ML24226A020
| ML24226A020 | |
| Person / Time | |
|---|---|
| Site: | Kemmerer File:TerraPower icon.png |
| Issue date: | 08/12/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR49917 | |
| Download: ML24226A020 (13) | |
Text
From:
GMAIL LEE2 <lee2councilenergy@gmail.com>
Sent:
Monday, August 12, 2024 11:42 PM To:
TerraPowerEnvironmental Resource
Subject:
[External_Sender] Docket ID NRC-2024-0078 - Comments of CIECP &
PHASE to NRC on TerraPower Scoping Process
Dear NRC:
Kindly accept the below Comments of CIECP and PHASE on the TerraPower Scoping Process.
Michel Lee, Esq.
Chairman Council on Intelligent Energy & Conservation Policy (CIECP)
Senior Analyst Promoting Health and Sustainable Energy (PHASE)
August 12, 2024 Comments of CIECP & PHASE to NRC on TerraPower Scoping Process RE: Docket ID NRC-2024-0078, Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; US SFR Owner, LLC; Kemmerer Power Station Unit 1 TO:
Office of Administration Mail Stop: TWFN-7-A60M Attn: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-001 Via email to: TerraPowerEnvironmental@nrc.gov
Dear NRC,
On behalf of the Council on Intelligent Energy & Conservation Policy (CIECP) and Promoting Health and Sustainable Energy (PHASE) it is respectfully submitted that the proposed Kemmerer Power Station Unit 1 by The TerraPower subsidiary SFR Owner, LLC (hereafter referred to as the TerraPower Project) warrants a particularly stringent and comprehensive analysis of all factors relating to the environment and public wellbeing.
Given the defense and geopolitical considerations which are logically deduced as the primary rationale for the TerraPower project, national and global security risks need to be broadly and deeply assessed and acknowledged to the public - as should be expected from an agency with integrity in a democracy.
Pressing forward with nuclear will most certainly present substantially elevated challenges, not only in safeguarding sites and full fuel cycle activities from malevolent action, but with respect to
changing climate and other conditions over which neither the Nuclear Regulatory Commission (NRC) nor the site licensee will have control.
We submit the many uncertainties and risks emerging even today caution strongly against small modular reactors (SMRs) and other so-called advanced and utterly unproven reactor designs.
Among the array of proposed designs, TerraPowers Natrium appears to be among the most improvident.
Moreover, the vast array of issues related to existing nuclear waste - of all classifications -
remain unresolved after nearly 80 years. Facilitating generation of even more radioactive wastes is feckless and irresponsible.
Hazards of particular concern for the TerraPower Projects, which are additive, interactive and affect multiple domains of risk are: (1) The exceptionally problem-dogged planning and operational history of sodium-cooled fast reactors. (2) Extreme storms, drought and other weather conditions and natural phenomena which, while rare in the past, must be recognized as plausible with climate change. (3) The vulnerability of an appreciable amount of the regions aging non-nuclear infrastructure, including power transmission facilities and corridors and surrounding area roadways. Such vulnerability is particularly relevant to accident mitigation. (4)
The pollutant load from radionuclides, toxic chemicals, and fossil fuel and mining operations in the region. This includes, of course, legacy pollutants from Wyomings retired and retiring coal mines and plants. The health and environmental impacts are cumulative and synergistic. (5)
The potential for cyberattack, attacks on the regional electric grid, and sabotage of site operations. The risk calculus must consider domestic terrorism and inside malevolent actors. (6)
Cost imposed on the public. (7) Radioactive waste.
Paramount in the array of issues requiring consideration in the scoping of an environmental impact statement (EIS) for the TerraPower Project is the fact that a considerable share of the overall risk burden will fall upon the public, both at the state and national level. In this regard, it is worth noting that the cost of any catastrophic accident, the cost of the transportation of nuclear waste, the cost of fuel development, and the cost of safeguarding all of what would be the Wyoming sites additionally generated high-level nuclear waste will be borne principally by the public.
All of these costs must be considered in scoping and quantified by independent impartial actors and transparently revealed and analyzed in an environmental impact statement (EIS).
As the industry reaps the profits - and TerraPower and its investors benefit from billions in federal and state subsidies - it is communities and the American public which bear the incalculable risks inherent in the operation of new SMRS long past their originally planned operation and safeguarding their waste products for literally millennia. The fact that the TerraPower Project is a demonstration project does not mitigate the risk.
We submit that the events which have already transpired in the first decades of our current century illustrates why low-probability, high consequence events must be taken into consideration in assessments, especially where the high consequence may be truly catastrophic. In the case of nuclear, to an unparalleled degree, cumulative effects, safety risks, and security risks are inextricably connected to environmental impacts.
The very conditions of climate change are risk multipliers for reactor operation and nuclear waste management and sequestration.
Below we emphasize certain areas which must be comprehensively investigated and candidly explored in scoping and an EIS.
The full consequences of a major accident or successful malignant insider saboteur and/or terrorist attack.
Severe accidents must not be discounted simply because NRC and licensee assumptions deem them unlikely. Plausible worst case scenarios mandate evaluation and transparent disclosure to the public.
Obvious security issues which are in the public record may not reasonably be excluded from consideration and discussion. These include threats posed individually and interactively from the cyber realm; drones (such as with drone swarms which have already occurred over US nuclear plants); and from emerging AI and directed-energy weapons. While risks resulting from sabotage and terrorism may be unquantifiable, they still demand due recognition in the scoping process for an EIS.
Safety and security are matters intricately tied to environmental impacts and public health.
Hence safety and security and may not legitimately be deemed out-of-scope in the EIS.
The potential impacts of a catastrophic accident are well documented. A spent fuel pool fire, for example, could render the surrounding region uninhabitable for the remainder of the 21st century.
The impact of the changing climate and the chaos attendant to extreme weather is relevant not only to the risk of initiating (slowly or rapidly) an accident, but to mitigation capability. Mitigation relies upon reliable communication, transportation infrastructure and rapid response capability with strong situational awareness. Nobody who has picked up a newspaper over the past few decades could reasonably assert these conditions are a given.
Looking forward into the century, it is no longer valid to assume that the necessary level of access or emergency response capability will be available.
The placement of accident risk burden upon the public.
The 1957 Price-Anderson Act absolves nuclear plant operators - as well as firms involved in nuclear construction and maintenance - of most of the liability for damages in the event of a major accident. The 1957 act was supposed to be a temporary measure, needed until the private commercial nuclear industry and insurers gained some experience with the new nuclear power technology. Yet the industry has successfully lobbied over past decades for liability caps under the Price-Anderson Act and the insurance industry has shown no interest in underwriting policies for nuclear accidents.
In June 2024, Congress extended Price-Andersons imposition of liability upon the American taxpayer once again via the most propagandistically named ADVANCE Act - proving once again that both industry and insurers deem the financial risks of a consequential event too alarming to shoulder. That fact alone necessitates their incorporation into the scoping process and honest clearly stated disclosure in the EIS.
Design flaws, fabrication defects, construction problems, and human performance deficiencies must be assumed to be present - not dismissed as unlikely.
Incontrovertibly, there are significant technical knowledge gaps in the engineering and scientific understanding of how new untested reactors and their associated fuels, components, equipment and systems will behave (much less age) under real world conditions.
The nuclear industry has a long history of surprises in how rapidly deterioration mechanisms emerge. A recent example is the stress corrosion cracking discovered in critical safety injection system pipe welds at plants operated by the French energy giant EDF. Another recent example closer to home is the litany of failures - including abysmal quality control - at the now abandoned V.C. Summer nuclear reactor construction project in South Carolina that turned into a morass of lawsuits, investigations, criminal probes, and the bankruptcy filing of Westinghouse.
What this boils down to is the fact that computer models are just that: models. The TerraPower Project may not be legitimately promoted as safe or efficient. Scoping needs to be broad, because numerous assumptions underpinning the Natrium (the Latin word for sodium) reactor have not been validated.
Indeed, the failure history of sodium cooled reactors is long and global.
Although its promoters are touting the Natrium reactor as an amazingly novel design, it is a mere attempt at reinvention of a commercially failed technology initially developed in the 1950s, with some designs based on liquid fuel. The Molten Salt Reactor Experiment (MSRE) which involved liquid fuel operated at Oak Ridge National Laboratory (ORNL) in Tennessee from 1965 to 1969. The MSRE was based on the Aircraft Reactor Experiment, a concept designed at ORNL in the 1940s.
As the physicist, professor and Simons Chair in Disarmament, Global and Human Security at the University of British Columbia wrote in an essay published in the Bulletin of the Atomic Scientists, the push for molten salt reactors has its root in the 1950s mindset. But the first and the first and only commercial sodium cooled breeder reactor, Fermi-1, suffered a disastrous meltdown in 1966 as a result of a series of failures that had been dismissed as not credible by reactor engineers (Ramana, 2022).
A key concern with molten salt components is corrosion. ORNL tried to avert the problem with development of an alloy, but it had trouble managing stresses and developed cracks on surfaces exposed to the fuel salt. Dr. Ramana notes:
These problems remain relevant. Even today, no material can perform satisfactorily in the high-radiation, high-temperature, and corrosive environment inside a molten salt reactor. In 2018, scientists at the Idaho National Laboratory conducted an extensive review of different materials and, in the end, could only recommend that a systematic development program be initiated. In other words, fifty years after the molten salt reactor was shut down, technical experts still have questions about materials development for a new molten salt reactor design.
Molten salt reactors are a bad idea. The Molten Salt Reactor Experiments history is riddled with extensive problems, both during its operational lifetime and the half century thereafter.
These problems were not accidental but a result of the many material challenges faced by the
reactor itself. Should molten salt reactors ever be constructed, they are unlikely to operate reliably. And if they are deployed, they would likely result in various safety and security risks.
And they would produce several different waste streams, all of which would require extensive processing and would face disposal related challenges. Investing in molten salt reactors is not worth the cost or the effort.
(Ramana).
After the Fermi debacle and a failed attempt to use liquid sodium at the Seawolf reactor, nuclear proponents convinced Congress to subsidize the Clinch River Breeder Reactor Project, a federally funded demonstration effort in Tennessee. Safety issues and spiraling costs resulted in the demise of that before project as well. Reflecting on the history of Clinch River, Henry Sokolski, a former Deputy for Nonproliferation Policy in the Office of the Secretary of Defense, who went on to head the Nonproliferation Policy Education Center, wrote: In the case of Clinch River, the decision to launch the program ultimately rested on a cynical set of political calculations alloyed to an ideological faith in fast reactors and the future of the plutonium economy (Sokolski, 2019).
Molten sodium additionally has the distinct disadvantages. It react explosively when in contact with oxygen, including oxygen contained in water. As an article in Scientific American succinctly put it: On contact with air, it burns; plunged into water, it explodes (De Clercq, 2014).
A detailed inquiry by the Union of Concerned Scientists (UCS) into the purported safety improvements of SMRs and other so-called advanced reactor designs claimed by developers like TerraPower, likewise deemed the (very preliminary) designs to be neither demonstrably safer nor more secure than conventional large nuclear reactors (Lyman, 2021). Further, the cost and proliferation risks appear potentially considerable. Specifically, UCS wrote:
In conclusion, the deployment of a fast reactor-based closed fuel cycle would likely decrease safety, would likely cost far more than LWRs on a once-through fuel cycle, and would make nuclear weapons materials more accessible to terrorists. And these reactors would neither solve the nuclear waste problem nor significantly reduce uranium use over reasonable time scales.
(Lyman, p 72)
As many others have emphasized (Kemp et al, 2024), the proliferation risks of use of high-assay, low-enriched uranium (HALEU) are real. The danger of promoting proliferation posed by the Natrium reactor must be, accordingly, robustly considered in the scoping process.
The NRC must not rely on its own regulations and inspection regime as a means to evade recognition that components, equipment, and systems - including metals, welds, electrical cable, and concrete - deteriorate and can fail. For one thing, maintenance, as many NRC inspection reports attest, is not always done and is not always done correctly. For another, NRC regulations are not devoid of imperfection. Further, the history of industrial accidents, including nuclear accidents, demonstrates that failure of components, equipment and systems which are not considered technically necessary for safety can initiate or accelerate the severity of an accident.
The known unknowns and prognosticated effects and conditions of global warming.
The extreme storms, droughts, floods, wildfires, and dramatic temperature swings experienced in just the first 20-odd years of this century provide stark warning of what may be ahead.
The critical point is that the EIS may not properly rely on historic conditions. More critically, hubris needs to be shelved. Climate experts warn that the dynamics and interaction of climate change conditions will present many unpleasant surprises.
In April 2024, the Government Accountability Office (GAO) issued an important report titled Nuclear Power Plants: NRC Should Take Actions to Fully Consider the Potential Effects of Climate Change (U.S. GAO, 2024). A core finding (which public health and safety advocates have known for years) is that: NRCs actions to address risks to nuclear power plants from natural hazards in its licensing, license renewal, and inspection processes do not fully consider the potential increased risks from natural hazards that may be exacerbated by climate change (U.S. GAO, p 34).
The GAO also documented that the NRC does not use climate projections data to identify and assess risk as part of the safety reviews it conducts or the probabilistic risk assessments it reviews during the initial licensing process. In fact, the GAO found that the NRC has not conducted an assessment to demonstrate that the safety margins for nuclear power plants established during the licensing period are adequate to address the risks that climate change poses to plants (U.S. GAO, p 40).
The GAO concluded that the NRC cannot fully consider potential climate change effects on plants without using the best available informationincluding climate projections datain its licensing and oversight processes (U.S. GAO, pp 40-41).
We agree.
We are also dismayed that our nations nuclear power regulator simply shrugged off the GAO report in the NRCs August 2024 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (U.S. NRC GEIS, 2024).
Yet, beyond the general failure of the NRC to consider climate change effects, as identified by the GAO, we are alarmed by the NRCs longstanding refusal in scoping and EIS reports to discuss risk multipliers or review the elevation/exacerbation of risk from combinations of events which are increasingly occurring concurrently or in rapid succession, sometimes over very wide geographic regions.
Wyomings climate is changing. In the past century, parts of the state have warmed by 3 degrees Fahrenheit. Heat waves are becoming more common. Snowpack is decreasing and snow is melting earlier in spring. Heat and droughts have killed off trees and dried out soils and vegetation. Higher temperatures and drought are likely to increase the extent, frequency, and severity of wildfires in the state. All of these conditions contribute to the direct dangers posed by the TerraPower Project. These conditions also amplify the health hazard of radionuclide emissions, particularly for vulnerable populations, including pregnant women, babies, babies in utero, girls, persons with compromised health, and persons who have low-incomes.
Regardless of the findings in the NRC GEIS, it is impossible to bound ecological impacts in a generic manner. The NRC has a responsibility to look at the potential environmental impacts of the TerraPower Project in a holistic and comprehensive manner.
The cumulative environmental and health consequences of decades of radionuclide emissions into the environment. This must include consideration of the current science, not just reference to outdated studies and regulations.
Impact analysis must incorporate the reality that the impacts of radioactive emissions are cumulative and affirm that impacts from the TerraPower Project will be additive to the harmful emissions from fossil fuel and other industrial activities in the region. We emphasize region, because air and water flows, dust blows, and contaminants and isotopes are mobilized.
The NRC must consult with medical experts independent of the nuclear industry and acknowledge and incorporate the science pointing to the risks posed to those most susceptible to radiation and harmful chemicals, including women, adolescents, children, babies, breast-fed infants, the embryo/fetus, and persons exposed to radiation and chemicals from other sources such as medical diagnostic and treatment procedures (Lalonde, et al, 2023; Makhijani, 2023; Folkers & Gunter, 2022; Sexton-Oates et al, 2020; Olson, 2019; Landrigan et al, 2018).
A central principle of environmental protection must be to protect those most at risk, but that principle is disregarded with respect to emissions, effluents, and waste products from the nuclear fuel cycle.
The ultimate EIS should explicitly state that the US radiological protection regime does not consider noncancer illnesses, early failed pregnancies, or developmental disorders.
Indeed, in a 2022 National Academy of Sciences (NAS) report titled Leveraging Advances in Modern Science to Revitalize Low-Dose Radiation Research in the United States (NAS, 2022),
the NAS committee explicitly recognized that: Low-dose and low-dose-rate radiation effects on human health outcomes and the biological mechanisms of these effects are not fully understood and that there is increasing evidence that low-dose radiation exposure may be associated with non-cancer health outcomes such as cardiovascular disease, neurological disorders, immune dysfunction, and cataracts (NAS, p1). The committee discussed current epidemiological evidence on health effects associated with low doses of radiation and identifies knowledge gaps, particularly for health outcomes other than cancer, that are now being observed at lower doses than in the past. (p 26)
The NAS report also identified key deficiencies in the current US radiation protection system, including that it:
- Estimates cancer risks resulting from low-dose and low-dose-rate exposures based on interpolations from health effects observed in populations exposed to higher doses of radiation and to types of radiation that are different from those that may be of most relevance to the general population.
- Assumes that stochastic effects are limited to cancer, despite accumulating evidence of effects on non-cancer outcomes including circulatory diseases, neurological disorders, immune dysfunction, and cataracts
- Derives risk estimates from population averages that do not account for the known or potential variation in sensitivity among individuals due to genetic, lifestyle, and environmental factors.
(NAS, p 53, Box 3.1 Current Assumptions of the Radiation Protection System)
The NAS committee further observed that the NRCs regulations for protection against radiation are still based primarily on scientific publications issued in the 1970s (NAS, p 55). Among the areas of insufficient consideration are the many more recently discovered mechanisms for tissue, cellular, and genetic regulation, including epigenetic modification, immune status, cellular senescence, aging, and systemic interactions (NAS, p 87, Box 5.1. Challenges in Low-Dose Radiation Research).
Given the history of unplanned leaks, given that many have gone on for years before discovery, and given the fact acknowledged by the NRC that corrosion of buried pipes is likely to lead to more radioactive leaks in the future, scoping must acknowledge and address these additional exposure risks to the public.
Additional radioactive exposures to beta, alpha, and gamma rays from a variety of types of additionally generated radioactive waste will also be incurred by members of the public through transportation activities. Scoping should consider and an EIS should note that such exposures may be significant at an individual and population level, especially to those residing or working along road and rail routes.
Evaluation of the impacts of decades more of radioactive emissions must also include acknowledgement that nuclear power is neither a zero-emission nor a carbon-free industrial activity. Indeed, even during power generation, nuclear produces carbon-14, a radioactive form of carbon which will persist for some 5,700 years. Tritium is now recognized to be a far more pernicious pollutant than previously understood (Ferreira et al, 2023; Makhijani, 2023; NAML, 2022).
The cost and risks attendant to decades more of high-level and low-level nuclear waste.
The long-term tax and economic effects of adding to what will likely result in a high level nuclear waste dump in Wyoming for an indefinite, and potentially centuries-long, duration must be addressed.
Part of the equation will be the costs and complexities of ultimate decommissioning and remediation of the site.
Whether waste will remain at the site in perpetuity or ultimately be transported to another site in Wyoming or elsewhere, all the additional spent fuel will still need to be stored and protected at the TerraPower Project location for decades to come.
The US began a search for potential geologic repository sites in 1970. More than half-a-century later, we have none and the Nuclear Waste Policy Act (NWPA), passed in 1982, puts the liability for permanent sequestration of high-level nuclear waste on the American taxpayer.
Yucca Mountain was defunded in 2010 and there is no current realistic expectation that the project will be resuscitated.
Consolidated interim storage facilities (CISFs) proposed by Holtec International in New Mexico and Waste Control Specialists in Texas have faced judicial scrutiny and fierce opposition. The governors of both Texas and New Mexico have opposed these facilities, in large part because of the safety and security concerns. These interim nuclear waste storage facilities have also been staunchly opposed by Native American Tribes and Indigenous groups, farmers, ranchers, and the oil and gas industry.
The decades of additional high-level nuclear waste which would be generated by the TerraPower Project will only add to the problem of nuclear waste and raise all attendant costs.
Presuming TerraPower postulates the removal of spent fuel from the site, waste transportation costs must be included in the accounting, with acknowledgement that the level of spent fuel transportation risk is unique to the energy sector, substantial in sum, and will be borne by the
public. The calculus of costs should include security, first responder and emergency planning, equipping, training, and staging costs.
Exploration of all reasonable energy alternatives, especially the renewable clean forms of energy that are widely viewed as the energy technologies of the future as well as efficiency technologies, demand-side options, grid upgrades, and battery/storage.
In contrast to nuclear power, all of these energy solutions are less costly, more sustainable, and do not present anywhere near the level of national and global security risks inherent in nuclear.
As former NRC Chairman Dr. Allison Macfarlane, has commented, promoters of nuclear power such as TerraPower put forth advanced nuclear as a way of averting the most alarming consequences of climate change. But when it comes to averting the imminent effects of climate change, even the cutting edge of nuclear technology will prove to be too little, too late. Put simply, given the economic trends in existing plants and those under construction, nuclear power cannot positively impact climate change in the next ten years or more. Given the long lead times to develop engineered, full-scale prototypes of new advanced designs and the time required to build a manufacturing base and a customer base to make nuclear power more economically competitive, it is unlikely that nuclear power will begin to significantly reduce our carbon energy footprint even in 20 yearsin the United States and globally. No country has developed this technology to a point where it can and will be widely and successfully deployed.
If only tens to hundreds of billions of dollars were not being squandered to support nuclear vanity projects like the TerraPower Project, a sustainable future is within reach. The most affordable, rapidly scalable and sustainable technologies that we have right now to combat climate change are renewables, supported by demand side management, delivered though a modernized, more dependable grid, and backed up by storage and battery power.
These cleaner alternatives also present drastically less security risk.
Or, as US Department of Energy Secretary Jennifer Granholm correctly observed: No county has ever been held hostage for access to the sun. No country has ever been held hostage for access to the wind. They have not ever been weaponized, nor will they be (Granholm, 2022).
Environmental justice, especially the environmental and health impacts on indigenous, lower income and communities of color.
Such impacts are well understood to be disproportionate regardless of whether the issue is chronic low-level toxic exposure or disasters of virtually any scale. Impacts deriving from the full fuel cycle must be acknowledged and robustly considered. These include the significant negative impacts which will be inflicted upon environmental justice communities and the land of Indigenous Peoples distant from the Natrium reactor.
Population growth.
Additional population growth in the region would exponentially increase the potential damage calculation for virtually every area of concern.
NRC must use up-to-date knowledge and not rely on outdated reports, studies and regulations - as all of which are based on climate, safety and security conditions which have changed and may be reasonably anticipated to change further over the ensuing decades.
Finally, we aver that the NRC may not reasonably cite regulations (either its own or those promulgated by other bodies) as an evidentiary basis for any assertion or finding.
Regulations are merely regulatory tools and operational guides subject to deficiencies and implementation failures.
The NRC owes a duty to the public to look at the conditions and dangers of the real world and assess and describe them with candor.
Sincerely, M. Lee, Esq.
On behalf of:
Council on Intelligent Energy
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