ML24295A105
| ML24295A105 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/21/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR72901 | |
| Download: ML24295A105 (6) | |
Text
From: klineisfine@aol.com Sent: Monday, October 21, 2024 2:28 AM To: PerryEnvironmental
Subject:
[External_Sender] Comments/Questions Perry DGEIS (Docket # NRC 2023-0136)
Attachments: Perry chasm.pdf
Thank you for this opportunity to comment on and ask questions about issues related to the Perry Draft Generic Environmental Impact Statement (NRC Docket # 2023-0136)
Connie Kline HYDROGEOLOGICAL Seismic On January 31, 1986, (just prior to plant operation) there was a magnitude 5 earthquake, the epicenter of which was 10 miles south of the Perry plant. The quake was felt in 10 states and Canada and produced at least 12 aftershocks. The quake was tectonic (naturally occurring) and certain high frequency data demonstrated an excedence of the reactor's seismic magnitude design basis of 5.3. (1)
There have been numerous previous and subsequent earthquakes near the plant, as recently as August 2024, including several with a magnitude of 4.0 to 4.5, yet the vicinity of the plant is not recognized as seismically active.
For example, per the Ohio Department of Natural Resources interactive maps https://gis.ohiodnr.gov/MapViewer/?config=earthquakes:
On 1/26/2001 a magnitude 4.5 earthquake struck the city of Ashtabula, OH.
On June 10, 2019 a magnitude 4.2 earthquake struck in Lake Erie near the city of Eastlake, OH.
On August 27, 2023 with aftershocks continuing into 2024, a magnitude 4.2 earthquake struck Madison, Oh The plant was built on a known fault in Lake Erie traversing the intake and discharge water tunnels as well as a number of onsite faults. (2) There are other faults south of the plant and The Akron Magnetic Boundary, a fault line running from Lake Erie in the area of the reactor south to Akron Ohio. (3)
In 1975 during excavation, a chasm 30' wide and 20' deep running about two-thirds of the building site was discovered and filled with concrete. (newspaper article attached)
Question - Why are the 1986 earthquake and the Akron Magnetic Boundary ignored in the DGEIS?
Erosion The Updated Final Safety Analysis Report (UFSAR) and previous FSARs acknowledge that few studies have been done of lake shoreline erosion in the plant area though erosion is an obvious, serious ongoing problem. Erosion of the '"toe" (lake-level) of the bluff that Perry sits on is postulated to be as much as 3-4 feet annually. (see Endnotes 4 & 5)
"Final design and permit applications for the shoreline permanent protection construction will be initiated when the lake shoreline (toe of bluff) has receded to a point 250 feet away from the closest safety class structure (emergency service water pumphouse)." (4)
"In early spring of 1975, significant shore erosion was observed at...the plant site in the vicinity of site construction operations...(which was) directly attributed to sustained high lake levels which allowed wave attack to undermine the toe of the bluff.. In 1983, a rock protected sheet pile breakwall was erected (to protect a) section of the lake shoreline approximately 2,200 feet long...In 1992,...the interim revetment was extended 1300 feet west to the northwest... (5)
The LRA indicates that another 1200 foot erosion control project is to be completed in 2024. The NRC says the project will begin this Fall. (LRA p. 1739 & 1794)
Question - I requested but was never provided copies of state agency permits (OEPA, ODNR etc.)
required for the 2024 erosion control project.
Question - Has that erosion control project been completed?
Landslides According to the LRA (p. 1816) and the Updated Final Safety Analysis Chapter 2.5,(p.112 - see Endnote 1), the Perry site, like the surrounding offsite area, has a high groundwater table. Observations made in the test borings at the site indicate groundwater levels usually ranging from three to five feet below ground surface in the main plant area..."
Each loaded Holtec dry cask with overpack weighs 200 tons. (6) There are now 29 (two loaded in August 2024 - see below) dry casks on site and that number is expected to almost double to 53 by 2046 on the existing pad. This is a loading of approximately 11,000 tons to the surface of unstable soils. (LRA,
- p. 1719)
According to the Ohio Department of Natural Resources (ODNR), due to earthquake vibrations, erosion, tons of dry cask weight, groundwater penetration etc., the bluff on which Perry sits is potentially subject to landslides, a topic which has been inadequately addressed in the DGEIS. (7)
LEAKS especially TRITIUM Nuclear reactors routinely leak and release into air, soil, and water carcinogens, teratogens, and mutagens some of which are chemically indistinguishable from non-radioactive, life-sustaining elements.
Strontium-90 and cesium-137 replace calcium and potassium respectively causing bone and muscle cancer. Iodine-131 causes thyroid cancer. Cobalt-60 is a liver, kidney, and bone carcinogen. (8)
The LRA pp. 2020-2021 concedes that:
"The issue (of inadvertent radionuclide release) is relevant to license renewal because all commercial nuclear power plants routinely release radioactive gaseous and liquid materials into the environment...(T)here have been numerous events at nuclear power reactor sites that involved unknown, uncontrolled, and unmonitored releases of (radioactive) liquids into the groundwater, (t)he majority of (which) involved tritium...(O)ther radioactive isotopes, such as cesium and strontium, have also been inadvertently released into groundwater. The types of events include leakage from spent fuel pools, buried piping, and failed pressure relief valves on an effluent discharge line."
Scientists have determined that there is no safe dose or threshold of radiation exposure. (9)
The Perry Updated Final Safety Analysis Report (UFSAR Chapter 11, p. 23) states, "Essentially, all tritium in the primary coolant is eventually released to the environs...The study...estimated that approximately 90 percent of the tritium release was observed in liquid effluent, with the remaining 10 percent leaving as gaseous effluent."
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21307A187 Tritium readily crosses the placental barrier and "can have significant biological consequences including damage to DNA, impaired physiology and development, reduced fertility and longevity, and can lead to elevated risks of diseases including cancer."
Exploring Tritium Dangers, Dr. Arjun Makhijani, Ph.D., nuclear engineer and radiation expert https://ieer.org/wp/wp-content/uploads/2023/02/Exploring-Tritum-Dangers.pdf Perry has a mercury discharge variance because the reactor "cannot meet the 30-day average permit limit...and has also demonstrated...that there is no readily apparent means of complying without constructing prohibitively expensive end-of-pipe controls for mercury.
(p. 11) https://epa.ohio.gov/static/Portals/35/permits/doc/3IB00016.fs.pdf It was not until 2007, as the result of a lawsuit, that nuclear power plants began voluntarily reporting tritium levels above an arbitrary EPA annual drinking water standard of 20,000 picocuries/liter (pCi/L) which many experts believe should be reduced to 400 pCi/L.
Question - Why hasn't the NRC made tritium reporting mandatory?
Perry has had a number of tritium leaks in the past decade:
1/20/2014 - 46,2000 pCi/L into groundwater due to a feedwater leak.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML14063A063 July 2015 - 15,900 pCi/L https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML15223A440 1/31/20 through March 2021 tritium and cobalt-60.leaks in the reactor cooling system.
https://www.nrc.gov/docs/ML2111/ML21119A030.pdf (p. 115-117)
December 16 -17, 2021 to January 2022...tritium ranging from 10,100 to 14, 800 pCi/L https://www.nrc.gov/docs/ML2311/ML23117A196.pdf (pp. 32-33) 6/22/23 - 40,000 pCi/L. As of October 2023, the source of this significant tritium leak was unresolved.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23200A079 1/5/24 - 291,000 pCi/L, the largest single leak to date https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML24024A186 Question - Was the source of the 6/23/23 leak identified?
From the Perry LRA:
P. 1821 In May 2006, the Nuclear Energy Institute implemented the Groundwater Protection Initiative, an industry-wide voluntary effort to enhance nuclear power plant operators' management of groundwater protection...(in) instances where the inadvertent release of radioactive substances may result in detectable levels of plant-related materials in subsurface soils and water...Aspects addressed by the GPI include site hydrology and geology, site risk assessment, onsite groundwater monitoring, and remediation...This guidance was further updated in February 2019...
Twenty-one indoor piezometers were installed in 1975 during plant construction...More than 30 outdoor piezometers were installed to monitor the underdrain system performance in 1975, 1983/84, or 1989. The historical piezometers were insufficient by themselves... (so) 12 new triplet groundwater monitoring wells were installed P. 1827 The groundwater monitoring wells, piezometers, and manholes (that) monitor (for tritium) are sampled at different frequencies - quarterly, biannually, semiannually, as needed and periodially.
Please explain the sequence of events that lead to discovery of a leak of a radioactive substance.
Question - Are leaks discovered immediately by a piezometer and if so, how?
Question - Are some ongoing leaks only discovered when manholes, monitoring wells, or piezometers are sampled?
Question - If so, does this mean that a leak might not be discovered for up to two years?
Question - Is triated water due to a leak retained for a period of time before being released into Lake Erie?
Question - If so, does that retention time period vary?
Question - What are the longest and shortest retention times?
Question - Exactly how are the piC/L of tritium measured/determined?
There has been a failure to analyze the additive, synergistic, and cumulative effects of tritium and other radionuclides released into Lake Erie the shallowest of the Great Lakes, with an average depth of 58 feet (LRA p. 1810). which already contains toxic chemicals including PCBs, heavy metals, pesticides, herbicides, and biocides which EH uses to kill mollusks and other invasive aquatic species around the plant's intake and discharge tunnels in the lake.
Question - Why doesn't the NRC contract this type of research with an agency such as the National Academy of Sciences?
EMERGENCY PLANNING Question - if the license extension is granted and the Perry plant can operate for 60 years, how can the NRC justify granting a November 16, 2021 license amendment to reduce emergency planning by eliminating shift positions, increasing response time, eliminating emergency planning information contained in implementing procedures and instructions etc.?
https://www.nrc.gov/docs/ML2127/ML21270A112.pdf AGING, DETERIORATING REACTOR PARTS, COMPONENTS, SYSTEMS etc.
Reactor metal and concrete parts, sealants, coatings, other components, and structures are subject to extreme mechanical, thermal, radiation, chemical, and fatigue stressors which weaken, deteriorate, and degrade them. The NRC acknowledges that some components and structures like buried pipes and cables or building foundations are inaccessible and can't be inspected due to their location. Others in the reactor core or containment, used fuel storage etc. aren't inspectable due to high levels of radiation.
(2/3/21 email from Allen Hiser, NRC Division of New and Renewed Licenses available)
The NRC relies to the extent possible on visual monitoring and inspections, robots, thermography, x-ray etc. to analyze the integrity of some reactor structures and components. The NRC also relies heavily on laboratory analyses such as accelerated aging, computer modeling, simulations, and so-called "Generic Aging Lessons Learned" which are not as reliable as "autopsies" - analyses performed on real-world parts and components "harvested" through replacement or at decommissioning.
Very few parts, components, structures taken from operating or decommissioned reactors have been harvested or analyzed (according to the NRC, as of July 2022, none have been harvested world-wide from GE Mark III BWRs like Perry) to determine reasons for failure or detrimental effects of aging. In some instances, reactor operators have refused to collect these parts etc.
In December 2017, The Pacific Northwest National Laboratory, under NRC contract, published a report "Criteria & Planning Guide for Ex-Plant Harvesting to Support Subsequent License Renewal" describing many knowledge "gaps" in the NRC's license renewal review process and recommended the licensing renewal review process "require...strategic 'harvesting' of real-world safety-critical aged components from decommissioned and operating reactors to provide reasonable assurance of safe, reliable operation during the license extension period." The NRC removed the 2017 report from public view and substituted a 2019 Rev. 1 in which the commission eliminated all references to knowledge gaps as well as the recommended requirements to "harvest" and "autopsy" real world aged materials. (10)
Question - Why hasn't the NRC promulgated a rule to require the harvesting and autopsying parts and components removed from operating and decommissioned to determine?
WASTE Perry's spent fuel pool can can hold up to 4820 assemblies. As of 2022, the pool was two-thirds full.
Question - How full is the pool now?
Perry's reactor core included both the General Electric - GE14 and Global Nuclear Fuel - GNF2 fuel types. During the refueling outage that ended in April 2019, Perry went to a complete core of GNF2 (3/8/21 email from Scott Burnell NRC Public Affairs Officer is available)
Each fuel assembly contains80-100 used, irradiated highly radioactive fuel rods.
Each year U.S. commercial reactors produce about 2,000 tons of high-level radioactive waste (about 30 tons/reactor annually) for which there is no permanent national disposal facility due to the cancellation of the Yucca Mt., NV repository.
Therefore, about 90,000 tons of high-level radioactive waste remain in problematic spent fuel pool and dry casks at 75 environmentally unsuitable reactor sites in 33 states. (11)
"Each 1000-megawatt nuclear reactor contains as much long-lived radioactive material as...1,000 Hiroshima-sized bombs" from which humans and the environment must be protected virtually forever.
(12)
ENDNOTES (1) https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21361A214 "After five years of detailed seismic monitoring, CEI continues to conclude that the Leroy earthquake was purely tectonic and unrelated to the deep injection wells...to the north." p.139 The enriched high frequency spectrum for the January 31, 1986 earthquake,...therefore, exceeded the original design basis at frequencies greater than 15 Hz...This high-frequency exceedance of the design basis response spectra is addressed further in Section 3.7... p. 152 https://www.nrc.gov/docs/ML1203/ML12037A027.pdf (2) https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML19289C580 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21307A253 p. 97-99 (3) https://www.nrc.gov/docs/ML0915/ML091520189.pdf p. 4 (4) https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21361A222 p. 256 (5) ibid. p. 246-7, 254-56, 263 (6) p. 1 https://www.mass.gov/doc/memo-re-pilgrims-spent-fuel-dry-cask-storage-issues/download (7) https://dam.assets.ohio.gov/image/upload/ohiodnr.gov/documents/geology/GF8_Hansen_1995.pdf (8) http://static1.1.sqspcdn.com/static/f/356082/26211376/1431107993237/LeakFirst_ReportLater_BeyondN uclear_March2015.pdf https://radioactivity.eu.com/phenomenon/strontium_90 https://radioactivity.eu.com/phenomenon/caesium_137 https://radioactivity.eu.com/phenomenon/iodine_131 (9) https://nap.nationalacademies.org/resource/11340/beir_vii_final.pdf (10) https://beyondnuclearinternational.files.wordpress.com/2019/04/autopsy_pnnl-27120_harvesting_dec2017.pdf https://www.nrc.gov/docs/ML1908/ML19081A006.pdf https://www.govtech.com/news/federal-lab-finds-gaps-in-knowledge-of-nuclear-reactors-aging (11) P. 2 https://www.gao.gov/assets/gao-21-603.pdf (12) https://www.helencaldicott.com/is-helen-caldicotts-nuclear-madness-still-relevant/
https://www.helencaldicott.com/is-helen-caldicotts-nuclear-madness-still-relevant/
Dr. Helen Caldicott "Arguing Against Nuclear Energy" Federal Register Notice: 89FR72901 Comment Number: 6
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Subject:
[External_Sender] Comments/Questions Perry DGEIS (Docket # NRC 2023-0136)
Sent Date: 10/21/2024 2:27:55 AM Received Date: 10/21/2024 2:28:24 AM From: klineisfine@aol.com
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