ML11208C272
| ML11208C272 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/25/2011 |
| From: | Barczak S Southern Alliance for Clean Energy |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR32237 00008, NRC-2009-0039 | |
| Download: ML11208C272 (3) | |
Text
Page 1 of I PUBLIC SUBMISSION As of: July 26, 2011 Received: July 25, 2011 Status: PendingPost Tracking No. 80ecabf6 Comments Due: July 25, 2011 Submission Type: Web Docket: NRC-2009-0039 Application for Renewal: Florida Power Corporation; Crystal River Unit 3 Nuclear Generating Plant Comment On: NRC-2009-0039-0004 Florida Power Corporation, Crystal River Unit 3 Nuclear Generating Plant; Notice of Availability of Draft Supplement 44 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Crystal River Unit 3 Nuclear Generating Plant Document: NRC-2009-0039-DRAFT-0005 Comment on FR Doc # 2011-13817 Submitter Information Name: Sara Barczak Address:
P.O. Box 1842 Knoxville, TN, 37901-1842 Organization: Southern Alliance for Clean Energy
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cleanenergy.org Clean Energy July 25, 2011 Cindy Bladey, Chief Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration Mail Stop: TWB-05-BO1M U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sent via online comment form at www.regulations.gov RE: Docket No. NRC 2009-0039, Southern Alliance for Clean Energy Comments on the draft Supplement #44 to the Generic Environmental Impact Statement regarding Crystal River Unit 3 License Renewal To whom it may concern:
1.866.522.SACE wxvw.cfeanenergV.crg P.O, Box 1842 Knoxville. TN 37901 865.637.6055 34 Wall Street. Suite 607 Asheville. NC 28801 828.254,6776 250 Arizona.Avenue, NE Atlanta, GA 30307 404.373,5832 P.O. Box 8282 Savannah, GA 31412 912.201.0354 P.O. Box 1833 Piltstboio, NC 27312 919.360.2492 P.O. Boy, 5O.51
.lacksonville FL 32240 904.710.5538 Southern Alliance for Clean Energy is a regional non-profit conservation and energy consumer organization with members throughout the Southeast, including Florida. We have focused on energy policy, including nuclear power concerns, since 1985.
Southern Alliance for Clean Energy is concerned about Progress Energy's application to relicense Crystal River Unit 3 and extend the operating life of the troubled plant for an additional 20 years beyond the original 40-year operating license. As the NRC is aware, for the past three years Progress Energy has been struggling to bring Crystal River back online due to the uprate and relicensing project that required significant changes to the facility. During that work, an unexpected, massive crack, or "delamination" of the concrete, in the containment structure was unearthed. After significant analysis by Progress and the NRC, an attempt to remedy the problem, which included retensioning of tendons, resulted in additional, unexpected cracking of the containment vessel.
The project and subsequent analysis and repairs have now been underway for three years at costs of nearly $500 million.' Progress Energy now intends to spend more than $1 billion in additional costs to complete yet another round of repairs. We are skeptical of that decision and whether the repairs will ultimately prove successful. Because of anti-consumer state legislation that was passed in Florida several years ago, Progress ratepayers in Florida are paying in advance for some of the costs of this project, an endeavor that may ultimately prove unsuccessful. Thus we are very concerned about the cost implications for customers in Florida. We believe the NRC should be too and thus recommend that the environmental impact statement be delayed.
Robert Trigaux, "Crystal River nuclear startup again delayed as costs approach $500 million," St. Petersburg Times, March 15, 2011. At http://www.tampabay.cont/news/business/energy/crystal-river-nuclear-startup-again-delayed-as-costs-approach-500-rnillion/ 1157496
The Florida Public Service Commission (PSC) is set to hear Progress Energy's request for nuclear cost recovery in August, which originally requested $22.2 million for Crystal River.2 The PSC's decision regarding this matter will not be known until late October-early November 2011.
Additionally, a second docket has been established to address Progress' decisions made during the reactor's outage. 3 It is premature for the NRC to proceed with the EIS until the PSC's decisions in both dockets are known.
As each aging reactor gets relicensed, it becomes increasingly clear that many of these nuclear plants are experiencing serious problems. From leaking tritium pipes to age-worn parts, the Union of Concerned Scientists relies on the NRC's records to conclude that, "the NRC has issued more than one hundred technical reports about the degradation of valves, pipes, motors, cables, concrete, switches, and tanks at nuclear plants caused by aging." 4 Currently, the NRC does not take these aging effects into consideration in Probable Risk Assessments (PRAs). We recommend that the NRC develop guidelines for considering the identified risks of aging in their risk assessments.
Given the NRC Near-term Task Force's recent report on the ongoing Fukushima Dai-ichi nuclear disaster,5 we believe it is also premature to consider license renewal until additional reports are released and deeper analysis of the findings can be conducted. The Crystal River reactor is located in a coastal area that is prone to hurricanes, making it likely to be subject to many, if not all, of the task force's twelve recommendations. As asserted by the task force, Fukushima underscores the fact that worst case scenarios are difficult, if not impossible, to fully plan for.
We urge the NRC to delay review of this renewal until Progress Energy can actually demonstrate progress and provide certainty that the reactor will operate again; the NRC determines recommendations and regulatory implementation based on Fukushima; and the FL PSC assesses the situation in both dockets currently before them.
In closing, we request that the public comment period remain open for an extended period of time, given the containment damage that has required continuous, extensive, and expensive repairs for several years, the unknowns at the FL PSC and the still-to-be determined regulatory impacts on the existing U.S. reactor fleet post-Fukushima. Thank you for your consideration. If you have any questions, please do not hesitate to contact me at 912.201.0354.
Sincerely, Sara Barczak Program Director, High Risk Energy Choices Southern Alliance for Clean Energy 2 Progress Energy Press Release May 2, 2011. At https://www.progress-energy.com/company/media-roo°tinews-arc hi ve/press-re Iease. page?ti tie= Progress+E nergy+fi ing+wou Id+s Ii ght ly+reduce+custormer+nutc lear+cost-recovery+charge&pubdate=05-02-201 1. The FL PSC docket is #110009-El.
3 See FL PSC docket #100437-El
' Lochbaum, David. "Nuclear Plant Risk Studies: Failing the Grade," report released by the Union of Concerned Scientist in August 2000. At http://www.ucsusa.org/assets/docuiuents/nuclearpower/nuc-risk.pdf "Recommendations for Enhancing Reactors Safety in the 2 1 " Century: The Near-Termn Task Force review of Insights from the Fukushima Dai-ichi Accident." July 2011. At http://pbadupws.nrc.gov/docs/ML I118/ML1I1861807.pdf