of a linear non threshold theory, yes. |

|
Appendix A

NUREG-1437, Supplement 27 A-208 October 2006

S-1

T-1

| MR. CAMERON: Okay. Thank you and there is a discussion of the BIER 7 report in the draft

| environmental impact statement.

|

| Do you have a quick follow up, sir, because we really need to move on.

|

| AUDIENCE: Well, I wondered if I, I presume that you couldn't calculate an increase number of

| cancers that would develop because of the increased exposure to radiation in the locality of this

| plant. 

|

| And second the study you cited that was commissioned by the National Cancer Institute was a

| bonafide epidemiology study that, that really looked for a hot spot.

|

| MR. EMCH: What they did was they looked at all of the available data from various counties, the

| counties where these, where these plants were located, control counties that, that would

| presumably not have any effects from them and that we can certainly give you that information. 

|

| It's, it's full of information like, I don't want to get into it because it actually, some of it I have

| trouble understanding.

|

| But I'm a health physicist not an epidemiologist, that's why I have some difficulty with part of it.

|

| I'm sorry, what was the, there was another part of it or? Oh, yes, yes.

|

| Actually these the, the international committees like the international, I can never remember, it's

| commission and radiation protection, I believe it is, they have, there's a publication ICRP-60 that

| does have coefficients that you can, that you multiply these coefficients times a dose. 

|

| If you say this person got a certain dose you can calculate it times those coefficients.

|

| Now if you took, those coefficients are really intended to be used for population dose. But if you

| took those coefficients and multiplied them times a number like .01 milligram per year it's, it's

| not worth doing. It's so small.

|

| MR. CAMERON: Okay. Thank you, Rich. Yes.

|

| MS. OVERHEISER: My name is Liz Overheiser and I have two questions involving the last point

| on the board there.

|

| That includes, well, yes I guess, all of, and when you consider those solar and wind power

| would that be like a centralized like field of windmills and --

|

| MR. PHAM: Yeah. The, the model -- 
Appendix A

October 2006 A-209 NUREG-1437, Supplement 27

MS. OVERHEISER: -- sun panels. |

|

MR. PHAM: Again the modeling assumption, can you hear me okay. |

|

The modeling assumption is that Palisades produces a certain amount of megawatts right now, |

780 plus some change. |

|

The, so what we look at as an alternative is a, that we're going to replace that we need |

something to provide the same capacity. |

|

And so whether the, the wind farm is separated into several different areas or all centralized in |

one location. The bottom line is you, we have certain, some [thumb]rules that we have for X |

amount of, a certain number of, of megawatts per acreage for the wind farm production. |

|

So in the end aggregately you're going to need that much acreage, you know, even if it's in one |

place or all separated. |

|

MS. OVERHEISER: Well, I'm -- |

|

MR. CAMERON: Okay. Do you want to a follow up there, go ahead. |

|

MR. OVERHEISER: I'm worried about like the environmental effects. Is that moderate or large |

considering that it would be all in one place. |

|

MR. CAMERON: And there's a, there's a good, a good point is that conceivably there would be |

different environmental effects depending on whether it was centralized or decentralized. Good |

comment also but Dave can you talk to, to that in terms of how we considered that in the draft? |

Thank you. |

|

DR. MILLER: It, it does depend on what alternative source you're talking about. Now for |

instance the gas, coal, they have to be in one place to replace that base load. |

|

The, the combination of alternatives that we look at which would mean drawing from more than |

one single source to make up that amount would therefore be a smaller incremental part |

compared to the overall whole. |

|

I hope I'm getting to your question. Because, because the impacts then are looked at. So for |

the one where you'd need a coal plant on an entire site that would look at consuming that entire |

site. |

|
Appendix A

NUREG-1437, Supplement 27 A-210 October 2006

| For the kind of individual piecing together of different sources of energy then it's fractioned by

| the amount they contribute. So that's how the impacts are evaluated. Does that get to what

| you're after?

|

| MR. CAMERON: And maybe, maybe we should also consider that as a comment.

|

| DR. MILLER: Yeah, I was about to say --

|

| MR. CAMERON: Yeah, okay --

|

| DR. MILLER: -- I mean that's something we, we are going to take away with us today. It's a

| simple answer and current modeling in what we looked at in alternatives. Yes, it's all

| collectively or is all centralized in one location.

|

| MR. CAMERON: Okay. Let me, let me try to, I know we have two people here we haven't heard

| from, from you. So let me, let's just do some, try to do this quickly so we can get --

|

| MS. ANDERSON: Elizabeth Anderson. I would like to ask Rani this question. You know,

| because -- if you really feel that a place should be shut down are you allowed to deny the

| license renewal or are you only allowed to give recommendations?

|

| MS. FRANOVICH: If we feel that a plant needs to be shut down license renewal is not even a

| consideration. We will issue an order to shut them down when we feel it is necessary.

|

| License renewal is should they extend operation from the end of their current term, which is a

| 40 year terms, for another 20 years.

|

| If we have a concern about utilities performance today to the point where we're not comfortable

| with letting them continue to operate we won't wait for license renewal to take action.

|

| MS. ANDERSON: This recommendation --

|

| MR. CAMERON: The NRC is not an advisory body. They're a regulatory body and if the

| regulations are, are violated and the plant needs to be shut down we have the authority to --

|

| MS. FRANOVICH: We have the authority to issue an order to shut the plant down. We have a

| number of other tools in our toolbox to either impose additional requirements if we feel that

| there are safety issues at the plant and to enforce existing requirements to demand information.

|

| I mean we're a regulatory agency. We, we determine whether or not a plant is safe enough to

| operate. And if we don't think that they're safe enough to operate irrespective of license

| renewal we will take the actions that --
Appendix A

October 2006 A-211 NUREG-1437, Supplement 27

MR. CAMERON: Okay. Thank you for that question too. And Ken and then with Corrine and |

then Bob are you ready. |

|

MR. RICHARD: I have a quick one for the health risk physicist. When you were answering her |

question you were -- alpha, beta, gamma radiation like it was altogether, it's all the same thing. |

And now you're talking about normal background; can you explain to me the difference between |

alpha, beta and gamma radiation |

|

MR. CAMERON: We have them, we have them behind you right over here. Okay, Rich, you got |

a question, right? |

|

MR. EMCH: Yes. |

|

MR. CAMERON: Okay, good. And Corrine we're going to go to you and then we're going to go |

back to presentations. |

|

MR. EMCH: As you pointed out, sir, there are a number of different kinds of radiation alpha, |

beta, gamma and neutrons. Actually if you look at some of the documents you'll find that we |

even attribute a different quality of factor to fission product fragments. |

|

MR. CAMERON: Speak up, Richard, if you can. |

|

MR. EMCH: Okay. And all, I mean all this is when, when I'm saying a dose I'm usually talking in |

terms of the whole body or total body dose, okay. |

|

But we do also look at organ doses. We look at internal, you know, doses taken through |

ingestion and through inhalation. And, and when we do that that's when you really start, that's |

when the ones like the alpha and the, and the beta really start to come into play because they're |

really not dangerous at all outside of the body but once they get inside the body they can be, |

yes. |

|

And those are included in the dose models, yes, sir. |

|

MR. CAMERON: Okay. Corrine. |

|

MS. CAREY: Yes. Regarding the screen that is showing up there. Which one of those is |

insignificant? Small, moderate, large. Because time and again I keep hearing reference to |

impact is insignificant. |

|

MR. CAMERON: Can you just give us, why don't you discuss the individual items and explain |

those very quickly to Corrine and I think it will be obvious, Dave. |
Appendix A

NUREG-1437, Supplement 27 A-212 October 2006

| MS. CAREY: I wanted a specific answer --

|

| MR. CAMERON: Right.

|

| MS. CAREY: -- and I wanted to know if significance is a matter of a cumulative situation like

| radiation is itself and if so at what numerical point does insignificance become significant.

|

| MR. CAMERON: Okay. We got a little bit more information on what Corrine's question is with

| that. Do you think you can --

|

| DR. MILLER: I think I can.

|

| MR. CAMERON: Okay.

|

| DR. MILLER: And Corrine help me --

|

| MR. CAMERON: Good.

|

| DR. MILLER: -- if I don't get it.

|

| MR. CAMERON: Okay.

|

| DR. MILLER: We try to be very careful not to call anything insignificant in our evaluations. In

| fact we try to stick because of the definitions I provided earlier to small, moderate and large.

|

| And if I use the term insignificant anywhere I, I should be corrected. But I, I hope that I didn't. I

| don't think I did.

|

| In terms of quantification there are elements of these that simply aren't quantifiable but we use

| weight of evidence and multiple lines of evidence to come to the conclusion about whether it's a

| small, medium or large.

|

| And we use those definitions that I had provided earlier and we would skip back to them if you

| like. That, that, to look at the impact to the resource that we're concerned about and, and in

| essence the semi quantitative magnitude of that impact.

|

| MR. CAMERON: Okay. And if, if Corrine needs further information please, please talk to her. 

| Bob Palla. Thank you, thank you both, Dave and thank you Rich and Rani. Bob.

|

| [Presentation by Mr. Bob Palla]

|

| MR. CAMERON: All right, thank you.
Appendix A

October 2006 A-213 NUREG-1437, Supplement 27

MR. PALLA: -- questions. |

|

MR. CAMERON: Thank you. Any questions on SAMAs at all? Okay. We have one question, |

two questions and then we're going to go on to Bo for a wrap up so that we can get to you all for |

comments. And this is Kathryn. |

|

MS. BARNES: Yeah, if you could give me an example of a severe accident that might happen |

and the SAMA that you would procure for it just as an example such as what would happen |

during a meltdown with the embrittlement issue. |

|

MR. PALLA: Well, I'm, I'm not going to give you an example of an embrittlement issue because |

it doesn't, it doesn't really tie in very well. |

|

But I guess an example that may be a little easier to understand is just that if you, if one looks at |

the risk profile of the plant, meaning the different types of sequences or scenarios that could |

lead to core damage one that always seems to get a lot of attention is called the station |

blackout sequence. |

|

Basically you loss, it's a loss of offsite power. The plant is equipped with several diesel |

generators. In this particular type of an event they would fail. They fail to start or they fail to run |

but they are not available so the plant is basically sitting there without any power to, to supply |

the pumps. |

|

So the way that this could be covered through SAMAs, and I'm, I'm flipping pages here just to |

find the ones that are applicable. |

|

One of the SAMAs, SAMA 10 it's described in more detail in Chapter 5 and in Chapter, in |

Appendix G but this SAMA would involve modifying turbine driven auxiliary feed water systems |

so it can be operated indefinitely without AC DC or pneumatic support. |

|

So basically by implementing that SAMA the plant would be able to continue to supply water to |

the steam generators which would remove heat from the reactor core. |

|

This could be sustained for, for several hours and in the meantime in, in PRA space we always |

look at recovery of offsite power and there's a, there's a curve that describes the probability of |

recovering as a function in time. |

|

But if you can extend the ability of the plant to cope with these station blackout events for, for |

several hours you increase the change of recovering power. And so then at that point the main |

line front, front, front line systems would be available and -- |

|
Appendix A

NUREG-1437, Supplement 27 A-214 October 2006

S-2

| MS. BARNES: Is that with a --

|

| MR. CAMERON: Okay, yeah. Let's, let's go to this gentleman here and then maybe you can get

| more into those examples with Kathryn after the meeting because it is, it seems very complex. 

| But you did a good job of providing a simplified explanation.

|

| AUDIENCE: Have you factored into your considerations the impact of an earthquake. And the

| reason I ask that is that, well, we don't have earthquakes here really. The largest earthquake in

the continental United States occurred in the Midwest in the early 19th | century. That could

| happen again. Have you taken that into consideration --

|

| MR. PALLA: Yeah --

|

| AUDIENCE: -- in your computations.

|

| MR. PALLA: -- within the, I'll explain how we handle that and --

|

| AUDIENCE: And that regards to both the reactor and as well as those waste storage containers

| that are sitting there on the shore of Lake Michigan.

|

| MR. PALLA: Okay. So --

|

| MR. CAMERON: Okay --

|

| MR. PALLA: I'll, well, I'll begin by saying we did not look at the waste containers in this, in the,

| it's not in the scope of the SAMA analysis.

|

| What we looked at is the impact on the plant. We, the way that this [was] done we have a

| probabilistic safety assessment that looks at internally initiated events. This is what I referred to

| as the PSA.

|

| And then there, in the early to mid 1990s all plants were requested to perform an individual

| plant examination for external events. And this is done via a generic letter from NRC. It's not,

| it, it basically required every licensee to look at the, the vulnerabilities of the plants to external

| events in, including seismic events.

|

| So those, the insights from the, that study were brought to bear in the process of looking for

| potential improvements to the plant. So we, we, we have quantified estimates in core damage

| frequency for internal events, we have some estimate of approximately how much a seismic

| event contribute relative to what an internal, internally initiated event would contribute.

|
Appendix A

October 2006 A-215 NUREG-1437, Supplement 27

S-3

And as part of this study we did in fact identify one seismic related change and there's a SAMA |

that involves replacing some under voltage relays with seismic requalified relays that these, |

these relays were judged to be a, kind of a soft spot so to speak in, in the design. |

|

So this was an improvement that was identified specifically for seismic. |

|

AUDIENCE: But what was your -- |

|

MR. CAMERON: Okay. Thank you. |

|

AUDIENCE: -- decision on the -- |

|

MR. CAMERON: Sir. Now let's go to a quick follow up because we really need to move on so |

that we can hear from all of you. Go ahead. |

|

AUDIENCE: I would like a quick question as to what sort of seismic event did you assume in |

this calculation. In other words on a Richter scale. And second why wouldn't you include the |

waste or the spent rod storage in this calculation because I don't think we can count on, on |

Yucca Mountain coming online because as I understand it there have been some conflicting |

information that's been presented on the Yucca Mountain situation and that might not be |

approved for many years. |

|

MR. CAMERON: And Bob can you try to put this into a little bit of perspective -- |

|

MR. ELLEGOOD: Let me -- |

|

MR. CAMERON: -- just because, John, can I just finish, thank you. |

|

Just because the spent fuel pool or the dry storage and this may be where you're going, John, |

isn't considered as a SAMA doesn't mean that the NRC isn't concerned and take account of |

seismic in terms of that. And, John, go ahead. |

|

MR. ELLEGOOD: Let me answer the seismic question for you. The entire plant is designed to |

survive seismic events. The earthquake for Palisades for safe shutdown or designed basis is a |

point 2G earthquake. That's not characterized in terms of the Richter scale because the Richter |

scale is more of a energy release during an earthquake and for seismic analysis it doesn't |

provide the right type of scale to use for the design activity. |

|

In terms of how frequently are you going to get that size of an earthquake here that's going to |

be about every 15,000 years you would achieve an earthquake of about .2G which is the design |

basis earthquake. |
Appendix A

NUREG-1437, Supplement 27 A-216 October 2006

| The plant was designed for that as well as the original storage pads were designed for that size

| of an earthquake. 

|

| Does that answer your question.

|

| AUDIENCE: Well, I guess I don't understand how you can say it's 15,000 years for this part of

| the Midwest because new information suggests that it's a rebound of the land --

|

| MR. CAMERON: Okay, I think we've --

|

| MR. ELLEGOOD: It comes from a series of government studies that calculated that particular

| turn frequency.

|

| MR. CAMERON: And we really need to, to move on and if you can provide more information to,

| to that gentleman offline fine. But, Bob, thank you.

|

| MR. PALLA: You don't want me to say --

|

| MR. CAMERON: Do you, did you, did you want to add anything more?

|

| MR. PALLA: Well, what I, what I would add is that from the risk point of view what we would look

| at in, in contrast to a specific G value for the design within a seismic risk study you look at the

| whole range of potential seismic levels. And it's, it's called seismic hazard.

|

| Obviously you could postulate extremely high G levels but the probabilities of those things are

| correspondingly much lower. And in this individual plant examination that I spoke of this

| seismic analysis that, that I spoke of it relies on, on the seismic hazard curve for the site.

|

| And you, you look at the ability of the various components and the structures to be able to

| withstand that, the, the spectrum of, of the loads. And at some point they don't, they would fail

| and, and this is all solved in a very complicated matter.

|

| But the end result if you, you end up with some components that are generally thought to be

| the, the lowest prone to fail and they might give you the, via the greatest interest for looking at

| them in terms of reducing risk.

|

| So we did go to the individual plant examination. We used it to help identify seismic related

| fixes that would have the greatest impact on risk.

|

| MR. CAMERON: Great. That, I'm glad you added that seismic hazmat curve that looks at

| different G factors and probability. All right.

|
Appendix A

October 2006 A-217 NUREG-1437, Supplement 27

MR. PHAM: I'm sure Bob is available afterwards, sir, if you want to address the question some |

more. |

|

MR. CAMERON: Okay. Bo. |

|

MR. PHAM: Okay. So Dave and Bob has, have gone through the details of our analysis and |

right now I'd like to turn us to the conclusion in which we found as David and Bob both |

mentioned that the impact of license renewal are small in all areas. |

|

We also concluded that the alternative actions including the no action alternative may have |

moderate to large environmental -- impact in some categories. |

|

Based on these results our preliminary recommendation is that the adverse environmental |

impacts of license renewal for Palisades are not so great that it is not unreasonable to preserve |

the option for license renewal for the energy planning decision makers. |

|

This slide is a quick recap of where we are right now. We issued the draft environmental impact |

statement for Palisades on February 14th, 2006. The comment period for the draft ends on |

May 18th, 2006. There are regulations require a 40, 45 day period from the issuance of the draft |

until the, until the closing of the comment period but we actually build in a 70, at least a 75 day |

period there. |

|

So we expect to issue the final impact statement around October time frame of this year. |

|

And then this slide identifies me as your primary point of contact with the NRC awaiting |

preparation of the environmental impact statement for Palisades. |

|

It also identifies where the documents related to our review may be found in the local area at |

the South Haven Memorial Library. |

|

The documents are also available online at the www.nrc.gov website. |

|

And in addition as you came in today you were asked to fill out a registration card. If you |

included your name or address on that card we will automatically mail a copy of the draft and |

final environmental impact statements to you. |

|

If you did not fill out a card I encourage you to do so as it, it's a good opportunity for us to |

include you in the part of the public outreach process that we have for the review. |

|

And if you need to register please see Christina or Laura out front would be your best. |

|
Appendix A

NUREG-1437, Supplement 27 A-218 October 2006

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| In addition to providing comments at this meeting there are other ways you can submit the

| comments for our review process. You can provide written comments to the chief of rules and

| directives branch at the address on the screen. You may also make the comments in person if

| you happen to be in Rockville but for many of you that's not the case so we provided an email

| address for Palisadeseis@nrc.gov.

|

| All of our comments, your comments will be collected and considered. 

|

| And this concludes my remarks and presentation.

|

| MR. CAMERON: Thank, thank you very much.

|

| MR. PHAM: Thank you all again for coming.

|

| MR. CAMERON: And thank you, Carl, those, those were very very good questions.

|

| We're going to go to the comment part of the meeting so we have an opportunity to hear from

| you and we're going to go first to Mr. Tom Tanlzos who is the chair of the Van Buren County

| Board of Commissioners. And after Mr. Tanlzos we'll hear from one of his colleagues Richard

| Freestone and then Mr. Wayne Radell Covert Township supervisor. And this is Mr. Tanlzos, the

| chair.

|

| MR. TANLZOS: Thank you.

|

| MR. CAMERON: Thank you.

|

| MR. TANLZOS: I'll use the microphone. My name is Tom Tanlzos, county commissioner. I

| represent South Haven Township, South Haven City and the northern half of Covert Township

| which includes the plant.

|

| I'm also the chairman of the commissioners for Van Buren County.

|

On March 22nd | we did pass in 2005, we passed the unanimous resolution in support of the

| license renewal of the nuclear power plant and I will submit that as a certified copy to you.

|

| One of the things even though you might see it was an economic decision for the County, for

| the Township and the area, yes, these are all true benefits of having the plant in our area.

|

| But if there was any concern that it was harming the environment or the residents of this county

| or this area we would not have taken such action.

|
Appendix A

October 2006 A-219 NUREG-1437, Supplement 27

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W-1

W-2

W-3

W-4

So I would like to present this to you and on behalf of the Board of Commissioners that we |

unanimously support the license renewal application. |

|

Thank you. |

|

MR. CAMERON: Okay, thank you, Chairman Tanlzos. And we'll attach this to the transcript and |

also have this as a formal comment on your record too. So, Ron, I'm just going to give this to |

you right now. |

|

How about Mr. Freestone. Is he still here? |

|

MR. FREESTON: I don't have anything additional to add to what Mr. Tanlozos said. I'm also a |

county commissioner and support the renewal license. |

|

MR. CAMERON: Okay. Thank you, Mr. Freestone. |

|

Mr. Radell. Covert Township supervisor. |

|

MR. RADELL: Yes. My name is Wayne Radell and I'm the supervisor for Covert Township. |

Covert Township has supported Palisades Plant since its inception in 1965. The plant's very |

location is a direct result of the township's encouragement to construct and operate a nuclear |

plant in this area. |

|

Consumers Energy, it's predecessor, Consumers Power and the plant's current operator |

Nuclear Management Company have been good stewards of the environment. At no time since |

the plant's beginning operation in December of 1971 to the present has posed any threat or |

danger to the residents of Covert or the surrounding area. |

|

The Covert Township board has officially gone on record to support Palisades license renewal |

activities through a resolution of support enacted on March 8th, 2005. |

|

As the host township for Palisades nuclear plant Covert Township and seven other taxing |

entities received over $6 million annually in taxes from the plant. Over the years this tax money |

for the township has funded paving roads throughout the township, building water mains |

throughout the township, lighting intersections and increased fire and police protection for our |

citizens. |

|

Covert public schools receives the lion share of that tax money and provides first class school |

facilities and services. |

|
Appendix A

NUREG-1437, Supplement 27 A-220 October 2006

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X-2

| Covert Township is very much in favor of Palisades Nuclear Plant's license renewal. It has

| been, there has been a partnership between Covert Township and Palisades since the

| beginning.

|

| We look forward to that partnership continuing for another 20 years and longer. Thank you.

|

| MR. CAMERON: Okay, thank you, Mr. Radell.

|

| Now we're going to hear from Mr. Dale Lewis and then we'll hear from Mr. Maynard Kauffman

| and then Mr. Wade Adams.

|

| Mr. Lewis.

|

| MR. LEWIS: I just had an operation on my throat, nose last week so I can't speak very loud so I

| won't speak very long either.

|

| Palisades is a great vehicle for industrial growth and growth in South Haven. At the present

| time during normal operations Palisades employees 600 people from their operations. And if

| you can imagine in your town, and I presume that most of you are from outside South Haven

| since I don't recognize too many of you, if you have something that, a plant that employed 600

| people and that were to close down there would be great economic impact on the area.

|

| So the nuclear plant right now, Palisades, is in a refueling outage where 900 more people come

| in to South Haven to work on the outage to repair things, to improve things.

|

| You can imagine what that does to the hotels, motels in South Have. It's a great economic

| boost to South Haven.

|

| If you were to close Palisades down and I haven't heard a good reason tonight for doing it, it

| would make South Haven a ghost town almost because there just wouldn't be the jobs that are

| there now.

|

| And I have, as I say I haven't heard a word that says anything about a good reason to close

| Palisades down.

|

| So and we as a city council, oh by the way, I was mayor of South Haven for four years and

| while I was mayor we passed a resolution also endorsing the continuation of Palisades. Thank

| you.

|

| MR. CAMERON: Thank you, Mr. Lewis. Thank you, thank you very much.

|
Appendix A

October 2006 A-221 NUREG-1437, Supplement 27

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Y-2

Y-3

We're going to go to Ryan McCoy at this point because he's here with his family and his young |

son and maybe they want to go bed. But -- |

|

MR. McCOY: I didn't mean to interrupt. |

|

MR. CAMERON: Go ahead. |

|

MR. McCOY: I'll be real brief. |

|

MR. CAMERON: Go ahead. |

|

MR. McCOY: My name is Ryan McCoy. I'm a citizen of South Haven. I'm not affiliated with |

anyone. I'm here mainly to be educated about it. I, I'm blessed to live close to the beach and |

I'm on the beach every day and I see that plant every day and I'm, frankly I'm worried so I want |

to know what's going on. |

|

What I've heard from our former mayor and, and some of the commissioners has all been |

economic based. It's all about economy and jobs. |

|

And this touches me deeply because I'm a recently unemployed worker who was selling topical |

plants and I lost my job from environmental impact from hurricanes. |

|

So I'm unemployed and I still stand opposed to it. I want to know what I'm seeing here more is |

public relations and not a lot of truth. There was a gentleman asked a really profound question |

why the dry cast things weren't affiliated or weren't in with the seismic analogy. And to me that |

seems more important than the deteriorating radioactive, see and I don't even know the |

terminology, so forgive me. |

|

But what I want to see happen is that economy take a backseat to ecology. If this is not |

ultimately safe for our citizens, if our citizens are breathing radioactive fumes, if there's a |

potential for a major accident that wipes us all out there's no need for an economy. |

|

I'd like to see economy take a backseat to ecology. I'd like better answers on, on the questions |

that are asked, a lot less lip service. |

|

I have a young child I want to see grow up in South Haven. I want him to grow up healthy. It's |

a beautiful community. We'll find ways to replace the economy. |

|

These alternatives that you say have vast potential for economic sustain ability. The waste |

generated, dry casting it there and not having a home for it worries me. 20 years from now |
Appendix A

NUREG-1437, Supplement 27 A-222 October 2006

Y-4

Y-5

| what's that going to be like or where are we going to be with, how much more waste will they

| produce in those 20 years.

|

| And right now from what I've read and again I'm naive so I'm here to be educated but we don't

| have a home or a place to put this waste that's one of the most toxic substances on the plant

| from what I understand. It's sitting 150 yards from our precious resource the lake. Why that

| doesn't trouble more people I don't know.

|

| I understand the need for economy and jobs. Let's get that behind us and let's look at the

| ecology. I think that's most important.

|

| You know, I'm happy to remain unemployed for another couple of months if that's what it takes. 

| But I'd like to see some true answers, some truth, a lot less PR, a lot less bureaucracy and let's,

| you know, let's really talk about what's, what matters here.

|

| I could go on and on but thank you for listening and for the opportunity and clearly I'm opposed

| to the re licensing. I've got a lot more to learn. But I think the economy is no, is no reason, it

| shouldn't be the top consideration.

|

| MR. CAMERON: Okay. Thank you, Mr. McCoy. And I'm going to ask John Ellegood at some

| point not, not now, John.

|

| MR. ELLEGOOD: Whatever you want.

|

| MR. CAMERON: But since you're here in the community and since there's lots of questions that

| I think Mr. McCoy has is the draft, at some point not necessarily tonight but at some point, you

| guys could hook up and maybe you could, you could talk about some of these issues. That

| may be, may be helpful to him.

|

| And, Mr. McCoy, did your, did your wife want to say anything? I know she's out there but --

|

| MR. McCOY: I'm sure she doesn't. She's a little tied up.

|

| MR. CAMERON: Yeah.

|

| MR. McCOY: Our opinions are very similar.

|

| MR. CAMERON: Okay. All right.

|

| MR. McCOY: I'll just stand behind what I said.

|
Appendix A

October 2006 A-223 NUREG-1437, Supplement 27

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P-5

P-6

MR. CAMERON: Good. Thank you very much. Let's go to Mr. Kauffman, Michigan Land Trust |

and then we'll go to Mr. Adams. |

|

MR. KAUFFMAN: I appreciate the opportunity to speak. Maynard Kauffman speaking on behalf |

on Michigan Land Trustees. |

|

I live on a farm about ten miles straight east of here. And my comments are about alternatives. |

And what I want to do first is say I am opposed to the 20 year extension of the Palisades |

operating license. I think it's a needless risk. And I'll try to explain why. |

|

My hope is that by the time the current license expires in 2011 that nuclear power should be |

replaced by wind power and by a lot more conservation and more efficient use of electrical |

energy. That is possible. I'll come back to that. |

|

Also it's cheaper. Currently as according to my latest figures and I've been doing a lot of |

reading on this, wind energy is sold for four cents a kilowatt power or less sometimes when it's |

under long term contract to where as I understand the cost of nuclear energy is about three |

times higher than that. |

|

So we the taxpayers, the ratepayers are paying so somebody else can make money. And it's |

not necessary. Let me explain. |

|

Palisades sits on 432 acre site of which 80 acres is developed or I presumed used. That leaves |

200 to 300 acres of land which could be available for wind turbines. If you figure four acres per |

turbine and they're really large, this would be a four megawatt turbine and they exist, you would |

need or you would have room for about 50 large wind turbines. They could be erected on the |

site, more land could be rented for farmers down the line along the transmission line too. |

|

But even these 200 megawatts that would be produced here by wind is not negligible. That's |

one fourth as much roughly as the current nuclear plant provides. |

|

Now on page of the GEIS on page 845 I understand that wind power had been considered and |

rejected for a number of reasons. One of which is that it said could be intermittent and there's |

sense in which you could say that but I, I have a wind generator next to my house, nearby, and I |

say that wind power isn't seasonal. |

|

Because in this season it hasn't quit running for weeks and weeks. So it's not just intermittent |

but it might be seasonal. So certain other seasons might require a different mix of energy to |

keep the customers going. |

|

So that's one of the problems I have here. It isn't simply intermittent. It's seasonal. |
Appendix A

NUREG-1437, Supplement 27 A-224 October 2006

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P-8

P-9

P-10

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P-12

| In any case wind power is really growing worldwide. It's growing at the rate of 30 percent per

| year. Most of this is happening in Europe and in Europe Germany is in the lead with I believe at

| this point 14,600 megawatts of electricity from wind. They seem to know how to do it.

|

| So I suggest to the people at the NRC or to the, to the management company that they should

| go to Germany and ask and say we don't know how to make wind power work here maybe you

| could tell us how to do it. You may to say this in German so you might want to say ve con mein

| dusche dunday so they really understand what you're trying to do, okay.

|

| Okay. I'm not here to entertain. 

|

| I want to suggest that there are three paragraphs on page 8-45 of this GEIS dealing with wind

| power and together the three paragraphs includes so many distortions, falsehoods or simple

| stupidity that I think if this is a kind of an indication of what's in this book it's bad news because

| this is not going to gly.

|

| The way this is put down here is to sort of make wind a non starter. And it's not true because as

| I just said it is growing worldwide and it could here too if people were to take a different kind of

| attitude. 

|

| And incidently wind generators and their, their towers can be reused and recycled over and over

| again so that they have that advantage as well. And they provide the jobs that you're so

| concerned about in this community.

|

| So let me wind this up.

|

| There, I already mentioned in my comment earlier that it does not require 500 acres for a single

| wind generator and if the large ones, you know, the, the way the GEIS puts it you really have a

| system here where they say you need 500 acres or well actually they say 150,000 acres in

| order to provide 1000 megawatts.

|

| I've been on wind farms and many of you have seen them. They're not one per 500 acres. This

| is either a big mistake by somebody that should have known better or it's a blatant distortion. 

| As I suspect the latter because they don't want to deal with wind power they'd rather deal with

| nuclear because that's the business that they're in both for the commercial and governmental

| agency.

|

| So I, I worry about this.

|

| Finally I have to say that according to the GEIS again Consumers Energy has decided they

| didn't want to deal with what they call DSM and for you who haven't read the book DSM mean

| demand supply management. In other words giving advise to the consumer to use less energy
Appendix A

October 2006 A-225 NUREG-1437, Supplement 27

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to get complex for, you know, all of the things that could save energy. Oodles of it. They chose |

not to do that. Why? |

|

Well, it might be very costly or this or that. Now come on. This would be a way of trying to sort |

of curtail the need for licensing this plant in a risky way for another 20 years. |

|

Any relevance has said that we could do with 50 percent less electricity if we used it intelligently |

and if we conserved. And I think this certainly true because I see all over the place that people |

do waste a lot. |

|

So my point is that I think the, the put down of wind energy in this book is so blatant that I |

suspect I have to say I'm afraid I lose, I think that the nuclear regulatory commission loses |

credibility by people who know something about this. |

|

And that's a serious thing because I don't want to live in a society where governmental agencies |

lose credibility because they're supposed to be responsible. Thank you. |

|

MR. CAMERON: Thank you, Mr. Kauffman, serious, serious comments that we have to |

seriously consider. So thank you for pointing that out, pointing that out to us tonight. |

|

And then we're going to go Mr. Adams. |

|

MR. ADAMS: Thank you very much. I'm Wade Adams. I'm from Kalamazoo, Michigan. I |

decided to take the, I decided to come over with my wife and, and waste that energy. I hope it's |

not a waste. I didn't come here to have it, to be a waste. |

|

My concern is a catastrophic event. And as this plant becomes older and older as we already |

heard the Big Rock plant up in Charlaboy has been closed and it hasn't been generating |

electricity for some time. And as Mr. Kauffman said generating power by nuclear plants is not |

the cheapest way to generate energy. |

|

Now I came from Kalamazoo because we're right downwind of what could happen if radiation |

was released from the Palisades Plant. It would devastating to Southern Michigan perhaps |

Northern Indiana. It could, if you look at the Chernobyl case and I would guess that all those |

government authorities there in the Ukraine were just 100 percent behind Chernobyl until they |

had their accident. |

|

And of course I also lived through the 3 mile island incident when Jimmy Carter was president. |

So I, I believe that we would be far better to spend our money on safer distributing energy |

sources like wind power particularly in Michigan. |

|
Appendix A

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| My wife and I just came back from California. Even a state like Wyoming has tremendous

| numbers of wind generating plants now. Wyoming has tremendous amounts of coal. They have

| tremendous amounts of oil yet they are going to wind generation.

|

| And you look out across this nation the idea that you, you cannot have distributed types of

| energy production is insane in my view point.

|

| So in that respect we do not have to take the chance even though it might be in your estimation

| small on re licensing this plant. This plant if re licensed could be in operation for 60 years. I do

| not believe it was engineered to last 60 years and I don't believe you can change all the

| components in that plant to make it really be safe for 60 years or even 50 years.

|

| So let's invest in alternative energy sources. I hope and, and as far as jobs I'm a PHD did

| research in Kalamazoo for 27 years. 2500 of us lost our jobs quite recently when Pfizer decided

| to close that research facility. We're managing. 

|

| Certainly South Haven, Covert Township and this county will survive if you happen to have to

| close this plant in the next five years. Trust me.

|

| Finally I'd like to say that I hope when you do your consideration that you listen to what

| Abraham Lincoln said. We need government of the people, by the people and for the people.

|

| And what I am seeing increasingly in this nation is government of the corporation, by the

| corporation and for the corporation.

|

| I hope you will keep the people in mind. Thank you.

|

| MR. CAMERON: Thank you, Mr. Adams. We're going to next go to, to Mr. Hannan, Robert

| Hannan and then to Gary Kartch and Barb Geisler.

|

| Mr. Hannan, do you want to come up.

|

| MR. HANNAN: Thank you for allowing me to speak.

|

| It's just hard for me to imagine that, that we're all here in this room even talking about this. I

| think the humanity of, of this nuclear thing is, is not good. And if, and everyone in here is a

| human being and therefore we should all be able to define the meaning of humanity.

|

| And to take a risk like this in my mind I, I don't care how safe it is, you know, it's, it's still a risk

| and you people you're here defending yourselves from a risk, a potential risk.

|
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October 2006 A-227 NUREG-1437, Supplement 27

Z-2

AA-1

AA-2

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AA-5

So therefore you're admitting that there could be a meltdown. So I, I just find this whole thing |

just, us being here talking about this is totally insane. We shouldn't even, man should have |

never split the atom to begin with. It was a bad thing. It's very bad. |

|

And that's all, that's all I have to say. |

|

MR. CAMERON: Gary Kartch. |

|

MR. KARTCH: Thank you also for letting me speak. I wasn't really planning on saying anything |

but I am compelled to do so. |

|

The statement by the resident, Ryan McCoy, was very eloquent. He said he thinks the |

economy should take a backseat to ecology. I agree. But the secret that the people, the |

citizens of this country and state and county do not realize that the economics are indeed an |

issue. |

|

And forgive me for not having the information with me, the facts and figures at the moment, but |

the information I have been reading indicates that nuclear industry has received more |

government subsidies during its lifetime than any other industry. It's well over 50 percent of all |

of the tax incentives, breaks, guaranteed loans, supplementing catastrophic insurance for the |

industry etcetera. |

|

The amount of money that the taxpayers are paying out of their tax, taxes to the industry on top |

of these high electric rates that they're having to pay monthly rates is absolutely extraordinary. |

If people knew that and if that was, if that was analyzed down to a level and given to them so |

they could see it they would be absolutely appalled. |

|

And the renewable, the percentage of, of money going to renewal is something like 11 percent |

of all the money and the nuclear industry gets well, well over 50 percent as I say. |

|

Now in the, and the media has, you know, made some, had been reporting a large subsidy and |

tax incentives to the oil industry and everybody is appalled over that. The nuclear industry has |

them by a mile. |

|

So if this money were diverted to the renewalables and the technology to wind and solar you |

would and perhaps let's pretend that the, the information in the environmental impact statement |

is correct for a minute but as submitted by the, in the EIS, that, that wind turbines need X |

amount of acreage and all this and they can only produce X amount of megawatts etcetera. |

|
Appendix A

NUREG-1437, Supplement 27 A-228 October 2006

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AA-7

| If you take even a minuet amount of the money that is given to the nuclear industry just as a

| given and divert that to renewables and, and improve the technology of the renewables this

| would absolutely not be an issue.

|

| And I also concur with Mr. is it Hannan, who said these, how can we even be in this year of, of,

| of 2006 still being, trying to justify the manufacture of a waste that is absolutely lethal for

| hundreds and thousands of years. What are we going to do with it.

|

| Who, nobody wants it. This is the substance of which we are having international, you know,

| traumas over right now with North Korea and a few years ago it was, you know, India, Pakistan

| and every, every nation on earth wants nuclear and we're giving it to other nations. It's

| absolutely preposterous.

|

| The process by which we are generating electricity is the same process that was used to make

| the atomic bomb that was dropped on, on Hiroshima and Nagasaki. So this is a technology of

| death make no mistake about it. 

|

| We are made of better stuff than this. We are intelligent enough to create electricity in a

| manner that does not produce a waste. And to have the waste off of discussion for the

| environmental impact statement is absolutely scandalous.

|

| That is my comments. Thank you very much.

|

| MR. CAMERON: Is, is Barb Geisler still here.

|

| MS. GEISLER: Yes.

|

| MR. CAMERON: Oh, hi, Barb.

|

| MS. GEISLER: Hi.

|

| MR. CAMERON: Would you like to join us up here. This is Barb Geisler.

|

| MS. GEISLER: Thank you. I live 10 miles from here on a farm. I'm going to address something

| a little differently.

|

| In the early 80s I became, can you hear me or do I need to be over here more.

|

| MR. CAMERON: Maybe we, maybe we can bend it over a little towards you.

|

| MS. GEISLER: Yeah, okay.

|
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October 2006 A-229 NUREG-1437, Supplement 27

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BB-2

MR. CAMERON: See this, this. |

|

MS. GEISLER: I'm a little shorter than the guys. |

|

MR. CAMERON: Okay. Go ahead and see how that works. |

|

MS. GEISLER: Dose that work. |

|

MR. CAMERON: Is that better. It sounds good. |

|

MS. GEISLER: Okay. In the early 80s I, I became concerned about nuclear issues in, in a |

broad way. And I remember a film from that era which was called The Dark Circle |

documentary. And it, they interviewed lots of people in the nuclear industry both the weapons |

industry and the power industry. |

|

And what I remember from that is how intertwined they all are. That it, that you can't really |

separate atoms for peace, atoms for industry from, from the weapons industry. And Gary |

Kartch said, you know, it's, it's about death. Do we choose death or do we choose life. It really |

is about that ultimately. |

|

And in going to various meetings and conferences through the last 25 years I want to focus on |

just one thing which is I've heard a lot of whistle blowers speak. And their lives have been |

ruined. |

|

Now some of you may have seen the film about Karen Silkwood and maybe you thought that |

was over dramatized or not true or whatever. But I sat down with a women in her 70s at at least |

three of these events who told me what happened to her. |

|

She went, and this is I'm, I'm moving to the inside here. She was an innocent young girl. She |

went to work for the industry and she noticed that some figures weren't quite right. And so she |

thought she better tell her boss and she did and that was the beginning. |

|

Basically she was told you can either do the figures the way we want them or you can leave. |

And she realized either way she was a marked woman. And yes she did have to go |

underground. She, the, the act that protected people that came out I believe after Silkwood |

she, she, she literally had to go underground. This is, this a gramma tell me this. |

|

She, she was, she felt, she feels deliberately exposed. She was dying of bone cancer. |

|

Now this is just one woman speaking. I don't think she was lying but I can't prove this. But |

she's only one of several that I've talked to who had their lives ruined in one way or another. |
Appendix A

NUREG-1437, Supplement 27 A-230 October 2006

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BB-4

BB-5

BB-6

| Ann Harris at Lockspar, part of TVA, Curtis Overall eight years ordeal, same place. Finally won

| on appeals. Wrongful termination. I, he was in tears, divorced, everything else. Ann Harris

| was run off the road.

|

| Interestingly enough it was Curtis Overall whose, who pointed out the flaws Lockspar which led

| to Cook very near us, DC Cook being shut down for three years because they had the same

| kind of system.

|

| And I remember hearing a guy in St. Joe talk about working at Cook and becoming a whistle

| blower and his life was ruined too. That's very near us. People are threatened. They are called

| on the phone. They are run off the road.

|

| So knowing this I wonder if this isn't just a charade. How many of you within the industry would

| have the guts if you, if you decided it was, there were things that weren't quite right to say so in

| public. You'd, you'd pay a heavy price number one.

|

| Number two because of all this and because of the nature of this dangerous industry that has to

| be closed, it has to be secret, it has to be top down, it has to be authoritarian. This isn't a real

| democratic meeting here. It couldn't possibly be, you see. This is so we think we have some

| input.

|

| And when I look at our country as some others here mentioned tonight and I see it moving more

| and more toward secrecy and authoritarianism and it's Orwellian, isn't it. We live in a

| democracy but you know what? If you're a little Quaker lady in Palm Beach our wonderful new

| spy people are down there, you know, we're all being spied on you know that don't you.

|

| They wrote a report that these, and these are passivists, you know, Quakers are passivists,

| they wrote a report saying that this was a very dangerous group. We went through this in Viet

| Nam. Quakers are dangerous. They're not the real terrorists are they.

|

| So I guess I want to end by saying I don't think you can have nuclear weapons and nuclear

| power, the Dark Circle and also have democracy. And I think that's what we're up against in

| this country right now if you want to look at, excuse me, the big picture.

|

| So let's look for alternatives. We need a whole new way of living. We can get along with a lot

| less of this, look at this. Lights on all night. You go to the cities they're, and frankly we're going

| to, we're running out of oil, we're running out of natural gas, we're running out of a lot of stuff. 

| We're going to have to think about doing things a different way guys.

|

| And just keeping this little plant open 20 more years and maybe it won't blow maybe it will but

| it's not looking at what we're going to need in the future. That will be very different so let's, let's

| think about a new way.
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October 2006 A-231 NUREG-1437, Supplement 27

CC-1

Thank you. |

|

MR. CAMERON: Thank you, Barb. Thank you. Is Michael -- still here and did he, Michael, did |

you want to, okay. |

|

Let's go to, let's go to Kevin. Kevin, did you want to speak again. |

|

MR. KAMPS: Yeah. |

|

MR. CAMERON: Okay. Let's go to Kevin and then we'll go to Kathryn and Ken and Corrine and |

Mr. Hart. |

|

Kevin Kamps. |

|

MR. KAMPS: My name is Kevin Kamps. I work for Nuclear Information and Resource Service |

in Washington, D.C. But I'm from Kalamazoo, Michigan, a board member of |

Don't Waste Michigan for the Kalamazoo chapter. |

|

And what I thought I would really focus on because it really caused quite a stir earlier today and |

I think it deserves as much attention from the public as it can get because the public deserves |

to know about it was the incident last October involving the cask that was stuck on a crane |

above the pool at Palisades. |

|

And I just wanted to read some passages from NRC documents from Palisades documents that |

reveal the serious nature of that incident. |

|

So I'll start with something I read earlier. |

|

The NRC inspectors concluded that working outside the bounds of a work package on a crane |

with a suspended load that if dropped would damage the spent fuel pool warranted a safety |

significance determination. Had the load dropped the spent fuel pool could have sustained |

severe damage. |

|

The inspectors concluded working outside the bounds of the approved work package and |

manipulating the break release represented an increase in the risk of a load drop. This increase |

in risk is directly associated with the reactor safety cornerstone objective of the spent fuel, spent |

fuel cooling system as a radiological barrier. |

|

And what that last sentence means is if the cask which weighed 107 tons had fallen into the |

pool it would have cracked the floor of the pool, drained away the water which cools the waste |
Appendix A

NUREG-1437, Supplement 27 A-232 October 2006

| in the pool. And in a matter of time, some hours, the waste would catch on fire and it would be

| a large scale radiation release perhaps worse than Chernobyl.

|

| So what were the potentially catastrophic consequences had the cask dropped. And again this

| is from an NRC report entitled Technical Study of Spent Fuel Pool Accident Risk published in

| February of 2001.

|

| The analysis exclusively considered drops serve enough to catastrophically damage the spent

| fuel pool so that pool cooling water inventory would be lost rapidly and it would be impossible to

| refill the pool using onsite or offsite resources.

|

| There is no possibility of mitigating the damage only preventing it in the first place. The staff

| assumes the catastrophic heavy load drop creating a large cooling water leakage path in the

| pool would lead directly to a zirconium fire.

|

| Zirconium is the metal cladding around the fuel rods. It's, it's a combustible material, highly

| combustible.

|

| The time from a load drop until a fire varies depending on fuel age, burn up and configuration. 

| The dose rates in the pool area before any zirconium fire are tens of thousands of rem per hour

| making any recovery actions very difficult. Tens of thousands of rems per hour would deliver a

| lethal dose of radiation to someone close to that in a matter of minutes. 

|

| And that's what happened to the firefighters at Chernobyl. They received deadly doses of

| radiation in a very short period of time. They died two weeks later because their red blood cells

| stopped reproducing.

|

| MR. CAMERON: And that, that part is not in 

| the --

|

| MR. KAMPS: I'm sorry I'm, I'm trying to translate from --

|

| MR. CAMERON: Oh, if you, I think it just needs to be clear if you're purporting to read --

|

| MR. KAMPS: Okay.

|

| MR. CAMERON: -- from our document and then you're editorializing just tell us when you're

| editorializing.

|

| MR. KAMPS: I sure will, Chip.

|

| MR. CAMERON: All right.
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October 2006 A-233 NUREG-1437, Supplement 27

CC-2

MR. KAMPS: I'm sorry that I was -- |

|

MR. CAMERON: I know you didn't, I know you didn't intend it. |

|

MR. KAMPS: Right. I did not intend to at all. |

|

MR. CAMERON: Thank you, Kevin. |

|

MR. KAMPS: I'm reading directly from the NRC again. |

|

Based on discussions with NRC staff structural engineers it is assumed that only spent fuel |

casks are heavy enough to catastrophically damage the pool if dropped. |

|

In fact NRC has reported, "the possibility of a zirconium fire leading to a large fission product |

release cannot be ruled out even many years after final shutdown of a reactor". |

|

Palisades is an operating reactor so the waste in the pool is thermally hot, it's radioactively hot. |

All the more likely to lead to worst case end results. |

|

So this is a quote from a study done by Robert Alvarez and others in 2003 and it was about pool |

fires. This is the quote: "Spent fuel recently discharged from a reactor could heat up relatively |

rapidly to temperatures at which the zurcolode fuel cladding could catch fire and the fuel's |

volatile fission products including 30 year half life, cesium 137 would be released. The fire |

could well spread to older spent fuel. The long term land contamination consequences of such |

an event could be significantly worse than those from Chernobyl". |

|

Another quote from that same report, "The damage that can be done by a large release of |

fission products was demonstrated by the April 1996 Chernobyl accident. More than 100,000 |

residents from 187 settlements were permanently evacuated because of contamination by |

cesium 137. Strict radiation dose control measures were imposed. The total area of this |

radiation control zone is huge equal to half the area of the State of New Jersey. During the |

following decade the population of this area declined by almost half because of migration to |

areas of lower contamination". From the Alvarez study. |

|

And so we found out about this cask incident by a fluke because a number of us attended an |

unrelated NRC technical meeting where a piece of it was mentioned. But we understood what it |

could mean and so we followed up. |

|

And we did a Freedom of Information Act request which NRC informed us would take two to |

four weeks to get back to us. Well, it took two months to reach us. |

|
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NUREG-1437, Supplement 27 A-234 October 2006

CC-3

| And in the meantime we found out all that we could and we found the tables in that earlier report

| I read from about spent fuel waste fires and the casualty figures downwind were quite

| remarkable. The NRC's own numbers again 20,000 to 44,000 cancer deaths over time

| downwind out to a distance of 500 miles away from a pool fire. That was at 2001 NCR study.

|

| So we finally got the FOIA, this was after the Detroit Free Press exposed the incident in that

| front page article. We only received a partial FOIA response at this point. And the, the

| document that I read from earlier was the quarterly inspection report from the NRC. That was

| the first public document of that incident.

|

| But the details that came out in the FOIA were quite interesting. The precursors that led to the

| incident. Here's, here's a quote from an internal Palisades mia copa done by the inspection

| crew that inappropriately handled the crane.

|

| MR. CAMERON: And, Kevin, could you just sort of, sort of wrap up -- 

|

| MR. KAMPS: Uh-huh.

|

| MR. CAMERON: -- on this and, you know, feel free I mean read the quote or whatever but we'll

| just need to go on to some, some other, other people.

|

| MR. KAMPS: Well, I'd like to encourage everybody to go over to that table in the back corner

| and get their own copy of this thing and read it because it's worth it.

|

| So this is, this is the company's workers who made the mistake that could have overridden the

| emergency brake. That's the whole point. They shouldn't have handled the crane because

| they didn't understand the crane.

|

| We failed to consider the severity of the consequences if our troubleshooting caused the load to

| slip or fall into the spent fuel pool. This is why we set up an event response organization to, to

| allow an open forum with full consideration of how these activities will affect the plant and the

| health and safety of the public.

|

| This is the company saying this.

|

| The NRC earlier said that the risk of a load drop was increased because of this inappropriate

| handling.

|

| So I'll just, please do pick up a copy. The precursors of the event that led to this thing, the false

| setting of the emergency brake were due to the fact that Palisades lacks knowledge of the

| crane. They have to bring in the crane company to help them operate the crane.

|
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October 2006 A-235 NUREG-1437, Supplement 27

DD-1

The crane company representative who came last August to set the emergency brake had to |

get to vacation. He was in a hurry. So instead of setting the emergency brake correctly with |

three checks on the emergency brake he did one check. And he set it wrong that time. He |

thought he set it at 175 foot pounds. He actually set it at 140. |

|

So that was one precursor. He had to go home on vacation. And the other one was that |

Palisades doesn't know how to handle the crane. The people that did know how to handle it |

have left the company. |

|

And one of the amazing admissions by the company is that there may be other aspects of |

operations where we also lack full knowledge not just this crane. |

|

MR. CAMERON: Thank you. Thank you, Kevin. Kevin's report is back there on the table. I |

would also urge you to read the NRC inspection report so you can see what the NRC said about |

this particular incident. If you need to find out how to get a copy of that we'll be glad to get you |

a copy of the inspection report. |

|

There was also a dialogue this afternoon on this particular issue. It is in the transcript that will |

be available from this afternoon's meeting and we're going to go to, to Kathryn Barnes and then |

Ken Richards, Corrine, Paul Harden. |

|

Kathryn Barnes. |

|

MS. BARNES: I'm a member of Don't Waste Michigan. I'm one of the people that decide the, |

one of the intervenors. I live within a 50 mile radius of Palisades. I have a son that attends |

Western Michigan. He's in electrical engineering. He's almost graduated. He's nearby. |

|

I have my other son and their father work in Kalamazoo in carpentry. And my family pretty |

much all lives in the danger zone and a lot of my friends do. |

|

And I'm concerned about Palisades because through the years, you know, growing up here in |

Michigan the last time I was in Lake Michigan was as a baby, when I was a baby my mother has |

a photo of me in the water. |

|

When I was growing up I went swimming quite a lot in Lake Michigan. I can remember drinking |

the water, swimming, enjoying it. I can remember how many people were on the beach. It was |

just glorious. |

|

And I can remember drinking the water and it was clean, sometimes it tasted a little fishy but, |

you know, it wasn't a bad taste, you could drink it. You can't drink it now. |

|
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NUREG-1437, Supplement 27 A-236 October 2006

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| Since the, the building of the nuclear reactors the water quality has deteriorated. Last time I

| went swimming last year my daughter and my granddaughter, I have a little almost three year

| old granddaughter now, precious.

|

| They went swimming and they both got stinging rashes. And I got a rash myself although I was

| only in the water for a couple of minutes. And we cannot drink the water, it's got a bad, foul

| taste and I don't know if this is because of the chlorine, bromine and amean released or if it's

| from other things.

|

| One time I sat on the beach and I had the sand in my fingers etcetera and there was a lot of gas

| coming out of Palisades that day and I was near the plant. I got real sick afterwards.

|

| It reminded me of when I was out at the nuclear test site the feelings I had afterwards being

| very tired and nauseous and just really dead tired.

|

| I'm a cancer survivor. I know what it's like to go through that dark cloud. I've seen children from

| Chernobyl. I've seen their sunken eyes and their handicaps and I feel so sad for what they've

| gone through, what their parents that carried them went through. That's an end to the, to the

| lineage of people.

|

| Once you have a nuclear disaster you lose your DNA. When you lose your DNA quality you

| use up the seed for cancer and then you set the seed for death. And there's no getting it back.

|

| I live on land where there's pesticide use. I'm been a victim of that which is an essentially a

| cause of cancer not radiation but radiation does cause cancer too.

|

| I've seen frogs with ten arms. I've seen a lot of things from broken DNA. And here what you

| have is, I know a man who worked at Palisades and he's still in the nuclear industry he's got a

| real high job in the nuclear industry. 

|

| And he told me that it's well known quote un quote, is what he said it's well know within the

| nuclear industry that Palisades is the most likely to blow of all the nuclear power plants in the

| United States at this time.

|

| And I asked him well why is that. I said is it, are they covering something up like they did at DC

| Cook which for ten years they covered up the fact that they had a non functioning coolant

| system. Or if they had a meltdown they could not have, they could not have stopped the

| meltdown.

|

| And only by the grace of God we have not had a meltdown yet.

|
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Well, they covered that up and as people have mentioned the whistle blower got in trouble for |

that. And now he said no he says Palisades they don't cover things up he says they just don't |

report it. |

|

And I think this, this incidents of the crane that was just mentioned that's another incident I |

believe that was not reported to the NRC. And I believe that Palisades asked for an exemption |

that they don't want to report things any more. |

|

I think that the premiss is upside down where they consider the, another 20 years of, of |

Palisades operating as, environmentally a small issue and they consider alternatives as a great |

impact. I think it's opposite actually. |

|

I think that Palisades was burgeoning nuclear waste which is a problem, unstable geological |

strata, the singing sands, the shifting sands, freezing and thawing conditions on the casks. |

Cask number four which is surrounded by other casks has bad welds, could crack. |

|

There's a lot of problems there and, and these aren't being addressed. The, at one of the |

meetings earlier and I've been to all of these meetings now, this is before there was a lot of |

people here. Thank God there's more people getting involved but maybe this is the last |

meeting. |

|

They were talking about the experimental use of sealants. And that wasn't addressed. There |

was other things that the NRC themselves wanted to address. |

|

And when I came to the meeting supposedly for that, those issues they switched locations and |

so they kept this, the public in the dark on that one. |

|

So where's, and I, I don't know the answers to those questions or if they were ever answered to |

the NRC's specifications. But I know there's real issues at Palisades. |

|

The biggest issue I've heard about and this is not disputed, this is fact. Is that it is embrittled. In |

a layman's terms I'll try to explain to you what embrittlement is. |

|

When a nuclear reactor has, of the, the design at Palisades is, had so many reactions through |

the years it gets like little finger holes in it, lots of little holes from all this stress and these |

reactions. Cooling, heating, cooling heating and the near misses they've had. |

|

And after you get this, these holes in the, in the design structure it becomes embrittled which |

means that if there was a stuck value, broken coolant pipes, lots of things could happen to |

cause a meltdown, okay, and then it starts heating up. And they cool, they had to cool it real |
Appendix A

NUREG-1437, Supplement 27 A-238 October 2006

DD-11

DD-12

DD-13

| fast. So they flood it with water. If the plant is embrittled as Palisades is it's like taking a really

| hot glass coffee pot and immersing it in cold water. Bang.

|

| That's what accurate embrittlement is and that's what I've hear would, would be the most

| probable thing that would happen to cause a meltdown.

|

| Well, what does a meltdown mean here. Okay, well, if you live in Covert, you know, you don't

| have a chance to say goodby to anyone.

|

| If you live anywhere close to Palisades you, you'll, you'll, you're gone. If you live downwind

| which could be in any direction but usually the wind comes from the Great Lakes. It comes

| from, from the west going east.

|

| MR. CAMERON: Kathryn, could you just try --

|

| MS. BARNES: I will try and wrap up, yes, I will to wrap up. 

|

| What it means that there is a huge area of contamination. It could go into Canada. It could

| affect all of us in Michigan and Canadians. And as in the case of Chernobyl that year Meyer --

| had the most insane bizarre food. I am sure in Michigan because of all our precipitation we had

| fallout.

|

| I had turnips, they got this big with a little narrow and then they bulged out again and they were

| rotten inside. I had cabbage that was huge and rotten inside. That's not normal. It's never

| happened since.

|

| But I, I think that it can affect everybody in the world.

|

| I would like to see with your rules, a rule be made if, if this nuclear power plant is relicensed that

| everybody that is in on the decision to relicense it be obligated with their families to live within

| five miles of Palisades until the plant is shut down.

|

| MR. CAMERON: Okay. Kathryn, thank you.

|

| MS. BARNES: That might make a difference.

|

| MR. CAMERON: Thank you. Ken Richards. Then we're going to Corrine and to Mr. Paul

| Harden.

|

| Ken Richards.

|
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October 2006 A-239 NUREG-1437, Supplement 27

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O-2

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O-4

O-5

KEN RICHARDS; Good evening. I'm Ken Richards Palisades Conversion Group. I'm going to |

try to get this down a bit but -- |

|

MR. CAMERON: We will have to keep you to five at this point. |

|

KEN RICHARDS: Yeah. Recently I got the generic impact statement license renewal and I've |

been reading through both the manual and its cover letters. I see despite potential radioactive |

hazards the NRC insists that environmental impact of the Palisades Nuclear Power Plant, all the |

radioactive materials about its reservation, such as the casks is always regarded as small |

throughout the report. |

|

But when I turn to alternative energy sources which should be pursued at Palisades plant site |

they're impacts are often referred to as large which all considering they would be taken into |

account the enormity of nuclear power the plant puts on the grid for alternatives to equal out in |

their current forms at the site. |

|

A rather particular assumption bracketing both the plant and the NRC's position as well yet |

ignoring the simple fact that of all the resources used to continue operation of this plant or |

renewables and other forms of electrical generation throughout the state it would turn the |

argument on its head. |

|

But my real concern here is the fact that the GEIS report does not take into consideration of dry |

cask storage. Other highly radioactive contaminated things such as the former steam |

generators on the site. |

|

Many would argue that Palisades reservation is already a defactile high level nuclear waste |

dump which to their, Palisades Conversion Group and my way of viewing the issue a large |

impact on this fragile lakeshore enviroment. |

|

More to the point potential in fact should things not go as designed or planned or promised |

which over the last 38 years time and time again have been broken. With an additional |

20 years worth of above ground dry storage cask along with other contaminated equipment |

which is sure to be replaced should this plant be pushed so far past its original design capacity |

which it already has by years now. |

|

Counter to the GEIS' insistence that no changes to the plant need take place in the additional |

20 years. Isn't the reactor head soon to be replace in July perhaps. |

|

I talked with the vice president and he said 2000 and something. |

|
Appendix A

NUREG-1437, Supplement 27 A-240 October 2006

O-6

O-7

| The pressure reactor vessel long in question operating in a patchwork method since

| embrittlement was discovered more than ten years ago. How long before this is replaced.

|

| Annealiated as once promised in court or a neutron thermal shield installed. And yes, the dry

| cask storage casks piling up on site.

|

| I'm sure we'll all hear about Yucca Mountain or the -- Indian reservation taking all of this off our

| hands for the umpteenth time in the last 20 years.

|

| Now there are over 20 to 30, somebody told me 29 here but I keep getting different answers,

| dry cask storage onsite. Will anyone here give us an exact number. Somebody did give me 29.

|

| This is a community concern for we will have to live with and care take all of this waste for

| generations to come. In '93 we were told these experimental cut waste storage casks would be

| gone in 1998 time and time again by Mark Savage the plant's spokesperson.

|

| Now we're told by the NRC there license to store fuel assemblies for 20 years. It'll last for 150

| years and above ground storage is our nation's nuclear future since the Feds haven't found a

| hole deep or dry enough to put all this radioactive waste and materials in. 

|

| After nearly 50 years of looking, instructing, spending and charging us ratepayers for a place to

| take all of it off our lakeshore nothing but this. Another promise broken, more public trust going

| by the wayside.

|

On April 4th | the Squaw Valley Reservation will be approved for above ground storage but with

| Yucca Mountain's inability to take this slated cask off the Goshite's hands, there will not be

| move in either nuclear waste storage site for all the waste piling up at Palisades now much less

| that all the additional waste produced during the 20 year relicensing period. All for a little

| electricity now. Decades perhaps centuries of radioactive waste for the local citizenry to look at.

|

| Yet the operators still insist this is a cheap form of power generation.

|

| Another concern is the plant's original seven mile cooling loop rumored to be back in use again. 

| It's affect of Lake Michigan's eco system. Is it or is it not back in use.

|

| MS. ELLEGOOD: There's no seven mile cooling loop.

|

| MR. RICHARD: Okay.

|

| MR. RICHARD: I, I agree --

|

| MR. CAMERON: -- I would have to ask you to, to wrap for us now.
Appendix A

October 2006 A-241 NUREG-1437, Supplement 27

O-8

MR. RICHARD: I know Mr. Bradley a welder who built it back in the 60s, oh yeah. |

|

MR. CAMERON: Okay, Ken, so if you could just make your main point for us. |

|

MR. RICHARD: Yeah, wrap it up. Questions |

about -- |

|

AUDIENCE: It's the last chance people have, let him speak. |

|

MR. RICHARD: -- the Palisades -- crane break down on October 11th. 55 hour shutdown with a |

110 casks containing spent fuel assemblies partially suspended broke in the air fell partly |

submerged over the fuel pool. |

|

The fuel pool went well beyond its original design capacity with fuel assemblies going back to |

the 70s. I gather from the Tribune article all the brakes froze because plant personnel did not |

set the emergency brake properly just before leaving for his vacation. |

|

How big a rem stream would this situation be giving off. How many rems the article certainly |

didn't say. Did the whole fuel pool area must have had, must have had to been |

decontaminated. How much did it receive. |

|

All that spent fuel at risk should that cask have dropped down onto decades where for spent |

fuel assemblies it would have caused a fire making for an accident much worse than Chernobyl. |

|

The article also pointed out this incident was considered of low significance by the NRC within |

its quarterly report. Quite a change from the NRC in the early 90s when dry storage cask |

storage was initiated at Palisades hearing the operators 30 violations for everything from |

cracked pipes to mishandled drop fuel assembly rods into its reactor vessel. Did they ever find |

the two pounds of missing fuel. |

|

To Palisades Conversation Group this incident further demonstrates the aged long time |

ineffectiveness of both the equipment and the personnel at the Palisades Plant right along with |

the current NRC not handing out violations for such -- |

|

This must have been some long term radiation being released for over two days within the flow |

through area. Were procedures fumbled, could not get their crane to budge for days because |

one brake froze and all the brakes shut down for 55 hours. What were the plant personnel |

doing scratching their heads. |

|

A further explanation of partly suspended a 110 pound metal inner cask leaves me with cause |

for concern as it did others, was not made clear in the article. |
Appendix A

NUREG-1437, Supplement 27 A-242 October 2006

| Just insistent that everything was okay. Just what is the shielding of a bare metal cask --

|

| MR. CAMERON: Ken, I'm going to have to ask 

| you --

|

| MR. RICHARD: -- that neutron thermal 

| shielding --

|

| MR. CAMERON: -- to wrap up -- 

|

| MR. RICHARD: -- that they're -- in the cask at the time.

|

| MR. CAMERON: Ken --

|

| AUDIENCE: Let him talk. 

|

| AUDIENCE: This needs to be answered in public record. This is the last chance he has.

|

| MR. CAMERON: He can submit his whole thing to us.

|

| AUDIENCE: We want to --

|

| AUDIENCE: We want -- 

|

| MR. CAMERON: Could you just please wrap up and then we're going to go to Corrine, okay.

|

| MR. RICHARD: We're wrapped up.

|

| MR. CAMERON: All right. Thank you. Corrine.

|

| MR. RICHARDS: Thank you.

|

| MS. CAREY: Will the volunteers for the Raging Grannies please come forward if you're

| available. You've seen this guy before. He was --

|

| MR. CAMERON: We have, we have.

|

| MS. CAREY: Yes. He's built as --

|

| MR. CAMERON: -- come up here again.

|

| MS. CAREY: -- a recycle but I added a couple touches here.
Appendix A

October 2006 A-243 NUREG-1437, Supplement 27

MR. CAMERON: All right. |

|

MS. CAREY: All right. Okay. I do encourage you to, yes, yes, all of you who would like to |

come, any honorary grannies are more than welcome. |

|

The, yes, I urge you to get the materials that are on these tables on the side. People look at |

these over here including some rare books. And do get this one which is the radioactive |

releases from nuclear power plants in the Great Lakes Basin including a picture down here of |

the Palisades Plant and it's, it's, yeah, it's discharge holes and a map etcetera of the Great |

Lakes area. |

|

And your very own picture of the current situation at the cask or the one that we heard about on |

March 18th. It happened in October. It made the federal reserve or the federal report to, yeah, |

register, in January. |

|

So yes we, we all question that. |

|

All right. So we are going to skip the one that says about -- this, the great region grannies are |

all over the country but they originated out in the Washington State area. There is another one |

the earth is going to throw up over, all over us. We'll skip that one. |

|

Give me a home where the rivers don't foam. But this one is, happens to be about the land of |

the beaver. Oh, I forget to use this. Now this is an example of how inadequate this kind of |

protection would be in a nuclear event, totally inadequate just like the fallout shelters of years |

back. |

|

So land of the beaver. Here in the land of the beaver (singing) they say we are nuclear free. |

We want to be happy believers but ask ourselves how can it be. |

|

There are nuclear ships in our harbors and the tridents are out in the straights. We have tested |

the crews, terriorized caribou's, do we look like the 51st state. |

|

They told us that we'd never do it. That no nuc mess would ever be found. But it's starting to |

look like we blew it and the bad stuff is spinning around. |

|

There are nuclear ships in our harbors and the tridents are out in the straights. We have tested |

the crews, terriorized caribou's maybe we'll be the dirtiest state. |

|

When business and George Bush are talking they put on their friendship display, big smiles, |

friendship display. |

|
Appendix A

NUREG-1437, Supplement 27 A-244 October 2006

EE-1

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| We wish they would do something shocking and have Georgie -- every state. We'll take nuclear

| ships from our harbors. We'll take tridents away from the straights. We'll not test the crews,

| terriorized caribou's and we won't be the dirtiest state. No, we won't be the dirtiest state neah,

| neah, neah.

|

| We won't be the dirtiest state, neah, neah, neah. And that includes Michigan so.

|

| MR. CAMERON: All right. Okay, thank you and Chester. 

|

| Mr. Paul Harden, site vice president at Palisades.

|

| MR. HARDEN: My name is Paul Harden. I'm the site vice president of Palisades Plant. And I'll

| focus my comments on the purpose of the meeting and that's the draft supplemental

| environmental impact statement.

|

| And I'd like to start off by commending the Nuclear Regulatory Commission on the scope and

| depth of that report. It's very comprehensive and Nuclear Management Company agrees with

| the conclusions although we may have some comments that are minor that we'll submit as well

| by the date none of which will affect the conclusions of the report.

|

| I'd like to spend a few minutes addressing the environmental impact of operating, continuing to

| operate the Palisades Nuclear Plant.

|

| But before I do that I'd like to recognize not all of us are ever going to agree whether nuclear

| power plants should exist. Not all of us are ever going to agree the public policy that this

| country has taken on how to deal with spent nuclear fuel. That's okay. That doesn't bother me.

|

| The fact that we have diverse people, diverse views and we have the freedom to speak our

| opinions is part of what makes this country great.

|

| What I would like to do is share a few facts.

|

| AUDIENCE: -- opinions and knowing --

|

| MR. CAMERON: Excuse me. 

|

| MR. HARDEN: Some of the facts --

|

| MR. CAMERON: Could we have the courtesy to just listen to the speaker. Thank you.

|

| MR. HARDEN: Some of the facts are the environmental responsibility is built into the design of

| nuclear power plants. There are multiple redundancies so that no single failures of whether it's
Appendix A

October 2006 A-245 NUREG-1437, Supplement 27

EE-4

EE-5

EE-6

human failure or equipment failures can cause incidents that would be adverse to the |

environment. |

|

There's environmental responsibility built into the way the plants are operated, the way they're |

managed and the regulatory oversight. The nuclear industry is one of the more heavily |

regulated and industries that has additional oversight that there are out there. And the |

inspectors do a very good job of challenging everything we do. |

|

Another fact is that in addition to continuously monitoring radiation levels on the site and |

monitoring all the release pathways from the site we go beyond that to verify that we're not |

having an adverse effect to the environment or the people that surround the plant. |

|

We regularly sample soil. We sample fish. We sample fruits. We sample cows milks to verify |

that there are no low or trace levels of radioactive material that could have come from the plant. |

And we do that on a regular basis. |

|

Another fact is that the employees that work at the Palisades Nuclear Plant over 600 employees |

they're also residents of the local areas. They raise their children here too and they have a |

deep respect and desire to keep the environment safe as well. They're just as concerned about |

their children as everyone else. |

|

Given that Consumers Energy and Nuclear Management Company are confident that we can |

operate Palisades Nuclear Plant and extend the license renewal period safely and with no |

adverse impact to the environment. |

|

That is why we are spending hundreds of millions of dollar each year as we proceed forward |

through the license renewal process upgrading the plant, changing the equipment. |

|

I heard some of the concerns in here with aging of equipment. In a nuclear power plant we are |

required to have what we call aging management programs. |

|

We do regularly change out components. Components that aren't changed out get inspected or |

tested to verify that they are in good condition to continue to operate. And if they start to |

degrade or the testing shows that there is degradation we change out those components to |

keep them going. |

|

I'm not up here to change the mind of anyone who is against nuclear power. But I do want to |

get those facts out. |

|

We agree that, with the conclusions of the draft report that there are no significant or adverse |

impacts of operating the Palisades Nuclear Plant in the continued license renewal period. |
Appendix A

NUREG-1437, Supplement 27 A-246 October 2006

| And if anyone would like to be educated on the facts or learn more about the plant I would be

| happy to discuss that with you. If you don't trust talking to someone who works for the plant I'd

| encourage you to talk to the Nuclear Regulatory Commission because nuclear power can be a

| safe and viable entity. 

|

| Everything we do in life has risks. It's a matter of agreement whether those risks are worth

| endeavoring whether it's a chemical plant, a coal plant or a nuclear plant. 

|

| But for the purpose of this meeting the draft environmental impact statement we agree with its

| conclusions and we look forward to operating the plant in a continued operating period.

|

| MR. CAMERON: Okay, thank you, thank you very much.

|
Appendix A

October 2006 A-247 NUREG-1437, Supplement 27

A.5 Letters and E-Mails Received on the Draft SEIS |

 
Appendix A

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Appendix A

NUREG-1437, Supplement 27 A-274 October 2006

GG-40

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Appendix A

October 2006 A-275 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-276 October 2006

GG-41

GG-42

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Appendix A

October 2006 A-277 NUREG-1437, Supplement 27

GG-43

GG-44

GG-45

GG-46

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Appendix A

NUREG-1437, Supplement 27 A-278 October 2006

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Appendix A

October 2006 A-279 NUREG-1437, Supplement 27

GG-47

GG-48

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Appendix A

NUREG-1437, Supplement 27 A-280 October 2006

GG-49

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Appendix A

October 2006 A-281 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-282 October 2006

GG-50

GG-51

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Appendix A

October 2006 A-283 NUREG-1437, Supplement 27

GG-52

GG-53

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Appendix A

NUREG-1437, Supplement 27 A-284 October 2006

GG-54

GG-55

GG-56

GG-57

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Appendix A

October 2006 A-285 NUREG-1437, Supplement 27

GG-58

GG-59

GG-60

GG-61

GG-62

GG-63

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Appendix A

NUREG-1437, Supplement 27 A-286 October 2006

GG-64

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Appendix A

October 2006 A-287 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-288 October 2006

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Appendix A

October 2006 A-289 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-290 October 2006

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Appendix A

October 2006 A-291 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-292 October 2006

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Appendix A

October 2006 A-293 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-294 October 2006

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Appendix A

October 2006 A-295 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-296 October 2006

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Appendix A

October 2006 A-297 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-298 October 2006

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Appendix A

October 2006 A-299 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-300 October 2006

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Appendix A

October 2006 A-301 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-302 October 2006

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Appendix A

October 2006 A-303 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-304 October 2006

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Appendix A

October 2006 A-305 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-306 October 2006

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Appendix A

October 2006 A-307 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-308 October 2006

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Appendix A

October 2006 A-309 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-310 October 2006

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Appendix A

October 2006 A-311 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-312 October 2006

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Appendix A

October 2006 A-313 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-314 October 2006

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Appendix A

October 2006 A-315 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-316 October 2006

HH-1

HH-2

HH-3

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Appendix A

October 2006 A-317 NUREG-1437, Supplement 27

II-1

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Appendix A

NUREG-1437, Supplement 27 A-318 October 2006

JJ-1

JJ-2

JJ-3

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Appendix A

October 2006 A-319 NUREG-1437, Supplement 27

JJ-4

JJ-5

JJ-6

JJ-7

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Appendix A

NUREG-1437, Supplement 27 A-320 October 2006

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Appendix A

October 2006 A-321 NUREG-1437, Supplement 27

KK-1

KK-2

KK-3

KK-5

KK-4

KK-6

KK-7

KK-8

KK-9

KK-11

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Appendix A

NUREG-1437, Supplement 27 A-322 October 2006

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Appendix A

October 2006 A-323 NUREG-1437, Supplement 27

LL-1

LL-2

LL-3

LL-4

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Appendix A

NUREG-1437, Supplement 27 A-324 October 2006

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Appendix A

October 2006 A-325 NUREG-1437, Supplement 27

MM-1

MM-2

MM-3

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Appendix A

NUREG-1437, Supplement 27 A-326 October 2006

MM-4

MM-5

MM-6

MM-7

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Appendix A

October 2006 A-327 NUREG-1437, Supplement 27

MM-8

MM-9

MM-10

MM-11

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Appendix A

NUREG-1437, Supplement 27 A-328 October 2006

MM-12

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Appendix A

October 2006 A-329 NUREG-1437, Supplement 27

NN-1

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Appendix A

NUREG-1437, Supplement 27 A-330 October 2006

NN-4

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Appendix A

October 2006 A-331 NUREG-1437, Supplement 27

NN-8

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Appendix A

NUREG-1437, Supplement 27 A-332 October 2006

NN-12

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Appendix A

October 2006 A-333 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-334 October 2006

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Appendix A

October 2006 A-335 NUREG-1437, Supplement 27

OO-1

OO-2

OO-3

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Appendix A

NUREG-1437, Supplement 27 A-336 October 2006

OO-15

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OO-20

OO-21

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Appendix A

October 2006 A-337 NUREG-1437, Supplement 27

OO-33

OO-34

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OO-37

OO-38

OO-39

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Appendix A

NUREG-1437, Supplement 27 A-338 October 2006

OO-50

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OO-52

OO-53

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Appendix A

October 2006 A-339 NUREG-1437, Supplement 27

PP-1

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Appendix A

NUREG-1437, Supplement 27 A-340 October 2006

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Appendix A

October 2006 A-341 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-342 October 2006

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Appendix A

October 2006 A-343 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-344 October 2006

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Appendix A

October 2006 A-345 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-346 October 2006

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Appendix A

October 2006 A-347 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-348 October 2006

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Appendix A

October 2006 A-349 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-350 October 2006

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Appendix A

October 2006 A-351 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-352 October 2006

QQ-1

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Appendix A

October 2006 A-353 NUREG-1437, Supplement 27

QQ-2

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Appendix A

NUREG-1437, Supplement 27 A-354 October 2006

RR-1

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Appendix A

October 2006 A-355 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-356 October 2006

SS-3

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Appendix A

October 2006 A-357 NUREG-1437, Supplement 27

TT-1

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Appendix A

NUREG-1437, Supplement 27 A-358 October 2006

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Appendix A

October 2006 A-359 NUREG-1437, Supplement 27

TT-12

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Appendix A

NUREG-1437, Supplement 27 A-360 October 2006

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Appendix A

October 2006 A-361 NUREG-1437, Supplement 27

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Appendix A

NUREG-1437, Supplement 27 A-362 October 2006

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Appendix A

October 2006 A-363 NUREG-1437, Supplement 27

UU-1

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Appendix A

NUREG-1437, Supplement 27 A-364 October 2006

UU-4

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Appendix A

October 2006 A-365 NUREG-1437, Supplement 27

UU-9

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Appendix A

NUREG-1437, Supplement 27 A-366 October 2006

UU-16

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Appendix A

October 2006 A-367 NUREG-1437, Supplement 27

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Appendix B

Contributors to the Supplement

October 2006 B-1 NUREG-1437, Supplement 27

Appendix B

Contributors to the Supplement

The overall responsibility for the preparation of this supplement was assigned to the Office of

Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission (NRC). The statement was

prepared by members of the Office of Nuclear Reactor Regulation with assistance from other

NRC organizations, Argonne National Laboratory, and Lawrence Livermore National

Laboratory.

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Bo Pham Nuclear Reactor Regulation Project Manager

Robert Schaaf Nuclear Reactor Regulation Project Manager

William Dam Nuclear Reactor Regulation Project Manager

Harriet Nash Nuclear Reactor Regulation Aquatic Ecology, Terrestrial Ecology

Leslie Fields Nuclear Reactor Regulation Cultural Resources

Jennifer A. Davis Nuclear Reactor Regulation Cultural Resources

Richard Emch Nuclear Reactor Regulation Health Physics

Alicia Williamson Nuclear Reactor Regulation Hydrology, Air Quality, Meteorology

Cristina Guerrero Nuclear Reactor Regulation Land Use, Socioeconomics

ARGONNE NATIONAL LABORATORY(a)

David Miller Team Leader

Ellen Moret Administrative Assistant

Michael Lazaro Air Quality, Meteorology

Konstance Wescott Alternatives, Cultural Resources

William Vinikour Aquatic Ecology

Halil Avci Health Physics

John Quinn Hydrology

Timothy Allison Land Use, Socioeconomics

Patricia Hollopeter Technical Editor

Kirk LaGory Terrestrial Ecology

LAWRENCE LIVERMORE NATIONAL LABORATORY(b)

Carol Kielusiak Cultural Resources

(a) Argonne National Laboratory is operated for the U.S. Department of Energy by the University of Chicago.

(b) Lawrence Livermore National Laboratory is operated for the U.S. Department of Energy by the University of

California.
 
Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to the Nuclear Management Company, LLC

Application for License Renewal of Palisades Nuclear Plant

October 2006 C-1 NUREG-1437, Supplement 27

Appendix C

Chronology of NRC Staff Environmental Review Correspondence

Related to the Nuclear Management Company, LLC

Application for License Renewal of Palisades Nuclear Plant 

This appendix contains a chronological listing of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and Nuclear Management Company, LLC (NMC), and other |

correspondence related to the NRC staff’s environmental review, under Part 51 of Title 10 of the |

Code of Federal Regulations (10 CFR Part 51), of NMC’s application for renewal of the

Palisades Nuclear Plant operating license. All documents, with the exception of those

containing proprietary information, have been placed in the Commission’s Public Document

Room, at One White Flint North, 11555 Rockville Pike (first floor), Rockville, Maryland, and are

available electronically from the Public Electronic Reading Room found on the Internet at the

following web address: http://www.nrc.gov/reading-rm.html. From this site, the public can gain

access to the NRC’s Agencywide Document Access and Management System (ADAMS), which

provides text and image files of NRC’s public documents in the Publicly Available Records

(PARS) component of ADAMS. The ADAMS accession numbers for each document are

included below.

March 22, 2005 Palisades, Applicant’s Environmental Report – Operating License

Renewal Stage (Accession No. ML050940449)

March 22, 2005 Letter from NMC to NRC, forwarding the application for renewal of the |

operating license for Palisades Nuclear Plant, requesting extension of

operating license for an additional 20 years

(Accession No. ML050940434)

April 6, 2005 Letter from NRC to NMC, “Receipt and Availability of the License

Renewal Application for the Palisades Nuclear Plant”

(Accession No. ML050960344)

April 7, 2005 E-mail from Britta Johnson, NMC, regarding U.S. Fish and Wildlife |

Service (FWS) correspondence (Accession No. ML051430125) |

April 7, 2005 E-mail from Britta Johnson, NMC, regarding State of Michigan

Department of History, Arts, and Libraries

(Accession No. ML051430130)
Appendix C

NUREG-1437, Supplement 27 C-2 October 2006

April 8, 2005 Letter from NRC to Ms. Lois Bemis, South Haven Memorial Library,

regarding Maintenance of Reference Material at the South Haven

Memorial Library at the Palisades Nuclear Plant, License Renewal

Application (Accession No. ML051100210)

April 12, 2005 Federal Register Notice of Receipt and Availability Regarding the

Renewal of Facility Operating License No. DPR-20 for an Additional

20-Year Period (70 FR 19104)

April 26, 2005 Letter from the Honorable Fred Upton, United States House of

Representatives, to NRC offering support for Palisades Nuclear Plant

license renewal (Accession No. ML051220248)

June 2, 2005 Letter from NRC to NMC transmitting, Determination of Acceptability

and Sufficiency for Docketing, Proposed Review Schedule, and

Opportunity for a Hearing Regarding the Application from Nuclear

Management Company, LLC for Renewal of the Operating License for

the Palisades Nuclear Plant (Accession No. ML051530122)

June 8, 2005 Federal Register Notice of Acceptance for Docketing of the

Application and Notice of Opportunity for Hearing Regarding the

Renewal of Facility Operating License No. DPR-20 for an Additional

20-Year Period (70 FR 33533)

June 20, 2005 Letter from NRC to NMC, forwarding Federal Register Notice of Intent

to Prepare an Environmental Impact Statement and Conduct Scoping

| Process for License Renewal for the Palisades Nuclear Plant

(Accession No. ML051710509)

June 27, 2005 Submittal from Kevin Kamps, providing comments regarding

Palisades Nuclear Plant license renewal application 

(Accession No. ML052420502)

June 30, 2005 Letter from NRC to Mr. Craig Czarnecki, FWS, Michigan Field Office,

“Request for List of Protected Species Within the Area Under

Evaluation for the Palisades Nuclear Plant License Renewal”

(Accession No. ML051820473)

June 30, 2005 Letter from NRC to Mr. Brian Conway, Michigan State Historic

Preservation Office (SHPO), “Palisades Nuclear Plant License

Renewal Review” (Accession No. ML051860359)
Appendix C

October 2006 C-3 NUREG-1437, Supplement 27

June 30, 2005 Letter from NRC to Mr. Don Klima, Director, Office of Federal Agency

Programs, Advisory Council on Historic Preservation, “Palisades

Nuclear Plant License Renewal Review”

(Accession No. ML051870009)

June 30, 2005 Letter from NRC to Mr. Gary L. Randall, Clerk of House, Michigan

House of Representatives, “Acknowledgment of Receipt of Your

Letter on the Applications for Renewal of the Operating Licenses for

Palisades Nuclear Plant and Donald C. Cook, Units 1 and 2, Nuclear

Plant” (Accession No. ML051820578)

July 7, 2005 Letter to Mr. Daniel J. Malone, Site Vice President, Palisades Nuclear

Plant, from the NRC, “Project Manager Change for the License

Renewal Environmental Review for Palisades Nuclear Plant”

(Accession No. ML051890081)

July 8, 2005 NRC meeting notice announcing public meeting in South Haven,

Michigan, on October 18, 2005, to discuss the environmental scoping

process for the application for the license renewal of Palisades

(Accession No. ML051920383)

July 13, 2005 Letter from NRC to the Honorable John A. Barrett, Chairperson,

Citizen Potawatomi Nation, Oklahoma, “Request for Comments

Concerning Palisades Nuclear Plant Application for Operating License

Renewal” (Accession No. ML051960002)

July 13, 2005 Letter from NRC to the Honorable Kenneth Meshigaud, Chairperson,

Hannahville Indian Community Council, “Request for Comments

Concerning Palisades Nuclear Plant Application for Operating License

Renewal” (Accession No. ML051950435)

July 13, 2005 Letter from NRC to the Honorable Robert Kewaygoshkum,

Chairperson, Grand Traverse Band of Ottawa and Chippewa Indians,

“Request for Comments Concerning Palisades Nuclear Plant

Application for Operating License Renewal”

(Accession No. ML051950495)

July 13, 2005 Letter from NRC to the Honorable Laura Spurr, Chairperson,

Nottawaseppi Huron Pottawatomi, “Request for Comments

Concerning Palisades Nuclear Plant Application for Operating License

Renewal” (Accession No. ML051950614)
Appendix C

NUREG-1437, Supplement 27 C-4 October 2006

July 13, 2005 Letter from NRC to the Honorable Lee Sprague, Ogema, Little River

Band of Ottawa Indians, “Request for Comments Concerning

Palisades Nuclear Plant Application for Operating License Renewal”

(Accession No. ML051960069)

July 13, 2005 Letter from NRC to the Honorable Frank Ettawageshik, President,

Little Traverse Bay Bands of Odawa Indians, “Request for Comments

Concerning Palisades Nuclear Plant Application for Operating License

Renewal” (Accession No. ML051950574)

July 13, 2005 Letter from NRC to the Honorable David K. Sprague, Chairperson,

Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians, “Request

for Comments Concerning Palisades Nuclear Plant Application for

Operating License Renewal” (Accession No. ML051950602)

July 13, 2005 Letter from NRC to the Honorable Floyd E. Leonard, Chief,

Miami Tribe of Oklahoma, “Request for Comments Concerning

Palisades Nuclear Plant Application for Operating License Renewal” 

(Accession No. ML051960027)

July 13, 2005 Letter from NRC to the Honorable Charles Todd, Chief,

Ottawa Tribe of Oklahoma, “Request for Comments Concerning

Palisades Nuclear Plant Application for Operating License Renewal”

(Accession No. ML051960011)

July 13, 2005 Letter from NRC to the Honorable John Miller, Chairperson,

Pokagon Band of Potawatomi Indians of Michigan, “Request for

Comments Concerning Palisades Nuclear Plant Application for

Operating License Renewal” (Accession No. ML051960173) 

July 13, 2005 Letter from NRC to the Honorable Audrey Falcon, Chief, Saginaw

Chippewa Indian Tribe of Michigan, “Request for Comments

Concerning Palisades Nuclear Plant Application for Operating License

Renewal” (Accession No. ML051960103)

July 15, 2005 Letter from Ms. Tonya Schuitmaker, Michigan House of

Representatives, providing comments regarding Palisades Nuclear

Plant license renewal application (Accession No. ML052420495)

July 28, 2005 Submittal from Kenneth Richards, providing comments regarding

Palisades Nuclear Plant license renewal application

(Accession No. ML052420501)
Appendix C

October 2006 C-5 NUREG-1437, Supplement 27

July 28, 2005 Letter from Nancy Ann Whaley, Supervisor, Geneva Township,

providing comments regarding Palisades Nuclear Plant license

renewal application (Accession No. ML052420497)

|

July 29, 2005 Letter to NRC from Mr. Craig Czarnecki, FWS, Michigan Field Office, |

“Endangered Species List Request, Proposed Palisades Nuclear

Plant (Palisades) License Renewal Project, Allegan, Berrien,

Kalamazoo, and Van Buren Counties, Michigan”

(Accession No. ML052650168)

August 18, 2005 Letter from Wayne Rendell, Supervisor, Covert Township, providing

comments regarding Palisades Nuclear Plant license renewal

application (Accession No. ML052420503)

August 19, 2005 Letter to NRC from Grant Smith, Cyndi Roper, Michael Keegan,

Alice Hirt, James Clift, Chuck Gordon, Maynard Kaufman, David Kraft,

Keith Gunter, Kevin Kamps, Mike Shriberg, and Thomas Leonard,

“Request for Extension for Comment Period on NRC’s Environmental

Reviews of the Palisades Nuclear Power Plant” (Accession No.

ML052380421)

August 20, 2005 Letter from Swami Tapasanarda, providing comments regarding

Palisades Nuclear Plant license renewal application

(Accession No. ML052420506)

August 20, 2005 Letter from Kathy Barnes, providing comments regarding Palisades

Nuclear Plant license renewal application

(Accession No. ML052510393)

August 22, 2005 Letter from Murielle and John Clark, providing comments regarding

Palisades Nuclear Plant license renewal application

(Accession No. ML052510389)

August 22, 2005 Letter from Kevin Kamps, Nuclear Information and Resource Service,

providing comments regarding Palisades Nuclear Plant license

renewal application (Accession No. ML052510468)

August 22, 2005 Letter from Gary Karch, providing comments regarding Palisades

Nuclear Plant license renewal application

(Accession No. ML052510391)
Appendix C

NUREG-1437, Supplement 27 C-6 October 2006

August 24, 2005 Letter to NMC from NRC, “Request for Additional Information (RAI)

Regarding Severe Accident Mitigation Alternatives (SAMAs) for the

| Palisades Nuclear Plant” (Accession No. ML052370327)

September 7, 2005 Letter from NRC to Mr. Kevin Kamps, Nuclear Information and

Resource Service, “Response to Request for Extension of

Environmental Scoping Comment Period Regarding the Palisades

| Nuclear Plant License Renewal” (Accession No. ML052410029)

September 21, 2005 Summary of Public Scoping Meetings to Support Review of Palisades

Nuclear Plant License Renewal Application

| (Accession No. ML052630426)

October 12, 2005 Letter from NRC to Dr. David R. Wade, Director, Michigan

Department of Community Health, Division of Environmental &

Occupational Epidemiology, “Request for Information on Cancer

Incidence Within the Area under Evaluation for the Palisades Nuclear

Plant License Renewal” (Accession No. ML052900205)

October 18, 2005 Letter from NMC to NRC, “Palisades Nuclear Plant, Response to

Supplemental Questions Concerning Radioactive Solid Waste

Management” (Accession No. ML053470428)

November 18, 2005 Letter from NMC to NRC, Supplement to “Response to NRC Request

for Additional Information dated August 24, 2005, dated October 21,

| 2005, and telecon on November 10, 2005A.1”

(Accession No. ML053470426)

| December 14, 2005 Letter from NRC to Mr. Daniel J. Malone, Site Vice President,

| Palisades Nuclear Plant, “Issuance of Environmental Scoping

| Summary Report Associated with the Staff’s Review of the Application

| by Nuclear Management Company, LLC, for Renewal of the

| Operating License for Palisades Nuclear Plant” 

| (Accession No. ML053490390)

| January 24, 2006 E-mail from J. Holthaus, Environmental Project Manager, NMC,

| Covert, Michigan, to B. Pham, Project Manager, NRC, Rockville,

Maryland, with attachments. Subject: “Palisades Cultural Resources

| Procedures.” Attachment 1: “Archaeological, Cultural and Historic

Resources,” FP-RP-ENV-01; Attachment 2: “Palisades Cultural

Resources,” LM-330. (Accession No. ML060240597)
Appendix C

October 2006 C-7 NUREG-1437, Supplement 27

February 14, 2006 Letter from NRC to U.S. Environmental Protection Agency, National

Environmental Policy Act Compliance Division, “Draft Supplement 27

to the Generic Environmental Impact Statement Regarding License

Renewal for Palisades Nuclear Plant” (Accession No. ML060450726) |

February 14, 2006 Letter from NRC to Mr. Daniel J. Malone, Site Vice President,

Palisades Nuclear Plant, “Notice of Availability of the Draft PlantSpecific Supplement 27 to the Generic Environmental Impact

Statement (GEIS) Regarding License Renewal for Palisades Nuclear

Plant” (Accession No. ML060450681) |

May 15, 2006 Letter to NRC from Mr. Michael T. Chezik, U.S. Department of the |

Interior, providing comments regarding Palisades Nuclear Power

Plant license renewal application (Accession No. ML061570025).

May 22, 2006 Letter to NRC from Mr. Kevin Kamps, Nuclear Information and |

Resources Service, response to request for comment period

extension regarding Palisades Nuclear Plant license renewal review |

(Accession No. ML061380030).

May 26, 2006 Letter to NRC from Mr. Kenneth A. Westlake, Chief,

U.S. Environmental Protection Agency, NEPA Implementation

Section, providing comments regarding Palisades Nuclear Plant

license renewal application (Accession No. ML061640114).

June 19, 2006 Letter to NRC from Ms. Martha MacFarlane Faes, Environmental

Review Coordinator, Department of History, Arts, and Libraries,

providing comments regarding Palisades Nuclear Plant license

renewal application (Accession No. ML061920480). |

September 5, 2006 E-mail from J. Holthaus, Environmental Project Manager, NMC, |

Covert, Michigan, to B. Pham, Project Manager, NRC, Rockville, |

Maryland. Subject: “Status of the Federally listed Pitcher’s Thistle |

(Cirsium pitcheri) on the Palisades Nuclear Plant Site” (Accession No. |

ML062480156). |

Appendix D

Organizations Contacted

October 2006 D-1 NUREG-1437, Supplement 27

Appendix D

Organizations Contacted

During the course of the U.S. Nuclear Regulatory Commission staff’s independent review of |

environmental impacts from operations during the renewal term, the following Federal, State,

regional, local, and Native American Tribal agencies were contacted: 

Advisory Council on Historic Preservation, Washington, D.C.

Citizen Potawatomi Nation, Shawnee, Oklahoma.

City of South Haven Water Filtration Plant.

Covert Township, Covert, Michigan.

Grand Traverse Band of Ottawa and Chippewa Indians, Suttons Bay, Michigan.

Hannahville Indian Community Council, Wilson, Michigan.

Little River Band of Ottawa Indians, Manistee, Michigan.

Little Traverse Bay Bands of Odawa Indians, Harbor Springs, Michigan.

Match-E-Be-Nash-She-Wish Band of Potawatomi Indians, Dorr, Michigan.

Miami Tribe of Oklahoma, Miami, Oklahoma.

Michigan Department of Community Health, Lansing, Michigan.

Michigan Department of Environmental Quality, Kalamazoo, Michigan.

Michigan Department of Environmental Quality, Lansing, Michigan.

Michigan Economic Development Corporation, Lansing, Michigan. 

Michigan State Historic Preservation Office, Lansing, Michigan.

Nottawaseppi Huron Potawatomi, Fulton, Michigan.
Appendix D

NUREG-1437, Supplement 27 D-2 October 2006

Ottawa Tribe of Oklahoma, Miami, Oklahoma.

Pokagon Band of Potawatomi Indians of Michigan, Dowagiac, Michigan.

Saginaw Chippewa Indian Tribe of Michigan, Mt. Pleasant, Michigan.

U.S. Fish and Wildlife Service, East Lansing, Michigan.

Van Buren-Cass Counties Health Department.
Appendix E

Nuclear Management Company, LLC’s

Compliance Status and Consultation Correspondence

October 2006 E-1 NUREG-1437, Supplement 27

Appendix E

Nuclear Management Company, LLC’s

Compliance Status and Consultation Correspondence

Correspondence received during the process of evaluation of the application for renewal of the

license for Palisades Nuclear Plant (Palisades) is identified in Table E-1. Copies of the

correspondence are included at the end of this appendix.

The licenses, permits, consultations, and other approvals obtained from Federal, State,

regional, and local authorities for Palisades are listed in Table E-2. 

Table E-1. Consultation Correspondence 

Source Recipient Date of Letter

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

Michigan State Historic Preservation

Office

(B. Conway)

June 30, 2005

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

U.S. Fish and Wildlife Service

(C. Czarnecki)

June 30, 2005

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

Advisory Council on Historic

Preservation 

(D. Klima)

June 30, 2005

U.S. Nuclear Regulatory

Commission (P.T. Kuo)

Citizen Potawatomi Nation

(J. Barrett) 

July 13, 2005(a)

U.S. Fish and Wildlife Service

(C. Czarnecki)

U.S. Nuclear Regulatory Commission

(P. T. Kuo)

July 29, 2005

U.S. Department of the Interior |

(M. Chezik) |

U.S. Nuclear Regulatory Commission May 15, 2006

U.S. Environmental Protection |

Agency (K.A. Westlake) |

U.S. Nuclear Regulatory Commission May 26, 2006

Michigan State Historic |

Preservation Office (M.M. Faes) |

U.S. Nuclear Regulatory Commission

(B. Pham)

June 19, 2006

(a) Similar letters were sent to 10 additional Native American Tribes listed in Appendix C.
Table E-2. Federal, State, Local, and Regional Licenses, Permits, Consultations, and Othe

| Approvals for the Palisades Nuclear Plant 

Agency Authority Description Number

Issue

Date

Expiration

Date 

NRC 10 CFR Part 50 Operating license,

Palisades NuclearPlant

DPR-20 03/24/71 03/24/11 Authorizes o

Nuclear Plan

FWS Section 7 of the Endangered

Species Act (16 USC 1536)

Consultation – – – Requires a F

consult with whether a praffect endanspecies

MDEQ Clean Water Act, Section 402

(33 USC Section 1251 et seq.),Michigan Act 451. Public Actsof 1994, as amended, Parts 31and 41, et. al.; MichiganExecutive Orders 1991-31,1995-4, and 1995-18.

NPDES permit M10001457 09/23/04 10/01/08 Discharge o

stormwater t

MDEQ Clean Air Act (42 USC 7401, et

seq.); Michigan Act 451, PublicActs of 1994 (as amended), Part55

RenewableOperating Permit (AirQuality)

200200005 02/04/03 02/04/08 Operation of 

emission soheating boileboiler, feedwemergency gcleaners).

NUREG-1437, Supplement 27 E-2 October 2006
Table E-2. (contd)

Agency Authority Description Number

Issue

Date

Expiration

Date R

MDEQ

Michigan Act 207. PublicActs of 1941, as amended,Section 5; Michigan ExecutiveOrder 1998-2

AbovegroundStorage TankRegistration

Facility No.91084220 (DieselTanks No. 1)

Annual Annual Storage of fla

combustible aboveground 

SCDHEC South Carolina Radioactive 

Waste Transportation andDisposal Act (Act No. 429 of1980.)

Radioactive WasteLicense for Delivery

0006-21-06 01/09/06 12/31/06

RenewedAnnually

Shipment of 

to a licensed facility within Carolina

TDEC Tennessee Code Annotated

68-202-206

Radioactive WasteLicense for Delivery

T-M 1003-L06 01/01/06 12/31/06 Shipment of 

to a licensed facility within Tennessee

– = A consultation is not given an identifying number and does not have an issue or expiration date.CFR = Code of Federal RegulationsFWS = U.S. Fish and Wildlife ServiceMDEQ = Michigan Department of Environmental QualityNPDES = National Pollutant Discharge Elimination SystemNRC = U.S. Nuclear Regulatory CommissionSCDHEC = South Carolina Department of Health and Environmental ControlTDEC = Tennessee Department of Environment and ConservationUSC = United States Code

October 2006 E-3 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-4 October 2006
Appendix E

October 2006 E-5 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-6 October 2006
Appendix E

October 2006 E-7 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-8 October 2006
Appendix E

October 2006 E-9 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-10 October 2006
Appendix E

October 2006 E-11 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-12 October 2006
Appendix E

October 2006 E-13 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-14 October 2006
Appendix E

October 2006 E-15 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-16 October 2006
Appendix E

October 2006 E-17 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-18 October 2006
Appendix E

October 2006 E-19 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-20 October 2006
Appendix E

October 2006 E-21 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-22 October 2006
Appendix E

October 2006 E-23 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-24 October 2006
Appendix E

October 2006 E-25 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-26 October 2006
Appendix E

October 2006 E-27 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-28 October 2006
Appendix E

October 2006 E-29 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-30 October 2006
Appendix E

October 2006 E-31 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-32 October 2006
Appendix E

October 2006 E-33 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-34 October 2006
Appendix E

October 2006 E-35 NUREG-1437, Supplement 27
Appendix E

NUREG-1437, Supplement 27 E-36 October 2006
Appendix F

GEIS Environmental Issues Not Applicable

to Palisades Nuclear Plant

1 (a) The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all

2 references to the “GEIS” include the GEIS and its Addendum 1.

October 2006 F-1 NUREG-1437, Supplement 27

Appendix F

GEIS Environmental Issues Not Applicable

to Palisades Nuclear Plant

Table F-1 lists those environmental issues listed in the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996, 1999)(a) and in Part 51 of |

Title 10 of the Code of Federal Regulations (10 CFR Part 51), Subpart A, Appendix B, |

Table B-1, that are not applicable to Palisades Nuclear Plant (Palisades) because of plant or

site characteristics.

Table F-1. GEIS Environmental Issues Not Applicable to Palisades

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

SURFACE-WATER QUALITY, HYDROLOGY, AND USE (FOR ALL PLANTS)

Impacts of refurbishment on surfacewater quality1 3.4.1 No refurbishment is planned

at Palisades.

Impacts of refurbishment on surfacewater use1 3.4.1 No refurbishment is planned

at Palisades.

Altered salinity gradients 1 4.2.1.2.2

 |

The Palisades cooling system

does not discharge to an

estuary. 

Water-use conflicts (plants with oncethrough cooling systems)1 4.2.1.3 Palisades does not use a

once-through cooling system.

Water-use conflicts (plants with cooling

ponds or cooling towers using makeup

water from a small river with low flow)

2 4.3.2.1 The Palisades cooling system

does not use makeup water |

from a small river with low

flow.
Appendix F

NUREG-1437, Supplement 27 F-2 October 2006

Table F.1 (contd)

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

AQUATIC ECOLOGY (FOR ALL PLANTS)

Refurbishment 1 3.5 No refurbishment is planned

at Palisades.

AQUATIC ECOLOGY

(FOR PLANTS WITH ONCE-THROUGH AND COOLING POND HEAT DISSIPATION SYSTEMS)

Entrainment of fish and shellfish in early

life stages

2 4.2.2.1.2

4.4.3

This issue is related to heatdissipation systems that are

not installed at Palisades.

Impingement of fish and shellfish 2 4.2.2.1.3

4.4.3

This issue is related to heatdissipation systems that are

not installed at Palisades.

Heat shock 2 4.2.2.1.4

4.4.3

This issue is related to heatdissipation systems that are

not installed at Palisades.

GROUNDWATER USE AND QUALITY

Impacts of refurbishment on groundwater

use and quality

1 3.4.2 No refurbishment is planned

at Palisades.

Groundwater-use conflicts (potable and

service water, and dewatering; plants that

use >100 gpm)

2 4.8.1.1

4.8.2.1

Palisades uses <100 gpm of

groundwater. 

Groundwater-use conflicts (plants using

cooling towers withdrawing makeup water

from a small river)

2 4.8.1.3

4.4.2.1

The Palisades cooling system

does not use makeup water

from a small river.
Appendix F

Table F.1 (contd)

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

October 2006 F-3 NUREG-1437, Supplement 27

Groundwater-use conflicts (Ranney wells) 2 4.8.1.4 Palisades does not have or |

use Ranney wells.

Groundwater-quality degradation (Ranney

wells)

1 4.8.2.2 Palisades does not have or

use Ranney wells.

Groundwater-quality degradation

(saltwater intrusion)

1 4.8.2.1 Palisades uses <100 gpm of

groundwater and is not

located near a saltwater

body.

Groundwater-quality degradation (cooling |

ponds in salt marshes)

1 4.8.3 This issue is related to heatdissipation systems that are

not installed at Palisades.

Groundwater-quality degradation (cooling |

ponds at inland sites)

2 4.8.3 Palisades is not located at an

inland site.

TERRESTRIAL RESOURCES

Refurbishment impacts 2 3.6 No refurbishment is planned

at Palisades.

Cooling-pond impacts on terrestrial |

resources

1 4.4.4 This issue is related to a

heat-dissipation system that

is not installed at Palisades.

AIR QUALITY

Air quality during refurbishment

(nonattainment and maintenance areas)

2 3.3 No refurbishment is planned |

at Palisades.
Appendix F

Table F.1 (contd)

ISSUE–10 CFR Part 51, Subpart A,

Appendix B, Table B-1 Category

GEIS

Sections Comment

NUREG-1437, Supplement 27 F-4 October 2006

HUMAN HEALTH

Radiation exposure to the public during

refurbishment

1 3.8.1 No refurbishment is planned

at Palisades.

Occupational radiation exposures during

refurbishment

1 3.8.2 No refurbishment is planned

at Palisades.

Microbial organisms (public health)

(plants using lakes or canals, or cooling

towers or cooling ponds that discharge to

a small river).

2 4.3.6 The Palisades cooling system

does not discharge to a small

river.

SOCIOECONOMICS

Public services, education (refurbishment) 2 3.7.4.1 No refurbishment is planned

at Palisades.

Offsite land use (refurbishment) 2 3.7.5 No refurbishment is planned

at Palisades.

Aesthetic impacts (refurbishment) 1 3.7.8 No refurbishment is planned

at Palisades.

F.1 References

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants: Main Report, Section 6.3 – Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report. NUREG-1437, Vol. 1, Addendum 1, Washington, D.C.
Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Palisades Nuclear Plant

in Support of License Renewal Application 

October 2006 G-1 NUREG-1437, Supplement 27

Appendix G

NRC Staff Evaluation of Severe Accident Mitigation Alternatives

(SAMAs) for Palisades Nuclear Plant

in Support of License Renewal Application 

Section 51.53(c)(3)(ii)(L) of Title 10 of the Code of Federal Regulations (10 CFR) requires that

license renewal applicants consider alternatives to mitigate severe accidents if the U.S. Nuclear |

Regulatory Commission (NRC) staff has not previously evaluated severe accident mitigation |

alternatives (SAMAs) for the applicant’s plant in an Environmental Impact Statement (EIS) or |

related supplement or in an environmental assessment. The purpose of this consideration is to

ensure that plant changes (i.e., hardware, procedures, and training) with the potential for

improving severe accident safety performance are identified and evaluated. SAMAs have not

been previously considered for Palisades Nuclear Plant (Palisades); therefore, the remainder of

Appendix G addresses those alternatives.

G.1 Introduction

Nuclear Management Company, LLC (NMC), submitted an assessment of SAMAs for Palisades |

as part of the Environmental Report (ER) (NMC 2005a). This assessment was based on the |

most recent Palisades Probabilistic Safety Assessment (PSA) available at that time, a plantspecific offsite consequence analysis performed using the MELCOR Accident Consequence

Code System 2 (MACCS2) computer program, and insights from the Palisades Individual Plant

Examination (IPE) (Consumers Power 1993) and Individual Plant Examination of External |

Events (IPEEE) (Consumers Power 1995). In identifying and evaluating potential SAMAs, NMC |

considered SAMA candidates that addressed the major contributors to core damage frequency

(CDF) and population dose at Palisades, as well as SAMA candidates for other operating plants

that have submitted license renewal applications. NMC identified 23 potential SAMA |

candidates. The list was reduced to eight unique SAMA candidates by eliminating SAMAs that |

are not applicable at Palisades because of (1) design differences; (2) the required extensive |

changes that would involve implementation costs known to exceed any possible benefit; (3) the

excessive dollar value associated with completely eliminating all internal and external event

severe accident risk at Palisades, or (4) having only effects on systems with low risk

significance based on the plant-specific PSA. NMC assessed the costs and benefits associated

with each of the potential SAMAs and concluded that several of the candidate SAMAs evaluated

would be cost-beneficial and warrant further review for potential implementation.

On the basis of a review of the SAMA assessment, the NRC issued a request for additional |

information (RAI) to NMC by letter dated August 24, 2005 (NRC 2005), and in a teleconference

with NMC on November 10, 2005. Key questions concerned peer reviews of the PSA and the |

potential impact of unresolved peer review comments; major plant and modeling changes
Appendix G

NUREG-1437, Supplement 28 G-2 October 2006

incorporated within each evolution of the PSA model; source term and economic assumptions

used in the Level 3 PSA; detailed information on some specific candidate SAMAs; and

consideration of additional lower cost SAMAs. NMC submitted additional information by letters

dated October 21, 2005 (NMC 2005b), and November 18, 2005 (NMC 2005c). In the

| responses, NMC provided summaries of PSA peer review comments and the resolution status

of each; a summary of the major changes made to each PSA model version and resultant

changes to dominant risk contributors to CDF; additional detail on source term and economic

assumptions used in the Level 3 PSA; additional information regarding specific SAMAs; and a

description of future plans for evaluating potentially cost-beneficial SAMAs. NMC’s responses

| addressed the NRC staff’s concerns and resulted in the identification of additional potentially

cost-beneficial SAMAs.

 

An assessment of SAMAs for Palisades is presented below.

G.2 Estimate of Risk for Palisades

NMC’s estimates of offsite risk at Palisades are summarized in Section G.2.1. The summary is

followed by the NRC staff’s review of NMC’s risk estimates in Section G.2.2.

G.2.1 NMC’s Risk Estimates

| Two distinct analyses were combined to form the basis for the risk estimates used in the SAMA

analysis: (1) the Palisades Level 1 and 2 PSA model, which is an updated version of the IPE

| (Consumers Power 1993), and (2) a supplemental analysis of offsite consequences and

economic impacts (essentially a Level 3 PSA model) developed specifically for the SAMA

| analysis. The SAMA analysis was based on the most recent Palisades Level 1 and Level 2

PSA model available at the time of the ER, referred to as PSA version PSAR1c. The scope of

the Palisades PSA does not include external events.

The baseline CDF for the purpose of the SAMA evaluation was approximately 4.05 x 10-5 | per

| year. The CDF was based on the risk assessment for internally initiated events. NMC did not

include the contribution from external events within the Palisades risk estimates; however, it did

account for the potential risk reduction benefits associated with external events by doubling the

estimated benefits for internal events. This is discussed further in Section G.6.2.

| Table G-1 provides the breakdown of CDF by initiating event. As shown in this table, events

| initiated by loss of offsite power (LOOP), small break loss-of-coolant accidents (LOCAs), and

steam generator tube rupture (SGTR) are the dominant contributors to CDF. The contribution of

internal flooding to the CDF is approximately 1.0 x 10-7 | per year (NMC 2005a).
Appendix G

October 2006 G-3 NUREG-1437, Supplement 27

Table G-1. Palisades Core Damage Frequency for Internal Events

Initiating Event

CDF

(per year)

% Contribution

to CDF

LOOP (including station blackout) 1.24 × 10 | -5 31

Small break LOCA 1.02 × 10-5 25

SGTR 6.06 × 10-6 15

General transient with main condenser available 2.94 × 10-6 7

Loss of instrument air 2.41 × 10-6 6

Loss of service water 1.84 × 10-6 5

Loss of main feedwater 9.07 × 10-7 2

Loss of the main condenser 6.46 × 10-7 2

Pressurizer safety valve spurious opening 4.08 × 10-7 1

Other Initiators 2.69 × 10-6 6

Total CDF (internal events) 4.05 × 10-5 100(a) |

(a) Total may not equal 100% because of rounding. |

The Level 2 Palisades PSA model is based on the original 1993 IPE submittal. Subsequent to

the IPE submittal, the containment event tree (CET) was updated to reflect improvements in the

state of knowledge on severe accidents and the implementation of a plant modification to

prevent early core relocation into the Palisades auxiliary building. The Level 2 PSA consists of

a detailed CET to represent dependencies among phenomenological assumptions. The CET |

was quantified by a relatively detailed process involving the development of probability |

distributions for a number of key phenomena, along with point estimate values for other issues. 

The CET end states were grouped into release categories by magnitude and timing of the |

expected releases. The result of the Level 2 PSA was a set of release categories with their |

respective frequency and release characteristics. The results of the updated analysis for

Palisades are provided in Table E.3-5 of the ER. The frequency of each release category was

obtained from the quantification of the CET for each Level 1 accident sequence. The release |

characteristics were obtained from the results of accident analyses of representative sequences

for each release category using the Modular Accident Analysis Program (MAAP) computer

code.

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and public. Inputs for this analysis

include plant-specific and site-specific input values for core radionuclide inventory, source term

and release characteristics, site meteorological data, projected population distribution (within a

50-mi radius) for the year 2031, emergency response evacuation modeling, and economic data. |

The core radionuclide inventory is based on Palisades plant-specific Oak Ridge Isotope |
Appendix G

NUREG-1437, Supplement 28 G-4 October 2006

| Generator (ORIGEN) calculations. In response to an RAI (NMC 2005b), NMC stated that the

core inventory calculations were developed in response to Generic Letter (GL) 2003-01

| concerning control room habitability (NRC 2003a) and represent best-estimate fuel cycle data

| for Palisades for 23 GWd/MTU, 18-month fuel cycles. The magnitude of the onsite impacts

| (in terms of cleanup and decontamination costs and occupational dose) is based on information

| provided in NUREG/BR-0184 (NRC 1997a).

| In response to an RAI (NMC 2005b), NMC estimated the dose to the population within 50 mi of

| the Palisades site to be approximately 31.9 person-rem per year. The breakdown of the total

population dose by containment release mode is summarized in Table G-2. Basemat failures

and SGTRs dominate the population dose risk at Palisades.

Table G-2. Breakdown of Population Dose by Containment Release Mode

|

Containment Release Mode

Population Dose

(Person-rem(a) | per year) % Contribution 

SGTR 7.6 23.9

Early containment failure 1.6 5

Intermediate containment failure 0 0

Late containment failure 0.3 0.9

Intact containment 0.6 1.9

Basemat failure 21.6 67.8

Containment isolation failure 0.2 0.6

| Total population dose 31.9 100(b)

| (a) One person-rem = 0.01 person-Sv.

| (b) Total may not equal 100% because of rounding.

| G.2.2 NRC Staff’s Review of NMC’s Risk Estimates

NMC’s determination of offsite risk at Palisades is based on the following three major elements

of analysis: 

C The Level 1 and 2 risk models that form the bases for the 1993 IPE submittal

| (Consumers Power 1993) and the original and revised IPEEE submittals (Consumers

| Power 1995, 1996).

| C The major modifications to the IPE model that have been incorporated into the Palisades

PSA, and
Appendix G

October 2006 G-5 NUREG-1437, Supplement 27

C The MACCS2 analyses performed to translate fission product source terms and release

frequencies from the Level 2 PSA model into offsite consequence measures.

Each of these analyses was reviewed to determine the acceptability of NMC’s risk estimates for

the SAMA analysis, as summarized below.

The Palisades PSA model evolved through several stages, starting with development of an

initial Level 1 PSA model in 1982 to address the risk associated with failing to satisfy single

failure design criteria with respect to the main steam isolation valves (MSIVs). This model was

subsequently updated and submitted to NRC in 1993 in response to GL 88-20 (NRC 1988). 

Palisades has several atypical design features that can affect accident progression. 

Consequently, instead of relying on the results of previous Level 2 PSAs, plant-specific, |

detailed, deterministic evaluations were performed in support of the IPE submittal for the key

severe accident phenomena. These evaluations included reviewing available experimental

data, as well as creating a plant-specific version of MAAP, version 3.0B, referred to as |

CPMAAP.

The NRC staff's review of the Palisades IPE is described in an NRC report dated February 7,

1996 (NRC 1996). On the basis of a review of the IPE submittal and responses to RAIs, the |

NRC staff concluded that the IPE submittal met the intent of GL 88-20 (NRC 1988); that is, the |

IPE was of adequate quality to be used to look for design or operational vulnerabilities. The

NRC staff, however, encouraged the licensee to improve the human reliability analysis “to make

it a valuable tool for other applications.”

Numerous revisions have been to the IPE model since its submittal. A comparison of internal |

events risk profiles between the IPE and the PSA used in the SAMA analysis indicates a

decrease of approximately 1.0 × 10-5 per year in the total internal events CDF (from 5.07 × 10-5 |

per year in the IPE to 4.05 x 10-5 per year in PSAR1c). The PSA updates have involved the |

examination of plant operating logs, corrective action documents, out-of-service time histories

for selected components, industry data, implemented plant modifications, model review

comments, and suggested peer review changes. A summary listing of those changes that

resulted in the greatest impact on the internal events CDF was provided in the ER (NMC 2005a) |

and further discussed in the response to an RAI (NMC 2005b). The major changes are

summarized in Table G-3.

The CDF values for Palisades are comparable to the CDF values reported in the IPEs for other

combustion engineering plants. Figure 11.6 of NUREG-1560 shows that the IPE-based total |

internal events CDF for combustion engineering plants ranges from approximately 1.0 × 10-5 per |

year to 2.0 x 10-4 per year, with an average CDF for the group of 7.0 × 10-5 per year

(NRC 1997c). It is recognized that other plants have updated the values for CDF subsequent to |

the IPE submittals to reflect modeling and hardware changes. The current internal events CDF 
Appendix G

NUREG-1437, Supplement 28 G-6 October 2006

Table G-3. Palisades PSA Historical Summary

PSA Version Summary of Changes from Prior Version

CDF

(per year)

IPE (1993) IPE submittal 5.07 × 10-5

| PSAR1 (1999)

|

|

| Moved the internal events CDF model from Set Equation

| Transformation System (SETS) to Systems Analysis Programs for

| Hands-On Integrated Reliability Evaluations (SAPHIRE)

5.95 × 10-5

PSAR1a (2000) Removed the auxiliary feedwater (AFW) alternate steam supply line

to AFW pump P-8B from the model to reflect a plant modification

5.47 × 10-5

| Updated the main steam line break and SGTR initiating event

frequencies

| Updated selected human error probabilities 

PSAR1b (2000) Updated selected common cause failure logic for control and

solenoid valves

6.18 × 10-5

|

| Incorporated a plant modification that swapped the high-pressure

air power supplies for motor control centers MCC-7 and MCC-8;

| added additional direct current (DC) bus faults and added certain

DC demand failure modes

|

|

Set the summertime emergency diesel generator heating,

ventilation, and air-conditioning system success criteria to True for

all nominal baseline calculations

Eliminated the independent anticipated transient without scram

(ATWS) event trees by transferring all event trees to a single ATWS

event tree

PSAR1b-modified

(2001)

| Corrected a conservative shutdown cooling heat exchanger

modeling assumption

6.16 × 10-5

PSAR1b-modified

| w/HELB (2002)

| Updated the model to include main steam line breaks in the

component cooling-water (CCW) rooms

6.24 × 10-5

PSAR1c (SAMA;

2004)

Corrected diesel generator repair/recovery logic 4.05 × 10-5

|

|

Added modeling of failure of the primary coolant pump seals,

inadvertent primary coolant system safety relief valve opening, and

failure of the AFW flow control valves to close

|

| Incorporated modifications to the plant recirculation actuation

system and instrument air compressor

| Removed modeling conservatism in the service-water header valve

logic
Appendix G

October 2006 G-7 NUREG-1437, Supplement 27

Table G-3. (contd)

PSA Version Summary of Changes from Prior Version

CDF

(per year)

PSAR1c (SAMA; |

2004) (contd) |

Modified modeling of fire protection system (FPS) makeup to AFW

pump P-8C logic to include failure of condensate storage tank T-2;

FPS logic to include reliance on traveling screens; condensate

pump logic to include availability of both the gland seal condenser

and air ejector after condenser rupture; CCW pumps P-52A, P-52B, |

and P-52C logic to include failures as a result of steam line breaks

outside of containment; and MSIV autoclose logic for “containment |

high pressure” and “low steam generator pressure” to correctly |

account for steam line break and LOCA event initiators

|

|

|

|

|

Updated common cause failure data

results for Palisades are comparable to the updated estimates for other plants of similar vintage

and characteristics.

The NRC staff considered the peer reviews performed for the Palisades PSA and the potential |

impact of the review findings on the SAMA evaluation. In the ER and in response to an RAI,

NMC described the Combustion Engineering Owners Group (CEOG) Peer Review of the PSA. 

The CEOG peer review of the PSAR1a model resulted in 9 Level A comments (important and

necessary to address before the next regular PSA update) and 50 Level B comments (important

and necessary to address, but disposition may be deferred until the next PSA update). The

resolution of the peer review comments is described in the ER (NMC 2005a) and in response to

an RAI (NMC 2005b). All Level A and Level B comments have either been addressed in the

PSAR1c model used for the SAMA analysis, or further evaluated and judged to have no

significant impact on the SAMA evaluation. .

Given that the Palisades PSA has been peer reviewed and the peer review findings have either

been addressed or judged to have no impact on the SAMA evaluation, that NMC has

satisfactorily addressed the NRC staff’s questions regarding the PSA (NMC 2005b), and that |

the CDF falls within the range of contemporary CDFs for combustion engineering plants, the |

NRC staff concludes that the Level 1 PSA model is of sufficient quality to support the SAMA

evaluation.

As indicated above, the current Palisades PSA does not include external events. In the

absence of such an analysis, NMC used the Palisades IPEEE in the SAMA analysis to identify

the highest risk accident sequences and the potential means of reducing the risk posed by

those sequences, as discussed below.
Appendix G

NUREG-1437, Supplement 28 G-8 October 2006

| NMC submitted an IPEEE by letter dated June 30, 1995 (Consumers Power 1995), in response

| to Supplement 4 of GL 88-20. NMC did not identify any fundamental weaknesses or

| vulnerabilities to severe accident risk in regard to the external events related to seismic, fire, or

other external events. However, a number of areas were identified for improvement in both the

seismic and fire areas and were subsequently addressed as discussed below. In a letter dated

November 29, 1999, the NRC staff concluded that the Palisades IPEEE met the intent of

| Supplement 4 to GL 88-20, and that the licensee’s IPEEE process is capable of identifying the

most likely severe accidents and severe accident vulnerabilities (NRC 1999). 

Palisades performed a relatively robust seismic analysis as part of the IPEEE. The seismic

analysis utilized the existing plant PSA with event trees specifically developed to evaluate

seismic events. The resulting seismic CDF was estimated as 8.88 x 10-6 per year

| (NMC 2005a), about 20 percent of the internal events CDF. While the seismic analysis did not

identify any significant seismic concerns, several insights were gained about the most important

equipment failures during and after seismic events. The IPEEE identified four groups of

| equipment that contributed most of the seismic CDF; specifically, the fire protection system

| (FPS), the MSIVs, the emergency diesel generator (EDG) fuel oil supply (storage tank T-10),

and the bus under-voltage relay for safety bus 1D. NMC reviewed these groups to identify

| potential SAMAs. For three of these contributors, no additional SAMAs were identified. That is,

(1) the FPS failures (and possible SAMAs) were already identified as important contributors to

the Class 1A and 1B sequences from the internal events analysis; (2) given MSIV modeling

more closely representing actual operation, MSIV seismic interactions would not be risk

significant; and (3) since EDG fuel storage tank T-10 is not necessary to support a 24-hour

mission duration, there is no measurable benefit to strengthening or replacing tank T-10. For

the fourth contributor, NMC identified that the under-voltage relay for bus 1D was important to

start the EDG, and a SAMA was added to the list of candidate SAMAs to replace this relay with

one that is less susceptible to seismic activity (i.e., SAMA 22).

| On the basis of consideration of important random failures in the Palisades seismic analysis,

NMC also identified the importance of EDG 1-2 during a seismic event because it provides

| power to auxiliary feedwater (AFW) pump P-8C, which is the only AFW pump with a seismically

durable water supply. Adding an electrical cross-tie to provide alternate power to this pump

(SAMA 9), which had been identified to address internal initiating events based on the PSA

results, was also identified as a plant improvement that would limit the impact of this random

failure.

The IPEEE also found that some relays were vulnerable to seismic activity and that some

equipment anchorage improvements were required. These were addressed as part of the

| closeout of unresolved safety issue (USI) A-46 (NRC 1997b), and all actions with respect to

USI A-46 have now been completed. The NRC review and closure of USI A-46 for Palisades is

documented in a letter dated September 25, 1998 (NRC 1998). Completion of the last item

| requiring resolution was documented in a letter to the NRC in June 2003 (NMC 2003).
Appendix G

October 2006 G-9 NUREG-1437, Supplement 27

Based on the licensee’s IPEEE efforts to identify and address seismic outliers and their

incorporation into the SAMA process, the NRC staff concludes that the opportunity for seismicrelated SAMAs has been adequately explored.

A revised internal fire analysis for the Palisades IPEEE was submitted in Revision 1 of the

IPEEE, dated May 31, 1996 (Consumers Power 1996). The internal fire analysis was revised |

as the Fire Protection Program and Appendix R analyses were in the process of being upgraded

when the original IPEEE was submitted (Consumers Power 1995). The Palisades fire analysis |

was based on the Electric Power Research Institute’s (EPRI’s) fire-induced vulnerability |

evaluation (FIVE) methodology. The methodology employs a graduated focus on the most

important fire zones using qualitative and quantitative screening criteria (EPRI 1992). The fire

zones or compartments were subjected to at least two screening phases. In the first phase, a

compartment was screened out if it was found to not contain any equipment or cables

associated with safe shutdown or an initiating event. In the second phase, the licensee used

the IPE model of internal events to estimate the CDF resulting from a fire initiating event. The

conditional core damage probability associated with each fire compartment was based on the

equipment and systems unaffected by the fire. The CDF for each compartment was obtained

by multiplying the frequency of a fire in a given fire compartment by the conditional core damage

probability associated with that fire compartment. The most important fire areas/rooms

identified in Revision 1 of the IPEEE are the cable spreading room, the control room, the 1D

switchgear room, the turbine building, and the 1C switchgear room. The resulting fire CDF was

estimated as 3.31 x 10-5 per year (NMC 2005a), about 80 percent of the internal events CDF.

Revision 1 of the IPEEE fire document also provides a summary of the most important |

contributors to each of the accident classes. NMC used the event rankings within these

categories to identify the largest contributors to risk and to identify additional SAMAs to prevent |

or mitigate the loss of functions represented by these events. For example:

C The contribution from failures to initiate once-through cooling following a successfully |

suppressed fire, failures of AFW pump P-8B, or random failures of the AFW system |

could all be mitigated by providing an alternate means of secondary heat removal. The

installation of a direct drive diesel-driven injection pump (DDDIP) to back up the AFW |

system was identified by NMC to address these failures and was included as SAMA 3. |

The DDDIP also provides long-term steam generator makeup, assuming a portable |

generator is included.

C Failure to control AFW steam supply or injection could be mitigated by enhancing

primary side cooling. The addition of another high-pressure injection (HPI) pump or the |

conversion of AFW pump P-8C back to a high-pressure safety injection (HPSI) pump |

was identified to address these failures and included as SAMA 4.
Appendix G

NUREG-1437, Supplement 28 G-10 October 2006

C Station blackout (SBO) sequences were identified as important contributors in the

| Level 1 model. A SAMA to proceduralize the use of a steam-driven AFW pump to

operate without support systems was included to address these events (SAMA 10).

| Each of these SAMAs had also been identified to address internal initiating events established

| on the basis of the PSA results.

The licensee noted that in the IPEEE fire analysis, operator action was required to manually

| open subcooling valves to the suction of the HPSI pumps after the recirculation actuation signal

to ensure adequate HPSI net positive suction head, and that the alignment of these valves was

subsequently automated. The hardware modification addressed the importance of the action to

| align the subcooling valves; accordingly, no additional SAMAs were suggested for this

contributor.

| On the basis of the licensee’s IPEEE efforts to identify and address internal fire outliers and

their incorporation into the SAMA process, the NRC staff concludes that the opportunity for

internal fire-related SAMAs has been adequately explored.

Other external events considered in the IPEEE included high wind events, external flooding,

transportation, and nearby facility accidents. The risk associated with these events is small,

with the total CDF from other external events about 1.0 × 10-6 per year. The licensee reviewed

the insights from previous assessments of these events performed as part of the NRC

Systematic Evaluation Program and the IPEEE, and considered the potential for additional

SAMAs to reduce these risks. A detailed discussion is provided in Section E.5.1.6 of the ER. 

NMC concluded that no further modifications would be cost-beneficial. It is noted that the risks

from deliberate aircraft impacts were explicitly excluded since this was being considered in

other forums along with other sources of sabotage.

In light of the external events CDF being approximately equal to the internal events CDF, NMC

doubled the benefit that was derived from the internal events model to account for the

contribution from external events. This doubling was not applied to the one SAMA that

specifically addressed seismic risks (i.e., SAMA 22), since this SAMA is specific to only seismic

risk and does not have a corresponding risk reduction in internal events. However, this

doubling was applied to those SAMAs that addressed both fire or seismic and internal events

(i.e., SAMAs 3, 4, 9, and 10), since these SAMAs do have a corresponding risk reduction in

| internal events. The fire risk analysis is described in the IPEEE and in the ER as producing

conservative CDF results. While conservative assumptions were used for the majority of fire

areas, other aspects of the analysis were considered to be optimistic (NRC 1999). Thus, the

degree of conservatism in the result is not clear. Furthermore, the risks due to external events

| that are discussed above are the results of analyses that were performed at varying times prior

to the current Palisades internal events PSA. The methodologies also vary in the degree of

completeness and conservatism. Consequently, the results cannot be directly compared with
Appendix G

October 2006 G-11 NUREG-1437, Supplement 27

those from the current PSA. Not withstanding the above, the NRC staff agrees with the

applicant’s conclusion that the risk posed by external events is approximately equal to that due

to internal events. Therefore, the NRC staff concludes that the applicant’s use of a multiplier of

2 to account for external events is reasonable for the purposes of the SAMA evaluation. |

The NRC staff reviewed the general process used by NMC to translate the results of the Level 1

PSA into containment releases, as well as the results of this Level 2 analysis. NMC |

characterized the releases for the spectrum of possible radionuclide release scenarios using a

set of six release categories, defined on the basis of the timing and magnitude of the release. |

The frequency of each release category was obtained from the quantification of a linked

Level 1-Level 2 model, which effectively evaluates a CET for each Level 1 accident sequence. |

Each end state from the Level 2 analysis is assigned to one of the release categories. The

process for assigning accident sequences to the various release categories and selecting a

representative accident sequence for each release category is described in the ER. The

release categories and their frequencies are presented in Section E.2.5.5 of the ER

(NMC 2005a), as are the source terms used for the SAMA evaluation based on the MAAP 3.0B

computer code. The NRC staff concludes that the process used for determining the release

category frequencies and source terms is reasonable and appropriate for the purposes of the

SAMA analysis.

In response to an RAI (NMC 2005b), NMC identified that the core inventory used for the

Palisades MACCS2 analysis was based on plant-specific data, and that fuel cycle parameters

were best estimates and consistent with expected Palisades fuel cycles. The NRC staff |

concludes that the best plant-specific estimate provides a reasonable basis for estimating the

reactor core radionuclide inventory in the consequence assessment.

The NRC staff reviewed the process NMC used to extend the containment performance |

(Level 2) portion of the PSA to an assessment of offsite consequences (essentially a Level 3

PSA). This included consideration of the major input assumptions used in the offsite

consequence analyses. The MACCS2 code was utilized to estimate offsite consequences. 

Plant-specific input to the code includes the source terms for each release category and the

reactor core radionuclide inventory (both discussed above), site-specific meteorological data, |

projected population distribution within a 50-mi radius for the year 2031, emergency evacuation |

modeling, and economic data. This information is provided in Appendix E of the ER

(NMC 2005a).

NMC used a composite set of site-specific meteorological data obtained from the plant |

meteorological tower and the nearby Benton Harbor Ross Field National Weather Station

(for hourly precipitation). The data were processed from hourly measurements for the |

2000 calendar year as input to the MACCS2 code. The data for 2000 were nearly complete, |

missing only 4 hours of scattered data. Data from these locations and from this year were |

selected because they provided an adequate representation of the Palisades meteorological |
Appendix G

NUREG-1437, Supplement 28 G-12 October 2006

| data. Site meteorological data for 2001, 2002, and 2003 were also evaluated as sensitivity

| cases to ensure that the 2000 data composed a representative data set. Population dose and

| economic costs were only minimally impacted (less than 8 percent change) because of the use

| of different data sets. The meteorological data for 2000 were found to result in the highest

| population dose and economic costs, and were therefore chosen as the basis for the SAMA

analysis. The NRC staff notes that previous SAMA analyses results have also shown little

| sensitivity to year-to-year differences in meteorological data and considers use of the 2000 data

to be reasonable.

| The population distribution that the applicant used as input to the MACCS2 analysis was

| estimated for 2031, based on extrapolation from U.S. Census population data for 1990 and

| 2000. U.S. Census data from 1990 and 2000 were used to determine a total annual average

population growth rate (1.1 percent per year). It was assumed that the growth rate would

remain the same as that reported between 1990 and 2000. The annual population growth was

| applied uniformly to all sectors to calculate the 2031 population distribution. A population

| sensitivity case was performed by using a 30 percent uniform increase in population for all

sectors. The 30 percent population case showed about a 20 percent change in population dose

and about a 50 percent change in cost risk. The NRC staff considers NMC's methods and

| assumptions for estimating population doses reasonable and acceptable for purposes of the

SAMA evaluation.

| The emergency evacuation model assumed a single evacuation zone extending out 10 mi from

the plant. It was assumed that 95 percent of the population would move at an average speed of

| approximately 0.81 m/s with a delayed start time of 15 to 30 minutes (NMC 2005a). This

assumption is conservative relative to the NUREG-1150 study (NRC 1990), which assumed

evacuation of 99.5 percent of the population within the emergency planning zone. Two

evacuation sensitivity cases were performed, one with an evacuation speed of 0.41 m/s

| (a factor of 2 decrease), and one with a 90-minute delay. The results demonstrated that the

population dose and economic costs are relatively insensitive to this parameter. The

evacuation assumptions and analysis are deemed reasonable and acceptable for the purposes

of the SAMA evaluation. 

| Much of the site-specific economic data were provided from SECPOP2000 (NRC 2003b) by

| specifying the data for each of the counties surrounding the plant, to a distance of 50 mi. In

addition, generic economic data that are applied to the region as a whole were revised from the

MACCS2 sample problem input when better information was available. The agricultural

economic data were updated using available data from the 1997 Census of Agriculture

(USDA 1998). These included per diem living expenses, relocation costs, value of farm and

| nonfarm wealth, and fraction of farm wealth from improvements (e.g., buildings). In response to

an RAI, NMC provided additional information on several economic parameter input values used

in the MACCS2 calculations.
Appendix G

October 2006 G-13 NUREG-1437, Supplement 27

The NRC staff concludes that the methodology NMC used to estimate the offsite consequences |

for Palisades provides an acceptable basis from which to proceed with an assessment of risk

reduction potential for candidate SAMAs. Accordingly, the NRC staff based its assessment of

offsite risk on the CDF and offsite doses reported by NMC. 

G.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by NMC are discussed in this section.

G.3.1 Process for Identifying Potential Plant Improvements

NMC’s process for identifying potential plant improvements (SAMAs) consisted of the following

elements:

C Review of the most significant basic events from the Palisades PSAR1c Levels 1 and 2 |

PSA; |

C Review of potentially cost-beneficial SAMAs from license renewal applications for six |

other U.S. nuclear sites; |

C Review of potential plant improvements identified in the Palisades IPE and IPEEE; and |

C Review of the dominant fire areas and seismic risk contributors, and SAMAs that could |

reduce the associated fire and seismic risk at Palisades.

To provide consistency with previous industry SAMA analyses and to provide a recognized |

source of ideas for the types of enhancements that could be proposed to address plant-specific

insights, NMC also reviewed a generic list of 266 SAMAs developed from previous industry

SAMA analyses.

On the basis of this process, an initial set of 23 candidate SAMAs, referred to as Phase 1 |

SAMAs, was identified. In Phase 2 of the evaluation, NMC performed a qualitative screening of

the initial list of SAMAs and eliminated SAMAs from further consideration using the following

criteria:

C The SAMA is not applicable at Palisades because of design differences; |

C The SAMA requires extensive changes that would involve implementation costs known |

to exceed any possible benefit; or
Appendix G

NUREG-1437, Supplement 28 G-14 October 2006

| C The SAMA costs more than $5.6 million to implement (the modified maximum averted

cost-risk (MMACR), which represents the dollar value associated with completely

eliminating all internal and external event severe accident risk at Palisades).

| Based on this screening, 14 SAMAs were eliminated, leaving 9 for further evaluation. These

remaining SAMAs, referred to as Phase 2 SAMAs, are listed in Table E.5-4 of the ER

(NMC 2005a). During the initial stage of the Phase 2 evaluation, NMC qualitatively screened

out one of the nine remaining SAMA candidates based on plant-specific insights regarding the

low risk significance of systems affected by the SAMA (i.e., SAMA 17), bringing the number of

remaining SAMAs to eight. A detailed cost-benefit analysis was performed for each of the eight

remaining SAMA candidates. To account for the potential impact of external events, the

| estimated benefits based on internal events were multiplied by a factor of 2 (except for the

SAMA specific to seismic risk, since this SAMA would not have a corresponding benefit on the

risk from internal events).

NMC also assessed the impact on initial screening if the MMACR were based on a 3 percent

discount rate rather than 7 percent, or if the MMACR were increased by a factor of 2.3 to reflect

the potential impact of uncertainties. As a result, four additional SAMAs would have been

retained for the Phase 2 analyses. These SAMAs are discussed further in Section G.6.2.

G.3.2 Review of NMC’s Process

NMC’s efforts to identify potential SAMAs focused primarily on areas associated with internal

initiating events, but also included explicit consideration of SAMAs for seismic and fire events. 

The initial list of SAMAs generally addressed the accident sequences considered to be

important to CDF and population dose from functional, initiating event, and risk reduction worth

| (RRW) perspectives at Palisades, and included selected SAMAs from other plants.

A preliminary review of NMC’s SAMA identification process raised some concerns regarding the

set of 23 SAMAs evaluated in the initial screening and how this set relates to the generic list of

266 SAMAs developed from industry sources. In response to an RAI, NMC clarified that the

generic list of 266 SAMAs was used only as a source of ideas for the types of enhancements

that could be proposed to address the plant-specific risk insights for Palisades (NMC 2005b).

| In its ER (NMC 2005a), NMC provided a list of basic events ranked by RRW for both CDF

(Level 1 PSA) and population dose (Level 2 PSA). For the Level 1 importance list, NMC

considered all basic events with a RRW greater than 1.01. For the Level 2 importance list, NMC

reviewed a composite file composed of those basic events representing the top 97 percent of all

| population doses and again considered all basic events with a RRW greater than 1.01. NMC

correlated the top risk contributors to CDF and population dose with the SAMAs evaluated in the

| ER. The two tables provided basic event identifiers, RRW, and potential SAMAs for each basic

event. Two events in the CDF importance list (Table E.5-1 of the ER) were estimated by the
Appendix G

October 2006 G-15 NUREG-1437, Supplement 27

NRC staff to have a very large risk achievement worth (e.g., RXC-MECH-FAULTS and RXC- |

ELEC-FAULTS). In the case of mechanical faults alone, the NRC staff estimated that an orderof-magnitude increase in the failure probability would increase the CDF to 6.8 x 10-5 per year. 

The NRC staff requested an NMC assessment of whether a SAMA is warranted to ensure that |

these subsystems do not degrade (NRC 2005). In its response, NMC agreed that there may be |

demonstrable value in assuring that there is no degradation in performance over time. 

However, given the significant routine testing that already is required by existing plant

procedures, NMC stated that what would be considered appropriate as a SAMA has already

been implemented at Palisades (NMC 2005b). On the basis of this information, the NRC staff |

concludes that the set of SAMAs evaluated in the ER addresses the major contributors to CDF

and offsite dose, and that the review of the top risk contributors does not reveal any new

SAMAs.

NMC identified Palisades-specific candidate SAMAs for seismic and fire events using a

combination of the Palisades PSA models and insights from the IPEEE. As a result, one SAMA

related specifically to seismic events was identified and retained for evaluation. Furthermore,

four SAMAs already identified and retained for evaluation to address internal initiating events

were also recognized as being effective in seismic and fire events. Potential plant

enhancements for other external events (high wind events, external flooding and probable

maximum precipitation events, and transportation and nearby facility accidents) were

determined to be too costly, sufficiently addressed by existing plant features/capabilities, or

already addressed by an existing SAMA. The NRC staff considers the applicant’s rationale for

eliminating these enhancements from further consideration to be reasonable.

The NRC staff questioned NMC about several candidate SAMAs that were identified as

potentially cost-beneficial at other combustion engineering plants but not addressed by NMC |

(NRC 2005). In response, NMC provided an assessment of the applicability/feasibility of each

of these enhancements and concluded that most of these SAMAs would not be warranted at

Palisades because they are not applicable to Palisades, would not provide a significant benefit |

at Palisades, or are already addressed by existing SAMAs for Palisades (NMC 2005b,c). |

However, NMC determined that two of the NRC-staff-identified enhancements could be |

applicable to Palisades. These enhancements are as follows:

C Add the capability to flash the field on the EDG to enhance SBO recovery, and |

C Replace an existing air-operated containment sump valve with a motor-operated valve to |

reduce common cause failures.

NMC did not provide a further assessment of these SAMAs as part of its response, but instead, |

indicated that these two SAMAs have been entered into the Palisades corrective action system

for further review and, if determined to be cost-beneficial, they will be further evaluated for

possible implementation in accordance with Palisades plant design processes (NMC 2005c). |
Appendix G

NUREG-1437, Supplement 28 G-16 October 2006

The NRC staff requested further justification from NMC concerning the elimination of three

SAMAs as part of the Phase 1 screening (NRC 2005). The qualitative arguments presented for

eliminating these SAMAs were either incomplete, unclear, or unconvincing to the NRC staff. In

| its response to the RAIs, NMC provided further information (NMC 2005b). The NRC staff’s

| concern and NMC’s response for each of the three SAMAs are discussed below:

| C SAMA 12 – automate boron injection for anticipated transient without scram (ATWS)

| conditions. NMC eliminated this SAMA because it is a boiling-water reactor mitigation

| feature that is not applicable to a pressurized-water reactor. The NRC staff then

| questioned why it was identified as a modification to the existing chemical volume

| control system injection system to reduce ATWS sequences. In its response, NMC

noted that the basic events impacted by this SAMA were conservatively modeled in the

| PSA, thus artificially increasing their RRW importance measure. NMC reevaluated the

| RRWs, considering both updated reliability data and hardware changes made at

Palisades in the 1990s, and showed that none of the basic events would be above the

| 1.01 RRW threshold for SAMA consideration. On the basis of this, SAMA 12 was

screened from further consideration in the final evaluation.

| C SAMA 19 – provide an HPI suction cross-tie to the opposite heat exchanger. This

| SAMA specifically addresses failures of the HPSI pump suction subcooling valves

between the heat exchangers and the HPI pumps, and was eliminated by NMC because

failure of these same valves is addressed by SAMA 17. The NRC staff questioned

whether the two different sets of plant enhancements would accomplish the same effect

| since each of these SAMAs addresses different initiating events. In its response, NMC

noted that the basic events impacted by this SAMA were conservatively modeled in the

| PSA, thus artificially increasing their RRW importance measure. NMC indicated that, if

containment integrity is preserved, adequate net positive suction head is available

| regardless of the state of the two HPSI pump suction subcooling valves. Given that the

conditional likelihood of containment failure is about 1 × 10-2, the importance of these

| valve failures is actually much less than the current PSA model results. On the basis of

| this, SAMA 19 was screened from further consideration in the final evaluation.

| C SAMA 20 – improve performance of the traveling screens. NRC eliminated this SAMA

based on the assumption that existing plant procedures were adequate to prevent

traveling screen failure. The NRC staff questioned whether this was a good assumption

| given the potential for human error during procedure implementation. In its response,

| NMC noted that the current analysis does not include a human error. NMC reevaluated

the RRW by incorporating the impact of human error and showed that the event would

| be below the 1.01 RRW threshold for SAMA consideration. On the basis of this,

SAMA 20 was screened from further consideration in the final evaluation.
Appendix G

October 2006 G-17 NUREG-1437, Supplement 27

The NRC staff considers the applicant’s rationale for eliminating these three enhancements

from further consideration to be reasonable.

On the basis of the initial screening, NMC eliminated SAMAs 1, 15, and 18 from further |

consideration because their implementation cost was estimated to exceed the MMACR. The

NRC staff identified possible lower cost alternatives for these SAMAs and requested that NMC

provide an evaluation of these alternatives (NRC 2005). In its response, NMC provided further

information (NMC 2005b):

C SAMA 1 – This SAMA involves installing an additional EDG. The NRC staff questioned |

whether there were lower cost alternatives such as providing nonsafety-grade backup |

power from the gas turbine generating facility co-located near the Palisades Plant or

installation of a nonsafety-grade diesel generator. NMC responded that it had previously |

looked into the possibility of an agreement with the gas facility to reduce plant risk from

SBO events. However, the gas plant is operated as a peaking unit, is online only when

there is a need for additional power, and does not have a black start capability. This

alternative is therefore not considered feasible. Relative to the installation of a

nonsafety-grade diesel generator, NMC noted that 87 percent of the CDF from LOOP |

events is associated with the dominant SBO scenario. While SAMA 1 was identified to

address the broad category of LOOP events, SAMA 10 was developed as a mitigating

strategy to deal specifically with the SBO scenario. NMC’s position is that SAMA 10 is a

lower cost alternative to the nonsafety-grade EDG and will provide a significant |

percentage of the expected benefit of SAMA 1. However, NMC did commit to

conducting an evaluation to determine the potential risk reduction and cost benefit of |

installing a nonsafety-grade diesel generator as a lower cost alternative to an additional |

EDG, subsequent to the evaluation of SAMA 10, and has entered this action into the

Palisades corrective action program for further review. If determined to be costbeneficial, the lower cost alternative will be evaluated for possible implementation in

accordance with Palisades plant design processes (NMC 2005c).

C SAMA 15 – This SAMA involves adding a bypass line around the safety injection and |

refueling water tank (SIRWT) return lines. Adding this line would increase the number of

potential leakage paths for contaminated containment sump water back to the SIRWT

during the recirculation phase of an accident. Because of the proximity of the SIRWT |

vent to the main control room heating, ventilation, and air-conditioning (HVAC) normal |

intakes, this SAMA would increase the control room dose consequences significantly |

during an accident, thereby requiring plant modifications to the control room HVAC if |

implemented. The NRC staff questioned whether there were lower cost alternatives that

would eliminate the need to modify the main control room HVAC system, such as locking |

open one of the return line valves as an alternative to adding a bypass line. NMC

responded that the recirculation line valves perform two distinct functions, and that they |

are required to be open during the injection phase and closed when the SIRWT level
Appendix G

NUREG-1437, Supplement 28 G-18 October 2006

falls to the low-low setpoint. Improving the probability of opening by locking open one of

the valves would increase the probability of failure of the isolation function. Accordingly,

locking open one valve is not considered a viable option. However, NMC also indicated

| that Palisades is currently in a study phase with respect to GL 2003-01 (NRC 2003a)

and Generic Safety Issue 191 (“Assessment of Debris Accumulation on PWR Sump

| Performance”), in which the performance of these valves is being analyzed. Required

actions in response to these issues will override any changes considered solely for

SAMA. Based on this, SAMA 15 was screened from further consideration in the final

evaluation.

| C SAMA 18 – This SAMA involves installing a permanent, dedicated pump and line to the

EDGs to serve as the primary EDG cooling source. The NRC staff questioned whether

there were lower cost alternatives such as installing an additional line or temporary

| connection directly from the FPS and bypassing the service-water lines. NMC did not

| provide a further assessment of these SAMAs as part of its response, but instead

| committed to conducting an evaluation to identify a lower cost alternative, and has

entered this action into the Palisades corrective action system program for further

review. If determined to be cost-beneficial, the lower cost alternative will be evaluated

for possible implementation in accordance with Palisades plant design processes

(NMC 2005c).

The NRC staff considers NMC’s rationale for eliminating SAMA 15 from further consideration to

| be reasonable, and NMC’s commitment to further evaluate lower cost alternatives for SAMAs 1

and 18 through the Palisades corrective action program to be acceptable.

The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional,

possibly even less expensive, design alternatives can always be postulated. However, the NRC

staff concludes that the benefits of any additional modifications are unlikely to exceed the

benefits of the modifications evaluated and that the alternative improvements would not likely

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated

| with maintenance, procedures, and training are considered.

The NRC staff concludes that NMC used a systematic and comprehensive process for

identifying potential plant improvements for Palisades, and that the set of potential plant

improvements identified by NMC is reasonably comprehensive and therefore acceptable. This

process included reviewing insights from the plant-specific risk studies, reviewing plant

improvements considered in previous SAMA analyses, and using the knowledge and

experience of its PSA personnel.
Appendix G

October 2006 G-19 NUREG-1437, Supplement 27

G.4 Risk Reduction Potential of Plant Improvements

NMC evaluated the risk reduction potential of the eight remaining SAMAs that were applicable |

to Palisades. Most of the SAMA evaluations were performed in a bounding fashion in that the

SAMA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit and are conservative.

NMC used model requantification to determine the potential benefits. The CDF and population |

dose reductions were estimated using Palisades PSA model PSAR1c. The changes made to |

the model to quantify the impact of SAMAs are detailed in Section E.6 of Attachment E to the

ER (NMC 2005a) and in response to an RAI (NMC 2005b). Table G-4 lists the assumptions |

considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk

reduction in terms of percent reduction in CDF and population dose, and the estimated total

benefit (present value) of the averted risk based on a 7 percent and a 3 percent discount rate. 

This analysis methodology was also used for the three SAMAs (SAMAs 3, 4, and 10) that were

originally identified and retained for evaluation to address internal initiating events, but that were

also recognized as being effective in fire events. The determination of the benefits for the

various SAMAs is further discussed in Section G.6.

For the one SAMA that specifically addresses seismic events only (SAMA 22), the reduction in

CDF and population dose was not directly calculated. For this SAMA, a bounding estimate of

the impact of the SAMA was made by assuming that the contribution to risk from external

events is approximately equal to that from internal events, that seismic events contribute

21 percent of the external events risk, and that 69 percent of the seismic risk could potentially |

be eliminated by this SAMA based on information from the IPEEE.

The NRC staff has reviewed NMC’s bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for

the various SAMAs on NMC’s risk reduction estimates.

G.5 Cost Impacts of Candidate Plant Improvements

NMC estimated the costs of implementing the remaining candidate SAMAs through the

application of engineering judgment, use of estimates from other licensees’ submittals for

similar improvements, and development of site-specific cost estimates. The cost estimates

conservatively did not include the cost of replacement power during extended outages required

to implement the modifications, nor did they include contingency costs associated with

unforeseen implementation obstacles (NMC 2005b). Estimates were presented in terms of

dollar values at the time of implementation or estimation and were not adjusted to present-day |
Table G-4. SAMA Cost-Benefit Screening Analysis for Palisades |

SAMA(a) Assumptions

% Risk Reduction

Total Benefit Using

7% Discount Rate

($)

Total Benefit

Using 3%

Discount Rate

($)

Cost

($) CDF

Population

Dose

3. Install a direct drive |

diesel-driven injectionpump (DDDIP). Reduces the risk ofstation blackout (SBO) |scenarios by providingan injection method tosupplement theturbine-driven auxiliary |feedwater (AFW) pump. |

Reduced the existing AFWpump failure probabilities byfactors ranging from 7 to 19 to simulate theaddition of a DDDIP. Alsoeliminated common causefailures and random systemfailures to represent theindependence of the DDDIP.

15 14 793,000 | 1,050,000 1,100,000

4. Install an additional |

high-pressure injection |(HPI) pump. IncreasesHPI diversity andreduces the probabilityof requiring reactor |pressure valve (RPV) |depressurization early inan accident.

Reduced the “A” train pumpand valve failure rates toreflect the installation of theadditional pump and the factthat only one pump train ofthree is required for success.Modeled by squaring each ofthe independent failureprobabilities of the “A” train,which ranged originally from2.5E-07 to 2.6E-03. Alsoreduced the common causefailure term by an order ofmagnitude.

3 1 85,400 108,000 1,620,000

NUREG-1437, Supplement 27 G-20 October 2006

Appendix G
Table G-4. (contd) |

SAMA(a) Assumptions

% Risk Reduction

Total Benefit Using

7% Discount Rate

($)

Total Benefit

Using 3%

Discount Rate

($)

Cost

($) CDF

Population

Dose

10. Modify the turbine- |

driven AFW train sothat it can operateindefinitely withoutalternating current |(AC), direct current |(DC), or pneumatic |support.

Eliminated all AC powerrecovery failures tosimulate the indefiniteoperation of the turbinedriven AFW pump.

27 33 1,750,000 2,340,000 200,000 |

13. Provide a nitrogen |station that would |automatically provide abackup air supply tothe CV-2010 valve. Reduces theimportance of Loss ofInstrument Air to thevalve.

Assumed a failureprobability of 1E-02 for thenitrogen station. |

5.2 4.4 262,000 346,100 220,000 |

14. Enhance the main |control room to includecontrols for the cross-tiebetween theservice-water system |and the fire protection |system. Reduces the |time required toestablish the cross-tie.

Eliminated seal loss-of- |

coolant accidents (LOCAs) |that would occur on loss ofseal cooling.

5 7 344,000 463,000 2,900,000 |

October 2006 G-21 NUREG-1437, Supplement 28

Appendix G
Table G-4. (contd) |

SAMA(a) Assumptions

% Risk Reduction

Total Benefit Using

7% Discount Rate

($)

Total Benefit

Using 3%

Discount Rate

($)

Cost

($) CDF

Population

Dose

16. Install new |

insulation and laggingon the emergency |diesel generator (EDG) |exhaust ducts insidethe EDG rooms andmake procedural |changes to alignalternate room cooling.

Eliminated the EDG roomcooling recovery event.

4 4 237,000 316,000 160,000

22. Replace the |under-voltage relays |for EDGs 1-1 and 1-2with seismically |qualified relays. |

Eliminated all Class IA andIB external events.

15 15 414,000 550,000 110,000

23. Make procedural |

changes to direct thecooldown of theprimary coolant pump |(PCP) seals on loss of |PCP seal cooling.

Eliminated seal LOCAs thatwould occur on loss ofseal cooling.

5 7 344,000 463,000 100,000

(a) SAMAs in bold are potentially cost-beneficial when either a 7 percent or 3 percent real discount rate is used in the NRC staff's analysis.

NUREG-1437, Supplement 27 G-22 October 2006

Appendix G
Appendix G

October 2006 G-23 NUREG-1437, Supplement 27

dollars. For some of the SAMAs considered, so little, if any, benefit would be obtained from |

implementation of the proposed enhancement that it was not necessary to develop a cost

estimate.

The NRC staff reviewed the bases for the applicant’s cost estimates (as presented in

Section E.6 of Appendix E of the ER and in a response by NMC to an RAI (NMC 2005b)). For |

certain improvements, the NRC staff also compared the cost estimates to estimates developed

elsewhere for similar improvements, including estimates developed as part of other licensees’

analyses of SAMAs for operating reactors and advanced light-water reactors. The NRC staff

reviewed the costs and found them to be consistent with estimates provided in support of other

plants’ analyses.

The NRC staff questioned the applicant about the cost estimate for SAMA 21 and the use of the |

FPS as backup for the containment spray system. In the ER, the implementation cost for this |

SAMA is estimated to be $7,000,000. A similar SAMA at Brunswick was estimated to cost only

$100,000. In response to an RAI, NMC provided a detailed breakdown of how the site-specific

cost estimate was derived and noted that the Brunswick SAMA is for a procedural change, while |

SAMA 21 is a major plant modification (NMC 2005b). On the basis of a review of this additional |

information, the NRC staff considers the cost estimate for SAMA 21 to be reasonable.

The NRC staff concludes that the cost estimates provided by NMC are sufficient and

appropriate for use in the SAMA evaluation. 

G.6 Cost-Benefit Comparison

NMC’s cost-benefit analysis and the NRC staff’s review are described in the following sections.

G.6.1 NMC Evaluation

The methodology used by NMC was based primarily on NRC’s guidance for performing costbenefit analysis, that is, NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook |

(NRC 1997a). The guidance involves determining the net value for each SAMA according to |

the following formula: 

Net Value = (APE + AOC + AOE + AOSC) – COE |

where,

APE = present value of averted public exposure ($), |

AOC = present value of averted offsite property damage costs ($), |

AOE = present value of averted occupational exposure costs ($), |
Appendix G

NUREG-1437, Supplement 28 G-24 October 2006

| AOSC = present value of averted onsite costs ($), and 

COE = cost of enhancement ($). 

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. NMC’s derivation of

each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency’s revised policy on discount

| rates. Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed: 

| one at 3 percent and one at 7 percent (NRC 2004). NMC provided both sets of estimates (NMC

2005a).

| Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula: 

APE = Annual reduction in public exposure () person-rem/year) 

| x monetary equivalent of unit dose ($2000 per person-rem) 

x present value conversion factor (10.76 based on a 20-year period with a

7 percent discount rate). 

| As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

losses extending over the remaining lifetime (in this case, the renewal period) of the facility. 

Thus, it reflects the expected annual loss due to a single accident, the possibility that such an

accident could occur at any time over the renewal period, and the effect of discounting these

potential future losses to present value. NMC calculated an APE of approximately $688,000 for

the 20-year license renewal period, which assumes elimination of all severe accidents.

| Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction 

x offsite economic costs associated with a severe accident (on a per-event basis) 

x present value conversion factor. 

For the purposes of initial screening, which assumes all severe accidents are eliminated, NMC

calculated an annual offsite economic risk of about $125,000 based on the Level 3 risk analysis. 

This results in a discounted value of approximately $1,345,000 for the 20-year license renewal

period.
Appendix G

October 2006 G-25 NUREG-1437, Supplement 27

Averted Occupational Exposure (AOE) Costs |

The AOE costs were calculated by using the following formula: |

AOE = Annual CDF reduction 

x occupational exposure per core damage event 

x monetary equivalent of unit dose 

x present value conversion factor.

NMC derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided |

for immediate occupational dose (3300 person-rem) and long-term occupational dose |

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these

doses was calculated by using the equations provided in the handbook in conjunction with a |

monetary equivalent of unit dose of $2000 per person-rem, a real discount rate of 7 percent, |

and a time period of 20 years to represent the license renewal period. For the purposes of

initial screening, NMC calculated an AOE of approximately $15,400 for the 20-year license |

renewal period, which assumes all severe accidents are eliminated. 

Averted Onsite Costs |

The AOSC include averted cleanup and decontamination costs and averted power replacement |

costs. Repair and refurbishment costs are considered for recoverable accidents only and not

for severe accidents. NMC derived the values for AOSC based on information provided in

Section 5.7.6 of the regulatory analysis handbook (NRC 1997a). |

NMC divided this cost element into two parts: the Onsite Cleanup and Decontamination Cost, |

also commonly referred to as averted cleanup and decontamination costs, and the Replacement |

Power Cost. |

Averted cleanup and decontamination costs (ACC) were calculated using the following formula: 

ACC = Annual CDF reduction 

x present value of cleanup costs per core damage event 

x present value conversion factor. 

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

the regulatory analysis handbook to be $1.5 x 109

 (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the term of the proposed

license extension. For the purposes of initial screening, which assumes all severe accidents

are eliminated, NMC calculated an ACC of approximately $479,000 for the 20-year license

renewal period.
Appendix G

NUREG-1437, Supplement 28 G-26 October 2006

Long-term replacement power costs (RPC) were calculated using the following formula: 

RPC = Annual CDF reduction

x present value of replacement power for a single event 

x factor to account for remaining service years for which replacement power is

required 

x reactor power scaling factor

| NMC based its calculations on the value of 816 megawatts electric (MW(e)). Therefore, NMC

applied a power scaling factor of 816 MW(e)/910 MW(e) to determine the replacement power

costs. NMC calculated an RPC of approximately $287,000 for the 20-year license renewal

period, which assumes all severe accidents are eliminated. 

For the purposes of initial screening, which assumes all severe accidents are eliminated, NMC

calculated an AOSC of approximately $766,000 for the 20-year license renewal period.

Using the above equations, NMC estimated the total present dollar value equivalent associated

with completely eliminating all severe accidents at Palisades to be about $2,814,000. To

account for additional risk reduction in external events, NMC doubled this value to $5,630,000,

which is the MMACR and represents the dollar value of completely eliminating all internal and

external event severe accident risk at Palisades.

| NMC’s Results

| If the implementation costs for a candidate SAMA were greater than the MMACR of $5,630,000,

then the SAMA was screened from further consideration. A more refined look at the costs and

benefits was performed for the remaining SAMAs. If the expected cost for those SAMAs

exceeded the calculated benefit, the SAMA was considered not to be cost-beneficial. The

cost-benefit results for the individual analysis of the SAMA candidates are presented in Table

| G-4. In the baseline analyses contained in the ER (using a 7 percent discount rate), NMC

identified five potentially cost-beneficial SAMAs. Based on an analysis using a 3 percent

discount rate, as recommended in NUREG/BR-0058 (NRC 2004), no additional SAMA

candidates were determined to be potentially cost-beneficial. The potentially cost-beneficial

SAMAs are:

| C SAMA 10 – modify the turbine-driven AFW so that it can operate indefinitely without AC,

| DC, or pneumatic support. This SAMA involves a procedural revision and analysis to

| direct AFW flow adjustments based on decay heat level so that the steam generator 

level can be maintained when instrumentation fails on DC power depletion.
Appendix G

October 2006 G-27 NUREG-1437, Supplement 27

C SAMA 13 – add a nitrogen station. This SAMA involves the use of a nitrogen station to |

automatically provide backup air supply for critical instrumentation and reduce the

importance of loss of instrument air.

C SAMA 16 – add insulation to the EDG exhaust ducts. This SAMA involves insulating the |

EDG exhaust ducts and making procedural modifications to prevent overheating of EDG |

engines. |

C SAMA 22 – replace under-voltage relays with a seismically qualified model. This SAMA |

involves replacing relays to reduce the likelihood of failure of automatic start of the EDGs

and to reduce the contributions from loss of power due to the relays. |

C SAMA 23 – modify procedures for primary coolant system cooldown and provide |

associated training. This SAMA involves procedural modifications to reduce the |

probability of reactor coolant pump seal failures related to long-term high-temperature |

exposure after recovery of component cooling water. |

NMC performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment (NMC 2005a). NMC considered the

impact of analysis uncertainties on the results of the SAMA analysis by increasing the benefits

by a factor of 2.3. The result of the analysis is that one additional Phase 2 SAMA candidate

was determined to be potentially cost-beneficial:

C SAMA 3 – add a DDDIP. This SAMA involves installing a non-safety-related DDDIP to |

supplement the turbine-driven AFW pump and reduce the risk of SBO scenarios.

In the ER, NMC stated that it will implement or continue to consider the above six SAMAs |

identified in the analysis (SAMAs 3, 10, 13, 16, 22, and 23) through the appropriate Palisades

design process.

In response to RAIs by the NRC staff, NMC committed to further evaluate possible lower cost

alternatives for two SAMAs originally eliminated in the Phase 1 screening analysis and to further

evaluate two additional SAMAs determined to be applicable to Palisades but not yet evaluated

by NMC:

C Lower cost alternative to SAMA 1 – installing an additional EDG, |

C Lower cost alternative to SAMA 18 – installing a permanent, dedicated pump and line to |

the EDGs,
Appendix G

NUREG-1437, Supplement 28 G-28 October 2006

| C Additional SAMA to add the capability to flash the field on the EDGs, and

| C Additional SAMA to replace an existing air-operated containment sump valve with a

| motor-operated valve.

The potentially cost-beneficial SAMAs and NMC’s plans for further evaluation of these SAMAs

are discussed in more detail in Section G.6.2.

G.6.2 Review of NMC’s Cost-Benefit Evaluation

The cost-benefit analysis performed by NMC was based primarily on NUREG/BR-0184

| (NRC 1997a) and was executed consistent with this guidance.

| To account for external events, NMC multiplied the internal event benefits by a factor of 2 for

each SAMA, except the one Phase 2 SAMA that specifically addressed seismic risk only

(SAMA 22). Doubling the benefit for SAMA 22 is not appropriate since this SAMA is specific to

seismic risk only and would not have a corresponding benefit on the risk from internal events. 

While SAMAs 3, 4, and 10 were recognized as being effective in fire events, doubling of the

benefit for these SAMAs is appropriate since they were also identified based on their

importance in internal events. Given that the CDF of 4.3 × 10-5 | per year from internal fires,

seismic events, and other external events as reported by NMC (NMC 2005a) is about the same

as the CDF of 4.0 × 10-5 | per year from internal events, the NRC staff agrees that the factor of

| 2 multiplier for external events is reasonable.

NMC considered the impact that possible increases in benefits from analysis uncertainties

would have on the results of the SAMA assessment. Information regarding the uncertainty

distribution of the internal events CDF is summarized in Section E.7.2 of the ER (NMC 2005a). 

| In the uncertainty assessment described therein, the 95th percent confidence level for the

internal events CDF is approximately 2.3 times the point estimate CDF. NMC reexamined the

initial set of SAMAs to determine if any additional Phase 1 SAMAs would be retained for further

analysis if the benefits (and MMACR) were increased by a factor of 2.3. Four such SAMAs

| were identified: SAMA 11 – install an additional high-pressure boron injection system to

| increase the means of injecting boron into the reactor in an ATWS; SAMA 15 – add a bypass

pipeline around the SIRWT return valves to prevent injection pump failure given failure of the

| return valves to open; SAMA 18 – provide a dedicated pump and pipeline to the EDGs for

| cooling, thereby reducing system dependencies; and SAMA 21 – enable the FPS as a backup

for the containment spray system. However, based on further consideration of their costs and

the limited benefit of eliminating the basic events addressed by three of these SAMAs, NMC

concluded that SAMAs 11, 15, and 18 would not be cost-beneficial even if the systems were

completely reliable. The specific rationale is provided in Section E.7.2.1 of the ER. The NRC

staff considers the applicant’s rationale for eliminating SAMAs 11, 15, and 18 from further
Appendix G

October 2006 G-29 NUREG-1437, Supplement 27

consideration in the final evaluation to be reasonable. SAMA 21 was retained for consideration

in the final evaluation as discussed below.

NMC also considered the impact on the Phase 2 screening if the estimated benefits were

increased by a factor of 2.3 (in addition to the factor of 2 multiplier already included in the |

baseline benefit estimates to account for external events). Of the SAMAs evaluated in the

Phase 2 analysis, only SAMA 3, add a DDDIP, was found to be potentially cost-beneficial after |

having been classified as not cost-beneficial in the baseline analysis. Although not costbeneficial in the baseline analysis, NMC included SAMA 3 within the set of potentially costbeneficial SAMAs that it intends to evaluate further for potential implementation. |

SAMA 21, which was retained for further evaluation as a result of an uncertainty assessment,

was subsequently eliminated by NMC. The detailed cost-benefit analysis for this SAMA

assumed that all loss of containment spray events would be eliminated. The PSA model result

was about a 40 percent reduction in the population dose and, since the containment spray

system has a minimal impact on CDF, no reduction in the CDF. The estimated total benefit

(present value) of the averted risk, assuming a 7 percent discount rate, was calculated to be |

about $3,570,000 (which assumes a doubling of the benefit to account for external events). 

Since this total estimated benefit is significantly less than the estimated cost of implementation

of $7,000,000, NMC concluded that this SAMA would not be cost-beneficial. The NRC staff has

reviewed NMC’s bases for calculating the risk reduction for this SAMA and concludes that the

rationale and assumptions for estimating risk reduction are reasonable and generally

conservative (i.e., the estimated risk reduction is higher than what would actually be realized). 

The NRC staff also reviewed the bases for the estimated implementation cost of this SAMA and

found it to be consistent with estimates provided in support of other plants’ analyses. 

Accordingly, the NRC staff agrees with the NMC conclusion that this SAMA is not costbeneficial.

During its review, the NRC noted that the offsite economic cost risk estimated for Palisades is

larger than that estimated at other sites having similar CDF and population dose. The NRC staff |

asked NMC to provide additional information on the input assumptions used in the MACCS2

model and other factors that may contribute to this difference (NRC 2005). In response to the

RAI, NMC provided additional detail on the input assumptions made for several MACCS2

economic parameters (NMC 2005b). The NRC staff concludes that the input assumptions are

consistent with those used in other recent industry analyses, and that the noted differences in

offsite economic cost risk are most likely due to population differences.

In its ER, NMC stated that several SAMAs are cost-beneficial based on the methodology

applied in the analysis and warrant further review for potential implementation. Five SAMAs

were found to have positive net values in NMC’s baseline analysis (SAMAs 10, 13, 16, 22, and

23). One additional SAMA candidate was determined by NMC to be potentially cost-beneficial

based on consideration of uncertainties (SAMA 3). NMC noted that three SAMAs in particular
Appendix G

NUREG-1437, Supplement 28 G-30 October 2006

show the largest potential for delivering a cost-beneficial risk reduction at Palisades, specifically,

SAMAs 10, 13, and 16.

NMC performed a probabilistic evaluation to investigate the impact on the remaining cost-

| beneficial SAMAs if SAMA 10 were to be implemented. On the basis of information provided in

Section E.6.9 of the ER, implementation of SAMA 10 would alter the cost-effectiveness of the

remaining SAMAs such that several of the aforementioned SAMAs would no longer be costbeneficial.

NMC noted in the ER that while the above results are believed to accurately reflect areas for

improvement at the plant, additional engineering reviews are necessary to determine ultimate

| implementation. NMC stated that it will implement or continue to consider the six SAMAs

identified in the analysis through the appropriate Palisades design process (SAMAs 3, 10, 13,

16, 22, and 23). In response to RAIs by the NRC staff, NMC also committed to further evaluate

possible lower cost alternatives for two SAMAs originally eliminated in the Phase 1 screening

analysis (SAMAs 1 and 18), and to further evaluate two additional SAMAs determined to be

applicable to Palisades but not yet evaluated by NMC (add the capability to flash the field on the

EDG, and replace an existing air-operated containment sump valve with a motor-operated

valve). NMC has entered these 10 potentially cost-beneficial items into the Palisades corrective

action system for further review. If determined to be cost-beneficial, these alternatives will be

evaluated for possible implementation in accordance with Palisades plant design processes.

The NRC staff notes that all of the potentially cost-beneficial SAMAs identified in either the

| baseline analysis or the uncertainty analysis are included within the set of SAMAs that NMC

| plans to further evaluate. Several additional SAMAs, representing lower cost alternatives to

| SAMAs originally eliminated in the Phase 1 screening analysis and SAMAs determined to be

| applicable to Palisades but not yet evaluated by NMC, will be assessed as part of this

evaluation. The NRC staff concludes that, with the exception of the 10 potentially costbeneficial SAMAs discussed above, the costs of the SAMAs evaluated would be higher than the

associated benefits.

G.7 Conclusions

NMC compiled a list of 23 SAMA candidates based on a review of the most significant basic

events from the plant-specific PSA, Phase 2 SAMAs from license renewal activities for other

plants, and insights from the plant-specific IPE and IPEEE. A qualitative screening removed

| 14 SAMA candidates that (1) were not applicable at Palisades because of design differences,

(2) require extensive changes that involve implementation costs known to exceed any possible

| benefit, or (3) cost more than $5,600,000 to implement (the modified maximum averted

cost-risk). An additional SAMA candidate was eliminated based on plant-specific insights

regarding the low risk significance of systems affected by the SAMA, leaving eight SAMA

candidates for further evaluation.
Appendix G

October 2006 G-31 NUREG-1437, Supplement 27

For the remaining SAMA candidates, a more detailed design and cost estimate was developed

as shown in Table G-4. The cost-benefit analyses showed that five of the SAMA candidates

were potentially cost-beneficial in the baseline analysis (SAMAs 10, 13, 16, 22, and 23). NMC

performed additional analyses to evaluate the impact of parameter choices and uncertainties on

the results of the SAMA assessment. As a result, one additional SAMA was identified as

potentially cost-beneficial (SAMA 3). NMC has indicated that a further evaluation of these six

potentially cost-beneficial SAMAs will be performed.

In response to RAIs by the NRC staff, NMC committed to further evaluate possible lower cost

alternatives for two SAMAs originally eliminated in the Phase 1 screening analysis (SAMAs 1

and 18) and to further evaluate two NRC-staff-identified plant enhancements determined to be |

applicable to Palisades but not yet evaluated by NMC (add the capability to flash the field on the

EDG, and replace an existing air-operated containment sump valve with a motor-operated

valve). NMC has entered these 10 potentially cost-beneficial items into the Palisades corrective

action system for further review. If determined to be cost-beneficial, they will be further

evaluated for possible implementation in accordance with Palisades plant design processes.

The NRC staff reviewed the NMC analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by NMC are reasonable

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

events was somewhat limited by the unavailability of an external event PSA, the likelihood of

there being cost-beneficial enhancements in this area was minimized by inclusion of a

candidate SAMA related to dominant seismic events, inclusion of several candidate SAMAs

related to dominant fire events, improvements that have been realized as a result of the IPEEE

process, and inclusion of a multiplier to account for external events.

The NRC staff concurs with NMC’s identification of areas in which risk can be further reduced in

a cost-beneficial manner through the implementation of all or a subset of the identified, 

potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the

NRC staff agrees that further evaluation of these SAMAs by NMC is warranted. However, these

SAMAs do not relate to adequately managing the effects of aging during the period of extended

operation. Therefore, they need not be implemented as part of the license renewal pursuant to

10 CFR Part 54.
Appendix G

NUREG-1437, Supplement 28 G-32 October 2006

G.8 References

| 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental

| Protection Regulations for Domestic Licensing and Related Regulatory Functions.”

|

| 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

| Renewal of Operating Licenses for Nuclear Power Plants.”

| Consumers Power Company (Consumers Power). 1993. Letter from G.B. Slade, Consumers

| Power Company, Jackson, Michigan, to U.S. Nuclear Regulatory Commission Document

| Control Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 - Palisades

Plant - Individual Plant Examination for Severe Accident Vulnerabilities (IPE).” (January 29,

1993). 

| Consumers Power Company (Consumers Power). 1995. Letter from K.M. Haas, Consumers

| Power Company, Jackson, Michigan, to U.S. Nuclear Regulatory Commission Document

| Control Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 - Palisades

Plant, Response to Generic Letter 88-20 Supplement 4, ‘Individual Plant Examination of

External Events for Severe Accident Vulnerabilities, Final Report.’” 

(June 30, 1995).

| Consumers Power Company (Consumers Power). 1996. Letter from R.W. Smedley,

| Consumers Power Company, Jackson, Michigan, to U.S. Nuclear Regulatory Commission

| Document Control Desk, Rockville, Maryland. Subject: “Docket 50-255 - License DPR-20 -

| Palisades Plant, Submittal of Revised IPEEE Report Based on Re-analysis of Internal Fires,

‘Individual Plant Examination of External Events Report, Revision 1, Final Report.’” (May 22,

1996).

| Electric Power Research Institute (EPRI). 1992. Fire-Induced Vulnerability Evaluation (FIVE). 

| EPRI Report TR-100370, (April 1992).

| Nuclear Management Company, LLC (NMC). 2003. Letter from D.E. Cooper, Nuclear

| Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission

| Document Control Desk, Rockville, Maryland. Subject: “Final Closeout of Unresolved Safety

Issue A-46 Outliers.” (June 26, 2003).

| Nuclear Management Company, LLC (NMC). 2005a. Applicant’s Environmental Report –

| Operating License Renewal Stage, Palisades Nuclear Plant, Docket No. 50-255. Covert,

| Michigan. (March 2005).

| Nuclear Management Company, LLC (NMC). 2005b. Letter from P.A. Harden, Nuclear

| Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission
Appendix G

October 2006 G-33 NUREG-1437, Supplement 27

Document Control Desk, Rockville, Maryland. Subject: “Response to NRC Requests for |

Additional Information Dated August 24, 2005, Relating to License Renewal for the Palisades

Nuclear Plant.” (October 21, 2005).

Nuclear Management Company, LLC (NMC). 2005c. Letter from J. Holthaus, Nuclear |

Management Company, LLC, Covert, Michigan, to U.S. Nuclear Regulatory Commission |

Document Control Desk, Rockville, Maryland. Subject: “Supplement to ‘Response to NRC |

Request for Additional Information Dated August 24, 2005 relating to License Renewal for the

Palisades Nuclear Plant,’ dated October 21, 2005, (Accession Number ML052990316) and

telecon on November 10, 2005.” (November 18, 2005).

U.S. Department of Agriculture (USDA). 1998. “1997 Census of Agriculture, National |

Agriculture Statistics Service. Available URL: http://www.nass.usda.gov/census97/volume1/

vol1pubs.htm.

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, “Individual Plant

Examination for Severe Accident Vulnerabilities.” (November 23, 1988). |

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1150. Washington, D.C. |

U.S. Nuclear Regulatory Commission (NRC). 1996. “Review of Individual Plant Examination

Submittal for Internal Events – Palisades Nuclear Plant” (TAC No. M74444).” Washington, D.C. |

(February 7, 1996). |

|

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation |

Handbook. NUREG/BR-0184. Washington, D.C. |

U.S. Nuclear Regulatory Commission (NRC). 1997b. “Verification of Seismic Adequacy of |

Mechanical and Electrical Equipment in Operating Reactors,” Unresolved Safety Issue (USI)

A-46, (Generic Letter 87-03). Washington, D.C. (February 27, 1987). |

U.S. Nuclear Regulatory Commission (NRC). 1997c. Individual Plant Examination Program: |

Perspectives on Reactor Safety and Plant Performance. NUREG-1560. Washington, D.C. |

U.S. Nuclear Regulatory Commission (NRC). 1998. “Palisades Plant - Resolution of

Unresolved Safety Issue (USI) A-46, Verification of Seismic Qualification of Equipment in

Operating Plants (TAC No. M69468).” Washington, D.C. (September 25, 1998). |

U.S. Nuclear Regulatory Commission (NRC). 1999. “Palisades Plant – Review of Individual |

Plant Examination of External Events (IPEEE) Submittal (TAC No. M83653).” |

Washington, D.C. (November 29, 1999). |
Appendix G

NUREG-1437, Supplement 28 G-34 October 2006

| U.S. Nuclear Regulatory Commission (NRC). 2003a. “NRC Generic Letter 2003-01: Control

Room Habitability.” OMB Control No.: 3150-0011 (ML031620248). Washington, D.C. 

| (June 12, 2003).

| U.S. Nuclear Regulatory Commission (NRC). 2003b. SECPOP2000: Sector Population, Land

| Fraction, and Economic Estimation Program. NUREG/CR-6525, Rev. 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the

U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.

| U.S. Nuclear Regulatory Commission (NRC). 2005. Letter from R. Schaaf, U.S. Nuclear

| Regulatory Commission, Rockville, Maryland, to P.A. Harden, Nuclear Management Company,

| LLC, Covert, Michigan. Subject: “Request for Additional Information (RAI) Regarding Severe

Accident Mitigation Alternatives for Palisades Nuclear Plant.” (August 24, 2005).
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 27

3. DATE REPORT PUBLISHED

MONTH

October

YEAR

2006

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for License Renewal of Nuclear Plants

Supplement 27

Regarding Palisades Nuclear Plant

Final Report

5. AUTHOR(S) 6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Number 50-255

11. ABSTRACT (200 words or less)

This final supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted to

the Nuclear Regulatory Commission (NRC) by Nuclear Management Company, LLC (NMC) to renew the operating license for

the Palisades Nuclear Plant (Palisades) for an additional 20 years under 10 CFR Part 54. This final SEIS includes the NRC

staff's analysis that considers and weighs the environmental effects of the proposed action, the environmental impacts of 

alternatives to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. 

The NRC staff's recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for Palisades are not so great that preserving the option of license renewal for energy-planning decision makers would be

unreasonable. This preliminary recommendation is based on the following: (1) the analysis and findings in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (NUREG-1437); (2) the Environmental Report submitted

by NMC; (3) consultation with other Federal, State, Tribal, and Local agencies; (4) the staff's own independent review; and (5)

the staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Palisades Nuclear Plant

Supplement to the Generic Environmental Impact Satement

GEIS

National Environmental Policy Act

NEPA

License Renewal

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001