ML24045A005
| ML24045A005 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/06/2024 |
| From: | Goldsmith A - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2020-0201, 89FR960 000004 | |
| Download: ML24045A005 (1) | |
Text
2/14/24, 6:39 AM blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a 1/3 PUBLIC SUBMISSION As of: 2/14/24, 6:35 AM Received: February 06, 2024 Status: Pending_Post Tracking No. lsa-jh0j-a6cv Comments Due: February 22, 2024 Submission Type: Web Docket: NRC-2020-0201 Virginia Electric and Power Company; Dominion Energy Virginia; North Anna Power Station, Units 1 and 2 Comment On: NRC-2020-0201-0008 Virginia Electric and Power Company; North Anna Power Station Units 1 and 2; Draft Environmental Impact Statement Document: NRC-2020-0201-DRAFT-0008 Comment on FR Doc # 2024-00147 Submitter Information Name: Aviv Goldsmith Address:
Spotsylvania, VA, 22551 Email:precursors@aol.com General Comment My name is Aviv Goldsmith and I live within the 50 mile radius of the project. I am concerned about the project impacts and the lack of diligence in the analysis as was summarized in the DEIS.
Public outreach within the 50 mile radius is insufficient. In todays world of social media and online access reliance on old methods of notification are inadequate and not in the public interest. Few of the 2.5 million in the 50 mile notice are aware of this document or these proceedings. Scoping and announcements should be increased and comment period extended.
The project description in section 2.1 is largely focused on civil and mechanical elements of the facility.
There is insufficient information on the electrical controls, safeguards, monitoring systems, etc.
Page 2-8 discussion of dosing (lines 16-29) is misleading as it separates the dosages from each generating unit whereas the impacts to the environment and the public are from the combined dosage.
Page 2-9 discussion of dosing (lines 14-35) is misleading as it separates the dosages from each generating unit whereas the impacts to the environment and the public are from the combined dosage.
Page 2-14s statement that the applicant will continue to operate during the SLR term in the same manner as it would during the current renewed license ignores all technological improvements in the industry that have occurred since the original renewed license. The statement also ignores all industry information that has developed with regard to operations, safety, geologic hazards, transport hazards, and storage/disposal hazards.
SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Tam Tran, Ashley Waldron, Antoinette Walker-Smith Mary Neely Comment (4)
Publication Date:1/8/2024 Citation: 89 FR 960
2/14/24, 6:39 AM blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a 2/3 Page 2-15 statement that the environmental impacts of decommissioning would be unchanged by the additional years of operation ignores the potential for increased fuel and nuclear waste that would be onsite after additional years of operation. It also ignores the potential equipment failures from facility operations beyond its original design life.
The section on Alternatives is inadequate. Page 2-15 rightly states that For a replacement energy alternative to be reasonable, it must be either (1) commercially viable on a utility scale and operational before the reactor s operating license expires or (2) expected to become commercially viable on a utility scale and operational before the reactors operating license expires. The natural gas alternative (page 2-17 line 24) should not have been eliminated from the study since it clearly is currently commercially viable.
On page 2-19, the potential contribution from offshore wind of 500 MWe seriously understates the likely capacity expected to become commercially viable on a utility scale and operational before the reactors operating license expires. As stated on page 2-23 Dominion indicated that offshore wind generation is a 3 major component of its strategy to meet standards mandated in the VCEA and that it plans to 4 increase total offshore wind generation to more than 5,000 MW over the next 15 years (VEPCO 5 2020-TN8351, VEPCO 2020-TN8381). The attached social media notice is just one example of Dominions wide ranging claims for offshore wind.
The page 2-22 impacts from offshore wind are overly focused on areas of disturbance and not on lifecycle impacts.
Page 2-25 statement A utility-scale offshore wind alternative of this size would therefore require 272 wind turbines, and more than 270 square nautical miles 26 (230,000 ac) (93,000 ha), which exceeds the area of the Federal waters off coastal Virginia that is designated for wind energy leasing ignores the fact that federal waters are not subject to state boundaries and also that the Dominion electric system is connected to the interconnected PJM grid which can transport bulk power from many areas.
Page 2-29s elimination of natural gas generation due to carbon emissions ignores the potential for carbon sequestration and other offsets.
Page 2-29s elimination of purchased power ignores the many diverse source of power including from within the Dominion and PJM system. Its elimination from consideration is too sweeping and is unsubstantiated.
The conclusion that substantially all of the impacts are SMALL in Table 3-1 indicates an inherent pro-nuclear bias in the analysis.
The top of page 3-7 states that population growth and population centers are within the area of potential impact. What new mitigation measures is Dominion proposing to offset the operating extension?
Certainly improvement of evacuation routes should be considered. Perhaps subsidy of skilled trade education programs, environmental programs, civil engineering could be considered.
Even the changing socioeconomic characteristics of the Lake Anna area are not explored in detail (Section
- 3) nor impacts thereon mitigated.
The seismic analysis in section 3.4 is inadequate. We have already seen seismic events that exceed the design conditions.
Submittal 1 of 2
2/14/24, 6:39 AM blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a blob:https://www.fdms.gov/dbc6f7a7-7b8d-4410-afe2-fcfd79cf668a 3/3 Attachments Screenshot_20240130-205214_LinkedIn