ML24296A021

Comment (8) E-mail Regarding Perry Lr Draft EIS

ML24296A021
Person / Time
Site:	Perry
Issue date:	10/21/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR72901
Download: ML24296A021 (6)

Text

From: daryl237@yahoo.com Sent: Monday, October 21, 2024 3:50 PM To: PerryEnvironmental

Subject:

[External_Sender] Written Comments on Perry Relicensing - Docket ID NRC-2023-0136 Attachments: Written comments on Perry Relicensing Final.docx

Attached are my comments on the Perry relicensing EIS in opposition to a 20-year operating extension.

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Federal Register Notice: 89FR72901 Comment Number: 8

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[External_Sender] Written Comments on Perry Relicensing - Docket ID NRC-2023-0136 Sent Date: 10/21/2024 3:50:13 PM Received Date: 10/21/2024 3:50:45 PM From: daryl237@yahoo.com

Created By: daryl237@yahoo.com

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"PerryEnvironmental" <PerryEnvironmental.Resource@nrc.gov>

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Post Office: mail.yahoo.com

Files Size Date & Time MESSAGE 362 10/21/2024 3:50:45 PM Written comments on Perry Relicensing Final.docx 22256

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Docket ID NRC-2023-0136

I am writing to state my objections to the relicensing of the Perry Nuclear Power Plant.

Radioactive Contamination Onsite at PNPP

I attended the scoping meeting at the Perry Library on October 25, 2023. An older man introduced himself as a nuclear proponent. Still, he said he would not condone relicensing the plant if the radioactive contamination around it was not cleaned up. At the online Draft EIS meeting on October 1, 2024 I asked where that contamination was located. The answer was that it was contained in ponds inside the plant boundary. I assume that these are open ponds and likely contain tritium which is exposed to the weather.

Q. How large and how many of these ponds are there?

Q. What happens when an especially heavy rainstorm occurs accompanied with wind gusts in excess of 35 miles per hour? What about evaporation during dry periods with temperatures of 80+ degrees?

Tritium is an egregious problem at Perry with ongoing tritium releases into Lake Erie as well as the well-documented leakages that exceed the EPA annual drinking water standard of 20,000 picocuries/liter (pCi/L). These include the largest single leak to date on 1/5/24 - 291,000 pCi/L. Other excessive leakages occurred; one on 6/22/23 of 40,000 pCi/L. and a reported series of leaks from January 3, 2020 through March 2021 of tritium and cobalt-60 from the reactor cooling system.

Despite this history of leakages, questions remain:

Q. What time period elapses before tritium leaks are discovered?

Q. Why hasn't the NRC made reporting mandatory?

Q. Has the source of the 6/22/23 leak been identified?

Concerning the regular releases of tritium into Lake Erie:

Q. Why are there no available studies of the additive, synergistic, and cumulative effects of tritium and other radionuclides?

This shallow lake is already the recipient of toxic chemicals and 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. https://epa.ohio.gov/static/Portals/35/permits/doc/3IB00016.fs.pdf

Q. How can the NRC condone the excuse of prohibitively expensive end -of-pipe controls for mercury discharges into the regions source of drinking water for millions of its citizens thus passing on the prohibitively expensive costs in health consequences to the citizens?

Other serious issues with the Perry site exist with potentially catastrophic consequences if one or more events caused failure to the sites integrity. These include the on-going erosion of the cliff site, the effects of the increasing seismic activity, and hydrological conditions leading to potential landslides.

Specifically:

Erosion of the '"toe" (lake-level) of the bluff that Perry sits on is postulated to be as much as 3-4 feet annually.

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21361A222 p. 256

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML21361A222 p. 246-7, 254-56, 263

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)

Please provide copies of state agency permits (OEPA, ODNR etc.) required for the 2024 project.

Seismic Activity

There have been numerous earthquakes within a 10 mile radius of the plant, one as recently as August 2024, including several with a magnitude of 4.0 to 4.5.

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 exceedance of the reactor's seismic magnitude design basis of 5.3.

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

Q. Why is the 1986 earthquake ignored in both the LRA and the GEIS?

Landslides 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.

https://dam.assets.ohio.gov/image/upload/ohiodnr.gov/documents/geology/GF8_Hansen_1995.pdf

The high groundwater table at the PNPP site combined with increasingly heavy rainfall occurrences points to amplified danger of landslides due to climate change. During the October 19, 2023 online scoping session the question of how the NRC will respond to climate change in its LRA EIS. The answer was that the NRC could not predict climate change effects and was not a consideration.

However at the October 1, 2024 Advance Act implementation comment session when the subject came up again it was asserted that the NRC would be considering the effects of climate change. Now the draft EIS has been released without reference to climate change noted in the table of contents.

And yet it is clear that climate change is changing every assumption about the future integrity of the built environment, especially as it relates to structures situated on already tenuous sites.

Q. Will this perilous situation be addressed or will there be consequences that will be excused as Unknowable and Unforeseeable?

Emergency Planning

On November 16, 2021, The NRC released a license amendment to reduce emergency planning by eliminating shift positions, increasing response time, eliminating emergency planning information contained in implementing procedures and instructions, etc.

Q. How can the NRC justify reductions in emergency planning for a plant being operated 20 years beyond its engineered lifespan?

https://www.nrc.gov/docs/ML2127/ML21270A112.pdf

Aging, Deteriorating Reactor Parts, Components, Systems

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-rays, 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, and 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.

https://beyondnuclearinternational.files.wordpress.com/2019/04/autopsy_pnnl-27120_harvesting_dec2017.pdf

https://www.nrc.gov/docs/ML1908/ML19081A006.pdf

Q. Why hasn't the NRC promulgated a rule to require the harvesting and autopsying of parts and components removed from operating and decommissioned to determine possible future performance levels?

Waste

Page 1719 of the LRA notes that Perry has loaded 25 Holtec MPC-68 and four MPC-89 dry cask systems.

Q. Were two Holtec MPC-89 dry cask systems with potentially faulty basket variants loaded in August 2024 per the NRC exemption issued in May 2024?

Q. What were the consequences to Holtec for its violations in failing to notify the NRC of the canister basket design?

9/12/2023 NRC Holtec Report of Apparent Violations Being Considered for Escalated Enforcement https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23145A175

5/3/24 EA/FONSI granting an exemption for Holtec dry cask system(s) in question at Perry https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML24103A110

Perry's spent fuel pool can hold up to 4820 assemblies. As of 2022, the pool was two-thirds full.

Q. 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.

It appears that safe removal of this waste will be impossible to accomplish under current conditions.

No other prudent property owner would burden their community with a threat of this level nor would they be allowed to do so.

As if the foregoing observations and questions were not enough ammunition for a convincing argument against relicensing here is the final straw:

Perrys Operating Performance

According to the NRC Reactor Oversight Process which measures reactor performance using 24 indicators, ranked numerically from the best-performing reactor (#1) to worst over 23 years from 2000-2023, Perry ranked 102 out of 106 reactors.

https://beyondnuclear.org/wp-content/uploads/2024/05/5-9-24-Lochbaum-working.xlsx-ROP-Action-Matrix-Column-Ratings-12-2000-thru-12-2023-1.pdf

Daryl Davis Cleveland, Ohio