ML24055A004
| ML24055A004 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/24/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR4631 | |
| Download: ML24055A004 (5) | |
Text
From:
rick feher <raf@oaklandbridge.com>
Sent:
Saturday, February 24, 2024 1:37 AM To:
Kim Conway Cc:
Lalliana Mualchin; robert freehling; rick feher
Subject:
[External_Sender] Docket Nos. 50-275 and 50-323, NRC-2023-0192 Attachments:
scoping comments, DCPP EIS; 50-275 and 50-323, NRC-2023-0192.rtf Kim Conway Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 23 February, 2024 Ms. Conway, Please include the following (text below or document attached) among scoping comments for the Diablo Canyon EIS.
Docket Nos. 50-275 and 50-323, NRC-2023-0192 Thank you, Rick Feher (916) 455 2039 (916) 743 7973 These comments support recommendations regarding the scope of the Nuclear Regulatory Commission (NRC) proceeding considering extending the license of Diablo Canyon Nuclear Power Plant (DCPP). Specifically, they urge the NRC to add consideration of the deterministic Maximum Credible Earthquake (MCE), and not limit evaluation of seismic hazard to probabilistic models with a return period which can understate the actual risk that an earthquake can happen at any time.
From a public safety and earthquake hazard point of view, an unpredictable and sudden occurrence of a large and strong earthquake in the region, particularly but not exclusively on the nearby Hosgri fault, can cause a range of possible damage to the nuclear plant, including and up to a catastrophic nuclear accident of DCPP that could expose a large population of the state to radiation release, leading to the risk of deaths and health problems for generations.
The negative consequence or risk of such earthquake eventuality may far exceed the relatively small benefit of continued operation of this power plant. The primary benefit that the state sees for continued operation of DCPP is reliability during extreme and relatively rare heat events that can happen during the early evening hours in summer. That was the finding of state reports. The unacceptable seismic risk of continued operation of DCPP can be avoided by using a prudent and conservative estimate of the hazards appropriately in all aspects of DCPP. This should be done in a transparent manner. If this can not be done to the satisfaction of the stake-holders and public, it may be necessary to terminate operating DCPP.
Many studies on potential earthquake sources or faults in the area of the DCPP have been made for hazard assessmentmore precisely, strong ground motion hazard. Enough is known, probably, over studied and analyzed now. The largest earthquake that each fault can generate is presumably the strongest and most impactful for that particular fault. This is called Maximum Credible Earthquake (MCE), that was adopted by the state for many years without problems until it was eclipsedand without debateby a new paradigm based on probability. The new method requires combining all sources (its probabilities) even though they may occur at different times. It is necessary that this information (MCEs) be clearly provided so that decision makers and the public can easily understand.
The impacts on DCPP by the largest earthquake on each fault would be different mostly due to size or magnitude and distance (from fault to site). The most impactful or highest hazard source can be easily determined by comparing all the sources. This particular fault is the controlling structure with its MCE for all aspects of DCPP. This must be provided. It is not accurate to state the hazard estimate in this manner as worst case scenario, because it may not be the worst that can happen, but it is a credible one.
Once again, it is not acceptable to operate DCPP without mitigating the risk of nuclear accident that can be caused by an unpredictable and sudden occurrence of a powerful earthquake as stated above. It can happen at any time and the time to make this decision is now.
The above comments incorporate significantly the expertise of Lalliana Mualchin, formerly chief seismologist at the California Department of Transportation, also formerly Professional Registered Geophysicist in California, who has extensive experience reviewing seismic hazard reports for hospitals, schools and critical structures, including nuclear power plants in California during his active service. Dr. Mualchin (Ph.D. in geophysics, Saint Louis University, 1974) lives in Placerville, California. These comments also draw upon the knowledge of Robert Freehling, an energy policy expert who has been involved in Diablo Canyon proceedings before the California Public Utilities Commission in 2016 and 2023; Robert lives and works in Nevada City, California; and Rick Feher, a citizen writer and researcher who has been involved in the planning of public infrastructure in California for decades. He lives and works in Sacramento, California.
Federal Register Notice:
89FR4631 Comment Number:
49 Mail Envelope Properties (6F9BA5F4-7113-46C5-B395-6DEC30C26DD3)
Subject:
[External_Sender] Docket Nos. 50-275 and 50-323, NRC-2023-0192 Sent Date:
2/24/2024 1:37:28 AM Received Date:
2/24/2024 1:37:41 AM From:
rick feher Created By:
raf@oaklandbridge.com Recipients:
"Lalliana Mualchin" <mualchin@hotmail.com>
Tracking Status: None "robert freehling" <rfreeh123@sbcglobal.net>
Tracking Status: None "rick feher" <raf@oaklandbridge.com>
Tracking Status: None "Kim Conway" <Kimberly.Conway@nrc.gov>
Tracking Status: None Post Office:
oaklandbridge.com Files Size Date & Time MESSAGE 4635 2/24/2024 1:37:41 AM scoping comments, DCPP EIS; 50-275 and 50-323, NRC-2023-0192.rtf 6232 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Docket Nos. 50-275 and 50-323, NRC-2023-0192 Scoping comments, Diablo Canyon EIS These comments support recommendations regarding the scope of the Nuclear Regulatory Commission (NRC) proceeding considering extending the license of Diablo Canyon Nuclear Power Plant (DCPP). Specifically, they urge the NRC to add consideration of the deterministic Maximum Credible Earthquake (MCE), and not limit evaluation of seismic hazard to probabilistic models with a return period which can understate the actual risk that an earthquake can happen at any time.
From a public safety and earthquake hazard point of view, an unpredictable and sudden occurrence of a large and strong earthquake in the region, particularly but not exclusively on the nearby Hosgri fault, can cause a range of possible damage to the nuclear plant, including and up to a catastrophic nuclear accident of DCPP that could expose a large population of the state to radiation release, leading to the risk of deaths and health problems for generations.
The negative consequence or risk of such earthquake eventuality may far exceed the relatively small benefit of continued operation of this power plant. The primary benefit that the state sees for continued operation of DCPP is reliability during extreme and relatively rare heat events that can happen during the early evening hours in summer. That was the finding of state reports. The unacceptable seismic risk of continued operation of DCPP can be avoided by using a prudent and conservative estimate of the hazards appropriately in all aspects of DCPP. This should be done in a transparent manner. If this can not be done to the satisfaction of the stake-holders and public, it may be necessary to terminate operating DCPP.
Many studies on potential earthquake sources or faults in the area of the DCPP have been made for hazard assessmentmore precisely, strong ground motion hazard. Enough is known, probably, over studied and analyzed now. The largest earthquake that each fault can generate is presumably the strongest and most impactful for that particular fault. This is called Maximum Credible Earthquake (MCE), that was adopted by the state for many years without problems until it was eclipsedand without debateby a new paradigm based on probability. The new
method requires combining all sources (its probabilities) even though they may occur at different times. It is necessary that this information (MCEs) be clearly provided so that decision makers and the public can easily understand.
The impacts on DCPP by the largest earthquake on each fault would be different mostly due to size or magnitude and distance (from fault to site). The most impactful or highest hazard source can be easily determined by comparing all the sources. This particular fault is the controlling structure with its MCE for all aspects of DCPP. This must be provided. It is not accurate to state the hazard estimate in this manner as worst case scenario, because it may not be the worst that can happen, but it is a credible one.
Once again, it is not acceptable to operate DCPP without mitigating the risk of nuclear accident that can be caused by an unpredictable and sudden occurrence of a powerful earthquake as stated above. It can happen at any time and the time to make this decision is now.
The above comments incorporate significantly the expertise of Lalliana Mualchin, formerly chief seismologist at the California Department of Transportation, also formerly Professional Registered Geophysicist in California, who has extensive experience reviewing seismic hazard reports for hospitals, schools and critical structures, including nuclear power plants in California during his active service.
Dr. Mualchin (Ph.D. in geophysics, Saint Louis University, 1974) lives in Placerville, California. These comments also draw upon the knowledge of Robert Freehling, an energy policy expert who has been involved in Diablo Canyon proceedings before the California Public Utilities Commission in 2016 and 2023; Robert lives and works in Nevada City, California; and Rick Feher, a citizen writer and researcher who has been involved in the planning of public infrastructure in California for decades. He lives and works in Sacramento, California.