ML23326A044

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Comment (4) of Daryl M Davis on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Energy Harbor Corp.; Energy Harbor Generation Llc.; Energy Harbor Nuclear Corp.; Perry Nuclear Power Plant, Unit 1
ML23326A044
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 11/09/2023
From: Desiree Davis
- No Known Affiliation
To:
Office of Administration
References
NRC-2023-0136, 88FR69967 00004
Download: ML23326A044 (1)


Text

11/22/23, 9:21 AM blob:https://www.fdms.gov/d367f26d-5cd0-46ec-bc8c-9dae482ea803 SUNSI Review Complete Template=ADM-013 As of: 11/22/23, 9:20 AM E-RIDS=ADM-03 Received: November 09, 2023 PUBLIC SUBMISSION ADD: Lance Rakovan, Status: Pending_Post David Herrington, Tracking No. lor-xlur-m6qb Antoinette Walker-Smith, Mary Neely Comments Due: November 09, 2023 Comment (4) Submission Type: Web Publication Date:

10/10/2023 Docket: NRC-2023-0136 Citation 88 FR 69967 Energy Harbor Corp.; Energy Harbor Generation LLC.; Energy Harbor Nuclear Corp.; Perry Nuclear Power Plant, Unit 1 Comment On: NRC-2023-0136-0002 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; Energy Harbor Corp.; Energy Harbor Generation LLC.; Energy Harbor Nuclear Corp.; Perry Nuclear Power Plant, Unit 1 Document: NRC-2023-0136-DRAFT-0004 Comment on FR Doc # 2023-22374 Submitter Information Name: Daryl M Davis Address:

Cleveland, OH, 44109 Email: daryl237@yahoo.com Phone: 12168486912 General Comment Written Comments on Perry Relicensing - Environmental Scoping - Docket ID NRC 2023-0136 Several of my concerns are of events that cannot be prevented or, as in the case of the worst nuclear accidents, are predictable. It seems that these events are routinely dismissed as inconsequential to the health and well-being of the environment, its inhabitants, and the continued viability of regional ecosystems.

Leaks - On June 23, 2023, a tritium leak occurred. "The tritium activity level was determined to be 40,300 pCi/L, and subsequent tests have confirmed continued elevated tritium levels."

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23200A079 This is just the most recent of noted leaks since 2014 which seem to be beyond the ability of the plant operator to prevent or of the regulatory body to address effectively.

In Appendix E of the First Energy LRA there is this statement all commercial nuclear power plants routinely release radioactive gaseous and liquid materials into the environment. And there have been numerous events at nuclear power reactor sites that involved unknown, uncontrolled, and unmonitored releases of liquids containing radioactive material into the groundwater. The majority of the inadvertent liquid release events involved tritium, which is a radioactive isotope of hydrogen. However, other radioactive isotopes, such as cesium and strontium, have also been inadvertently released into groundwater. ML23184A081 Appendix E, 4.5.5.3 Background [GEIS 4.5.1.2] 4-14 This statement in Appendix E is particularly interesting since at the October 25th EIS scoping meeting at the Perry Library a man named Michael Wyatt rose to state that although he was pro nuclear power he insisted that the piles of radioactive silt at the plant must be removed. He was a convincing witness. I blob:https://www.fdms.gov/d367f26d-5cd0-46ec-bc8c-9dae482ea803 1/2

11/22/23, 9:21 AM blob:https://www.fdms.gov/d367f26d-5cd0-46ec-bc8c-9dae482ea803 assumed that he must be referring to the leaked tritium that everyone knows about. However, he stated that this silt has been there for a very long time and I wonder what other radioactive elements might be contained in that radioactive silt. Certainly, it must be removed but it must also be identified. At this time I have not seen any mention in Appendix E of this identification at PNPP.

Flooding, storms, and tornados - The removal and identification of the radioactive silt becomes even more urgent as the effects of climate change result in the increasingly heavier rain and wind storms that Lake County has been experiencing. Flooding will continue to distribute radioactive silt and threaten the structure of the plant. Strong winds and tornados have recently caused serious damage in the area. As storms increase in frequency and strength concerns arise about the condition of the cooling towers.

Experience has shown that failure of cooling towers can result in loss of coolant. Appendix E of the LRA appears not to have recorded the tornados that occurred in 2023 in the area.

Erosion - Erosion on Lake Erie has been a serious problem for decades. Portions of Perry Park have fallen into the lake and recent storms have exacerbated the problem. Property owners along the lake have sought to secure financial assistance for protection from wave action caused subsidence. It is unrealistic to expect the wave action to have spared the shoreline at the Perry plant.

Earthquakes - It is a well-documented fact that earthquakes occur in the region - two notably close to the magnitude design basis. It is concerning that earthquakes can affect groundwater.

See attached file(s)

Attachments Written Comments on Perry Relicensing blob:https://www.fdms.gov/d367f26d-5cd0-46ec-bc8c-9dae482ea803 2/2

Written Comments on Perry Relicensing - Environmental Scoping - Docket ID NRC 2023-0136 Several of my concerns are of events that cannot be prevented or, as in the case of the worst nuclear accidents, are predictable. It seems that these events are routinely dismissed as inconsequential to the health and wellbeing of the environment, its inhabitants and the continued viability of regional ecosystems.

Leaks - On June 23, 2023 a tritium leak occurred. "The tritium activity level was determined to be 40,300 pCi/L, and subsequent tests have confirmed continued elevated tritium levels." https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23200A079 This is just the most recent of noted leaks since 2014 which seem to be beyond the ability of the plant operator to prevent or of the regulatory body to address effectively.

In Appendix E of the First Energy LRA there is this statement all commercial nuclear power plants routinely release radioactive gaseous and liquid materials into the environment. And there have been numerous events at nuclear power reactor sites that involved unknown, uncontrolled, and unmonitored releases of liquids containing radioactive material into the groundwater. The majority of the inadvertent liquid release events involved tritium, which is a radioactive isotope of hydrogen. However, other radioactive isotopes, such as cesium and strontium, have also been inadvertently released into groundwater. ML23184A081 Appendix E, 4.5.5.3 Background [GEIS 4.5.1.2] 4-14 This statement in Appendix E is particularly interesting since at the October 25th EIS scoping meeting at the Perry Library a man named Michael Wyatt rose to state that although he was pro nuclear power he insisted that the piles of radioactive silt at the plant must be removed. He was a convincing witness. I assumed that he must be referring to the leaked tritium that everyone knows about. However, he stated that this silt has been there for a very long time and I wonder what other radioactive elements might be contained in that radioactive silt. Certainly it must be removed but it must also be identified. At this time I have not seen any mention in Appendix E of this identification at PNPP.

Flooding, storms and tornados - The removal and identification of the radioactive silt becomes even more urgent as the effects of climate change results in the increasingly heavier rain and wind storms that Lake County has been experiencing. Flooding will continue to distribute radioactive silt and threaten the structure of the plant. Strong winds and tornados have recently caused serious damage in the area. As storms increase in frequency and strength concerns arise about the condition of the cooling towers. Experience has shown that failure cooling towers can result in loss of coolant. Appendix E of the LRA appears not to have recorded the tornados that occurred in 2023 the area.

Erosion - Erosion on Lake Erie has been a serious problem for decades. Portions of Perry Park have fallen into the lake and recent storms have exacerbated the problem. Property owners along the lake have sought to secure financial assistance for protection from wave action caused subsidence. It is unrealistic to expect the wave action to have spared the shoreline at the Perry plant.

Earthquakes - It is a well-documented fact that earthquakes occur in the region - two notably close to the magnitude design basis. It is concerning that earthquakes can affect groundwater.