ML13119A203

Comment (11) of Sandra Kurtz on the Scoping Regarding the Re-licensing for Sequoyah Nuclear Reactors 1 and 2

ML13119A203
Person / Time
Site:	Sequoyah
Issue date:	04/25/2013
From:	Kurtz S - No Known Affiliation
To:	Rules, Announcements, and Directives Branch
References
78FR15055 00011, NRC-2013-0037
Download: ML13119A203 (1)

Text

Sequoyah License Renewal Comment NRC-2013-0037

/1 Ti 7)iv'rn CI'-C: r_7_From: Sandra Kurtz Chattanooga, TN Comments to the Nuclear Regulatory Commission for Scoping regarding the Re-licensing for Sequoyah Nuclear Reactors 1 and 2 SUNSI Review Complete Template = ADM -013 E-RIDS= ADM -03 Add= --.--" (

COMMENTS TO THE NUCLEAR REGULATORY COMMISSION FOR SCOPING REGARDING RECLICENSING FOR SEQUOYAH NUCLEAR REACTORS 1 AND 2 The Supplemental Environmental Impact Statement should not be supplemental given that the original EIS goes back to the 1980s. I don't think that NRC and TVA can say that in that time there has been 'no significant environmental impact' and not really start from scratch.To say because it's been operating for 32 years without 'significant environmental impact'which is questionable in itself, is enough reason to give it a go-ahead for another 20 years is faulty reasoning.

Sequoyah Nuclear Plant Reactors 1 and 2 opened respectively in 1981 and 1982. By the time relicensing for 20 more years of operation is granted they will be 40 years old. They were actually designed for only 30 years of life. Aging increases risk of leaks and accidents that cause costly shutdowns.

This past year NRC issued a notice of violation for too many shutdowns in a year (SCRAMS) at Sequoyah.* There is concern over flooding in the light of lessons learned from Fukushima and the TVA discovery that their own calculations on flood risk at both Watts Bar and Sequoyah were too low. Analysis must be done to assess the risk to the urban population in and around Chattanooga should dams upstream break or an earthquake occur. Flooding mitigation must be done and is bound to be costly.* It is not out of the question for an earthquake to occur that would impact Sequoyah should it be above a seismic level of 4.9. With new information and Fukushima recommendations, an updated analysis is needed rather than relying on the original EIS.In this age of climate disruption, water quality and quantity is of prime importance.

Nuclear Plants use inordinate amounts of water each day when operating and about two-thirds is evaporated through the cooling towers and is not returned to the river. The Union of Concerned Scientists tells us that the typical 1,000 MW-electric nuclear power reactor can use up to a whopping 714,740 gallons per minute. This is water that could be used by other businesses, industries, and for drinking water. The water returned to the river is carrying heat that has impacts for the aquatic ecosystem.

While fish can move to avoid heated water plumes, the aquatic drift community and certain macroinvertebrates upon which fish feed cannot. In a climate unstable world, water will be THE ultimate constraining resource.

We have already seen TVA's nuclear plants shut down because of summer temperatures that prevented proper cooling. With temperatures rising scientists predict periods of excessive rain, severe drought conditions, and hotter temperatures in the summer here. Climate change must be addressed as an environmental impact for this SEIS.The SEIS document states that extending Sequoyah operations continues

'potential availability' to support TVA's agreement with Dept. of Energy to produce tritium until 2035.Tritium is a radioactive form of hydrogen that becomes a radioactive form of water. If ingested, inhaled, or absorbed through the skin, tritium can permeate living cells and cause damage at the cellular level. In both 2003 and in 2011, tritium was found in the groundwater at Sequoyah.

Tritium is also made at Watts Bar I where it has been leaking through the absorber rod cladding and~where it has also leaked into the river. Chattanooga drinking water derives primarily from the TN River downstream from Watts Bar and Sequoyah.

We have been exposed for 40 years and don't need another 20 years to satisfy the Department of Energy's desire to make tritium in a supposedly commercial power plant in order to boost fission in nuclear bombs for military use. Then there is the possible use of radioactive mixed oxide fuel (MOX) being considered for use at the request. of Dept. of Energy. It is experimental and never been used in a commercial nuclear plant and this one not designed for it." Spent fuel storage is inadequately protected as rod density in the fuel pool increases.

This rod crowding is a serious safety concern. Why have 20 more years of radioactive spent fuel?There are many questions that should be adequately analyzed and answered:

Where do we put it and how will it be monitored and managed? Is the Watts Bar radioactive waste going to be transported to SQN as well? Has the proposed Independent Spent Fuel Storage Building been put in place and is it secure enough?* The SEIS states that there are only two feasible alternatives to consider meeting the need for power in the future? Alternatives:

1. Decommission SQN and build a new nuclear plant replacement with a 40-year license somewhere besides the SQN site. 2. Construct new natural gas-fired generators and infrastructure in place of SQN, but not on the SQN site. Can it be that TVA and NRC cannot think of any other alternatives such as shutting SQN down and meeting power demand and even baseload with solar, wind, energy efficiency, demand-side management, and other now-viable energy alternatives to name some? These will be cheaper, healthier and safer. Consider other alternatives.

• NRC found that radiation doses to the public will continue at current levels associated with normal operations and also for occupational doses to employees.

We are told that the range of doses are all well below regulatory limits. Thus, it was concluded that since the range of dosages are well below regulatory limits, there is no significant additional impact if the license is renewed for another 20 years. The idea that we are all safe forever once one sets radiation exposure standards is not true. We know now that there is no safe dose of radiation and that those standards are likely to change as was done after Fukushima to protect the nuclear industry from public outrage. In fact, ionizing radiation is cumulative.

There is cancer risk even without an accident.

We have enough background radiation as is. A license* to add human made radiation for another 20 years should not be granted.* Numerous accidents, incidents, SCRAMS, shutdowns, leaks, dishonesty in equipment monitoring, lack of proper reports filed, ignoring safety procedures, poor nuclear employee education, and the installation of non-certified equipment, does not assure the public that TVA can properly run their nuclear plants. Ice-condenser technology is old and more subject to hydrogen explosions and meltdowns than other designs. There can never be enough so-called failsafe measures to avoid human error. We can and should move on to other ways to produce electricity.

Submitted by Sandra Kurtz 3701 Skylark Trail Chattanooga, TN 37416