ML11304A056
| ML11304A056 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/26/2011 |
| From: | Bogen D Seacoast Anti-Pollution League |
| To: | Bladey C K Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR47612 00020, NRC-2010-0206 | |
| Download: ML11304A056 (6) | |
Text
'I Page 1 of 2 PUBLIC SUBMISSION As of: October 27, 2011 Received:
October 26, 2011 Status: PendingPost Tracking No. 80f5d984 Comments Due: October 26, 2011 Submission Type: Web Docket: NRC-2010-0206 Notice of Receipt and Availability of Application for Renewal of Facility Operating License Comment On: NRC-2010-0206-0013 NextEra Energy Seabrook, LLC; Notice of Availability of Draft Supplement 46 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Seabrook Station, Unit 1 Document:
NRC-2010-0206-DRAFT-0031 Comment on FR Doc # 2011-19875 Submitter Information Name: Doug Bogen -Address: PO Box 1136 Portsmouth, NH, 03802 Organization:
Seacoast Anti-Pollution League Fri C))General Comment Cindy Bladey, chief Rules, Announcements, and Directives Branch (RADB)Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington, DC
Dear Ms. Bladey,
On behalf of Seacoast Anti-Pollution League, I would like to submit the following comments (see attached file)on the Draft Supplemental Environmental Impact Statement (DSEIS) for Seabrook Station's proposed re-licensing.
These comments are submitted as expansion/clarification of my oral comments given at the DSEIS public meeting in Hampton, New Hampshire on September 15th.Doug Bogen Executive Director Seacoast Anti-Pollution League 25-kQcx`RO-6 Tcnic -4e z- /t -£o/3 http://fdms.erulemaking.net/fdms-web-agency/component/contentstreamer?objectld=0900006480f5d98...
10/27/2011 Page 2 of 2 Attachments Seabrook DSEIS Comments 10-26-11 https:l//fdms.eruleinaking.netlfdms-web-agency/component/contentstreamer?objectld=090000648Of5d98...
10/27/2011 Seacoast Anti.Potlution League Helping protect our seacoast since 1969 PO Box 1136 Portsmouth, NH 03802 Tel. 603-431-5089 Sapl.info@comcast.net October 26, 2011 Cindy Bladey, chief Rules, Announcements, and Directives Branch (RADB)Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington, DC
Dear Ms. Bladey,
On behalf of Seacoast Anti-Pollution League, I would like to submit the following comments on the Draft Supplemental Environmental Impact Statement (DSEIS) for Seabrook Station's proposed re-licensing.
These comments are submitted as expansion/clarification of my oral comments given at the DSEIS public meeting in Hampton, New Hampshire on September 15 In general, we are concerned about the assumptions and the timeframe the SEIS uses in its presumed purpose. There is of course an inherent difficulty in projecting twenty years into the future, as required by your legally allowed but nevertheless premature consideration of NextEra's proposal at this time. You seem to be operating on the assumption that the plant structures and the environment surrounding them, particularly the hydrogeologic regime, will largely remain the same two decades into the future. While the draft SEIS does make some general references to potential climate change impacts and existing degradation of plant infrastructure, there seems to be the presumption throughout this report that things will remain the same, that what's happening now will continue at the same rate two to four decades into the future.Similarly, with respect to future power needs and sources you repeatedly appear to rely on the assumption that what's needed or available now will necessarily persist for future decades. As someone who has closely watched regional electric power policy development over the past decade, as well as nuclear industry planning over several decades, I am highly troubled by some of the assumptions and statements you make to justify the purpose of this SEIS.For example, in the executive summary (pg. xvi), the draft SEIS summarizes your dismissal of alternative power options "due to technical, resource availability, or commercial limitations that currently exist and that the NRC staff believes are likely to continue to exist when the existing Seabrook license expires." Considering that you're talking about two decades hence, that's quite a predictive ability, one that many other energy planners and developers would be envious of if was based on any real-world experience.
The basic facts are that the nuclear industry and government energy planners have been consistently wrong about future energy needs and subsequent power development for decades now, and there are dozens of unfinished/killed reactor construction sites (eg., Seabrook #2) and electric power overcapacities (eg., New Hampshire/New England) to show for that. Due to technical change, resource un-availability and commercial opportunities, our power system is changing now, and that change away from "discrete" centralized power sources like Seabrook will no doubt accelerate in coming decades. So we have little reason to trust the NRC staff's "beliefs" about future power needs and options.Again, in the draft SEIS's discussion of environmental impacts of alternatives (section 8), the draft SEIS repeatedly refers to "current" use of various alternatives (pgs. 8-32/line 34, 8-34/line 29 and probably elsewhere) and "current" needs for Seabrook's power (pgs. 8-42/line 12, 8-45/line 30), as if we lived in a static energy environment and the present conditions were an adequate predictor of future needs and options. For accuracy's sake at the very least, shouldn't you correct the text on 8-42/line 12 and 8-45/line 30 to say "presumed to exist in 2030"? Isn't that the real issue here?Relatedly, the draft SEIS repeatedly refers to a need for "discrete" sources of power (pgs. 8-33/line 33, 8-34/line 31 and probably elsewhere), ignoring and negating the distinct advantages of having a decentralized and diversified power system, and more relevant to the current situation, assuming once again that the present serves as an appropriate guide and predictor for the future. Where is it written that we will always need 1250 MW from one "discrete" source on New Hampshire's seacoast, when it isn't even contracted to be used here?Regarding the draft SEIS's comparison of alternative power sources, the general approach appears to be "divide and conquer," as if there was one "discrete" solution, or we would even desire to find solely one alternative power source to replace Seabrook.
As you knock down each alternative power source in turn, you make one feeble though inappropriate attempt to combine two potential sources -new NGCC and wind farms -that once again appears based on past experience rather than future potential.
Besides ignoring the fact that New Hampshire already has an overcapacity of underutilized ICCG plants not far from Seabrook to employ before building new capacity, you proceed under the dubious assumption that most new wind farms will be land-based.
This assumption ignores recent analysis (eg., DOE-NREL, June 2010) on the potential feasibility and greater efficiency of offshore wind development.
If I read it correctly, the DOE report finds there's enough socio-economically feasible wind power potential just of the New Hampshire coast alone to replace Seabrook, let alone vastly greater potential off adjacent coasts in Maine and Massachusetts.
This poorly researched "straw man" approach to viable alternatives does a disservice to the NEPA process you are obligated to address, let alone commonsense public understanding of future power options in our region.Regarding radioactive effluent releases generally, the draft SEIS does admit (on pg. 4-45) that all nuclear plants are expected to "release radioactive material to both the air and water during normal operations," yet it neglects to provide any specifics as to the quantities of these emissions.
Given that it's been definitively established now that there are NO completely safe levels of radiological exposures (NAS BEIR VII, 2005), one would think that some specific estimates of the amounts and kinds of radioactive substances being emitted into our local environment (beyond those given for tritium) would be appropriate here. When I turned to the appropriate page in the draft SEIS (pg. 4-46), I found simply a reference to a previous report by NextEra. Perhaps a brief chart summarizing these quantities in milliCuries could be added here.I was even more dismayed to find that all the stated figures for calculated doses to the public missing negative sign (-) on the exponents, resulting in a description of potential lethal doses!Please correct these typos! Also on that page (line 34-35), you state broadly that the radiological impacts from Seabrook "are not expected to change significantly" based solely on past performance, yet you don't take into account the detection limits of existing environmental monitoring or that emissions could conceivably increase to the cumulative dose limits without raising regulatory alarms. Given the propensity of aging equipment and foundations to leak more (as evidenced by ongoing tritium leaks), the future impacts from these potential emissions increases may not be "insignificant." Specific to tritium, the draft SEIS provides a great amount of monitoring data and other details of ongoing leaks that have not been previously available to the public, though there seems to be little discussion of the amelioration of these leaks beyond increased pumping of groundwater.
There is also scant mention of the relatively high detection limits of employed environmental monitoring, particularly in seawater, which results in the technically correct but nevertheless misleading statements, such as on page 4-59, line 2 that "no offsite migration of tritium in groundwater has been observed," pg. 4-44, line 7 that "[surface water] samples showed not indication of tritium," and again on pg. 4-44, line 28-30 that "no tritium or gamma emitters were detected in any of the groundwater samples collected during the year," and that "results do not indicate any measurable impact from Seabrook plant operation." This last line is repeated throughout the discussion of other environmental parameters and in the summary without reference to detection limits, which could mislead the reader to conclude that there was "no impact" when the cumulative environmental impact could be quite larger.Also, I found it odd and unclear why you refer to tritium leakage to groundwater as "new and potentially-significant information" (pg. 4-58), when the overall problem has been known and monitored for fully 12 years now -more that half the operating age of the plant. And NextEra's applied solution by dilution into to the ocean, while regulator-approved, just does not seem to make sense in the long run (40 more years!), when again, no amount of increased radioactive exposure is completely safe. Also, section 2.2.5 (pg. 2-29) doesn't seem to mention unit 2 dewatering (at 32,000 gpd), even though that appears to be the lion's share of dewatering activities on the plant site.On climate impacts, since my scooping meeting comments a year ago largely focused on this, I'm glad to see some reference to related research, though the description of impacts from increased storms, storm surge, coastal flooding, more powerful/more frequent hurricanes, etc.is vague or non-existent.
Perhaps more importantly, your IGCC-based description of potential sea level rise estimates is now considered by most climate scientist to be too conservative and out-of-date.
The current business-as-usual sea level rise projections have been effectively DOUBLED, as detailed a in major report released last May and elsewhere.
Given all this, the draft SEIS's defense, based on NextEra's previous pronouncements, that the plant's "critical structures" are 20ft. above mean tide is simply not adequate to the issue at hand. How about rest of plant site, the waste storage, site access/egress, powerlines/transformers?
What about the effects on groundwater infiltration and tritium migration?
Given the gravity the issue, a bit more explanation beyond "it's above the projected high-tide" seems in order here.
While we welcome any reference to on-site C02 emissions and relative life-cycle emission analysis, almost every study you cited is from the IAEA, hardly an unbiased source. How about including some independent, peer-reviewed studies? One in particular you should include is "Valuing the greenhouse emissions from nuclear power: A critical survey," by Benjamin K. Sovacool, in Energy Policy 36 (2008), pgs. 2940-2953, which is a broad survey of existing studies and comes to much more unequivocal conclusions about nuclear versus renewable power life-cycle emissions.
Overall, we have to object to your conclusions that the adverse environmental impacts of continued operation of the Seabrook plant are not great enough to deny the option of license renewal, particularly considering the report's poor comparison of replacement power alternatives as well as its own conclusions about LARGE impacts to several economically-important marine species. You owe it to the residents around the Seabrook plant, human or otherwise, to provide a fairer comparison of the alternatives at hand and a more transparent description of the radiological impacts, and considered at the general time of the license renewal, rather than now or in the past. If you are unable to do that given current experience with respect to these alternatives, then the only fair approach would be to delay the final analysis until a more reasonable comparison can be made.Thank you for the opportunity to provide these comments.Sincerely, Doug Bogen Executive Director Seacoast Anti-Pollution League Exeter, NH