ML15282A351

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Comment (60) by Ernest Goitein Opposing Re-Licensing of the Diablo Canyon Power Plant
ML15282A351
Person / Time
Site: Diablo Canyon  
Issue date: 08/25/2015
From: Goitein E
- No Known Affiliation
To:
Rules, Announcements, and Directives Branch
References
80FR37664 00060, NRC-2009-0552
Download: ML15282A351 (2)


Text

9/1/2015 9//215N RC-2009-.0552-DRAFT- 0053.htmlI As of: 9/1/15 4:50 PM Re'eivedl: Aiigjst 25 201 5 PUBLIC SUBMISSION Status: PendingPost Tracking No. ljz-8kr4-sooz Comments Due: August 31, 2015 Submission Type: Web Docket: NRC-2009-0552 Notice of Receipt and Availability of Application for Renewal of Diablo Canyon Nuclear Power Plant License Comment On: NRC-2009-0552-0026 Diablo Canyon Power Plant, Units 1 and 2; Notice of Intent to Prepare an Environmental Impact Statement Document: NRC-2009-O552-DRAFT-O053 Comment on FR Doc # 2015-15921

~~Submitter Information-,r Name: Ernest Goitein

/-.::2

i?/.

~Address:....

.* 167 Almendral Ave

  • g I:

167 Almendral Ave

\\--]_1..<--

5x

  • Atherton, CA, 94027 i

i Email: fego@pacbell.net SGeneral Comment

Dear NRC,

S I am the former nuclear project engineer, working for Bechtel Corporation, of the Trojan NPP.

Diablo Canyon is essentially a duplicate of Trojan except that Trojan used a cooling tower instead Sof once through cooling as is installed at Diablo Canyon.

S1) There is no reason why a cooling tower cannot be used at Diablo Canyon. Of course it will cost Smoney and affect the Heat Rate of the unit. It will reduce the pumping cost of the circulating water system since only 20% of the water needs to be pumped to plant elevation 85 ft above mean sea

  • \\level. The cooling tower pumping head will be in the order of 35 ft.

A recirculation system is of course an environmental benefit. It avoids killing microorganisms as the water is heated inside the steam condenser tubes and reduces the huge flow of hot water 24/7 Sinto the biologically sensitive area near the outfall discharge. In addition the intake structure's inflow is reduced from 100% to 20%. This five fold reduction in approach velocity will isignificantly reduce entrapment of small fish. The reduced flow will also reduce operating costs of S

the traveling screens.

fille:ll/C :/U ser slCAG/D ownl oadslN R C-2009-0O552-D RAF T-0O53.html 1l1/2

9/1/2015,

LN RC-2009-0552-DRAFT-0053.html

2) The most serious environmental impact could occur during a significant seismic event. The earthquake faults discovered, are near, as well as in very close proximity, of the plant. The original design of Diablo Canyon was based on a seismic response spectra specifically modeled on the known fault at the time and historic events including results from oil explorations. The structures as well as the pipe and electric and instrument cable tray supports are all based on the original response spectra. That means the support locations, spacing, snubbers, and spring supports are carefully calculated to avoid resonance.

Excessive and different motions caused by the forcing function of an other than design earthquake could disable the supports of Class I systems - unless a complete recalculation of all class I piping and cable tray supports are done.

Needless to say, the environmental effects of Class I systems during an earthquake would be a disaster

3) In addition the magnitude of the more recently discovered earthquake faults in all likelihood will exceed the original design. This does not only apply to the structures and supporting power and control systems. Of great concern are the internal components of the reactor vessel, the tube support system and driers in the four steam generators provided by Westinghouse, the NSSS supplier.
4) The spent fuel pool is a critical component - both during operation and during refueling. A larger than design earthquake and with a different forcing function could affect water levels, as well as fuel transfer tube during refueling.
5) As was learned after the Three Mile Island accident, the amount of hydrogen release inside the containment significantly exceeded the anticipated amount. Has Diablo Canyon updated it's hydrogen suppression system since then?

In my opinion all of the above is only a fraction of the concerns that could affect plant safety during an earthquake with a mfagnitude larger than design. A radioactive release would be an environmental disaster. Therefore NEPA would require that the above raised issues be considered in an EIS.

flle:lllC:lUserslCAGIDownloadslNRC-2009-O552-DRAFT-OO53.html22 212

9/1/2015 9//215N RC-2009-.0552-DRAFT- 0053.htmlI As of: 9/1/15 4:50 PM Re'eivedl: Aiigjst 25 201 5 PUBLIC SUBMISSION Status: PendingPost Tracking No. ljz-8kr4-sooz Comments Due: August 31, 2015 Submission Type: Web Docket: NRC-2009-0552 Notice of Receipt and Availability of Application for Renewal of Diablo Canyon Nuclear Power Plant License Comment On: NRC-2009-0552-0026 Diablo Canyon Power Plant, Units 1 and 2; Notice of Intent to Prepare an Environmental Impact Statement Document: NRC-2009-O552-DRAFT-O053 Comment on FR Doc # 2015-15921

~~Submitter Information-,r Name: Ernest Goitein

/-.::2

i?/.

~Address:....

.* 167 Almendral Ave

  • g I:

167 Almendral Ave

\\--]_1..<--

5x

  • Atherton, CA, 94027 i

i Email: fego@pacbell.net SGeneral Comment

Dear NRC,

S I am the former nuclear project engineer, working for Bechtel Corporation, of the Trojan NPP.

Diablo Canyon is essentially a duplicate of Trojan except that Trojan used a cooling tower instead Sof once through cooling as is installed at Diablo Canyon.

S1) There is no reason why a cooling tower cannot be used at Diablo Canyon. Of course it will cost Smoney and affect the Heat Rate of the unit. It will reduce the pumping cost of the circulating water system since only 20% of the water needs to be pumped to plant elevation 85 ft above mean sea

  • \\level. The cooling tower pumping head will be in the order of 35 ft.

A recirculation system is of course an environmental benefit. It avoids killing microorganisms as the water is heated inside the steam condenser tubes and reduces the huge flow of hot water 24/7 Sinto the biologically sensitive area near the outfall discharge. In addition the intake structure's inflow is reduced from 100% to 20%. This five fold reduction in approach velocity will isignificantly reduce entrapment of small fish. The reduced flow will also reduce operating costs of S

the traveling screens.

fille:ll/C :/U ser slCAG/D ownl oadslN R C-2009-0O552-D RAF T-0O53.html 1l1/2

9/1/2015,

LN RC-2009-0552-DRAFT-0053.html

2) The most serious environmental impact could occur during a significant seismic event. The earthquake faults discovered, are near, as well as in very close proximity, of the plant. The original design of Diablo Canyon was based on a seismic response spectra specifically modeled on the known fault at the time and historic events including results from oil explorations. The structures as well as the pipe and electric and instrument cable tray supports are all based on the original response spectra. That means the support locations, spacing, snubbers, and spring supports are carefully calculated to avoid resonance.

Excessive and different motions caused by the forcing function of an other than design earthquake could disable the supports of Class I systems - unless a complete recalculation of all class I piping and cable tray supports are done.

Needless to say, the environmental effects of Class I systems during an earthquake would be a disaster

3) In addition the magnitude of the more recently discovered earthquake faults in all likelihood will exceed the original design. This does not only apply to the structures and supporting power and control systems. Of great concern are the internal components of the reactor vessel, the tube support system and driers in the four steam generators provided by Westinghouse, the NSSS supplier.
4) The spent fuel pool is a critical component - both during operation and during refueling. A larger than design earthquake and with a different forcing function could affect water levels, as well as fuel transfer tube during refueling.
5) As was learned after the Three Mile Island accident, the amount of hydrogen release inside the containment significantly exceeded the anticipated amount. Has Diablo Canyon updated it's hydrogen suppression system since then?

In my opinion all of the above is only a fraction of the concerns that could affect plant safety during an earthquake with a mfagnitude larger than design. A radioactive release would be an environmental disaster. Therefore NEPA would require that the above raised issues be considered in an EIS.

flle:lllC:lUserslCAGIDownloadslNRC-2009-O552-DRAFT-OO53.html22 212