ML13190A011

Comment(1) of William R. Harris on Behalf of the Foundation for Resilient Societies on the 2nd Supp Environmental Impact Statement for Seabrook Station No. Unit 1

ML13190A011
Person / Time
Site:	Seabrook
Issue date:	06/30/2013
From:	Harris W R Foundation for Resilient Societies
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR26662 00001, NRC-2010-0206, NUREG-1437
Download: ML13190A011 (9)

Text

Mendiola, DorisMendiola, Doris

Subject:

FW: Filing of Comments of Foundation for Resilient Societies:

Docket NRC-2010-0206 on 2nd Supp EIS for Seabrook Station No. 1 -Attachments:

Foundation Comments Seabrook 2d Supp EIS -NRC-2010

-0206_Final.docx; Foundation Comments Seabrook 2d Supp EIS -NRC-2010

-0206_Final.pdf From: William R. Harris rmailto:wm.r.harris(gmail.com] /3Sent: Sunday, June 30, 2013 10:57 PMTo: Bladey, CindyCc: Thomas Popik

Subject:

Filing of Comments of Foundation for Resilient Societies:

Docket NRC-2010-0206 on 2nd Supp EIS for SeabrookStation No. 1 -

Dear Ms. Bladey,

On June 30, 2013, about 10:30 p.m. the Foundation for Resilient Societies timely filed Comments electronically via Regulations.Gov in NRC Docket NRC-2010-0206.

These are Comments on the 2nd Supplemental Environmental Analyses to NUREG- 1437, ADAMS Document ML 13113 A 174 of April 2013 for theRelicensing of Seabrook Station No. I.Attached please find the Foundation Comments in both Word and PDF format. We request that theCommission Staff include these filings in the ADAMS database, and in the Docket for Seabrook Station -NRC-2010-0206.

We appreciate the opportunity to comment in this and other Commission dockets and rulemakings.

Sincerely, William R. (Bill) HarrisSecretary Foundation for Resilient Societies 52 Technology WayNashua, N.H. 03060IDm0C/OSUNSI Review CompleteTemplate

= ADM -013E-RIDS= ADM-03Add=& C (?'723)1.

Foundation for Resilient Societies SUPPLEMENTAL COMMENTS

-SEVERE ACCIDENT RISKSAND COST-EFFECTIVE MITIGATION ALTERNATIVES PROPOSED FOR INCLUSION IN FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT FORRELICENSING OF SEABROOK STATION NO. 1IN RE: SECOND DRAFT SUPPLEMENTAL COMMENTSSUPP. 46 TO NUREG-1437, APRIL 2013Comments due and filed June 30, 2013 inDocket NRC-2010-0206 Foundation for Resilient Societies 52 Technology WayNashua NH 03060www.resilientsocieties.ora 1

The Foundation for Resilient Societies, a non-profit corporation organized in theState of New Hampshire, appreciates the opportunity to provide Supplemental Comments on environmental impacts and, more importantly, cost-effective riskmitigation options for Seabrook Station No. 1 in Seabrook, New Hampshire.

Our Foundation previously commented on both environmental risks and riskmitigation options in October 2011. Our primary concerns remain unaddressed inthe Second Supplemental Draft Analyses (released in April 2013) for both severeaccidents and alternative mitigation options.We comment because nuclear power plants are integral to reliable operation ofregional electric grids. One hundred and two currently-licensed nuclear powerplants provide electricity generally at costs below most alternative sources ofelectric power; previously constructed power plants, if licensable for additional periods of operation, provide dispatchable baseload power critical to grid stability.

We understand that the risks of severe solar geomagnetic storms and of highaltitude electromagnetic pulse (EMP) explosions were not risks included in theDesign Basis for currently licensed nuclear power plants. Hence, these risks arenot included in Section 5.1 of the Supplemental EIS analyses that reviews "DesignBasis Accidents."

It is our understanding that -despite the bounds of Design Basis risk management

-when the Commission initiated a post-Fukushima review of the need to reanalyze the scope and efficacy of safety regulation for nuclear power plants, theCommission made a commitment to address high-consequence, low-probability risks, even if some of these hazards were beyond Design Basis risks. The MillerReport of July 2012 'proposed to broaden the scope of safety analyses for bothoperating and future licensable power plants.However, the Commission's consideration of "Severe Accidents" that might affectSeabrook

Station, as contained in Sections 5.2 and 5.3 of the Supplemental SevereAccident Analyses of April 2013, continues to exclude the substantial risk of solargeomagnetic storms.1 Charles Miller, et al., Recommendations for Enhancing Reactor Safety in the 21't Century, NRC, July 12, 2012. TheMiller Report proposed inclusion of beyond Design Basis hazards, strengthening blackout mitigation capabilities, enhancing spent fuel makeup capability and instrumentation, and other defense-in-depth concepts.

2 In April 2013, the owner-operator of Seabrook Station reported to a Space WeatherConference in Boulder, Colorado that NRC-licensed nuclear power plants atSeabrook Station in New Hampshire and at Point Beach, Wisconsin are "GIC hotspots" -meaning that northern

latitude, soil conductivity, and transmission linetopology combine to produce high observed GIC for Generator Step-Up (GSU)transformers.

2 According to multiple government and industry

reports, high GICcan cause overheating and unexpected failure of GSU transformers.

In turn,unexpected transformer failure during and after solar storms can cause reactor tripsand attendant nuclear safety issues.3In May 2013, Lloyd's of London, in collaboration with Atmospheric andEnvironmental

Research, Inc. of Lexington, Massachusetts, released a riskassessment of U.S. electric grid vulnerability to severe solar geomagnetic storms.4AER corroborates that generation plants proximate to coastlines and high salinitywater bodies have greater exposure to GIC.During the period that the Commission has prepared its Supplemental Analyses forSeabrook Station's severe accident risks and mitigation alternatives, evidence hasmounted that certain foreign nations -including North Korea and Iran -may beacquiring high altitude electromagnetic pulse (HEMP) weapons.

Protections against both solar weather and a significant portion of man-made EMP hazardscould be accomplished using the same mitigation equipment, a solution that couldbe both prudent and cost-effective.

Our Foundation encourages the Commission to address low probability hazards forwhich the consequences may be severe, but for which cost-effective remedies mayalso be available.

Our Board is appreciative that the Commission has determined toproceed with analysis of Petition for Rulemaking PRM-50-96, a petition that2 Available on the internet is a NextEra Energy briefing by Kenneth R. Fleischer, "NextEra Nuclear GMD Mitigation PowerPoint Presentation, Space Weather Workshop,

Boulder, Colorado, April 16, 2012. See the www.swpc.noaa website.

Specific NextEra view graphs form this presentation relating to Seabrook Station and Point Beach arereproduced as Appendix 2 of Foundation for Resilient Societies

Comments, May 1, 2012, in FERC Docket RM12-22-000, 47 pp.The Foundation for Resilient Societies is currently conducting a study of reactor trips during solar storms andexpects to publish the results in 2013.4 Solar Storm Risk to the North American Electric Grid found at:h2ttp://www.llvscm/-/-melodsreports/eme.ilast 20ryae iskse `2urep3rts/solar/2Ostorm%/2risk/20to/20th e%20north%20american%20electric%20grid.pdf, last accessed June 30, 2013.3 proposes on-site backup power to protect spent fuel pools during prolonged Lossof Outside Power (LOOP).5In our current Comments we have added a request to consider the retrofit of theSeabrook spent fuel pool by adding elevated containers of water (possibly withsoluble boron added), as a relatively low-cost complementary method ofprolonging the availability of water makeup. Using gravity feed and manual turn-on, turn-off

controls, these simple water storage containers could be bothcontinuously available and immune to remote cyber-attack.

When considering severe accident mitigation alternatives (SAMAs) for solargeomagnetic storm risks, we request that the Commission consider the baselinethreat to be the geomagnetic disturbance magnitude of the New York CentralRailroad Storm of 1921, in addition to the Carrington Event of 1859. We haveextrapolated from the March 13, 1989 Quebec solar storm that the New YorkRailroad Storm of 1921 might produce about 1,600 amps of GIC at Seabrook in a6storm with magnitude of about 4,800 nanoTeslas/minute.

A storm of themagnitude of the New York Central Railroad storm of 1921 has not reoccurred for92 years. This return period implies that the New England electric grid has risk ofprolonged electric grid blackout at an estimated frequency of approximately 1-in-100 years.We request that the Nuclear Regulatory Commission consider in its FinalSupplemental Environmental Impact Statement for Seabrook Station Relicensing as Severe Accident Risks the hazards contained in the following Table, and alsothe proposed mitigation alternatives (SAMAs) explained in the first column of thisTable. The Table is provided as an Appendix to our Comments.

5 See NRC-PRM-50-96, and ruling of the NRC published at 77 Fed. Reg. 74788-74798 dated December 18, 2012.6 See Foundation for Resilient Societies, Interim Report, Solar Storm Risks for Maine and the New England ElectricGrid, and Potential Protective

Measures, March 19, 2013. This report is available on our Foundation website,http://www.resililentsocieties.org and is retrievable via FERC Docket RM12-22-000.

The Report reviews currentoperating procedures of ISO-New England during warnings of solar geomagnetic storms and ensuing geomagnetic disturbances.

It compares both transmission capabilities at-risk and generating facilities at-risk with operating reserves projected to be available.

The report estimates the cost to protect the Maine grid against geomagnetic disturbance and compares this cost to the cost of a pending transmission upgrade to the Maine grid.4 Respectfully submitted, William R. Harris, Secretary, andThomas S. Popik, Chairman, for theFoundation for Resilient Societies 52 Technology WayNashua NH 03060www.resilientsocieties.org 5

APPENDIX TABLEUNADDRESSED SEVERE MITIGATION ALTERNATIVES (SAMAs)FOR SEABROOK STATIONRETROFIT OPTIONS KEY UNADDRESSED RISKS IN SEABROOK STATIONSUPPLEMENTAL EISAND CORRESPONDING BENEFITS OF RETROFITOPTIONSSEVERE SOLAR MAN-MADE CYBER ATTACKSTORM ELECTRO-MAGNETICPULSE (EMP)Option 1:Benefits:

Benefits:

Benefits:

NoneInstall Neutral GroundBlocking Device toprotect GSU transformers against Geomagnetically Induced Current (GIC)during scheduled transformer replacement in April 2014; oneblocking device required.

1. Eliminate half-cycle GSUtransformer saturation andharmonic production.

2. Prevent GSUtransformer overheating andvibration.

3. Reduce chance ofunexpected GSUtransformer failureand reactor tripsduring solar storms.4. Enhance regionalgrid stability duringsolar storms andreduce risk of Lossof Outside Power.5. Prevent harmonicinjection into localgrid and resulting Uninterruptible Power Supply (UPS)malfunction duringsolar storms,including UPS forstation power.1. Protect GSUtransformers againstE3 (long pulse)during nuclear EMPattack.2. Optionalinstallation of MetalOxide Varistors (MOV) along withNeutral GroundBlocking Devicecould also protectagainst El (fastpulse).3. Reduce recoverytime for regional gridand reduce risks dueto extended Loss ofOutside Power inaftermath of nuclearEMP attack.6 Option 2: For plannedGSU replacement in year2014, install transformers with high GIC"withstand" rating.Benefits:

1. Reduce core eddycurrents and resulting transformer overheating.

2. Enable plant tooperate throughsmall-to-moderate solar storms withoutdownrating.

Benefits:

Due to high GICduring nuclear EMPattack, no significant benefit expected.

Benefits:

NoneOption 3: Installunattended backup powersystem for spent fuel poolcooling.

See analysis inPetition for Rulemaking PRM-50-96 and NRCassessment datedDecember 18, 2012.Benefits:

1. Prevent boil-off ofspent fuel poolduring long-term LOOP; reduceradiation from spentfuel pool and allowcontinuing access tosite.2. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding landarea during long-term LOOP.Benefits:

1. Prevent boil-off ofspent fuel poolduring long-term LOOP; reduceradiation from spentfuel pool and allowcontinuing access tosite.2. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding land areaduring long-term LOOP.Benefits:

1. Backup powersystem would beunconnected tointernet andtherefore unaffected by cyber-attack.

2. Prevent boil-off ofspent fuel poolduring long-term LOOP caused bycyber-attack; reduceradiation from spentfuel pool and allowcontinuing access tosite.2. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding landarea during long-term LOOP causedby cyber-attack.

7 Option 4: Install largetank with makeup waterfor spent fuel pools; tankto be elevated withgravity feed and manualvalve system; water maycontain soluble boron.Benefits:

1. Delay boil-off ofspent fuel poolduring long-term LOOP from regionalgrid collapse; reduceradiation from spentfuel pool and allowcontinuing access tosite.2. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding landarea during LOOP ofseveral weeksduration.

Benefits:

1. Delay boil-off ofspent fuel poolduring long-term LOOP from regionalgrid collapse; reduceradiation from spentfuel pool and allowcontinuing access tosite.2. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding land areaduring LOOP ofseveral weeksduration.

Benefits:

1. Manual valvesystem would beunconnected tointernet andtherefore unaffected by cyber-attack.

2. Delay boil-off ofspent fuel poolduring LOOP ofseveral weeksduration; reduceradiation from spentfuel pool and allowcontinuing access tosite.3. Reduce risk ofspent fuel pool fireand resulting contamination ofsurrounding landarea during LOOPof several weeksduration.

8