ML23317A365
| ML23317A365 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/09/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 88FR67373 | |
| Download: ML23317A365 (8) | |
Text
From:
GMAIL LEE2 <lee2councilenergy@gmail.com>
Sent:
Thursday, November 9, 2023 11:18 PM To:
PerryEnvironmental
Subject:
[External_Sender] NRC-2023-0136 - Comments of CIECP & PHASE to NRC re Scoping Process and Preparation of Environmental Impact Statement for Perry Nuclear Power Plant, Unit 1 (North Perry, Ohio)
November 9, 2023 RE: NRC-2023-0136 - Comments of CIECP & PHASE to NRC re Scoping Process and Preparation of Environmental Impact Statement for Perry Nuclear Power Plant, Unit 1 (North Perry, Ohio)
TO:
U.S. Nuclear Regulatory Commission PerryEnvironmental@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.
Continued operation of an aging nuclear plant 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 Perry Nuclear Power Plant (Perry) is the fact that a considerable share of the overall risk burden will fall upon the public, both at the state and national level. In this regard, 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.
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.
The very conditions of climate change are risk multipliers for reactor operation and nuclear waste management and sequestration.
Perry was designed for a world which no longer exists.
Hazards of particular concern for Perry which affect multiple domains of risk are: (1) Extreme variability in conditions of Lake Erie, including biota changes and temperature and water level fluctuation. (2) Erosion and wave attack undermining the lower portion of the bluff upon which Perry sits. (3) Earthquakes. (4) Activities and incidents associated with fracking in the area. (5)
Extreme weather conditions and events, particularly events that have been rare in the past, but are deemed plausible with climate change.
We further submit that the scoping process and EIS must fully consider the following:
The full consequences of a major accident or successful malignant insider saboteur and/or terrorist attack.
Severe accidents must not be discounted simply because NRC and licensee assumptions deem them unlikely. Plausible worst case scenarios mandate evaluation and transparent disclosure to the public.
Obvious security issues which are in the public record may not reasonably be excluded from consideration and discussion. These include threats posed individually and interactively from the cyber realm; drones (such as with drone swarms which have already occurred over US nuclear plants); and from emerging AI. While risks resulting from sabotage and terrorism may be unquantifiable, they still demand due recognition in the EIS.
Safety and security are matters intricately tied to environmental impacts, public health, and the no action alternative to relicensing. Hence safety and security and may not legitimately be deemed out-of-scope in the EIS.
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.
While most tremblors have been small, hundreds of earthquakes have been recorded in Ohio, mostly around Lake Erie. Lake Erie has more earthquake activity than other Great Lakes because there are more faults present. Water level change in the region has been identified by scientists as a potential modulator of stresses in the nearby seismic fault system which could induce earthquakes. Regional fracking activity has also been implicated in quakes. On January 31, 1986, just a couple of months after Perry was issued an operating license, but before the nuclear plant began operating, a 5.0 magnitude earthquake shook the region. The epicenter
was just 10 miles south of the nuclear plant. The quake was felt in 10 states and Canada and produced at least a dozen aftershocks. In 2019, an earthquake in Lake Erie registered a 4.0 magnitude and also produced numerous aftershocks. On August 27, 2023, a 4.2 magnitude earthquake struck the area.
While the level of quake risk in the region is still being investigated by scientists, the originally estimated level of risk to Perry would appear to have been underassessed. This came to light in a 2011 investigation by the Associated Press which included review of more than 11,000 pages of records produced by the NRC in a document request. Using NRC data and applying NRC methodology, the AP found that Perrys risk of severe earthquake damage to be 24 times as high as previously thought. The NRC should be cognizant of the strong possibility that the aging Perry plant (and the deteriorated buried inaccessible systems upon which it relies) may be more vulnerable than assumed to a larger-than-accounted-for earthquake or even to a series of minor quakes over time.
The impact of the changing climate and the chaos attendant to extreme weather is relevant not only to the risk of initiating (slowly or rapidly) an accident, but to mitigation capability. Mitigation relies upon reliable communication, transportation infrastructure and rapid response capability with strong situational awareness. Nobody who has picked up a newspaper over the past few decades could reasonably assert these conditions are a given.
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.
The placement of accident risk burden upon the public.
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.
The industry and insurers deem the financial risks of a rare but consequential event too alarming to shoulder. That fact alone necessitates their incorporation into the scoping process and honest disclosure in the EIS.
Aging-related deterioration of buried or otherwise inaccessible or difficult-to-inspect piping, electrical cables, concrete and other equipment and structures must be assumed to be present.
Incontrovertibly, there are significant technical knowledge gaps in the engineering and scientific understanding of age-related deterioration mechanisms (e.g., alkali silica reaction, neutron embrittlement, stress corrosion, etc.).
Yet the NRC has failed to mandate the harvesting and independent lab analysis of aging components, equipment, and structures from U.S. nuclear sites. Instead materials are being sold for scrap or sent out for disposition at storage facilities. Perhaps even more troubling, the NRC has acknowledged that it allows the licensees of decommissioning sites to destroy plant operational records. This means that readily available and cheap to maintain aspects of the
paper/digital record which could flag developing problems and critically inform the extended operation of reactors are being irretrievably lost.
What this boils down to is the fact that computer models used to rationalize continued running of plants beyond their originally planned lifetime have not been validated.
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. For one thing, maintenance, as many NRC inspection reports attest, is not always done and is not always done correctly. For another, NRC regulations are not devoid of imperfection. 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.
The known unknowns and prognosticated effects and conditions of global warming.
The extreme storms, droughts, floods, wildfires, and dramatic temperature swings experienced in Ohio in just the first 20-odd years of this century provide stark warning of what may be ahead.
Lake Erie is classified as highly stressed and deteriorating with significant flooding and erosion issues. Temperature and water levels have fluctuated dramatically over the past few decades.
In general, a substantial decrease in ice cover due to warmer winters has strengthened the ice-albedo feedback and caused increase in summertime water temperatures. In some years, high water levels have led to severe flooding and storms have accelerated natural erosion processes. Higher hotter lake water conditions are projected to predominate in the future. Yet, climate change is also expected to bring severe and sometimes abruptly visiting extreme cold fronts which can lead to the formation of river ice-and-debris clumps which can block water intake systems. Hot temperatures and the removal of the lid of winter ice can also markedly increase evaporation rates with implications for water availability. Blooms of cyanobacteria and fish kill events where populations of fish die en masse are also likely to increase in the future.
For example a fish kill along a 25-mile stretch from Cleveland to Perry in 2021 was blamed on oxygen depletion. In addition Northeast Ohio can also expect to experience periods of drought and brushfires.
The critical point is that the EIS may not 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.
The cumulative environmental and 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.
Impact analysis must incorporate the reality that the impacts of radioactive emissions are cumulative and affirm that impacts from additional releases from Perry will be additive to all those released previously.
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 harmful chemicals, including women, adolescents, children, babies, breast-fed infants, the embryo/fetus, and persons exposed to radiation and chemicals from other sources such as medical diagnostic and treatment procedures.
A central principle of environmental protection must be to protect those most at risk, but that principle is disregarded with respect to emissions, effluents, and waste products from the nuclear fuel cycle.
The EIS should explicitly state that the US radiological protection regime does not consider noncancer illnesses, early failed pregnancies, or developmental disorders.
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. Tritium leaks and tritium emitted into the air (for example through venting) must be given serious attention as newly emerging evidence indicates the isotope to be a far more pernicious pollutant than previously believed.
Additional radioactive exposures to beta, alpha, and gamma rays from a variety of types of additionally generated radioactive waste will also be incurred by members of the public through transportation activities. EIS should note that such exposures may be significant at an individual and population level, especially to those residing or working along road and rail routes.
Evaluation of the impacts of decades more of radioactive emissions must also include acknowledgement that nuclear power is neither a zero-emission or carbon-free industrial activity. Indeed, even during power generation, nuclear produces carbon-14, a radioactive form of carbon which will persist for some 5,700 years.
The cost and risks attendant to decades more of high-level and low-level nuclear waste.
The long-term tax and economic effects of adding to what is in effect a high level nuclear waste dump in Ohio for an indefinite, and potentially centuries-long, duration must be addressed.
Part of the equation will be the additional costs and complexities of ultimate decommissioning and remediation of the site.
Whether waste will remain at the site in perpetuity or ultimately be transported to another site in Ohio or elsewhere, all the additional spent fuel will still need to be stored and protected at Perry for decades to come.
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.
Yucca Mountain was defunded in 2010 and there is no current realistic expectation that the project will be resuscitated.
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 have faced fierce opposition. The governors of both Texas and New Mexico have opposed these facilities, in large part because of the safety and security concerns. These interim nuclear waste storage facilities have also been staunchly opposed by Native American Tribes and Indigenous groups, farmers, ranchers, and the oil and gas industry.
The decades of additional high-level nuclear waste which would be generated by the relicensing of Perry will only add to the problem of nuclear waste and raise all attendant costs.
Should the EIS postulate the removal of spent fuel from the Perry site, waste transportation costs must be included in the accounting, with acknowledgement that the level of spent fuel transportation risk is unique to the energy sector, substantial in sum, and will likely be borne by the public. The calculus of costs should include security, first responder and emergency planning, equipping, training, and staging costs.
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.
Population growth.
Additional population growth in the region would exponentially increase the potential damage calculation for virtually every area of concern.
Perry is just 35 miles Northeast of the city of Cleveland, Ohio.
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 its 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, M. Lee, Esq.
On behalf of:
Council on Intelligent Energy
& Conservation Policy
Promoting Health and Sustainable Energy
Federal Register Notice:
88FR67373 Comment Number:
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Subject:
[External_Sender] NRC-2023-0136 - Comments of CIECP & PHASE to NRC re Scoping Process and Preparation of Environmental Impact Statement for Perry Nuclear Power Plant, Unit 1 (North Perry, Ohio)
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