ML20052F550
| ML20052F550 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/10/1982 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0884, RTR-NUREG-884 NUDOCS 8205130179 | |
| Download: ML20052F550 (4) | |
Text
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s RECEIVED
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May 1C f 19%Y1'21982* I m anm uerm ama U.S. Nuclear Regulatory Commission summgu a y
G Washington, D. C.
20555
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ATTN: Director, Division of Licensing g
RE:
OCRE COMMENTS ON DES FOR PERRY NUCLEAR POWER PLANT, 2
DOCKET NOS. 50-440/441.
(NUhEG-0884) 1 Ohio Citizens for hesponsible Energy ("0CRE"), an Inter-venor in the operating license proceeding before the Atomic Safety and Licensing Board for the Perry Nuclear Power Plant, hereby files its comments on the Draft Environmental Statement for Perry, NUREG-0884.
First, OCHE requests that the comment period on the DES be extended for the convenience of the public.
Since this is one of the few instances in which the NRC has invited public comment in its review of tne Perry facility, OCHE feels that d
the public should be accomodated to the fullest extent possible.
COMMENTS 1.
OCHE disagrees that an analysis of production costs (DES Sec. 2.2) shows a strong economic justification for operation of the facility because the capacity factors used by both Staff and Applicant in the analyses are unrealistic.
Based on the operating experience of the two CAPC0 nuclear plants in operation, Davis-Besse and Beaver Valley, OCRE suggests using a capacity factor of 35%.
Using this figure in the cost analysis would result in savings if PNPP is not operated and the same quantity of electricity were generated using coal.
2.
The NRC also considers the diversity of fuel supply provided i
by the operation of PNPP to be a factor favoring its opera-tion.
The only problem foreseen that could cause a fuel shortage is a strike by coal miners.
Such strikes could easily be averted by provididg better wages and working conditions for miners.
OCHE suggests that the $4 billion
~j plus invested in PHPP could have been better spent in that manner; OCHE does not believe in investing in tech-nology at the expense of humanity.
3.
As far as the NRC's contention that operation of both PNPP o@$
units will result in "significant cost savings for area customers" (DES at p. 2-5), OCRE would suggest that the NRC explain their view to the public at the next rate hike en hearing.
A 17% rate hike request oy CEI is currently pending 0
before the PUC0; this is the first (but undoubtedly not 3
[j the last) such rate hike to include the costs of Perry.
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4.
OCHE disagrees with the statement (p. 3-1, second footnote)
$g that there have been no changes in alternative energy Wo sources since the publication of the FES-CP.
The FES-CP(200 g, was released in 1974; to say that there have b_esn no
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advances in alternative energy technology since 1974 is totally absurd. The NRC also does not seem to consider conservation to be a viable alternative to energy con'sumption and the construction of additional generating facilities.
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Conservation in the most important alternative.
The i
Applicant could encourage conservation by the use of time of day pricing.
innovative pricing structures, e.g.,
Unfortunately, the Applicant has encouraged the increased use of electricity through their rate structures, promotional advertising, and by providing lower rates to those owning all-electric homes.
S.
Section 5.9.4.1.4.6, Risk Considerations, is deficient First, the attempted comparision in several respects.
of the economic risks of nuclear accidents to the risks t
of accidents, und continual emissions, from the use-of fossil fuels to generato electricity neglects several A fossil fuel generating plant important differences.
does not accumulate the fission product inventory present in nuclear plants.
An accident at a coal plant would never require evacuation of the public, as no danger of prompt fatalities would exist.
The continual emissions of sulfur dioxide and nitrogen oxides which can cause.
acid rain can be controlled through the use of scrubbers.
Utilities, however, have resisted the installation of such equipment at their fossil fuel plants.
l the comparision of ' uclear riska n
Secondly, OCRE considoro to other accident risks encountered by the public to be reprehensible.
People engaging in activities involving risk such as driving automobiles, flying in airplanes, using firearms, smoking cigarets, etc. do so voluntarily with an understanding of-the. risks involved and perhaps j
oven some degree of control over them.
The Perry Nuclear Power Plant was forced upon the people of Northeas.t Ohio 1
without tneir knowledge or consent.
The people did not l
ask the Applicant to build a nuclear plant at Perry.
There is still no significant unbiased :ational debate full risis of nuclear power
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or educational program on the (nor are these risks fully known, even to the experts).
The public participation afforded by the NRC's licensing process has been ineffective, largely due to the vast economic inequities between the parties involved. The public is forced to either accept living near a nuclear Obviously not every-plant such as Perry, or move away.
one is in a position to do so.
OCRE considers the relationship between short-term uses 6.
and long-tcrm productivity (Sec. 6.3) to be a crucial 1ssue of the nuclear power debate.
The 2 Perry units will cost at least $4 billion, and will have a lifetime l'
of 40 years, if that. This lifetime is limited by physical the severe environment, with neutron i
- factors, i.e.,
l activation and embrittlement of components and radiation-induced degradation of materials, found in nuclear reactors.
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In comparision,. fossil fuel plants do not have this severe radiation environment, and can be expected to operate for a much longer time.
For example, the Painesville Municipal Light Plant is around 100 years old and is still operating.
Of course, equipmen.t and components have had to be replaced over that time, but this could be done quickly and easily without exposing workers to radiation.
Fossil fuel plants are also more efficient in their conversion of chemical energy to electricity.
Therefore, fossil fuel generation of electricity is advantageous from the viewpoint of the most efficient use of resources.
Fossil fuel plants also do not produce radioactive wastes or require de-commissioning after their useful life has ended.
Fossil fuels, particularly coal, do not require the energy-intensive refinement process necessary for uranium.
The 3 gaseous diffusion plants in the United States use more electricity than the entire continent of Australia.
One might question whether the energy spent in enriching uranium for use in reactors is ever recovered in the operation of the reactors.
Other alternatives, e.g., sclar, wind, hy droele c tric, and conservation, are even more superior to nuclear than is coal in terms of commitment of resources and long-term productivity.
A complete compar194.on of alternatives would indicate that the operation of PNPP is the least dcsirable option.
7.
OCHE contends that the analysis of occupational radiation exposure for BWRs (Sec. 5.9.3.1.1) is faulty because it neglects the newest data which shows that occupational radiation exposure in nuclear power plants is increasing dramatically. Average exposures at BWRs rose 55% in 1980, from 733 to 1136 person-rems (Critical Mass Energy Journal, Oct./Nov.1981,pp.8-9).
1 8.
OCHE questions the projected population growth around PNPP given in Sec. 4.3.1.
Lake County is characterized as having slow population growth.
The undersigned OCHE Representative, having been a life-long resident of Lake County, strongly disagrees with that statement; on the contrary, Lake County has experienced great growth in recent years.
The eastern end of the county especially is now the site of increasing commercialization.
Ic le the areas in closest proximity to the Perry plant which are now experiencing the greatest growth.
The Madison area especially (which is down-wind from PNPP) is growing rapidly. OChE believes that the plant is located ~too close to populated areas, and special emergency prepared-ness may be needed, or PNPP should operate at lower power levels.
Of course, the latter option would nake
, PNPP_even less, competitive with alternatives.
OCHE has many other differences with the Staff's analysis in NUREG-0884.
However, since OCHE's objections are too numerous to pursue herein, and since most of these objections relate more to the NRC's inothodology thun to the specifics of the PNPP facility, OCHE will pursue other routes'in addressing these concerns.
Respectfully submitted, hwW Susan L. Hiatt OCHE Representative 8275 Munson Rd.
Mentor, OH 44060
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