NRC-2022-0183, Comment (1) of Ethan P. Billhartz on Vistra Operations Company, LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2
| ML23339A035 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/03/2023 |
| From: | Billhartz E Univ of Alabama-Birmingham |
| To: | Office of Administration |
| References | |
| NRC-2022-0183, 88FR75629 00001 | |
| Download: ML23339A035 (1) | |
Text
12/5/23, 8:40 AM blob:https://www.fdms.gov/487016d7-5fa5-4161-a614-32b8e0a09732
SUNSI Review Complete Template=ADM-013 As of: 12/5/23, 8:35 AM E-RIDS=ADM-03 Received: December 03, 2023 PUBLIC SUBMISSIONADD: Tam Tran, Status: Pending_Post Antoinette Walker-Smith, Tracking No. lpq-0ixa-1ndr Lance Rakovan, Caroline Comments Due: December 26, 2023 Hsu, Mary Neely Comment (1) Submission Type: Web Publication Date:
11/3/2023 Docket: NRC-2022-0183 Citation: 88 FR 75629 Vistra Operations Company LLC Comanche Peak Power Company LLC Comanche Peak Nuclear Power Plant, Units 1 and 2
Comment On: NRC-2022-0183-2581 Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2
Document: NRC-2022-0183-DRAFT-2577 Comment on FR Doc # 2023-24294
Submitter Information
Name: Anonymous Anonymous
General Comment
Please see the attached file on my comments in support of accepting the renewal of the Comanche Peak Nuclear Power Plant.
Attachments
Public Docket Comment on Comanche Peak Nuclear Power Plant Unit 1 and 2
blob:https://www.fdms.gov/487016d7-5fa5-4161-a614-32b8e0a09732 1/1 1
Public Comment on License Renewal of Comanche Peak Nuclear Power Plant
Ethan P. Billhartz
Department of Engineering, University of Alabama-Birmingham
ASEM 616: QL Policy Issues in PtD
Professor Walaski
December 7, 2023
2
Public Comment on License Renewal of Comanche Peak Nuclear Power Plant
I am writing this comment to urge you to accept this application sought by Vi stra
Operations Company LLC for a twenty -year extension on the operating licenses for one of the
youngest nuclear plants in the United States. In October of 2023, Vistra submitted a renewal
application for Unit 1 and 2 Facility Operating License Nos. NPF -87 and NPF-89 of t he
Comanche Peak Nuclear Power reactors located southwest of Dallas-Fort Worth in Texas, whose
license is currently set to expire in 2030 and 2033. The license extension of the Comanche Peak
Power Company's nuclear plants would allow the Comanche Peak Nuclear Power Plant t o
provide thermal energy to Somervell County for a total lifespan of sixty years (Nuclear
Engineering International, 2023).
I felt compelled to comment on Document ID NRC -2022-0183-2581 because my
employment with an energy company, unrelated to Comanche Peak Nuclear Power Plant,
enhances my understanding for the need of a diverse mix of energy sources. A combination of
multiple sources such as wind, solar, hydropower, natural gas, geothermal and nuclear allow the
country to continue producing energy without disruption if one of the sources fails. The nuclear
power plant has the ability to provide large-scale storage, which is an important part of energy
security. The renewable plants can have limited sources and backup power sources may be
required. If the request for the operating extension is not granted, not only will the power sources
be compromised in Somervell County, but the local economy cou ld suffer as well. Over six
hundred workers and several hundred contractors with average salaries of well over $150,000
would be unemployed. Since the Comanche Peak complex is the largest taxpayer, Somervell
County will also have a financial impact from its closure (Texas Comptroller of Public Accounts,
2023).
3
Under normal conditions, the Comanche Peak Unit 1 and 2 nuclear stations can generate
enough electricity to power over a million homes and almost half that amount during periods of
peak demand. The current fuel mix in the Texas grid deems nuclear energy as a major player in
energy production with plans for additional expansions of nuclear stations to other parts of the
state. Significant concerns for the 7.7 million residents located near the Comanche Peak Nuclear
Power Plant include environmental impact, health and safety issuesfor local residents (IAEA,
2023). Wind and solar energy are promoted as safer and more environmentally friendly options
to consider. It is often overlooked that these sources rely on weather and time of day to be
efficient. The nuclear power plant is dispatchable and can adjust the output, depending on
demand of electricity according to need (IAEA, 2023).
My organization in the energy industry works with natural gas and electricity and strives
for net zero carbon emissions. While no energy source is free of emissions, most of the nuclear
plants release of carbon dioxide is during the complex construction process. Comanche Peak
Unit 1 and 2 nuclear stations are already established, therefore extending the license twenty more
years may prevent another nuclear station from being constructed in the area. The emissions
produced from uranium extractions would still occur, but the carbon dioxide emissions that result
from demolition and decommissioned sites are inevitable regardless of if the plant closes as
scheduled or an additional twenty years is added to the nuclear energy production.
In February of 2023, a notice by Nuclear Regulatory Commissions announced scoping
88 FR 10940 to determine if the Comanche Peak Unit 1 and 2 plants are safe, up to standards,
and secure deployment of these advanced reactors (The Federal Register, 2023). This is an in -
depth environmental analysis looking at the reactor vessel coolant system, engineered safety
features, auxiliary systems, steam and power conversions, containments, structure and 4
component supports, and the electrical instrumentation and control systems. In preparation for
license renewal, Comanche Peak Nuclear Power Plant implemented aging management
programs to ensure plant safety and efficiency. The aging management programs focused on
specific components to prevent, mitigate and monitor the aging process but also included
scheduled evaluations of the plant systems performance to determine if it is operating as its
intended function. As an attempt to promote safety, Comanche Peak Nuclear Power Plant
installed a new steam generation system in Unit 1 and disconnected the remaining recirculation
components. Some obsolete equipment has been shut down and is abandoned in place. On both
Unit 1 and 2, the reverse osmosis systems, jockey and diesel driven fire pump, electric hydrogen
recombiners, boron concentration system, portions of the potable and sanitary water system and
exhaust dampers were abandoned in place because they are no longer used (Nuclear Engine ering
International, 2023). On November 2, 2023, John M. Moses, Deputy Director, Division of
Rulemaking, Environmental and Financial Support, Office of Nuclear Material Safety and
Safeguards filed a preliminary recommendation "that the adverse environmental impacts of
license renewal for CPNPP are not so great that preserving the option of license renewal for
energy-planning decisionmakers would be unreasonable" (Justia Regulations, 2023).
The Comanche Peak Nuclear Power Plant took the appropriate steps needed to prepare
for the license renewal application. The plant operators executed their own scoping and
screening process to detect areas of weakness. The company acted responsibly and proactively
instituted an aging plan to detect cracking, cumulative fatigue damage and other forms of
damage expected to reduce the integrity of the walls. The Comanche Peak Nuclear Power Plant
willingly performed upgrades and eliminated outdated technologies. Vistra Operations Company
joined forces for the pursuit of a sustainable and climate-resilient future. Nuclear energy 5
accomplishes near net zero greenhouse emissions and has the highest capacity factor of energy
source towering above wind, solar, coal, hydropower, natural gas and geothermal energy
(Energy.gov, 2021). Comanche Nuclear Power should be allowed to continue to reliably provide
a large dispatchable carbon -free electricity, which is safer for the environment, affordable and
beneficial to the local economy. Please consider supporting Document ID NRC-2022-0183-2581.
6
References
Comanche Peak aims for 60-year life. Comanche Peak aims for 60-year life - Nuclear
Engineering International. (2023, January 4).
https://www.neimagazine.com/features/featurecomanche -peak-aims-for-60-year-life-
10490579/
IAEA. (2023, September 12). What is net zero? what is the role of Nuclear Power and
Innovations?. IAEA. https://www.iaea.org/bulletin/what-is-net-zero-what-is-the-role-of-
nuclear-power-and-innovations
Nuclear power is the most reliable energy source and its not even close. Energy.gov. (2021,
March 24). https://www.energy.gov/ne/articles/nuclear -power-most-reliable-energy-
source-and-its-not-even-close
Texas Comptroller of Public Accounts. (2023). Texas Comptroller Energy Tour: Nuclear
Overview. Home Comptroller.Texas.Gov.
https://comptroller.texas.gov/economy/economic-data/energy/2023/nuclear.php
The Federal Register. Federal Register. (2023, February 22).
https://www.federalregister.gov/documents/2023/02/22/2023-03668/notice-of-intent-to-
conduct-scoping-process-and-prepare-environmental-impact-statement-vistra
Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, units 1 and 2, 75629-
75630 [2023-24294]::. Justia Regulations. (2022, March 1).
https://regulations.justia.com/regulations/fedreg/2023/11/03/2023-24294.html