ML20237B742

Comment on Proposed Relicensing of Util Plant

ML20237B742
Person / Time
Site:	Calvert Cliffs
Issue date:	08/10/1998
From:	Johnston B AFFILIATION NOT ASSIGNED
To:	NRC
References
FRN-63FR31813 63FR31813-00006, 63FR31813-6, NUDOCS 9808190218
Download: ML20237B742 (3)

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(. Q q Comments on Proposed Relicensing of BG&E's Calvert Cliffs Nuclear Power Plant:

A) Suggestions for Scope of the Supplemental EIS, and B) Defects of the Generic EIS and New Information

, by BillJohnston,10 Aug.1998

.g 7 3458 IIolland Cliffs Road, Iluntingtown, MD 20639-9722, (301)855-1990 S

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Offeredin remembrance ofEdwarJ Lee Rogers, a nonderfid environmentallasyer anda wonderfedp pain inforgoing usualpursuits toprepare thesefew comments is a reminder of his values andcharacter.

The SEIS for Calvert Nuclear should fairly discuss the following:

A1) Why relicense now for 20 more years, when 15 years remain on the original 40 year license? Apparently the steam turbines at Calvert Cliffs need to be replaced, at a cost of over

$300 million. Do these units need replacing due to becoming brittle as a result of radiation, '

earlier than expected? Apparently there have been other major unexpected construction costs at the facility, totaling over $600 million, all of which ($1 billion) BG&E would like to recover from electric consumers, and/or amortize over as long a period as possible, mech of which I don't understand. Apparently, Ralph Nader's group Maryland PIRG has attempted to address this, by waming that BG&E will attempt to influence the MD legislature this next session to require that even if a consumer signs up to buy electricity from a cheaper producer than nuclear under on-coming deregulation of the industry, that consumer would nevertheless pay a surch to BG&E for such construction above. TF,1 s A'> c M 5

'5 4 + E % "ed.cf m These matters are all properly explored in the SEIS, for instance as relevant 3

socioeconomic and other requirements of NEPA. Also,if deregulation provided for passing o' true costs on to consumers, then the exorbitant prices of peak power on peak days would result in cutting those peaks substantially. Alternatively, such peak prices may hasten feasibility of j

rooftop photovoltaic supplying the grid, with payment to the homeowner, &e fS

&c A2) Much of the testimony at the July hearing in Solomons focused on the social and

\ rt economic benefits to the county from Calvert Nuclear and its employees. But if nuclear

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generation were halted, it is likely that the site would be used to construct a major alternative facility. This is because what is possibly most important is the structure and permission to hg withdraw water from the Bay to carry away the waste heat. Accordingly, whatever the outcome pp Pg i of the proposal to relicense, it would be all the same to county socioeconomic. Air quality, also I~ l frequently mentioned as a plus from the nuclear plant, could remain the same by tightening up [m on air e' missions from all fossil fuel plants. All these factors should be considered in alternatives.

m' i Yf i A3) Potential terrorist acts and their results, specific to Calvert Cliffs, including the nearby g, Columbia Gas storage tanks and operations, must be considered.

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A4) The waste heat generated by the 3pentfiset stor$d on site should be compared to that from > >

generation of electricity, taking into account all the waste heat from other units in ther tidewater - ~

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-g region (Chalk Point on the Patuxent, Morgantown on the Potomac River, others present or

':xpected over the term of the relicense), including at the nearby Columbia Gas facility. Such waste heat, amounting to about twice whatever electrical power is produced, provides some o local warming of the air and Bay and its tributaries, over and above global warming. Why d one never see infrared photographs of thermal discharges to the Chesapeake Bay and tributaries e showing in color the temperature gradients of the waste heat being carried away in the currents?

I suspect it is desired avoidance of such graphic information, as much as anything, since such photographs are so common new in other contexts.

• J A5) See B4c) below, as to Calvert Cliffs specifically.

The GEIS should be reopened and updated for the following deficiencies or new information B1) There was a failne of adequate notice to potential interested parties as required by NEPA, since there was no local notice of opportunity to participate in the GEIS. Apparently notice of the GEIS appeared only in the Federal Register, whereas nouce of the SEIS appeared in at least one local paper. "he local notice was the first fair notice to local interested parties, who may very weh have as much interest in the generic issues as in the strictly local issues, including defining the scope of the GEIS.

B2) The GEIS fails totally to develop the energy needs of the population, over the term of the relicensing, and thea to develop the significance of the different alternatives for generating power within that context. Population and per capita energy use, and their growth over the period, are a first step in tne evaluation of alternatives, as within the social-economic and other requirements of NEPA. Meaningful discussion of meeting greenhouse gas goals can only be within such context. Our likely next president, Al Gore, one of the few politicians who seems to understand the environmental challenges this nation and planet face, would certainly approve gos,ernmental agency attention to these matters, as aiding public education, one of NEPA's goals. It is certainly inadequate for the GEIS to beg off this issue by stating (page xxxiv): "No conclusions are made in this documect about the relative environmental consequences oflicense renewal or the construction and operation of attemative facilities for generating electric energy.

The infomiation in the GEIS is available for use by the NRC and the licensees . . (for the SEISsl This information will be updated periodically, as appropriate." is it the GEIS itself that will be so updated? This matter is generic and should be in the GEIS, not in any one SEIS where  ;

presumably consideration would be limited to a specific nuclear plant.

_ B3) The GEIS overlooks entirely the issue oflong term storage ofradioactive. waste, Neither.. - .~.- l methods of storage, required for tens of thousands ofyears, nor the costs for same are covered.

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O B4a) Since the GEIS was completed in early 1996, essentially no progress has been made in ultimate storage soletions, I believe.

I Funher, significant new infonnation has become available, as follows.

i, 1 B4b) The preferred site at Yucca Mountain in Nevada has been found by CalTech and Harvard j* scientists to have ground movement incompatible with stable storage over the tens of thousands j

) of years required for spent fuel rods and other nuclear waste.

B4c) Vectra Corporation, the maker of the NUHOM dry storage casks for storing spent fuel on site until a central repository becomes available, if ever, which happen to be the casks used at Calvert Cliffs, went out of business because of some problem with assuring the integrity of the casks, which impact the safety of future casks under relicensing.

B4d) Deregulation of the electric power industry is new, and significant for traditional approaches to meeting demand.

B4e) Whether the US should adhere to the agreements of the 1997 Kyoto conference on '

curbing greenhouse gas emissions is controversial. The potential for meeting proposed US CO 2 tions should therefore be addressed, that is, with and without relicensed nuclear power.

a B5) Terrorism, such as dropping a bomb on the spent fuel stored on site, to spread radioactivity over a large area, is not addressed at all in th; GEIS. Some reference is made to l

other documents which may addiess this, but this is not sufficient given the importance of this  !

subject. Clearly, the issue is being avoided, even as our cable television channels cre interrupted weekly for emergency drills, without any connection with the local nuclear plant being broadcast in 60se drills.

B6) Apparently, how spent nuclear fuel will be stored, as required for tens of thousands of years, remains unanswered. As to whatever impacts might result, from any method that might be chosen in the future, the NRC " concludes that these impacts are acceptable . . and would not require the NEPA conclusion, for any plant, that the option of extended operation (that is, the relicensing) . . should be eliminated." (GEIS, page xlvi.)

In other words, the entire problem of ultimate waste control is simply held to be manageable, and the issue now closed. The costs, including to future generations could be enormous. This is not acceptable, and must be addressed generically as to all plants. It is ludicrous, and illegal under NEPA, to avoid fair discussion of this major issue in the GEIS.

Discussion of alternatives must include some cost estimates, and comparison of:otal costs with nonnuclear alternatives, as per the socioeconomic and other requirements of NEPA. (The  ;

procedure of assessing future costs, by discounting at 3% their present value, is questionable- .

because there would be no present layaway of such funds to accrue in value to cover same when the time came. The obligation to protect such wastes essentially forever becomes more of the i generational debt we now commit to our offspring.) , , , ,_. . , , _

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