ML24093A004
| ML24093A004 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/01/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| Shared Package | |
| ML24270A050 | List: |
| References | |
| 89FR10107 | |
| Download: ML24093A004 (3) | |
Text
From:
Glenn Carroll <atom.girl@nonukesyall.org>
Sent:
Monday, April 1, 2024 3:33 PM To:
OconeeEnvironmental Resource
Subject:
[External_Sender] Nuclear Watch South Comments on the Draft EIS Docket ID NRC-2021-0146 To the Nuclear Regulatory Commission:
RE NRC DOCKET ID NRC-2021-0146 Nuclear Watch South submits the following comments on Draft Supplemental Environmental Impact Statement for a proposed second twenty (20) year operating license extension for the Oconee Nuclear Power Station in Seneca, South Carolina.
The three aging Oconee nuclear reactors are sited directly below Duke Energys Jocassee Dam more than 300 feet below the Jocassee Lake level and built into the side of the Keowee Dam about five feet below the Keowee Lake level. These reactors and dams were built simultaneously before the NRC or Duke Energy considered flooding-induced dam overtopping and breaches to be credible. The NRC has previously refused to consider public concerns that Duke Energys failure to adequately upgrade the reactors antiquated design leaves them vulnerable to catastrophic radiological accidents in the event that the upstream dams are breached due to flooding.
The NRC was first established in 1974 when Oconee started operation. Oconee was designed and construction began before the United States put a man on the moon, before word-processors were common and when mimeograph was the primary method to make multiple copies of documents.
Now that Duke Energy is proposing another 20 years of operation, the public has good reason to expect that before re-licensing the Oconee reactors, the NRC will examine their vulnerability to climate change-induced heavy precipitation and flooding.
The NRC has identified the 50-year-old Jocassee earthen Dam as a flood risk, yet claims in the draft Environmental Impact statement: "The effects of climate change on Oconee Station SSC's (systems, structures, and components) are outside the scope of the NRC staff's license renewal environmental review."
If the Jocassee Dam is breached the resulting 19' wall of water, the equivalent of five Mississippi Rivers, will cause a triple meltdown a mere 10 miles from Clemson University.
Oconee's design basis flooding accident is a sunny day failure of the Jocassee Dam. The surface of Lake Jocassee lies 15' below the top of the dam. If an atmospheric river were to dump enough water into the lake to breach the top of the dam an additional 100,000 acre feet, or 32.5 billion gallons, of water would create a downstream tsunami of greater than 19.5'.
The NRCs refusal to consider the foreseeable impacts of climate change on the risks of radiological accidents at these three aging reactors is unacceptable.
The NRC says the environmental impacts on Transportation, Human Health, Postulate Accidents, Uranium Fuel Cycle, and Radioactive Waste Management are all considered SMALL IMPACTS.
HOW ARE THE IMPACTS SMALL?
Each of the 3 Oconee reactors creates 25 tons of highly radioactive waste every year. It is all stored on site in pools of water and dry casks. There's no safe way to transport the stockpile of highly radioactive waste, and nowhere else for it to go. We're talking 80 years and 6,000 tons of high level radioactive waste sitting there.
The impacts from long-term spent fuel storage at Oconee must be analyzed in the EIS.
Portions of three states (South Carolina, North Carolina and Georgia) and 27 counties are in the Oconee Emergency Planning Zone which is home to 1,435,128 people.
Natural features and parks impacted by the Oconee Nuclear Station include Nantahala Forest, Pisgah National Forest, Sumter National Forest, Great Smoky Mountains National Park, Black Rock Mountain, Tallulah Gorge, Tugaloo State Park, Appalachian Trail, Tallulah Falls, Little Tennessee River, Chattooga River, Saluda River, French Broad River, Chauga River, Tugaloo River, Reedy River, Chattahoochee River and Soque Creek.
The impacts on these forests and watersheds must be considered in the EIS.
Oconee most directly impacts the Savannah River watershed. A wholesale accidental release of radioactivity from Oconee would make its way down the Savannah River from which four reactors at Georgia Power's Vogtle nuclear station take their cooling water. In such a scenario, the resulting steam would further spread a radioactive release from Oconee.
The possible contamination of Plant Vogtle and Plant Vogtle steam releases must be considered in the EIS.
Thank you, Glenn Carroll Nuclear Watch South coordinator Glenn Carroll Coordinator Nuclear Watch South P.O. Box 8574 Atlanta, GA 31106 atom.girl@nonukesyall.org 404-378-4263 404-432-8727 cell https://www.nonukesyall.org
Federal Register Notice:
89FR10107 Comment Number:
6 Mail Envelope Properties (0914c7ae42ff761e4ac6d82bfc7d4038)
Subject:
[External_Sender] Nuclear Watch South Comments on the Draft EIS Docket ID NRC-2021-0146 Sent Date:
4/1/2024 3:32:42 PM Received Date:
4/1/2024 3:32:52 PM From:
Glenn Carroll Created By:
atom.girl@nonukesyall.org Recipients:
"OconeeEnvironmental Resource" <OconeeEnvironmental.Resource@nrc.gov>
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