ML23132A265
| ML23132A265 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 02/12/2023 |
| From: | Thornton G - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2022-0201, 87FR77146 01652 | |
| Download: ML23132A265 (1) | |
Text
SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: March 08, 2023 Received: February 12, 2023 PUBLIC SUBMISSION ADD: Jill Caverly, Robert Sun, Antoinette Walker- Status: Pending_Post Smith, Mary Neely Tracking No. le1-z0d2-jo9p Comment (1652)
Publication Date: 12/16/2022 Comments Due: February 14, 2023 Citation: 87 FR 77146 Submission Type: Web Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License Document: NRC-2022-0201-DRAFT-1652 Comment on FR Doc # 2022-27164 Submitter Information Name: Gerald Thornton Address:
Farragut, TN, 37934 Email: gatwildcat@aol.com Phone: 865-719-9742 General Comment See attached file(s)
Attachments TRISO-X EIS Scoping Comments 2-12-23 file:///C/...eDrive%20-%20U.S.%20NRC/Desktop/NRC-2022-0201%202023-03-08%2012-04-27_docs/NRC-2022-0201-DRAFT-1652.html[3/28/2023 11:17:01 AM]
EIS Scoping Comments on TRISO-X Nuclear Material Fuel Fabrication Facility in Oak Ridge Tennessee NRC -2022-0201 It is important that NRC consider all potential environmental consequences of a facility to manufacture nuclear fuel, from cradle to grave, to see the full range of benefits and costs to building and operating such a facility. A comprehensive study may reveal that the chosen site may not be the best place for this facility or confirm that it is. To objectively figure this out, the environmental study needs to be comprehensive. The scope of studies needed for a comprehensive EIS must include:
Where will the uranium come from that will be used in the facility, and at what costs to the environment? For instance, uranium must be mined from one or more places. This will destroy the surface environment at the mine sites and may disrupt aquifers, wells, and surface drainage. Would the mining create radioactive dust that contaminates surrounding areas? What are the carbon costs of the mining process? Mining machinery uses a lot of fossil fuels either directly or indirectly to power electric equipment. Are there any species listed as threatened or endangered that will be adversely affected by the mining process?
How will the uranium and other inputs of materials be delivered to the facility, and at what carbon costs? Transportation of uranium and other precursors and process chemicals must be done by trains or trucks, which use a lot of fossil fuels. Will it be necessary to build new rail lines or roads? At what environmental costs?
What are the fossil fuel or carbon costs of building and operating the facility to manufacture the fuel pellets? It appears that the proposed facility will be rather energy intensive. NRC should determine just how much carbon-based fuel will be used to build the facility, and how much carbon will be used on an annual basis and over the expected lifetime of the facility.
How will the electricity supply for this facility be provided? What is the route of the power lines into the facility grounds? Will the power line corridor disrupt wildland habitats or effect threatened or endangered species? If the power line corridor would cross any part of the adjacent Black Oak Ridge Conservation Easement (BORCE), that would be a significant impact on the natural environment.
How much carbon fuel use would be offset by the use of the manufactured uranium fuel to produce electricity on an annual basis or the projected life of the facility? The facility will have large carbon inputs, but if it results in electricity production without carbon, that will offset the carbon that would otherwise be burned to produce electricity through thermal/steam processes.
In short, NRC needs to come up with the full carbon budget of this facility to see what impact it will have on global warming and climate change. It is often alleged that nuclear energy is carbon-free, but that is obviously not true because of all the carbon-based fuels that are used to build and operate nuclear facilities and to provide the raw materials needed for those operations.
NRC also needs to look closely at what will become of the end-product (the waste) from use of the proposed fuel pellets in nuclear reactors, and the carbon and other environmental costs of handling and disposing of those wastes. Since the nuclear reactors will not do anything without the fuel produced by this facility, it is proper to include the disposal costs of this fuel as part of the environmental analysis of this project. NRC must also examine the carbon fuel operating costs of the nuclear reactors. Although
the electricity eventually produced will be carbon-free, the construction and routine operation of the nuclear plants will also have carbon costs that should be factored into the overall environmental analysis.
At the plant site itself, it is critical to examine the reasonably foreseeable consequences of having the facility on the proposed site. What are the risks of a release of radioactive or hazardous chemicals from the facility if there is a failure of some sort? What waste materials will be intentionally released into the environment via air or water? What are their potential effects?
The tract of land proposed for the TRISO-X production facility clearly has a karst geology with channels into underground voids or caves. These, in turn, drain into the East Fork of Poplar Creek, which flows into the main Poplar Creek, a tributary of the Tennessee River. These streams are used for fishing, boating, swimming, and other recreation. Downstream towns use the Tennessee River as their source of drinking water. It is crucial to know what wastes from the proposed facility might find their way into this aquatic system and what harms they might do. The site is adjacent to the BORCE, which is known to have several rare or endangered species of plants and animals. What impacts might the facility have on these species? Bright lights during the night and loud production noises may be harmful to wildlife.
The site plans call for a detention basin over the karst area, where there are visible sinkholes, and immediately up-gradient from a very large sinkhole. If a detention basin at the proposed location is not heavily lined with impervious material, it will probably leak into the underground voids. Any contaminants that leak from or outflow from a detention basin at the proposed location will find their way into the aquifers feeding the East Fork of Poplar Creek. There may be a significant risk that any detention basin at the proposed location will occasionally be flooded by drainage from the adjacent ridge in the BORCE. NRC must study the hydrology of the watershed of the proposed facility, as altered by the hardscape created by the facility itself, and of the detention basin to determine if a detention basin at the proposed site will be stable and adequate to protect downstream water quality, wildlife, and human health. If not, NRC may conclude that this site is not appropriate for the nuclear fuel production facility.
Regardless of whether producing nuclear fuel pellets for nuclear reactors that do not yet exist is a good idea, it is crucial that NRC determine the full environmental impacts of building this particular facility on the proposed site. An appropriate EIS will inform NRC whether to approve a facility on the chosen site or to suggest that any such facility be built elsewhere on a more appropriate tract of land.
Respectfully submitted, Gerald A. Thornton 413 Sugarwood Drive Farragut, TN 37934