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Category:E-Mail
MONTHYEARML24206A0252024-07-20020 July 2024 NRR E-mail Capture - for Your Comments - State of Georgia - Vogtle Unit 1 - Emergency License Amendment Request for Technical Specification 3.7.9 ML24199A1592024-07-17017 July 2024 NRR E-mail Capture - Request for Additional Information - Vogtle 3 and 4 - Exemption for the Requirements in 10 CFR 50.71 Pertaining to the Submittal of Updated Final Safety Analysis Report ML24198A1672024-07-16016 July 2024 NRR E-mail Capture - Acceptance Review Vogtle 3 and 4 - License Amendment Request Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Surveillance Requirement L-2024-LLA-0083 ML24197A1572024-07-15015 July 2024 NRR E-mail Capture - Acceptance Review - Farley and Vogtle 1 and 2, LAR - TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown ML24197A0172024-07-12012 July 2024 NRR E-mail Capture - Fyi - Acceptance Review - Farley and Vogtle 1 and 2 - Alternative Request for Pressurizer Welds ML24194A0032024-07-11011 July 2024 NRR E-mail Capture - Fyi - Acceptance Review - Farley, Hatch, and Vogtle 1 and 2 - Alternative Request for Code Case N-572 ML24180A0012024-06-26026 June 2024 NRR E-mail Capture - Acceptance Review Farley 1 and 2 and Vogtle 1 and 2 - Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) (L-2024-LLR-0041) ML24170A9362024-06-18018 June 2024 NRR E-mail Capture - Fyi - Change to Estimated Completion Date for the SNC Fleet Physical Barrier Exemptions (L-2023-LLE-0018 and L-2023-LLE-0021) ML24178A3422024-05-16016 May 2024 NRR E-mail Capture - Request for Call - Proposed Vogtle 3 & 4 Tier 1 and Tier 2 Exemptions and LAR ML24120A0462024-04-29029 April 2024 COL Docs - Re Fyi - SNC Notification Received of Vogtle Unit 4 - Completion of Power Ascension Tests ML24120A0262024-04-29029 April 2024 COL Docs - FW Vogtle Electric Generating Plant, Unit 4 - Project Manager Reassignment ML24119A0012024-04-28028 April 2024 COL Docs - Fyi - SNC Notification Received of Vogtle Unit 4 - Completion of Power Ascension Tests ML24108A0132024-04-16016 April 2024 NRR E-mail Capture - (External_Sender) Responses from Wednesday 4/10/2024 Call with Southern Nuclear Operating Co. Vogtle 3&4 Licensing Actions ML24107A9322024-04-15015 April 2024 Document Request for Vogtle Electric Generating Plant Units 1 & 2 - Radiation Protection Inspection Report 2024-02 ML24107A7292024-04-15015 April 2024 Request for Vogtle Electric Generating Plant Units 1 & 2 - Radiation Protection Inspection - Inspection Report 2024-02 ML24106A0522024-04-12012 April 2024 NRR E-mail Capture - Acceptance Review - Vogtle 1 and 2 - Emergency Diesel Generator (EDG) Voltage and Frequency License Amendment Request (LAR) (L-2024-LLA-0031) ML24100A7842024-04-0909 April 2024 NRR E-mail Capture - for Your Action - Request for Additional Information (RAI) - Vogtle, Units 3 and 4 - Alternative Request for Explosively Actuated Valves (L-2023-LLR-0016) ML24099A0372024-04-0505 April 2024 NRR E-mail Capture - Acceptance Review - Vogtle Unit 3, License Amendment Request (LAR) Technical Specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP) - L-2024-LLA-0043 ML24095A2412024-04-0404 April 2024 NRR E-mail Capture - Acceptance Review for the Exemption Request Regarding the Final Safety Analysis Report Update Schedule at Vogtle, Units 3 and 4 ML24072A3982024-03-12012 March 2024 NRR E-mail Capture - for Your Action - Second Round Request for Additional Information (RAI) - Vogtle, Unit 1 - SG Tube Inspection Report - 1R24 (L-2023-LRO-0067) ML24061A2372024-03-0101 March 2024 SNC Email Dated March 1, 2024, Regarding SNC Response to NRC Letter for Vogtle 3 & 4 RES Info ML24057A0872024-02-23023 February 2024 NRR E-mail Capture - Acceptance Review - Alternative Request for Explosively Actuated Valves at Vogtle, Units 3 and 4 ML24046A1352024-02-15015 February 2024 COL Docs - Fyi - SNC Notification Received of Vogtle Unit 4 - Completion of Initial Criticality and Low-Power Testing ML24039A1122024-02-0808 February 2024 COL Docs - Re Fyi - SNC Notification Received of Vogtle Unit 4 Completion of Pre-Critical Tests ML24039A1922024-02-0808 February 2024 COL Docs - Correction - Re Fyi - SNC Notification Received of Vogtle Unit 4 Completion of Pre-Critical Tests ML24039A0882024-02-0808 February 2024 COL Docs - Fyi - SNC Notification Received of Vogtle Unit 4 Completion of Pre-Critical Tests ML24031A0502024-01-31031 January 2024 COL Docs - FW Erroneous Description of Tier 2 Change Process in Construction Lessons-Learned Report ML24017A1122024-01-17017 January 2024 NRR E-mail Capture - Request for Access to Cyber Security Data - Vogtle, Units 3 and 4 ML23360A0042023-12-23023 December 2023 NRR E-mail Capture - Fyi - Office of Nuclear Regulatory Research (RES) Requests for Vogtle 3 & 4 ML23348A0782023-12-13013 December 2023 NRR E-mail Capture - Voluntary Request for Closed Meeting Regarding Cyber Security Assessments at Vogtle, Units 3 and 4 ML23342A0802023-12-0808 December 2023 NRR E-mail Capture - Request for Additional Information (RAI) - Vogtle, Unit 1 - Review of SG Tube Inspection Report for Refueling Outage 24 (L-2023-LRO-0067) ML23331A9992023-11-27027 November 2023 COL Docs - Re Re Re ML23079A125 - Vogtle Electric Generating Station, Unit 3, NRC Response Letter to P. Durand, Regarding Comment on Federal Register Notice License Amendment No. 189 ML23331A9492023-11-26026 November 2023 Email Dated November 26, 2023, from Bo Pham to SNC and NRC - Vogtle Seismic Hazard Report ML23326A2802023-11-22022 November 2023 COL Docs - Re Re ML23079A125 - Vogtle Electric Generating Station, Unit 3, NRC Response Letter to P. Durand, Regarding Comment on Federal Register Notice License Amendment No. 189 ML23331A9622023-11-22022 November 2023 Email Dated November 22, 2023, from SNC to NRC - Vogtle Seismic Hazard Report ML23320A0342023-11-16016 November 2023 COL Docs - Re Acceptance Review of Southern Nuclear Operating Companys License Amendment Request to Remove Combined License Appendix C (EPID No. 2023-LLA-0123) ML23312A2632023-11-0808 November 2023 COL Docs - Action Request for State of Georgia Comment by 5pm Monday, November 13, 2023 - Vogtle Units 3&4, LAR-22-002, TS 3.8.3, Inverters - Operating Completion Time Extension ML23320A2372023-11-0808 November 2023 NRR E-mail Capture - (External_Sender) Proposed LAR Regarding the Ultimate Heat Sink at Vogtle, Units 1 and 2 ML23311A1512023-11-0707 November 2023 COL Docs - Re Acceptance Review of Southern Nuclear Operating Companys License Amendment Request to Remove Combined License Appendix C (EPID No. 2023-LLA-0123) ML23304A2272023-10-31031 October 2023 NRR E-mail Capture - Request for State of Georgia Comment by 5pm Monday, Nov. 6, 2023 - License Amendment Request for Vogtle Unit 4 - to Remove Combined License Appendix C ML23289A1362023-10-16016 October 2023 COL Docs - Action Request for State of Georgia Comment by 5pm Friday, October 20, 2023 - Vogtle Units 3&4, LAR-23-006, Rev.1, More Restrictive Action for Tech. Spec. 3.1.9 ML23283A0332023-10-10010 October 2023 COL Docs - FW Vogtle Units 3 and 4 (LAR 23-009) ML23283A0452023-10-0808 October 2023 E-Mail Re Plant Vogtle - Neop Letter Dated October 8, 2023 - Vogtle 3 & 4 - TS 3.7.6 License Amendment Request ML23279A2082023-10-0505 October 2023 Issuance of Formal RAIs - Vogtle, Units 1 and 2 - Proposed LAR and Proposed Alternative Request to Revise TS 3.4.14.1 and IST ALT-VR-02 (EPIDs L-2023-LLA-0061 and L-2023-LLR-0023) ML23275A1002023-10-0202 October 2023 COL Docs - Re Action Summary of 9.27.23 Clarification Call with Southern Nuclear Company on LAR-22-0002, TS 3.8.3 Inverters - Operating Completion Time ML23270B1912023-09-27027 September 2023 COL Docs - Update Vogtle Units 3&4 Acceptance Letter for LAR-22-002 Technical Specification 3.8.3, Inverters Operating ML23263A1042023-09-20020 September 2023 COL Docs - FW Fyi for Tomorrow'S Psm Meeting 2024-07-20
[Table view] Category:Letter
MONTHYEARIR 05000424/20244012024-08-15015 August 2024 4 - Security Baseline Inspection Report 05000424-2024401, 05000425-2024401, 05200025-2024402, and 05200026-2024403 - Cover Letter ML24218A1842024-08-0707 August 2024 Examination Report and Cover Letter ML24212A1442024-08-0101 August 2024 Integrated Inspection Report 05200025/2024002 and 05200026/2024002 IR 05000424/20240022024-07-29029 July 2024 Integrated Inspection Report 05000424/2024002 and 05000425/2024002 IR 05000424/20244042024-07-26026 July 2024 Material Control and Accounting Program Inspection Report 05000424/2024404 and 05000425/2024404 (Cover Letter) NL-24-0126, – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.62024-07-25025 July 2024 – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.6 NL-24-0282, License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements2024-07-25025 July 2024 License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements ML24204A0722024-07-23023 July 2024 Issuance of Amendment No. 225, Regarding LAR to Revise TS 3.7.9 for a one-time Change to Support Nuclear Service Cooling Water Transfer Pump Repairs - Emergency Circumstances NL-24-0286, Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair2024-07-20020 July 2024 Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair ML24191A4562024-07-19019 July 2024 Request for Relief and Alternative Requirements for Squib (Explosively Actuated) Valves First Test Interval NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 ML24194A0342024-07-12012 July 2024 Review of the Refueling Outage 1R24 Steam Generator Tube Inspection Report ML24191A3792024-07-10010 July 2024 – Initial Test Program and Operational Programs Inspection Report 05200026/2024011 NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0087, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks2024-06-21021 June 2024 License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks NL-24-0243, Registration of Spent Fuel Cask Use2024-06-18018 June 2024 Registration of Spent Fuel Cask Use NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) ML24163A0632024-06-12012 June 2024 2024 Licensed Operator Re-qualification Inspection Notification Letter Vogtle, Units 3 & 4 ML24155A1772024-06-0505 June 2024 Regulatory Audit in Support of Review of the LAR to Revise Emergency Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, Surveillance Requirements NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations ML24141A0482024-05-17017 May 2024 EN 56958_1 Ametek Solidstate Controls, Inc ML24094A1402024-05-16016 May 2024 Staff Response to Request for Revision to NRC Staff Assessment of Updated Seismic Hazard Information and Latest Understanding of Seismic Hazards at the Vogtle Plant Site Following the NRC Process for the Ongoing Assessment of Natural Hazard ML24130A2412024-05-13013 May 2024 Integrated Inspection Report 05200025/2024001 and 05200026/2024001 ML24120A1812024-05-13013 May 2024 Request for Withholding Information from Public Disclosure Responses to NRC Request for Additional Information for Refueling Outage IR24 Steam Generator Tube Inspection Report – Enclosure 2 ML24101A2112024-05-11011 May 2024 Expedited Issuance of Amendment No. 198 Change to Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 ML24127A2372024-05-0909 May 2024 Initial Test Program and Operational Programs Inspection Report 05200026/2024010 NL-24-0194, Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)2024-05-0707 May 2024 Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1) IR 05000424/20244032024-05-0101 May 2024 Cyber Security Inspection Report 05000424/2024403 and 05000425/2024403 Public ML24120A2832024-04-30030 April 2024 Project Manager Reassignment NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 NL-24-0170, Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report2024-04-25025 April 2024 Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report IR 05000424/20240012024-04-23023 April 2024 –Integrated Inspection Report 05000424/2024001 and 05000425/2024001 NL-24-0154, Preservice Inspection Progam Owners Activity Report2024-04-16016 April 2024 Preservice Inspection Progam Owners Activity Report ML24079A0062024-04-10010 April 2024 – Proposed Alternative to the Requirements of ASME Code of Operation and Maintenance of Nuclear Power Plants for Pressure Isolation Valve Testing Frequency ML24030A9092024-04-10010 April 2024 Issuance of Amendment Nos. 224 and 207, Regarding Revision to Technical Specification 3.4.14 (Reactor Coolant System) Pressure Isolation Valve Leakage Surveillance Requirement 3.4.14.1 ML24096A1322024-04-0505 April 2024 Individual Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for Hearing and Order (EPID L-2024-LLA-0043) - Letter NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. NL-24-0128, License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency2024-04-0404 April 2024 License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency NL-24-0116, Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred.2024-03-29029 March 2024 Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred. NL-24-0098, Report on Status of Decommissioning Funding2024-03-28028 March 2024 Report on Status of Decommissioning Funding NL-24-0112, Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards2024-03-28028 March 2024 Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards NL-24-0097, Exemption Request: Final Safety Analysis Report Update Schedule2024-03-22022 March 2024 Exemption Request: Final Safety Analysis Report Update Schedule NL-22-0267, License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements2024-03-20020 March 2024 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements ML24047A0362024-03-0404 March 2024 Response to Hatch and Vogtle FOF Dates Change Request (2025) ML24053A3562024-02-28028 February 2024 Annual Assessment Letter for Vogtle Electric Generating Plant, Unit 3 & 4 (Report 05200025/2023006 & 05200026/2023006) IR 05000424/20230062024-02-28028 February 2024 Annual Assessment Letter for Vogtle Electric Generating Plant Units 1 and 2 - NRC Inspection Report 05000424-2023006 and 05000425-2023006 NL-24-0060, Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03)2024-02-15015 February 2024 Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03) 2024-08-07
[Table view] |
Text
Justin Leous From: Sara Barczak [sara@cleanenergy.org]
Sent: Tuesday, July 22, 2008 3:08 PM To: Justin Leous
Subject:
JP: Revised SACE Vogtle License Renewal comments Attachments: F-SACE REVISED Vogtle LR comments 072208.pdf; ATTOO001; clipimage002.png; ATTOO002 Hi JP--
Thanks for allowing me to submit revised comments. I greatly appreciate it.
Let me know if you have any problems w/the attachment. I'll mail these revised comments too.
Thanks again--Sara Barczak 1
cIea n energyc org Clean Energy '
July 22, 2008 Chief, Rules, Rulemaking, Directives, & Editing Branch Division of Administrative Services Mailstop T-6D59 U.S. NRC Washington, DC 20555-0001 Email: VogtleLREIS@nrc.gov RE: Revised Comments on the DSEIS for Vogtle License Renewal-in place of 7/16/08 comments To Whom It May Concern:
Southern Alliance for Clean Energy (SACE) is a non-profit energy policy organization with members throughout Georgia and across the region. We promote responsible energy choices that create global warming solutions and ensure clean, safe and healthy communities in the Southeast.
SACE believes that extending the operating life of the existing Vogtle reactors poses unacceptable risks that should be avoided. Southern Company's Plant Vogtle is also the only site in the country undergoing permitting with the U.S., NRC for a license renewal, an early site permit (ESP), and most recently, a combined operating license (COL). We have serious concerns about the ability of the NRC and other relevant agencies to thoroughly review all the permits in a holistic manner that ensures coordination between the respective NRC project teams.
Other Energy Choices Exist We requested in our environmental scoping comments that the NRC fully research other energy choices, including renewables and energy efficiency and conservation as the application from Southern Nuclear was woefully inadequate. Thank you to the NRC staff for including updated wind information that was lacking in the application including that new certified wind maps of Georgia were released by the National Renewable Energy Laboratory in October 2006 that show there is substantial wind power available, especially offshore, with a potential of 10,000MW. (See the Georgia Wind Working Group website at www.gawwg.org.) Additionally, Southern Nuclear's application referenced 1986 wind data in spite of Southern Company being involved in an offshore wind study with Georgia Tech that was released in 2007,"Southern Winds: Summary Project Report 2007, A study of wind power generation potential off the coast of Georgia." That study recommended that Southern Company continue to pursue offshore wind and the NRC staff did -
include our recommendations to include that study in the draft EIS. We appreciate that inclusion.
According to the Department of Energy, wind power capacity factors continue to increase with technological advances, operational advances, and taller towers. The capacity factors for Class 4 and 5 wind projects in 2006 ranged from 35-45%. Additionally, in reference to lines 37-40 on page 8-68, the argument against wind turbines does not accurately portray modern methods for installing wind turbines. By making the argument that wind is not an alternative method to nuclear plant Vogtle because no more than 200 wind turbines have ever been put up at one time, Southern Company is making the assumption that wind plants are built in the exact manner that nuclear and
Page 2 of 4 Southern Alliance for Clean Energy revised Vogtle license renewal comments coal plants are, all at once. To the contrary, the most common method for installing wind plants are to either contract with a professional wind developer and enter a 20-year PPA. The second most common method is for the professional wind developers to enter into a partnership with the utility that will allow both entities to enjoy the financial benefits of wind plants. By doing this, the utility can simultaneously build wind plants. A great example is Xcel Energy who installed 2,635 MW of wind energy in 2007 alone. Further, an advantage of wind power is that the construction times are relatively short, 8-10 months, and allows for quick installation. This installation then allows for Southern Company to immediately assess its future needs for electricity, instead of trying to project 10 years into the future based on current consumer behavior. Lastly, offshore wind generally peaks during thesummer afternoons, which can help curb the peak load. This information should be considered in the final EIS.
Southern Company's direct comparison of nuclear to wind, nuclear to solar, and nuclear to energy efficiency ensures that Southern Company cannot truly appreciate the advantage of using a diverse options of energy resources. The extremely high costs of new nuclear reactors is unfair to consumers and Southern Company should instead implement serious efficiency programs to first reduce the amount of electricity that will be required in the future, and then use a mix of biomass, offshore wind energy, and solar to meet the rest of the demand.
The cost of the proposed Vogtle expansion is approximately $14 billion. According to the Department of Energy's latest numbers on offshore wind turbines ($2.6 million/ MW installed),
Southern Company could spend $13 billion for 5,060 MW of wind power. Although, in partnership with other developers, Southern Company would not spend this money in its entirety, and therefore it would save Southern Company capital, and defend customers from the rising cost of nuclear power (11-13 cents / kWh according to Progress Energy). Offshore wind energy' according to Georgia Tech and Southern Company's wind report is between 8-13 cents/kWh, and is not subject to fuel price increases. The NRC should investigate these costs more thoroughly in the final EIS.
We believe that the NRC failed to acknowledge in the draft EIS that many renewable energy technologies, including as wind, offer substantial water benefits. According to the Department of Energy's National Renewable Energy Laboratory, developing 1000 MW of wind in Georgia would save 1628 million gallons of water per year.' The NRC has completely overlooked this important information in the draft EIS and it must be incorporated before the final EIS is issued.
The draft EIS is still deficient in its analysis of energy efficiency. Energy efficiency and conservation represent the quickest, safest, cheapest way to provide more power and to best protect our air and water resources. As an added benefit, increased energy efficiency reduces water consumption by power plants that compete with local industries and cities for much needed water.
The NRC makes no mention of this connection. In December 2007, Georgia's Drought Response Unified Command (DRUC) highlighted the water-energy connection, issuing a statewide press release that stated:
DRUC encourages Georgiansto help save water by conserving electricity. Large amounts of water are requiredto generate electricity. In Georgia, each kilowatt hour (kWh) of electricity production consumes 1.65 gallons of water accordingto the NationalRenewable Energy Laboratory." To put it in context, the average Georgiahousehold's electricity use is 1,148 kilowatt hours per month, requiring 1,894 gallons of water to generate.
Page 3 of 4 Southern Alliance for Clean Energy revised Vogtle license renewal comments Negative Impacts on Our Water Resources Power plants have a tremendous impact on our water resources. Our energy choices make a big difference on the future of the river basins and the communities and businesses reliant on those water sources. And given that the license renewal for Vogtle is for 20 additional years of operation-taking us to 2047 and 2049 if approved, we believe the NRC needs to evaluate not only the Georgia of today, but the Georgia we may be living in 40 years from now. But the draft EIS doesn't really do this. The State of Georgia and surrounding states continue to face drought conditions, yet there is little analysis beyond a level 3 drought. The brief mention of a level 4 drought in Appendix E does not appear to take into account the impacts from the additional two proposed reactors and that must be done in the final EIS. It is unclear whether impacts to upstream users, such as those reliant on Lake Hartwell, the upper-most reservoir on the river, have been studied. This must be included in the final EIS. Plant Vogtle is already a large water user that is currently returning only about one-third of what it withdraws from the Savannah River. An additional 20 years of operation, as populations increase, will not be a positive development for our water resources.
Further, the proposed new nuclear reactors at Plant Vogtle are estimated to use 53 million gallons of water per day with 50-75% of that lost as steam. (Southern Nuclear OperatingCompany, Early Site PermitApplication, EnvironmentalReport, August 2006). This means that more water will be lost from the two existing and two proposed reactors at Plant Vogtle than is currently used by all residents of Atlanta, Augusta, and Savannah combined. iv From our review of the draft EIS for the ESP at Vogtle, the cumulative impacts on water quality and quantity have not been satisfactorily evaluated. Therefore, we believe that this issue is also remains deficient in terms of the license renewal evaluation-sort of a cart-before-the-horse phenomenon.
There are concerns about tritium contamination, a radioactive form of hydrogen that can impact our health. Faced with saltwater intrusion of the Floridan Aquifer, both Beaufort and Jasper counties in South Carolina and the Savannah area will become more dependent on the Savannah River for drinking water. In fact, in 2009 the City of Savannah's main line will begin blending Floridan aquifer with Savannah River water in order to help meet groundwater use reduction requirements.
There is no mention of this in the draft EIS. Plant Vogtle already contributes to the tritium in the river and allowing the reactors to operate for longer will do nothing to reduce this reality, let alone when and if more reactors come online. The NRC needs to study tritium in the river, future projections especially given the Savannah River Site's already large contribution to the tritium pollution, and to analyze this with droughts and future population growth in mind. Just stating on page 4-54 that SRS is the major contributor and that further operation of Vogtle will contribute limited tritium increases is not acceptable; an analysis of the cumulative exposure of people to tritium via their drinking water in particular is needed in the final EIS.
Licensing Deficiencies / Regulatory Concerns As we mentioned earlier, we have grave concerns that too many permits are occurring at the same time with Plant Vogtle: a license renewal, an early site permit, and a combined operating license.
Can the NRC keep up with all of this in a manner that is truly protective of public health? From our review of the draft EIS for the license renewal and the draft EIS for the ESP, we are doubtful; as we all know, bureaucracies themselves have their deficiencies. The idea that everything will be coordinated seamlessly between all these different staff and all these different projects seems unrealistic and now we have further proof that it is not being achieved.
Page 4 of 4 Southern Alliance for Clean Energy revised Vogtle license renewal comments Global Warming We asked the NRC to evaluate predicted effects of global warming on this region and how nuclear power plants may be negatively impacted or unable to generate electricity. This was demonstrated by the heat wave this past. summer in Europe and the U.S.-when nuclear power plants from Sweden to Alabama had to power back because the lake or river water temperatures were too high to allow for safe operation of their nuclear power plants. Yet this hasn't been analyzed in the draft-it is just mentioned in terms of comments that we already submitted; it must be done before a final EIS is issued. It wasn't done for the draft of the ESP either. When will the NRC address this important issue?
Summary The draft EIS for the relicensing of Plant Vogtle along with the draft EIS for the early site permit demonstrate that the NRC is not adequately protecting human health or the environment, rather, the NRC is protecting the nuclear power industry. Overlooking clean, safe energy alternatives and ignoring the tremendous impacts to our water resources and pocketbooks is not acceptable. The NRC must do better before issuing the final environmental impact statements.
Sincerely, Sara Barczak, Safe Energy Director Southern Alliance for Clean Energy 428 Bull Street, Suite 202 Savannah, GA 31401
'National Renewable Energy Lab, Economic Benefits, Carbon Dioxide (CO2) Emissions Reductions, and Water Conservation Benefitsfrom 1,000 Megawatts (MW) of New Wind Power in Georgia, June 2008. 300 MW land based and 700 MW offshore.
National Renewable Energy Laboratory, Consumptive Water Usefor U.S. Power Production,Paul A. Torcellini, Nicholas Long, & Ronald D.Judkoff, Dec. 2003.
DRUC Press Release, 12/11/07, at qtroL.w eeotnvtosgpLdoc/l 611 5714..
'Using 2005 Census figures and with the average per capita daily water use in GA at 75 gallons from surface and ground water sources, bttm"/water.uses.covi'waltnsctlabesidrttta.st.htrts. Water use figures for new reactors from Southern Nuclear Operating Company, Vogtle Early Site Permit Application, Environmental Report, August 2006.