ML24295A103

Comment (5) E-mail Regarding Perry Lr Draft EIS

ML24295A103
Person / Time
Site:	Perry
Issue date:	10/14/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR72901
Download: ML24295A103 (6)

Text

From: Pat Marida <patmarida@outlook.com>

Sent: Monday, October 14, 2024 9:04 PM To: Lance Rakovan Cc: Ted Smith

Subject:

[External_Sender] Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement Attachments: Perry Nuclear Reactor, ONFN.docx (1).pdf; Pat Marida Comments Perry Draft GEIS 10-2023.docx

TO: U.S. Nuclear Regulatory Commission (NRC)

Via: Lance Rankovan, lance.rankovan@nrc.gov RE: Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement FROM: Patricia Marida

Dear Mr. Rankovan and NRC staff and administrators,

For my comments I submit the two attached documents. Each has considerable documented analyses of immediate environmental threats from the operation of the Perry reactor, as well as the storage of its spent nuclear fuel close to Lake Erie.

Please let me know that you have received this message

Thank you.

Patricia Marida Columbus, Ohio

Federal Register Notice: 89FR72901 Comment Number: 5

Mail Envelope Properties (PH7PR11MB6698BCF6688E06EBE1A6E53AAB452)

Subject:

[External_Sender] Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement Sent Date: 10/14/2024 9:04:05 PM Received Date: 10/14/2024 9:04:27 PM From: Pat Marida

Created By: patmarida@outlook.com

Recipients:

"Ted Smith" <Theodore.Smith@nrc.gov>

Tracking Status: None "Lance Rakovan" <Lance.Rakovan@nrc.gov>

Tracking Status: None

Post Office: PH7PR11MB6698.namprd11.prod.outlook.com

Files Size Date & Time MESSAGE 659 10/14/2024 9:04:27 PM Perry Nuclear Reactor, ONFN.docx (1).pdf 986522 Pat Marida Comments Perry Draft GEIS 10-2023.docx 22324

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The Perry Nuclear Reactor (a commercial nuclearpower plant) sitsonthe shoreof Lake Erie 40 miles eastof Cleveland,Ohio. Perry is asingle 1260-megawatt General ElectricBoilingWater Reactor.Construction for two unitsbegan in 1977. Unit 2was canceled in1994 afterallmajor buildings and structureswere completed, includingthe 500-footcooling tower.Unit 1 began operations in 1987 and was licensedto March 2026.

Liabilityrelief:Perry was owned by FirstEnergy before they put theirenergy-generating subsidies into bankruptcy in2018. A new company, Energy Harbor, LLC, emerged asowner, absolving both FirstEnergy (now only delivering electricity)and new reactorowner (limited liabilitycorporation)of many previous liabilities.

Vistrabought Energy Harbor in March, 2024, making Vistrathe nationssecond largestnuclear fleetowner.

License expiration relief:$1.3 billioninsubsidiesfor FirstEnergysnuclear plants(see Ohio House Bill6 -

page 2) made the owners change theirminds about not renewing Perrys license.In2020 the Nuclear Regulatory Commission (NRC) extended Perrys license expiration date by 8 months to Nov. 2026. The NRC also changed the deadline forrequesting an extension from 5 to 3 years before expiration.This made the owners eligibletorequesta 20-year licenserenewal.

License renewal: A renewal application was made inJuly, 2023. That December, ONFN and Beyond Nuclear filedaPetition to Intervene, citinglargeand continuing tritiumreleasesand a seriousaccident potential.

The petitioncontains a reportby Geologist Dr. Rice on Bedrock, Earthquakes, and Flooding atPerry,saying thePerrys buildingscan slide intoLake Erie sooner ratherthan later,aspart ofa nearby park did. An outdated geotechnical analysisof the Perry siteis not predictiveof actualsite conditions including earthquakes, lake erosion,and leaks from wet and dry storage moving to the lake. Solution of the underlying Salina (salt)

Formation could destabilizetheentiresite.

Construction costwas 11 times theestimate: When the twin reactorplantwas announced in1971, itwas to cost

$632 million. The final cost was $7.4 billion.Unit 2 never opened, likelydue to economics includingcosts to finishconstruction,interestonborrowing, poor projected revenues, and increasinglyon back taxesdue.

Seismically activearea : Perry lieswithin 40 miles oftwo faults.Whistleblowers reported thata geologicfault linewas identifiedwhile Perry was under construction,and thatworkers were instructed tokeep quiet as they filledthefissure with thousands oftons of concrete.In 1986, a 5.0earthquake hit10 miles tothe south.Itwas feltin11 statesand Ontario. A citizengroup sued to block Perryfrom opening,citing futureearthquake risk,but was turned down by the Supreme Court. In 2019 an AP analysis ofgovernment data revealed Perrysrisk of severe earthquake damage to be 24 times as high as previously thought. Addressing multiple quakes in Lake County in 2022, ageologist noted thattheground isriddled with faults. See Dr.Rices reportabove.

Flooding :Perry is not compliant with flooding and other upgrades outlined in Lessons Learned from the Fukushima Nuclear Accident. Two streams run close to the plant.In 2015 a stream immediately west of the reactor was rerouted due to flooding hazards. In 2019, 2021, and 2022 Energy Harbor requested exemptions for Perrys flood mitigation requirements and asked to revisethemethodology forflood hazard analysis.

Shoreline erosion: Perry sitson a 40-foot bluffoverlooking Lake Erie.Wave activityis undercutting the bluffs,creating shoreline recession.According tothe Ohio Dept. of Natural Resources Lake Erie Shore Erosion Management Plan for Eastern Lake County, 3,500 feet(about half)of the Perrysiteshoreline isarmored with stone and steel.Recession along theunarmored shoreeast of theplant resultedin theremoval of severalhomes before Perry was constructed.Average recession ratesofunarmored shore reach 4.9feetper year inthe area.

FirstEnergy/Energy Harbor/Vistra Cut Corners on Nuclear Maintenance: ONFN outlines 30+ requests made toor granted by the Nuclear Regulatory Commission forwaivers on inspections,standards,maintenance, repairs,andupgrades for Perryand Davis-Besse. Exemptions given due toplanned closure in2021 continue.

Regular radioactive releases, accident concerns: The nuclear industryfailsto mention thatallnuclear plants make regularradioactive releasesintotheairand water. An accident atPerry posesthe riskof contaminating the drinkingwater ofmillions ofpeople. A Perry tritiumleakmade the news in2014.

Other incidents:

Twice in 2021, theNRC reduced Perrys emergency planning requirements,including forfires.

In 2017 it was found thatPerry had been operatingwithout accessto itsemergency dieselgenerators.

NRC inspections alsofailedtonotice this.Later,theNRC issued a White Finding.

In 2017, twenty-seven Perry workers faileddrug tests.Perrywas thetargetof NRC safetyinspectionsfor more than threeyears because ofhuman performance issuesin safetymanagement.

In2011 theUnion ofConcerned Scientistsdocumented aNear-Miss at Perry involvingmultiple issues.

In a 1991 Mistake by the Lake, the rupture ofa 36-inch pipe carryingwater criticalforcooling flooded thePerry sitewith 3million gallonsof water.Water flowed into vaultscontainingelectricalcables.

The Ohio House Bill 6 bribery scandal: In 2018 FirstEnergy claimed itstwo Ohio nuclear plants,Perry and Davis-Besse, were unprofitable and threatened to close them. In response, the Ohio legislaturepassed the infamous House Bill 6 inJuly 2019, giving FirstEnergy $1.3 billionin ratepayer money to keep the plants running.A year later,theDept. of Justicemade arrests,allegingthatFirstEnergy had bribed lawmakers and others to thetune of$60 million.The U.S. Attorney describedHouse Bill6 as likelythe largestbribery and money laundering scheme ever perpetrated againstthe people of Ohio." The legislaturerescinded$1.3 billion gift,but a large coal bailout and the gutting of Ohios renewable energy standards remains in place.No FirstEnergyofficialshave been charged with a crime,and the nuclearplants continueto operate-what happened tobeing unprofitable?See theONFN factsheeton FirstEnergydeception before the scandal broke:Ohio House Bill6,the FirstEnergy Bailout.

NUCLEAR REGULATORY COMMISSION: A CAPTURED AGENCY The NRC has been captured by the industryitwas setup to regulate.They have handed out safetyexemptions and approved the followingthree technologies:

High Level Radioactive Waste stored inthin canisters:NRC has licensed stainlesssteel dry storage canisters for nuclear waste that are a mere 5/8-inch thick.They arewelded shut and cannot be inspected,maintained, or repaired.Peak radiationlevelsfrom theirairvents are kept from the public.Thin canisterscould crack,causing major radioactive leaks and explosions. Scratches and gouges can compromise the outerlayers,precipitatingcracking.Thick-walled casksare required in Europe. They are designed to be monitored and maintained and are transportable,whilethin-walledcanistersarenot.

High Burnup Nuclear Fuel (HBF) hasbeen permittedby the NRC forover 20 years. Ithas more fissilematerial and is burned longer and hotter,saving utilitiesmoney. Perry went to 100% HBF in 2019. Spent (used)HBF ismore radioactiveand thermally hot, requiringlonger water coolingin fuelpools before dry storage.Higher temperatures damage the fuel,increasing explosionrisk and making itunstable fortransport. Substantial HBF safety riskshave been documented since 2014. NRC responded by allowing shorter,not longer, cooling times forspent fuel,exempting some canisters from verifying cooling. NRC is considering allowing even higher fuel burnups. For financialviability,new nuclearreactorswillrequire much higher burnups and enrichment - greatlyincreasing fuelstoragechallenges.

Dangerously overcrowded fuelpools: Spent (used) fuelcomes out so hotitmust be cooled infuelpools foryears. Because fuelpools are expensive,utilitiesareovercrowding existingpools. U.S.fuelpools now hold up to5 times more fuel than they were designed to handle. Outside electricityisneeded tocool the pools for refuelingorfor a weather incidentor electricoutages.Backup generators have limitedfuel and arenotorious for failure.Apool firecaused by lossof electricityoraterroristactcoulddwarf theFukushima disaster.

Updated October 2024. Contact Pat Marida patmarida@outlook.com.

10-14-2024

TO: U.S. Nuclear Regulatory Commission (NRC)

Via: Lance Rankovan, lance.rankovan@nrc.gov RE: Response to NRC comment meetings and the Perry Draft Generic Environmental Impact Statement FROM: Patricia Marida

Dear Mr. Rankovan and NRC staff and administrators,

For my comments I submit the following documents. Each has considerable documented analyses of immediate environmental threats from the operation of the Perry reactor, as well as the storage of its spent nuclear fuel so close to Lake Erie. Perry did not need to be built so near the lake, but it has a good view.

DOCUMENT 1: The Ohio Nuclear Free Network factsheet: The Perry Nuclear Reactor (also attached separately).

DOCUMENT 2 (54 pages): Dr. Julie Weatherington-Rices Declaration on Perry Geological Problems in this petition are particularly frightening. A lot is known now that was not available at the time of construction, while much was that was not considered or deliberately overlooked. These are not Dr. Rices opinion, all Dr. Rices facts and figures come from the Ohio Department of Natural Resources and other governmental sites. The NRC must take into consideration the environmental effects of a landslide beneath Perry. Please address all the conditions described in Dr. Rices report, and not just these few highlights.

Soils: The predominant soil is the Missouri. This large area that underlays the facility has an engineering rating of very limited for dwellings with or without basements and small commercial buildings. Therefore, from a soils limitation, this site should not have been considered for the Perry renewal application.

These bluff areas would be considered unstable and subject to erosion from wave action and landslides.

These soils range from loams to loamy fine sands. If there are leaks from the wet and dry storage containment systems, the radiated water would move quickly through the secondary fractures to the underlying glacial materials and bedrock and then out to the lake. This is of particular concern when the release of tritium is considered. Its not advisable to use the Lake as a contamination sink. Therefore, it is imperative that at all times, absolutely no contaminants leave the site.

Were these factors considered when the Perry plant was engineered and built? No they were not.

There is approximately 60 feet of unconsolidated materials under the plant. Unless structures are more than 60 feet deep, they are in unconsolidated materials.

From this map polygon Dr. Rice shows, the static ground water levels in the unconsolidated materials is only 5-15 feet below the surface so there is a very good possibility that the wet storage pools, if dug to any depth at all, are sitting in saturated conditions at least part of the year.

The Ohio Shale generates methane and radon gas in considerable amounts, which would enter the plant.

The facility must institute an ongoing investigation to ensure that waste stray heat is not reaching the Ohio Shale on site. The expansion of that shale could structurally undermine the facilities at the site.

Perry stands on a 60-foot bluff overlooking Lake Erie. Why the plant was not built farther back from the edge of the bluff is an engineering mystery, but the plant has a good view of the lake.

It is not clear to Dr. Rice how much consideration was made for the active process of shoreline erosion at the Perry plant. Over the years, whole sections of the shoreline including communities have ended up falling into the Lake.

Perry triple threatened - from the top, middle, and bottom of the bluff: Flooding and high water table at the top of the bluff; the spring created by the seeping of water out of the center of the bluff where the water table meets air, and at the bluff bottom; shoreline erosion - any of these could cause the bluff to give way. The reactor and buildings could at any moment slide into Lake Erie, the armoring being of no use to retain it.

The report is 54 pages, which goes into much more detail than can be conveyed here.

DOCUMENT 3: Perry License Extension Intervention Press Release 12-11-2023

DOCUMENT 4: Perry Relicensing Petition to Intervene-ONFN-BN.

Please answer this question. Does the NRC have documentation and engineering specification for this cementing event? It was apparently done in secret.

Adding to questions about its ability to safely construct and operate a nuclear power plant, a former worker at the Perry Nuclear Power Plant came forward to accuse CEI of hiding crucial geological information about site preparation. A bulldozer operator revealed that at least one hundred workers participating in excavation identified a geologic fault line. Workers were immediately ordered to keep quiet as the fissure was filled with thousands of tons of concrete and construction continued over the site. From the book The Division of Light and Power by Dennis J. Kucinich. Published in 2021 by Finney Avenue Books, LLC, Cleveland, Ohio, pp. 523-524.

• Cleveland Plain Dealer 25 May 1979, CEI is accused of hiding geology info on Perry plant, by Gary R. Clark and Daniel R. Biddle.

Sincerely,

Patricia Marida Columbus, Ohio