ML22350A062
| ML22350A062 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/15/2022 |
| From: | Curran D Beyond Nuclear, Sierra Club |
| To: | Office of Administration |
| References | |
| NRC-2020-0201, 87FR68522 00001 | |
| Download: ML22350A062 (1) | |
Text
12/16/22, 10:16 AM blob:https://www.fdms.gov/5310a08c-64e3-4f1f-8352-b43f779fcd99 SUNI Review Complete As of: 12/16/22, 10:14 AM Template=ADM-013 Received: December 15, 2022 PUBLIC SUBMISSION E-RIDS=ADM-03 Status: Pending_Post ADD: Tam Tran, Tracking No. lbp-hdek-o766 Antoinette Walker Smith, Mary Neely Comments Due: December 15, 2022 Comment (1) Submission Type: Web Publication Date:
11/15/2022 Docket: NRC-2020-0201 Citation: 87 FR 68522 Virginia Electric and Power Company; Dominion Energy Virginia; North Anna Power Station, Units 1 and 2 Comment On: NRC-2020-0201-0005 Notice of Intent To Conduct Scoping Process and Prepare Supplement To Draft Environmental Impact Statement Virginia Electric and Power Company North Anna Power, Units 1 and 2 Document: NRC-2020-0201-DRAFT-0003 Comment on FR Doc # 2022-24746 Submitter Information Email: dcurran@harmoncurran.com Organization: Beyond Nuclear and the Sierra Club General Comment See attached comments by Beyond Nuclear and the Sierra Club.
Attachments 2022.12.15 Beyond Nuclear Sierra Club Scoping Comments NA1and2 blob:https://www.fdms.gov/5310a08c-64e3-4f1f-8352-b43f779fcd99 1/1
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Background
NRC Office of Administration December 15, 2022 Page 2 0 HARM£!!._CURRAN NRC Office of Administration December 15, 2022 the NRC Staff must conduct its own independent review, which is not limited by VEPCOs Page 3 NRC Office of Administration December 15, 2022 sufficient rigor to protect against likely earthquakes. Because that assumption has been Page 4 Environmental Report and must correct any deficiencies in VEPCOs report.8 proven wrong, the new EIS must analyze this additional, proven risk. We note that in the Office of Administration As discussed in the Scoping Notice, this proceeding for the preparation of a site-specific 2022 Environmental Report Supplement, VEPCO has utterly failed to address the U.S. Nuclear Regulatory Commission environmental impact statement (EIS) for subsequent renewal of the North Anna operating Issues That Must be Covered by Site-Specific EIS for North Anna Units 1 and 2 environmental significance of the Mineral Earthquake or even acknowledge the Washington, D.C. 20555 licenses arises from two NRC decisions: Florida Power & Light Co. (Turkey Point Nuclear earthquakes occurrence.9 Submitted electronically via Federal rulemaking website Generating Units 3 and 4), CLI-22-02, __ N.R.C. __ (Feb. 24, 2022) (CLI-22-02) and Duke General Docket ID NRC-2020-0234 Energy Carolinas, L.L.C. (Oconee Nuclear Station, Units 1, 2, and 3), CLI-22-03, __ N.R.C. __ Cumulative effects of reliance on aging safety equipment, including seismic risks to aging (Feb. 24, 2022) (CLI-22-03). 2 In those decisions, the Commission reversed the agencys As a general matter, the NRC must conduct a site-specific environmental analysis for all equipment. The EIS should include a discussion of the cumulative effects of extended operation Re: Comments by Beyond Nuclear and the Sierra Club on Scoping of Environmental previous reliance on the NRCs generic environmental impact statement (GEIS) for initial environmental impacts previously classified as Category 1 (i.e., subject to generic findings) using aging safety equipment. The problems experienced by sixty-to-eighty-year-old equipment Impact Statement for North Anna Power Station, Unit Nos. 1 and 2, Docket ID license renewal3 for the purpose of approving subsequent license renewal applications.4 As using up-to-date and complete information. In addition, the NRC must re-evaluate environmental are distinct from, more severe, and less understood than the problems experienced by forty-to-NRC-2020-0201 explained by the Commission in CLI-22-02, [n]either the original 1996 GEIS nor the revised impacts previously characterized as Category 2 (i.e., subject to site-specific findings), using up- sixty-year-old equipment. Aging problems include reactor pressure vessel embrittlement, 2013 GEIS analyzed the environmental impacts of subsequent license renewal periods.5 to-date and complete information. irradiation-assisted stress corrosion cracking of reactor internals, concrete structures and
Dear Office of Administration Officials:
containment degradation, and electrical cable qualification and condition assessment, as Taken together, CLI-22-02 and CLI-22-03 establish procedural requirements for the Specific Scoping Issues identified in SECY-14-0016, Memorandum from Mark A. Satorius, NRC Executive Director of Pursuant to the notice published at 87 Fed. Reg. 68,522 (Nov. 15, 2022) (Scoping Notice), environmental review of VEPCOs 2020 subsequent license renewal application, including the Operations, to NRC Commissioners, re: Ongoing Staff Activities to Assess Regulatory Beyond Nuclear, Inc. (Beyond Nuclear) and the Sierra Club, Inc. (Sierra Club) submit the environmental report attached to the application as Appendix E. 6 Pursuant to these decisions, all Our most pressing concerns about the required scope of the EIS for North Anna Units 1 and 2 are Considerations for Power Reactor Subsequent License Renewal at 1 (Jan. 31, 2014) following comments regarding the scope of the U.S. Nuclear Regulatory Commissions (NRCs) environmental reviews for subsequent license renewal applications - including the North Anna described below. We note that this is not a comprehensive list and that we reserve the right to (ML14050A306) and the NRCs five-volume Expanded Materials Degradation Assessment supplemental environmental impact statement (SEIS) for the subsequent license renewal for review -- must address the Category 1 environmental impacts listed in Appendix A to 10 C.F.R. comment on the draft version of the EIS, as provided by the National Environmental Policy Act (EMDA), NUREG/CR-7153 (Oct. 2014) (EMDA Report).10 Virginia Electric and Power Companys (VEPCOs) North Anna Power Station, Units 1 and 2. Part 50, which formerly were exempted from consideration. As also provided in those decisions, (NEPA) and NRC regulations.
the Staff is now preparing a GEIS for subsequent license renewal. The NRC gave applicants the The cumulative impacts analysis should also include at the cumulative or compounding effects Description of Commenters option to either wait for the GEIS to be completed or perform a site-specific environmental Climate Change. The EIS for North Anna must include the most up to date research on the of operating an aging reactor for an extended period with safety equipment that is not only review. rapidly changing climate. Local, state, federal, and international authorities have published deteriorating in unknown ways but that has also experienced a beyond-design-basis earthquake Beyond Nuclear is a nonprofit, nonpartisan membership organization that aims to educate and significant information on projected climate changes such as sea level rise, subsidence, rising and may experience more of them.
activate the public about the connections between nuclear power and nuclear weapons and the VEPCO has requested a site-specific environmental review. Accordingly, VEPCO has submitted temperatures, storm intensity and duration, and drought since the previous NRC analysis. The need to abolish both to protect public health and safety, prevent environmental harms, and a revised Environmental Report.7 Under standard NRC practice, the NRC Staff will rely heavily NRC must use this updated climate research, information, and projections to define the baseline Impact mitigation by seismic upgrades. The EIS should address the cost-effectiveness of safeguard our future. Beyond Nuclear advocates for an end to the production of nuclear waste on the 2022 Environmental Report Supplement in preparing the site-specific EIS. Nevertheless, environment for the subsequent license renewal period. Further, the NRC must use this updated mitigation measures for reduction of accident risk. For instance, the EIS should address the costs and for securing the existing reactor waste in hardened on-site storage until it can be permanently climate information for conducting both a new review for previously labeled Category 1 and benefits of seismic safety upgrades to ensure that the design of North Anna Units 1 and 2 is disposed of in a safe, sound, and suitable underground repository. For more than fifteen years, (generic) issues and for updating the stale analysis of previously labeled Category 2 (site- adequate to protect public health and the environment in the event of another earthquake that Beyond Nuclear has worked toward its mission by regularly intervening in NRC licensing, specific) issues. The NRC must include climate impacts not simply in a siloed section but rather exceeds the design basis. The EIS should explain why seismic design upgrades were ordered for relicensing, and other proceedings related to nuclear safety matters. must consider how climate change will play a role in every aspect of how North Annas the (now-cancelled) North Anna Unit 3 reactors but not for Units 1 and 2. If costs were not operation, including its aging safety equipment, will interact with and be affected by the considered for Unit 3, should they nevertheless be considered for Units 1 and 2, which are older Founded in 1892, the Sierra Club is a national environmental organization with 3.8 million changing environment during the subsequent license renewal period of 2032 to 2053, as well as a and therefore more vulnerable?11 2
members across the United States. The purposes of the Sierra Club are to explore, enjoy, and 87 Fed. Reg. at 68,523. reasonable time period for decommissioning.
protect the wild places of the earth; to practice and promote the responsible use of the earths 3 Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (Final Impact mitigation by harvesting components from decommissioned reactors. The EIS ecosystems and resources; to educate and enlist humanity to protect and restore the quality of the Report), NUREG 1437, vols. 1-2 (May 1996) (ML040690705, ML040690738) (1996 GEIS); Environmental significance of 2011 Mineral Earthquake. The EIS for North Anna should also address the need to close the technical knowledge gaps and resolve the significant natural and human environment; and to use all lawful means to carry out these objectives. Generic Environmental Impact Statement for License Renewal of Nuclear Plants (Final Report), must consider the environmental significance of the occurrence of the 2011 Mineral NUREG-1437, Rev. 1 (June 2013) (ML13106A241) (2013 GEIS). Earthquake, which exceeded the reactors design basis. By exceeding the reactors design 9 See Hearing Request at 36; Reply at 14.
In 2021, the NRCs Atomic Safety and Licensing Board found that both Beyond Nuclear and the basis, the earthquake disproved the assumption underlying the NRCs issuance of 10 4
CLI-22-02, slip op. at 1-2, 12-13; CLI-22-03, slip op. at 2. operating licenses in 1978 (for Unit 1) and 1980 (for Unit 2) and renewal of those The five volumes of the EMDA Report are as follows: Volume 1, Core Internals and Piping Sierra Club have standing to challenge VEPCOs subsequent license renewal application.1 5 licenses in 2003, that the reactors could be operated safely and without significant (ML14279A321); Volume 2, Core Internals and Piping (ML14279A331); Volume 3, Reactor Id., slip op. at 12.
adverse environmental impacts because their SSCs were built to a design basis of Vessel Aging (ML14279A349); Volume 4, Concrete Aging (ML14279A430); and Volume 5, 6
Appendix E, Applicants Environmental Report, Subsequent Operating License Renewal Stage, Cable Aging (ML14279A461).
North Anna Power Station Units 1 and 2 (August 2020) (2020 Environmental Report). 8 11 See Louisiana Energy Services, L.P. (Claiborne Enrichment Center), LBP-96-25, 44 N.R.C. For a more comprehensive discussion of these issues, see Reply by Beyond Nuclear, 1 7 Virginia Electric and Power Co. (North Anna Power Station, Units 1 and 2), LBP-21-04, 93 Subsequent License Renewal Application, Appendix E, Environmental Report Supplement 1 331, 339 (1996) (NRC Staff ultimately is responsible for preparing the EIS required by Sierra Club, and Alliance for Progressive Virginia to Oppositions to Hearing Request and N.R.C. 179 (2021). (Sept. 28, 2022) (2022 Environmental Report Supplement). NEPA). Waiver Petition (Jan. 15, 2021).
2 3 4 NRC Office of Administration December 15, 2022 Page 5 uncertainties that exist regarding the performance and reliability of equipment that has aged past sixty years, including the harvesting of components from decommissioned nuclear reactors. As NRC has recognized, harvested reactor components [m]ay be the only practical source of representative aged materials; and could be used to validate larger aging data set[s]. 12 Furthermore, [e]x-plant materials offer unique environmental exposure that cannot be entirely replicated by laboratory testing with fresh materials.13 If NRC chooses not to close the technical knowledge gap, it should justify its decision not to do so.
Conclusion We appreciate this opportunity to identify some of our most pressing concerns about the scope of the EIS you will prepare for your decision on VEPCOs subsequent license renewal application.
Sincerely, Diane Curran Counsel to Beyond Nuclear and the Sierra Club 12 M. Hiser, P. Purtscher, A. B. Hull and R. Tregoning, Harvesting of Aged Materials from Operating and Decommissioning Nuclear Power Plants at 5 (Oct. 12, 2017) (ML17285A484).
13
. M. Hiser and A. Hull, Strategic Approach for Obtaining Material and Component Aging Information at 3 (June 2-4, 2015) (ML20332A097).
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