ML23339A035
| ML23339A035 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/03/2023 |
| From: | Billhartz E Univ of Alabama-Birmingham |
| To: | Office of Administration |
| References | |
| NRC-2022-0183, 88FR75629 00001 | |
| Download: ML23339A035 (1) | |
Text
12/5/23, 8:40 AM blob:https://www.fdms.gov/487016d7-5fa5-4161-a614-32b8e0a09732 SUNSI Review Complete Template=ADM-013 As of: 12/5/23, 8:35 AM E-RIDS=ADM-03 Received: December 03, 2023 PUBLIC SUBMISSION ADD: Tam Tran, Status: Pending_Post Antoinette Walker-Smith, Tracking No. lpq-0ixa-1ndr Lance Rakovan, Caroline Hsu, Mary Neely Comments Due: December 26, 2023 Comment (1) Submission Type: Web Publication Date:
11/3/2023 Docket: NRC-2022-0183 Citation: 88 FR 75629 Vistra Operations Company LLC Comanche Peak Power Company LLC Comanche Peak Nuclear Power Plant, Units 1 and 2 Comment On: NRC-2022-0183-2581 Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2 Document: NRC-2022-0183-DRAFT-2577 Comment on FR Doc # 2023-24294 Submitter Information Name: Anonymous Anonymous General Comment Please see the attached file on my comments in support of accepting the renewal of the Comanche Peak Nuclear Power Plant.
Attachments Public Docket Comment on Comanche Peak Nuclear Power Plant Unit 1 and 2 blob:https://www.fdms.gov/487016d7-5fa5-4161-a614-32b8e0a09732 1/1
1 Public Comment on License Renewal of Comanche Peak Nuclear Power Plant Ethan P. Billhartz Department of Engineering, University of Alabama- Birmingham ASEM 616: QL Policy Issues in PtD Professor Walaski December 7, 2023
2 Public Comment on License Renewal of Comanche Peak Nuclear Power Plant I am writing this comment to urge you to accept this application sought by Vistra Operations Company LLC for a twenty-year extension on the operating licenses for one of the youngest nuclear plants in the United States. In October of 2023, Vistra submitted a renewal application for Unit 1 and 2 Facility Operating License Nos. NPF-87 and NPF-89 of the Comanche Peak Nuclear Power reactors located southwest of Dallas-Fort Worth in Texas, whose license is currently set to expire in 2030 and 2033. The license extension of the Comanche Peak Power Company's nuclear plants would allow the Comanche Peak Nuclear Power Plant to provide thermal energy to Somervell County for a total lifespan of sixty years (Nuclear Engineering International, 2023).
I felt compelled to comment on Document ID NRC-2022-0183-2581 because my employment with an energy company, unrelated to Comanche Peak Nuclear Power Plant, enhances my understanding for the need of a diverse mix of energy sources. A combination of multiple sources such as wind, solar, hydropower, natural gas, geothermal and nuclear allow the country to continue producing energy without disruption if one of the sources fails. The nuclear power plant has the ability to provide large-scale storage, which is an important part of energy security. The renewable plants can have limited sources and backup power sources may be required. If the request for the operating extension is not granted, not only will the power sources be compromised in Somervell County, but the local economy could suffer as well. Over six hundred workers and several hundred contractors with average salaries of well over $150,000 would be unemployed. Since the Comanche Peak complex is the largest taxpayer, Somervell County will also have a financial impact from its closure (Texas Comptroller of Public Accounts, 2023).
3 Under normal conditions, the Comanche Peak Unit 1 and 2 nuclear stations can generate enough electricity to power over a million homes and almost half that amount during periods of peak demand. The current fuel mix in the Texas grid deems nuclear energy as a major player in energy production with plans for additional expansions of nuclear stations to other parts of the state. Significant concerns for the 7.7 million residents located near the Comanche Peak Nuclear Power Plant include environmental impact, health and safety issues for local residents (IAEA, 2023). Wind and solar energy are promoted as safer and more environmentally friendly options to consider. It is often overlooked that these sources rely on weather and time of day to be efficient. The nuclear power plant is dispatchable and can adjust the output, depending on demand of electricity according to need (IAEA, 2023).
My organization in the energy industry works with natural gas and electricity and strives for net zero carbon emissions. While no energy source is free of emissions, most of the nuclear plants release of carbon dioxide is during the complex construction process. Comanche Peak Unit 1 and 2 nuclear stations are already established, therefore extending the license twenty more years may prevent another nuclear station from being constructed in the area. The emissions produced from uranium extractions would still occur, but the carbon dioxide emissions that result from demolition and decommissioned sites are inevitable regardless of if the plant closes as scheduled or an additional twenty years is added to the nuclear energy production.
In February of 2023, a notice by Nuclear Regulatory Commissions announced scoping 88 FR 10940 to determine if the Comanche Peak Unit 1 and 2 plants are safe, up to standards, and secure deployment of these advanced reactors (The Federal Register, 2023). This is an in-depth environmental analysis looking at the reactor vessel coolant system, engineered safety features, auxiliary systems, steam and power conversions, containments, structure and
4 component supports, and the electrical instrumentation and control systems. In preparation for license renewal, Comanche Peak Nuclear Power Plant implemented aging management programs to ensure plant safety and efficiency. The aging management programs focused on specific components to prevent, mitigate and monitor the aging process but also included scheduled evaluations of the plant systems performance to determine if it is operating as its intended function. As an attempt to promote safety, Comanche Peak Nuclear Power Plant installed a new steam generation system in Unit 1 and disconnected the remaining recirculation components. Some obsolete equipment has been shut down and is abandoned in place. On both Unit 1 and 2, the reverse osmosis systems, jockey and diesel driven fire pump, electric hydrogen recombiners, boron concentration system, portions of the potable and sanitary water system and exhaust dampers were abandoned in place because they are no longer used (Nuclear Engineering International, 2023). On November 2, 2023, John M. Moses, Deputy Director, Division of Rulemaking, Environmental and Financial Support, Office of Nuclear Material Safety and Safeguards filed a preliminary recommendation "that the adverse environmental impacts of license renewal for CPNPP are not so great that preserving the option of license renewal for energy-planning decisionmakers would be unreasonable" (Justia Regulations, 2023).
The Comanche Peak Nuclear Power Plant took the appropriate steps needed to prepare for the license renewal application. The plant operators executed their own scoping and screening process to detect areas of weakness. The company acted responsibly and proactively instituted an aging plan to detect cracking, cumulative fatigue damage and other forms of damage expected to reduce the integrity of the walls. The Comanche Peak Nuclear Power Plant willingly performed upgrades and eliminated outdated technologies. Vistra Operations Company joined forces for the pursuit of a sustainable and climate-resilient future. Nuclear energy
5 accomplishes near net zero greenhouse emissions and has the highest capacity factor of energy source towering above wind, solar, coal, hydropower, natural gas and geothermal energy (Energy.gov, 2021). Comanche Nuclear Power should be allowed to continue to reliably provide a large dispatchable carbon-free electricity, which is safer for the environment, affordable and beneficial to the local economy. Please consider supporting Document ID NRC-2022-0183-2581.
6 References Comanche Peak aims for 60-year life. Comanche Peak aims for 60-year life - Nuclear Engineering International. (2023, January 4).
https://www.neimagazine.com/features/featurecomanche-peak-aims-for-60-year-life-10490579/
IAEA. (2023, September 12). What is net zero? what is the role of Nuclear Power and Innovations?. IAEA. https://www.iaea.org/bulletin/what-is-net-zero-what-is-the-role-of-nuclear-power-and-innovations Nuclear power is the most reliable energy source and its not even close. Energy.gov. (2021, March 24). https://www.energy.gov/ne/articles/nuclear-power-most-reliable-energy-source-and-its-not-even-close Texas Comptroller of Public Accounts. (2023). Texas Comptroller Energy Tour: Nuclear Overview. Home Comptroller.Texas.Gov.
https://comptroller.texas.gov/economy/economic-data/energy/2023/nuclear.php The Federal Register. Federal Register. (2023, February 22).
https://www.federalregister.gov/documents/2023/02/22/2023-03668/notice-of-intent-to-conduct-scoping-process-and-prepare-environmental-impact-statement-vistra Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, units 1 and 2, 75629-75630 [2023-24294] ::. Justia Regulations. (2022, March 1).
https://regulations.justia.com/regulations/fedreg/2023/11/03/2023-24294.html