ML23046A440
| ML23046A440 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/30/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR76219 | |
| Download: ML23046A440 (5) | |
Text
From:
Michel Lee Council <lee2councilenergy@gmail.com>
Sent:
Monday, January 30, 2023 12:23 PM To:
ComanchePeakEIS Resource
Subject:
[External_Sender] Docket ID: NRC-2022-0183 - Comments of CIECP &
PHASE re Scoping & EIS for Comanche Peak January 30, 2023 RE: Docket ID: NRC-2022-0183 - Comments of CIECP & PHASE to NRC re Conduct of Scoping Process and Preparation of Environmental Impact Statement for Vistra Operations Company LLC - Comanche Peak Nuclear Power Plant Units 1 and 2 U.S. Nuclear Regulatory Commission ComanchePeakEIS@nrc.gov
Dear NRC,
On behalf of the Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) it is respectfully submitted that consideration of relicensing a nuclear plant to run for 60 or more years warrants a particularly stringent and comprehensive analysis of all factors relating to the environment and public wellbeing. Such a long operation extension will impact the environment and public health in multiple ways.
Continued operation well into the century will also most certainly present substantially elevated challenges, especially with respect to changing climate and other conditions over which neither the Nuclear Regulatory Commission (NRC) nor the site operator will have control.
We submit the many uncertainties and risks emerging even today caution strongly against pushing aging machines past their limits. Moreover, the vast array of issues related to existing nuclear waste - of all classifications - remain unresolved after nearly 80 years. Facilitating generation of even more radioactive wastes is feckless and irresponsible.
Paramount in the array of issues requiring consideration in the scoping of an Environmental Impact Statement (EIS) for the Comanche Peak Nuclear Power Plant, it is worth noting that the cost of any catastrophic accident, the cost of the transportation of nuclear waste, and the cost of safeguarding all of the additional high-level nuclear waste (not to mention the waste which will already have been generated) is born principally by the public. All of these costs must be quantified by independent impartial actors and transparently revealed and analyzed in an EIS.
The NRC is well aware of these realities, of course. We recite them here simply to spotlight the fact that, as the industry reaps the profits, it is communities and the American public which bear the incalculable risks inherent in running these old nuclear plants long past their originally planned operation and safeguarding their waste products for literally millennia.
The NRC must not continue to rely on its Maintenance Rule as a means to evade recognition that components, equipment, and systems - including metals, welds, electrical cable, and concrete - age. Maintenance, again, as the NRC is well aware, is not always done and is not always done correctly. Further the history of industrial accidents, including nuclear accidents, demonstrates that failure of components, equipment and systems which are not considered technically necessary for safety can initiate or accelerate the severity of an accident.
Comanche Peak was designed for a world which no longer exists.
We submit that the events which have already transpired in the first decades of our current century illustrates why low-probability, high consequence events such as the rupture of gas pipelines, pandemics/epidemics, terrorism, extreme weather, and natural disasters must be taken into consideration in cost and technical capability calculations, especially where the high consequence may be truly catastrophic.
We further submit that the scoping process and EIS must fully consider the following:
The environmental consequences of a major accident or successful malignant insider saboteur and/or terrorist attack. The potential impacts of a catastrophic accident are well documented. A spent fuel pool fire, for example, could render many thousands of square miles uninhabitable for the remainder of the 21st century.
Hazards of particular concern for Comanche Peak include: (1) The potential failure of the Squaw Creek Reservoir. (2) A pipeline rupture or other event in the region due to the risks associated with fossil fuel installations and activities. (3) Earthquakes. (4) Wildfire. (5) Extreme weather conditions and events, particularly events that have been rare in the past.
These external hazards are highly relevant to their constraint of mitigation of an event at the nuclear plant. In our warming world, looking forward into the century, it is no longer valid to assume that the necessary level of access or emergency response capability will be available.
Aging-related deterioration of buried or otherwise inaccessible or difficult-to-inspect piping, electrical cables, concrete and other equipment and structures must be assumed.
Severe accidents must not be discounted simply because NRC assumptions deem them unlikely. Plausible worst case scenarios mandate evaluation and transparent disclosure to the public. Further, obvious security issues which are in the public record (such as threats in the cyber realm and from drones) may not reasonably be excluded from consideration and discussion.
The 1957 Price-Anderson Act absolves nuclear plant operators - as well as firms involved in nuclear construction and maintenance - of most of the liability for damages in the event of a major accident. The 1957 act was supposed to be a temporary measure, needed until the private commercial nuclear industry and insurers gained some experience with the new nuclear power technology. Yet the industry has successfully lobbied over past decades for liability caps under the Price-Anderson Act and the insurance industry has shown no interest in underwriting policies for nuclear accidents. These facts, we submit must be seriously considered by the NRC. The industry and insurers deem the financial risks of a rare but consequential event too alarming to shoulder. That fact alone necessitates makes their incorporation into the scoping process and honest disclosure in the EIS.
The known unknowns and prognosticated effects and conditions of global warming. The climate-linked events and extreme storms, droughts, floods, wildfires, and dramatic temperature swings experienced in Texas in just the first 20-odd years of this century provide stark warning of what may be ahead. Critically, no EIS may properly rely on historic conditions. More critically, hubris needs to be shelved. Climate experts warn that the dynamics and interaction of climate change conditions will present many unpleasant surprises. This is particularly relevant to nuclear facilities, because mitigation of events relies upon reliable communication,
transportation infrastructure and rapid response capability with strong situational awareness.
Nobody who has picked up a newspaper in over the past few decades could reasonably assert these conditions are a given. Moreover, the very conditions of climate change are risk multipliers for reactor operation and nuclear waste management and sequestration.
The cumulative environmental consequences of additional decades of radionuclide emissions into the environment - including carbon-14. Evaluation of the impacts of decades more of radioactive emissions, including the global warming gas that will persist for some 5,700 years and which has not been monitored must be carefully evaluated. Impact analysis must consider the synergistic interaction of such radionuclides with other known pollutants in the region.
The cumulative health consequences of additional decades of radionuclide emissions into the environment. This must include consideration of the current science, not just reference to outdated studies and regulations. The NRC must consult with medical experts independent of the nuclear industry and acknowledge and incorporate the science pointing to the risks posed to those most susceptible to radiation and toxic chemicals, including women, adolescents, children, babies, breast-fed infants, the embryo/fetus, and persons exposed to cumulative levels of radioactivity and other pollutants.
Given the history of unplanned leaks, given that many have gone on for years before discovery, and given the fact acknowledged by the NRC that corrosion of buried pipes is likely to lead to more radioactive leaks in the future, any assessment must acknowledge and address these additional exposure risks to the public.
Additional exposures to the public will also be incurred through transportation routes should the spent fuel ever be transported offsite.
Decommissioning costs. Where is the money for decommissioning to come from? How can it be assured? Decommissioning is very likely to be a cost born by taxpayers.
The potential health and environmental consequences of decades more of high-level and low-level nuclear waste. The US began a search for potential geologic repository sites in 1970. More than half-a-century later, we have none and the Nuclear Waste Policy Act (NWPA),
passed in 1982, puts the liability for permanent sequestration of high-level nuclear waste on the American taxpayer.
The cost of waste includes the cost of transportation to a permanent repository, should one ever be built, or to off-site so-called interim repositories. Consolidated interim storage facilities (CISFs) currently being proposed by Waste Control Specialists in Andrews, Texas and by Holtec International west of the Texas state line in New Mexico. The governors of both Texas and New Mexico have opposed these facilities, in large part because of the safety and security concerns. The decades of additional high-level nuclear waste which would be generated by the relicensing of Comanche Peak will only add to these concerns and raise all attendant costs.
Waste transportation costs must be included in any honest accounting, as these are unique in the energy sector, substantial in sum, and will likely be borne by the public. These costs include security, first responder and emergency planning, equipping, training, and staging costs.
The long-term tax and economic effects of placing a term high level nuclear waste dump in Texas for an indefinite, and potentially centuries-long, duration. Whether waste will
remain at the site in perpetuity or ultimately be transported to another site in Texas or elsewhere, all the additional spent fuel will still need to be stored and protected at Comanche Peak for decades to come.
Exploration of all reasonable energy alternatives, especially the renewable clean forms of energy that are widely viewed as the energy technologies of the future as well as efficiency technologies, demand-side options, grid upgrades, and battery/storage. In contrast to nuclear power, all of these energy solutions are less costly, more sustainable, and do not present anywhere near the level of national and global security risks inherent in nuclear.
Environmental justice, especially the environmental and health impacts on indigenous, lower income and communities of color. Such impacts are well understood to be disproportionate regardless of whether the issue is chronic low-level toxic exposure or disasters of virtually any scale.
The continued population growth in the region, which will exponentially increase the potential damage calculation for virtually every area of concern. Glen Rose, Texas is just 40 miles southwest of Dallas/Fort Worth, with a population of over 7.7 million.
NRC must use up-to-date knowledge and not rely on outdated reports, studies and regulations - as all of which are based on climate, safety and security conditions which have changed and may be reasonably anticipated to change further over the ensuing decades.
Finally, we aver that the NRC may not reasonably cite regulations (either it own or those promulgated by other bodies) as an evidentiary basis for any assertion or finding.
Regulations are merely regulatory tools and operational guides subject to deficiencies and implementation failures.
The NRC owes a duty to the public to look at the conditions and dangers of the real world and assess and describe them with candor.
Sincerely, Council on Intelligent Energy
& Conservation Policy Promoting Health and Sustainable Energy
Federal Register Notice:
87FR76219 Comment Number:
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Subject:
[External_Sender] Docket ID: NRC-2022-0183 - Comments of CIECP & PHASE re Scoping & EIS for Comanche Peak Sent Date:
1/30/2023 12:22:48 PM Received Date:
1/30/2023 12:22:56 PM From:
Michel Lee Council Created By:
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"ComanchePeakEIS Resource" <ComanchePeakEIS.Resource@nrc.gov>
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