ML24296A024

Comment (10) E-mail Regarding Perry Lr Draft EIS

ML24296A024
Person / Time
Site:	Perry
Issue date:	10/21/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR72901
Download: ML24296A024 (7)

Text

From: Bensi, Mark <Mark.Bensi@vistracorp.com>

Sent: Monday, October 21, 2024 4:38 PM To: Lance Rakovan

Subject:

[External_Sender] Vistra Comments on Perry DSEIS Attachments: PNPP DSEIS Supp 61 - Vistra Comments 10-21-24.docx

Lance,

Attached are Vistras comments on the DSEIS for your consideration. If you have any questions, please let me know. Thank you for the opportunity to review and comment on the draft document.

Thank You,

Mark J. Bensi Manager, Perry License Renewal Mark.Bensi@vistracorp.com Vistracorp.com

10 Center Rd l Perry, OH, 44081 440-280-6179

Federal Register Notice: 89FR72901 Comment Number: 10

Mail Envelope Properties (BYAPR08MB43445982EF95D68B836361B6F8432)

Subject:

[External_Sender] Vistra Comments on Perry DSEIS Sent Date: 10/21/2024 4:37:46 PM Received Date: 10/21/2024 4:37:58 PM From: Bensi, Mark

Created By: Mark.Bensi@vistracorp.com

Recipients:

"Lance Rakovan" <Lance.Rakovan@nrc.gov>

Tracking Status: None

Post Office: BYAPR08MB4344.namprd08.prod.outlook.com

Files Size Date & Time MESSAGE 400 10/21/2024 4:37:58 PM PNPP DSEIS Supp 61 - Vistra Comments 10-21-24.docx 61694

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

PERRY NUCLEAR POWER PLANT LR DSEIS COMMENTS

Comment Classification No. Section Page Line Comment Commenter Administrative

/Editorial Substantive

1. 3.10.1 3-112 10-14 DSEIS states that 44 percent of non-outage workers reside in Lake County; however, Cheyenne S our data indicate 60 percent of workers reside in Lake County. The DSEIS includes 30 Riggs long-term contract workers in its totals that the ER did not include and does not provide residence information for, but even with these additional 30 workers, the percentages appear to be incorrect. The DSEIS thus bases its Socioeconomic discussion on three counties, rather than one as the ER did.

Additionally, the reference for the above in the DSEIS appears incorrect, as EH 2023-TN9534" does not exist in the reference list. Assuming the reference was supposed to be EH 2023-TN9536", which is the PNPP LR ER.

2. Appendix F F-1 33-39 The discussion of Phase II screening seems somewhat disjointed. The sentence Ricky S ending in Line 33 states that six SAMAs were retained for Phase II (including the four Summitt added to address RAIs), but then the discussion of the screening process (1-5) in lines 35-37 applies to Phase I and not the Phase II assessment. The text on line 37 then indicates two unique SAMA candidates remaining which is true before the four added by the staff above. The conclusion is correct, but the text before the conclusion is not in sequence.

3. Appendix F F-31 7-17 The use of generally agrees in line 7 introduces uncertainty in the SE that should not Ricky S be present since all SAMAs, by the analysis, are found to not be cost effective and in Summitt the prior sections the Staff and their contractors agree that the inputs, approach, and outcomes are reasonable. The exception associated with SAMAs 5, 6, and 7 is due to the response to RAI-6 for sensitivity/uncertainty. However, the value provided was a 95-percentile maximum benefit and a detailed assessment would not achieve the risk benefit since the SAMA would only address a small fraction of the total risk.

Page l 1 PERRY NUCLEAR POWER PLANT LR DSEIS COMMENTS

Comment Classification No. Section Page Line Comment Commenter Administrative

/Editorial Substantive

4. Table 2-1 2-12 Row: The MW value of the NGCC plant is stated as 764 MW by the NRC. The ER (pg 7-19) Emily S Summary states that the NGCC plant of the Renewable Alternative would be 878 MWe to yield Keenan of 830 MWe net. Because of this difference the information in Row: Cooling System; Alternative Column: Renewable/NGCC would also be incorrect.

Column:

Renewabl e/NGCC

5. Table 2-1 2-12 Row: The NRC states that the withdrawal and consumption values are 7.8 MGD and 6 MGD. Emily S Cooling The PNPP LR ER states that the withdrawal and consumption values are 4.86 MGD Keenan System and 4.21 MGD.

Column: Note: This is also mentioned in the PNPP DSEIS Sections 3.5.6.1 and 3.5.6.2 NGCC

6. Table 2-1 2-12 Row: The number of workers for the renewable/NGCC combination is not stated in the PNPP Emily S Workforce LR ER, and source of this information is unclear. Keenan Column:

Renewabl e/NGCC

7. Section 2-13 22 The NRC states that the NGCC plant for the combination alternative would be 764 MW. Emily S 2.3.2.2 The ER states that the NGCC plant would be 878 MWe yielding 830 MWe net. Keenan Note: This difference also appears in the following PNPP DSEIS Sections: 2.3.2.2; 3.3.7.2; 3.3.8.1; 3.3.8.2; 3.5.7.1; 3.6.8; 3.9.10; 3.15.3.5; and Table 3-5.

8. Section 2-18 27-28 The NRC states that as of October 2020 there was 250 MW of fuel cell power Emily S 2.4.11 generation in the US. ENERCON cannot locate this 250 MW in the NRC cited source. Keenan The PNPP LR ER states that as of January 2020 there was 550 MW of fuel cell power generation in the US.

9. Section 3-148 3 The NRC states that the air dose due to noble gases with resulting gamma radiation in Emily S 3.13.1.2 gaseous effluents was 1.52 x 10-3 mrad using the source ML23117A196. The source Keenan ML23117A196 on PDF page 24/34 states that the value is 1.53E-02. It appears that 10-

2 and 10-3 have been switched.

Page l 2 PERRY NUCLEAR POWER PLANT LR DSEIS COMMENTS

Comment Classification No. Section Page Line Comment Commenter Administrative

/Editorial Substantive

10. 3.2.1 3-5 6 NRC identified the PNPP site comprises approximately 1,023 acres, but the area Emily S associated with the PNPP property in the LR ER is reported to be approximately 1,030 Keenan acres. It appears the DSEIS is utilizing the LULC table to identify the site acreage, but it was noted in the ER (Section 3.2, Table 3.2-1) that the acreage reported for land use/land cover will differ based on the raster (pixel-based) format of the MRLC data, and therefore will not exactly match site acreage reported throughout the LR ER.

11. 3.4.4 3-23 37-38 The NRC states that no mining explosions with a magnitude 3.0 occurred within 200 Jennifer S miles (322 km) of PNPP in 19704/5/2024; however, the USGS earthquake catalog lists Meek several rock bursts and explosions 3.0 magnitude within 322 km of PNPP between 1988 and 1997, as indicated in EH 2023 TN9536, Table 3.5-2, and a map list and csv download from the USGS Search Earthquake Catalog.

12. 3.4.4 3-24 11-17 The cited peak ground horizontal acceleration of 0.12-0.16 g on line 11 and 0.12-0.2 g Jennifer S on line 16 appear to be of a 0.2-second spectral acceleration rather than a peak Meek horizontal acceleration with a 2% probability of exceedance in 50 years. Based on Figure 3.4-2 of NUREG-1437, Revision 2, Volume 1 (Rukstales and Petersen 2019),

PNPP is in an area of 0.06-0.1 g peak horizontal acceleration with 2% probability of exceedance in 50 years

13. 3.5.2.5 3-40 32-35 The statement, If no intervening measures are takenall radionuclides would be Jennifer S discharged to Lake Erie via the gravity discharge system, is technically correct; Meek however, it is misleading because, as discussed during the in-person tour, a release would be entered into the corrective action program, and intervening measures would be determined on a case-by-case basis. The statement that follows, If water is pumped in response to a leak/spill event, water is discharged to the radioactive waste treatment system also does not mention that there is a corrective action program or any system in place to determine when intervening measures would be taken.

14. 3.3.7.1 3-17 23-27 The values given do not match those given in the PNPP LR ER Table 7.2-1 Emily S Keenan

Page l 3 PERRY NUCLEAR POWER PLANT LR DSEIS COMMENTS

Comment Classification No. Section Page Line Comment Commenter Administrative

/Editorial Substantive

15. 3.1 68 3/4 Human Health - Microbiological hazard to the public (plants with cooling ponds or canals or J. Grimm S cooling towers that discharge to a river) PNPP does not have cooling ponds, or canals, and does not discharge to a river. This category is not applicable to PNPP.

16. 2.2 2-8 32 Section 2.1.1 should read Section 2.2.1 J. Grimm E

17. 3.2.5.2 3-11 Table 3-6, or use of existing MDCTs statement is incorrect. Existing CTs are natural draft. J. Grimm E Row 2

18. 3.3.2 3-14 Table 3-8 2019 CO value disagreement with PNPP ER (2.86 tons/y vs ER 2.793). 2020 SO2 value J. Grimm S disagrees with PNPP ER (0.027 Tons/y vs. ER 0.063). 2021 SO2 value disagreement (.189 Tons/y vs. ER 0.048)

19. 3.3.4 3-15 22 air quality issues should read noise Issues J. Grimm E

20. 3.3.7.1 3-17 9 existing mechanical draft cooling tower would be used. PNPP has natural draft cooling J. Grimm E towers.

21. 3.11.2 3-123 9-10 Sanitary wastes are not controlled by the plants NPDES permit process as stated. They are J. Grimm E discharged to the municipal sanitary sewer system.

22. 3.11.6.1 3-126 14 PNPP does not have a discharge canal. Change to discharge tunnel or other accurate J. Grimm E nomenclature.

23. 3.13.1.1 3-145 7 Spent resin slurries are dewatered, not solidified. Statement should be corrected. J. Grimm E

24. 3.13.1.2 3-148 3 Air dose due to noble gases with resulting gamma radiation in gaseous effluents is listed J. Grimm S incorrectly as 1.52E-3 mrad. It should be 1.53E-02 mrad. (Source: Enclosure A, L-23-121, 2022 Annual Radioactive Effluent Release Report)

25. 3.4.3 3-23 17-20 Bluff erosion was localized to unprotected shoreline but the text can be interpreted to mean the B. Spiesman S entire shoreline within the protected shoreline via revetment has eroded 49 ft and that is not accurate. The GEIS sentence reads as follows: The majority of this loss occurred along a section of shoreline 17 approximately 700 ft (213.4 m) northeast of the Unit 1 cooling tower where current plant erosion 18 protection measures have been implemented with riprap rocks and sheet pile (Vistra 2024-19 TN9925). Attachment 13 of Vistra Letter L-24-083 (Responses to NRC RCI Nos. GE-1 and GE-2) disputes this as it states the erosion was present where current plant erosion protection measures end..

Page l 4 PERRY NUCLEAR POWER PLANT LR DSEIS COMMENTS

Comment Classification No. Section Page Line Comment Commenter Administrative

/Editorial Substantive

26. 3.5.2.5 3-40 12-13 It is important to note that per Perry procedures the NRC resident inspector is required to be B. Spiesman E notified in addition to the voluntary notification for the State of Ohio for groundwater tritium concentrations measured greater than or equal to 2,000 picocuries per liter (pCi/L).

27. 3.2.1.1 3-5 25 The lake county pumping station is within the site boundary but not the exclusion area M. Bensi S boundary.

28. 3.4.2 3-21 28-29 For the following sentence : Onshore mining near Perry Plant that might be a safety concern M. Bensi S would trigger the installation of a subsidence monitoring system to mitigate potential effects on the plant.

The phrasing might be a safety concern is more generic than the presentation in the PNPP ER (Section3.5.2) which states Should salt mining be initiated within 1,000 feet of the mineral rights boundary, a subsidence monitoring system, independent of the mining operator, will be installed and maintained during the life of the plant.

The additional specificity (within 1,000 feet of the mineral rights boundary) would alleviate the need to interpret what constitutes a safety concern.

29. 3.4.3 3-23 18-19 The DSEIS states the current plant erosion protection measures have been implemented. The M. Bensi S erosion protection measures have not yet been implemented. The area of erosion NE of the CT is not protected.

30. 3.11.6.1 3-126 14 For the text: discharge canal would There is no such canal at PNPP. M. Bensi E

31. 3.13.1.1 3-147 7-8 The DSEIS states these piezometers are being pumped this is present tense which implies M. Bensi S this is ongoing. Such pumping is performed as needed but is not a continuous activity.

32. 3.16.2.2 3-165 35-36 The sentence As described in Section 3.5.2.3 of this SEIS, recent releases of tritium to onsite B. Bensi S groundwater via the underdrain system have occurred at the Perry Plant site might imply that the Underdrain System is the source of the tritium which would be inaccurate.

Page l 5