ML24296A022

Comment (9) E-mail Regarding Perry Lr Draft EIS

ML24296A022
Person / Time
Site:	Perry
Issue date:	10/21/2024
From:	Public Commenter Public Commenter
To:	NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
89FR72901
Download: ML24296A022 (12)

Text

From: Pat Marida <patmarida@outlook.com>

Sent: Monday, October 21, 2024 8:26 PM To: PerryEnvironmental Cc: Lance Rakovan

Subject:

[External_Sender] Comments on NRC-2023-0136 Perry Draft EIS Attachments: Pat Marida Comments Perry Draft EIS NRC-2023-0136.docx; Perry Nuclear Reactor ONFN.pdf; Perry Maintenance-Stored Fuel-etc. NRC-2023-0136.docx

TO: PerryEnvironmental@nrc.gov; lance.rakovan@nrc.gov RE: NRC-2023-0136 FROM: Patricia Marida, coordinator, the Ohio Nuclear Free Network

Dear Mr. Rakovan and others at Perry Environmental,

I would like to submit the following documents.

THIS OUTLINE (ATTACHED AND BELOW) has links to Ohio Nuclear Free Network (ONFN) documents, each of which has considerable documentation of immediate environmental threats from the operation of the Perry reactor that must be addressed in the EIS, including the storage of Perrys spent nuclear fuel close to Lake Erie. Perry did not need to be built so near the lake, but it has a good view.

DOCUMENT 1: ATTACHED: The Ohio Nuclear Free Network factsheet: The Perry Nuclear Reactor

DOCUMENT 2: ATTACHED: Perry Maintenance-Stored Fuel-etc. NRC-2023-0136

The NRC must address the issues raised in this Petition to Intervene in Perrys relicensing, some of which are outlined in the press release below. See Documents 3, 4, and 5.

DOCUMENT 3: Perry License Extension Intervention Press Release 12-11-2023. Outlines 3 Contentions in Document 4, below.

DOCUMENT 4: Perry Relicensing Petition to Intervene-ONFN-BN. Please refer to this document which is on the NRC website.

DOCUMENT 5: Geologist Dr. Rice on Bedrock, Earthquakes, Flooding at Perry This 54-page declaration 11-22-23 is part of the Petition to Intervene, Document 4, above, but deserves special attention.

Revelations 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 was 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.

FINAL COMMENT: 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.

Thank you.

Sincerely, Pat Marida

Patricia Marida, Coordinator The Ohio Nuclear Free Network

Ohios Nuclear Watchdog Follow us on Facebook ITS TIME TO CONNECT NUCLEAR POWER AND CLIMATE CHAOS TO MILITARISM.

Federal Register Notice: 89FR72901 Comment Number: 9

Mail Envelope Properties (PH7PR11MB6698E022DB96ABB2E1D6871EAB4C2)

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[External_Sender] Comments on NRC-2023-0136 Perry Draft EIS Sent Date: 10/21/2024 8:25:44 PM Received Date: 10/21/2024 8:26:28 PM From: Pat Marida

Created By: patmarida@outlook.com

Recipients:

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

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Files Size Date & Time MESSAGE 6401 10/21/2024 8:26:28 PM image002.jpg 2046 Pat Marida Comments Perry Draft EIS NRC-2023-0136.docx 35670 Perry Nuclear Reactor ONFN.pdf 993421 Perry Maintenance-Stored Fuel-etc. NRC-2023-0136.docx 2747270

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10-21-2024

TO: PerryEnvironmental@nrc.gov; lance.rakovan@nrc.gov RE: NRC-2023-0136 FROM: Patricia Marida, coordinator, the Ohio Nuclear Free Network

Dear NRC staff and administrators at Perry Environmental,

I would like to submit the following documents. This outline has links to Ohio Nuclear Free Network (ONFN) documents, each of which has considerable documentation of immediate environmental threats from the operation of the Perry reactor that must be addressed in the EIS, including the storage of Perrys spent nuclear fuel too close to Lake Erie. Perry did not need to be built so near the lake, but it has a good view.

DOCUMENT 1: ATTACHED: The Ohio Nuclear Free Network factsheet: The Perry Nuclear Reactor

DOCUMENT 2: ATTACHED: Perry Maintenance-Stored Fuel-etc. NRC-2023-0136

The NRC must address the issues raised in this Petition to Intervene in Perrys relicensing, some of which are outlined in the press release below. See Documents 3, 4, and 5.

DOCUMENT 3: Perry License Extension Intervention Press Release 12-11-2023 Outlines 3 Contentions in Document 4, below.

DOCUMENT 4: Perry Relicensing Petition to Intervene-ONFN-BN. Please refer to this document which is on the NRC website.

DOCUMENT 5: Geologist Dr. Rice on Bedrock, Earthquakes, Flooding at Perry This 54-page declaration 11-22-23 is part of the Petition to Intervene, above, but deserves special attention.

Revelations 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 was 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.

FINAL COMMENT: 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.

Thank you.

Pat Marida

Patricia Marida, Coordinator The Ohio Nuclear Free Network

Ohios Nuclear Watchdog

Follow us on Facebook ITS TIME TO CONNECT NUCLEAR POWER AND CLIMATE CHAOS TO MILITARISM.

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.

• The NRC must address the issues listed below in the Perry EIS.

• The sum of these problems must also be addressed. There is an additive effect, and even a synergistic effect, when these issues are combined. The NRC must not look at each issue singly.

FirstEnergy, then Energy Harbor, and as of March 2024, acquired by Vistra, continues to be given waivers on inspections, standards, maintenance, repairs, upgrades and other regulations covering its nuclear reactors by the Nuclear Regulatory Commission (NRC). Here is a partial list of FirstEnergy requests for exemptions for the Perry Nuclear Station, along with NRC waivers granted.

Is there a place where the NRC lists all Perry waivers and exemptions (i.e., changes in standards) granted for the operation, maintenance, storage (i. e., all categories) can be found? If not, we would like to request for such a list to be made.

1) 5-15-24: Vistra Operations Company LLC.; Perry Nuclear Power Plant, Unit 1; Independent Spent Fuel Storage Installation; Exemption. OK to load Holtec 89 position multi-purpose canister with continuous basket shims where terms, conditions, and specifications in the Certificate of Compliance are not met.

2) The Nuclear Regulatory Commission (NRC) has neglected to update U.S. nuclear regulations to meet the International Atomic Energy Agency (IAEA) recommendations.

3) The NRC has not required any nuclear plants to implement the recommendations from the Lessons Learned from Fukushima.

4) 4-19-21 ML21106A027 Perry Nuclear Power Plant, Unit 1, Request to Revise the Methodology Used for Flood Hazard Analysis and to Request Exemptions to Support Flood Mitigation

5) 03/01/21 ML21035A170 Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment No. 192, Regarding Application to Revise Technical Specifications to Adopt TSTF-582, "Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements"

6) 2-16-21 ML21055A264 Summary of Teleconference with Energy Harbor to Discuss Potential License Amendment Request Related to Revising Flood Mitigation for Perry Nuclear Power Plant, Unit No.

1.

7) 1-11-21 ML21011A273 License Amendment Request to reduce Perry Emergency Plan

8) In Oct. 2020, the NRC proposed revision of the expiration date of Perrys Operating License for over a year, from March 18, 2026, to November 7, 2026.

9) 1-15-21 ML21018A004 Testing Extension Perry asking to defer Snubber Inspections claiming COVID Hardship

10) 2020: NRC has given even further maintenance exemptions to nuclear plants due to the coronavirus.

Reactors are allowed to run with fewer staff working much longer shifts. See the article Coronavirus Hits the Nukes, Keep Your Fingers Crossed for details.

11) 11-27-19 ML19331A011 Perry Compliance deferred over a year until December 2020.

12) 11-18-19 ML19323F020 Perry Nuclear Power Plant, Focused Evaluation Regarding Near-Term Task Force Recommendation 2.1 for Flooding. Fukushima modification recommendations deferred because Perry planned to close in May 2021.

13) 10/07/2019 ML19280C628 Perry Nuclear Power Plant - Report of Facility Changes, Tests, and Experiments (Perry modifications/regulation rollback)

14) 8-14-19 ML19163A023 Perry Nuclear Power Plant, Unit No. 1 - Issuance of Amendment No. 186 Concerning Changes to Emergency Response Organization.

15) 6-25-19 ML19176A078 Perry Nuclear Power Plant - Deviation from BWRVIP-139 Revision 1-A:

BWR Vessel and Internals Project, Steam Dryer Inspection and Flaw Evaluation Guidelines".

(Exemption to operate without Inspection)

16) 06/04/2019 ML19067A021 FENOC Fleet - Beaver Valley; Davis-Besse; Perry. Exemption from the Requirements of 10 CFR 73.55(p)(1)(i) and (ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather.

17) 2-25-19 ML19022A324 Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment No. 185 Concerning Extension of Containment Leakage Test Frequency.

18) 9/6/2018 ML18178A588 FENOC Fleet - Beaver Valley; Davis-Besse; Perry. Individual FR Notice

- Notice of Issuance of Exemption re: Exemption from the Definition of Physical Barrier.

19) 8/29/2018 ML18130A885 FENOC Fleet - Beaver Valley; Davis-Besse; Perry - Environment Assessment and Finding of No Significant Impact Related to Exemption Request for a Physical Barrier Requirement.

20) 1/22/2018 NRC has given permission to FirstEnergy to run its 4 reactors with leaking on Class 2 & 3 Piping.

21) 10/19/2017 ML17257A098 Perry Nuclear Power Plant, Unit 1 - Issuance of Amendment Concerning Revisions to the Environmental Protection Plan).

22) 10/16/2017 ML17270A030 Perry Nuclear Power Plant, Unit 1 - Approval of Alternative to Use ASME Code Case N-513-4 For Repair of Emergency Service Water System Piping.

23) 2-11-16 ML16147A007 Missile generation by tornado deferred. External objects and equipment on the ground that can become flying debris. This already occurred when a tornado hit Davis-Besse in 1998. Ottawa County Tornado 6/24/98: Storm Shuts Down Ohio Nuclear Plant

UNPLANNED SHUTDOWNS AND EVENT NOTIFICATIONS: FirstEnergy has had multiple unplanned shutdowns and Event Notifications (problems and breakdowns that require notification of the NRC). These occur on a regular basis.

8-8-16 Union of Concerned Scientists: Special Inspections: Safety Relief Valve Problems at Perry.

How can NRC assure the public that this had been adequately addressed?

Additional Waste Adds to Reactor Community Burden: The longer Perry operates, the greater the amount of high-level nuclear waste (HLW) onsite. Neither the U.S. nor the world has any idea for what to do with HLW/SNF.

In reality, serious challenges make it highly unlikely that HLW will be moved very far from the site of generation.

Amount of HLW at Perry: Reference is Bob Alvarez 2011 report: Spent Nuclear Fuel Pools in USA & Reducing Risks. See page 25, table of SNF Inventory plant by plant. As of 2010 there were 452 Metric Tons at Perry. That is about 10 tons of high-level waste generated per year. Official updated inventories are not available but can be estimated.

THIN NUCLEAR WASTE CANISTERS: Unbelievably, NRC has licensed thin-wall stainless steel dry storage canisters for high-level nuclear waste that are only 1/2-to 5/8-inch thick. These thin canisters are accumulating at Perry. They are welded shut and cannot be maintained or repaired. They cannot be inspected or monitored internally or externally. They can crack through and cause major radioactive leaks and explosions in as little as 17 years.

Peak radiation levels from outlet air vents are kept from the public. San Onofre Safety has documented these issues. Thick-walled casks are required in Europe. They are designed to be monitored, maintained, and transportable and are proven international standard. These tin cans have set up a scenario for disaster.

HIGH BURNUP FUEL : High Burnup nuclear fuel is over twice as radioactive and thermally hot as traditional waste, requiring up to 20 years cooling in fuel pools before dry storage. High Burnup damages both fuel and cladding, increasing the risk of hydrogen gas explosions and making it unstable for transport. Substantial safety risks from high burnup fuel have been documented since 2014. There are hundreds of tons of spent High Burnup Fuel at Perry.

IS THIS ACCURATE? The NRC has redefined High Burnup fuel, increasing the amount of heat output.

Under the new definition NO U.S. REACTOR IS USING HIGH BURNUP FUEL.

PLEASE ADDRESS: The NRC is ignoring their own regulations by approving short, 2-year cooling times for newer types of fuel. By allowing these short cooling times they've made returning fuel to fuel pools at Perry impossible. A steam flash would occur if returning were attempted, because fuel is excessively hot.

DANGEROUSLY OVERCROWDED FUEL POOLS: When used fuel is first taken out of nuclear reactors it is extremely hot and must be cooled in water for 5-6 years. These pools are expensive to build. The result is that FirstEnergy/Energy Harbor and now Vistra continues adding fuel to existing pools, ignoring specifications. Perry has more than twice as many fuel rods in their fuel pools as the pools were designed to hold.

LOSS OF OUTSIDE ELECTRICITY: Outside electricity is needed to cool the pools if a reactor is shut down, such as for refueling or a weather incident. This poses a serious problem if outside electricity is cut off. Perry has backup generators, but these have limited fuel, and backup generators are notorious for failure. A pool fire caused by loss of electricity or a criminal act would be catastrophic.

AGING/EMBRITTLEMENT: Perry is on Lake Erie, a critical resource for drinking water, recreation and livelihoods for millions of people. How long can you drive an old car? Nuclear reactors have a problem that old cars dont - embrittlement, or weakening of concrete and steel by continuous radioactive bombardment. A nuclear accident could wreak hundreds of billions of dollars in property damage with life-altering health consequences for tens of thousands. Or even worse, turning a large part of Ohio into a sacrifice, uninhabitable zone.

Contact Pat Marida patmarida@outlook.com.