ML11304A058
| ML11304A058 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/26/2011 |
| From: | Brooks K A State of NH, Office of the Attorney General |
| To: | Bladey C K Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR47612 00018, NRC-2010-0206 | |
| Download: ML11304A058 (5) | |
Text
PUBLIC SUBMISSION Page 1 of 1 As of: October 27, 2011 Received:
October 26, 2011 Status: PendingPost Tracking No. 80f5d4ca Comments Due: October 26, 2011 Submission Type: Web Docket: NRC-2010-0206 Notice of Receipt and Availability of Application for Renewal of Facility Operating License Comment On: NRC-2010-0206-0013 NextEra Energy Seabrook, LLC; Notice of Availability of Draft Supplement 46 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants and Public Meetings for the License Renewal of Seabrook Station, Unit 1 Document:
NRC-2010-0206-DRAFT-0029 Comment on FR Doc # 2011-19875 Submitter Information Name: Kelvin Brooks Address: 33 Capitol Street Concord, NH, 03301 Submitter's Representative:
K. Allen Brooks, Esq.Organization:
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ATTORNEY GENERAL DEPARTMENT OF JUSTICE 33 CAPITOL STREET CONCORD. NEW HAMPSHIRE 03301-6397 MICHAEL A. DELANEY ANN M. RICE AWrORNEY GENERAL DEPUTY ATTORNEY CJENERAL October 26, 2011 Ms. Cindy Bladey, Chief Rules, Announcements and Directives Branch Division of Administrative Services Office of Administration Mail Stop: TWB-05-B0IM U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 SUBJ: Docket ID NRC-2010-0206 RE: Comments of the Office of the Attorney General for the State of New Hampshire on the NRC Draft Environmental Impact Statement (NUREG-1437, Suppl. 46)for the Renewal of the Operating License for the Seabrook Station In July 2011 the U.S. Nuclear Regulatory Commission (NRC) issued Supplement 46 to NUREG-1437 as the draft Environmental Impact Statement (EIS) in support of the application for the renewal of the operating license for the Seabrook Station, which was submitted to NRC by NexlEra Energy Seabrook, LLC (NextEra) on May 25, 2010. The draft EIS was published in the Federal Register on August 5, 2011 (76 Fed. Reg. 47,612) and is open for public comment until October 26, 2011. The Office of the Attorney General for the State of New Hampshire (NHAG) is pleased to submit the following comments on the Seabrook draft EIS.As required by 10 C.F.R. § 51.53(c)(3)(ii)(L), NRC Staff has considered severe accident mitigation alternatives (SAMAs) at the Seabrook Station in Chapter 5 and Appendix F of the draft EIS. The NRC Staff evaluation consists of a review of the results of numerous probabilistic risk assessments (PRAs) and individual plant examinations (IPEs) that have been conducted by NextEra since as early as 1983 and updated as late as 2009. NRC Staff acknowledges that an updated version of NextEra's PRA model is scheduled to be issued in 2011 in order to address revised internal flooding requirements.
The updated PRA model is known to require a new SAMA to mitigate the risk of flooding in the control building, see Draft EIS at p. 5-8 (lines 8-14), and NRC Staff has concluded the SAMA is cost-beneficial for implementation, see id. at p.5-15 (lines 15-17 and 22-24), and Table 5.3-5 at p. 5-19 (SAMA #192). Since the Seabrook license renewal application is not expected to be issued until early 2013, sufficient time is available for the NRC Staff to fully review and to completely evaluate the updated PRA model when it is available.
Accordingly, NHAG recommends that NRC Staff review NextEra's Telephone 603-271-3658
-FAX 603-271-2110
- TDD Access: Relay NH 1.800-735-2964 Page 2 of 4 updated PRA model when it is available, and that NRC Staff incorporate its findings regarding SAMAs from that review in the final EIS.The draft EIS highlights, in general terms, a number of plant improvements already made by NextEra over the last 28 years based upon the results of the PRAs and IPEs. NRC Staff specifically notes, however, that NextEra has not yet implemented 14 plant improvements although each is supposedly addressed by a SAMA in the draft EIS.0 "Although no severe accident vulnerabilities were identified in the Seabrook IPE, 14 potential plant improvements were identified.
Four of the improvements have been implemented.
Each of the 10 improvements not implemented is addressed by a SAMA in the current evaluation." Draft EIS at p. 5-6 (lines 25-27)* "The Seabrook IPEEE did not identify any vulnerability due to seismic events but did identify two plant improvements to reduce seismic risk. Neither of the two improvements has been implemented.
Each of the two improvements is addressed by a SAMA in the current evaluation." Draft EIS at p. 5-9 (lines 2-5)* "While no physical plant changes were found to be necessary as a result of the IPEEE fire analysis, potential plant improvements to reduce fire risk were identified, of which four have been implemented.
The one improvement not implemented is addressed by a SAMA in the current evaluation." Draft EIS at p. 5-10 (lines 1 1-14)0 "The Seabrook IPEEE submittal also stated that, as a result of the Seabrook IPE, cost-benefit analyses were being performed for many potential plant improvements, which may also collaterally reduce external event risk. Four of these five potential plant improvements have been implemented, and the fifth is addressed by a SAMA in the current evaluation." Draft EIS at p. 5-11 (lines 22-26)It is not clear from the discussion presented in the draft EIS what each of these plant improvements entails -either the improvements already implemented or, more significantly, the improvements that remain un-implemented.
The draft EIS also does not explain why each of the 14 un-implemented plant improvements have not yet been yet implemented or whether any of these 14 un-implemented plant improvements needs to be implemented prior to the renewal of the Seabrook operating license. Likewise, the draft EIS does not indicate whether any of the 14 un-implemented plant improvements will ever be implemented in the future and if so by what date. Since NRC Staff took the effort to highlight these particular plant improvements (both .those implemented and those that remain un-implemented) in Chapter 5 of the draft EIS, NHAG recommends that NRC Staff supplement the discussion of these plant improvements, particularly those plant improvements that remain un-implemented, to address these shortcomings (i.e., the nature of the plant improvement, the reason(s) why an un-implemented plant improvement has not yet been implemented, the basis for a conclusion that an un-implemented plant improvement need not be implemented prior to license renewal, an explanation of whether the un-implemented plant improvement will ever be implemented, and if so the approximate date when the un-implemented plant improvement will be implemented).
According to the draft EIS statements quoted above, each of the 14 un-implemented plant improvements "is addressed by a SAMA in the current evaluation." However, from a review of Chapter 5 of the draft EIS it is not apparent where that discussion is presented (particularly since Page 3 of 4 the nature of each of the 14 un-implemented plant improvements is not described).
Although a general discussion of plant improvements appears on pages 5-13 through 5-20 in the draft EIS, and dozens of specific SAMAs have their cost-benefit analysis summarized in Table 5.3-5 of the draft EIS, no correlation has been provided between that information and the 14 un-implemented plant improvements.
N-HAG recommends that the NRC Staff supplement the information provided in the draft EIS to include a specific discussion of the SAMA for each of the 14 un-implemented plant improvements and to explain why such a discussion is needed (assumedly because the improvement will not be implemented as part of license renewal).Based upon the information presented in the draft EIS, NRC Staff and NextEra apparently agree that the following four SAMAs should be implemented because the benefits derived from the specific plant improvement outweigh their cost to implement: " SAMA 157 (provide independent AC power source for battery chargers)" SAMA 169 (RWST fill from firewater during containment injection)" SAMA 192 (install globe valve/flow limiting orifice upstream in fire protection system)" SAMA 193 (hardware change to eliminate MOV AC power dependency)
See Draft EIS Table 5.3-5 (highlighted items). With regard to these four SAMAs, NRC Staff notes that "NextEra plans to enter [them] into the Seabrook long-range plan development process for further implementation consideration." Draft EIS at p. 5-15 (lines 23-24). From this statement, however, it is unclear whether, in f_,c NextEra will be implementing the specific plant improvement at some point in the future (and if so approximately when) or merely"considering" whether to implement the specific plant improvement.
Given the collective cost of all four SAMAs (approximately
$580,000) and the collective value of all four SAMAs (39 percent reduction in core damage frequency and 51 percent reduction in population dose) as recounted in Table 5.3-5, NHAG recommends that all four SAMAs be implemented and implemented within a relatively short period of time.Finally, with regard to the four above-identified SAMAs, the draft EIS reaches the following conclusion regarding the timing for their implementation: "As stated by the applicant, the four potentially cost beneficial SAMAs are not aging-related.
The staff reviewed SAMAs 157, 165, 192, and 193. These mitigative alternatives do not involve aging management of passive, long-lived systems, structures, or components during the period of extended operation.
Therefore, they need not be implemented as part of license renewal pursuant to 10 CFR Part 54." Draft EIS at p. 5-20 (lines 26-30). However, nowhere in Chapter 5 are there specific details or discussions supportive of this general conclusion.
NHAG recommends that the NRC Staff supplement the draft EIS to explain its reasoning behind the conclusion that each of the four cost-beneficial SAMAs is not aging-related and, therefore, none of them need to be implemented prior to the renewal of the operating license for the Seabrook Station.
Page 4 of 4 Sincerely, K. Allen Brooks Senior Assistant Attorney General Chief,: Environmental Protection Bureau (603) 271-3679 KAB/cmc cc: Richard Sigel, Chief of Staff, Office of the Governor, State of N.H.Jeffrey A. Meyers, Legal Counsel, Office of the Governor, State of N.H.Thomas S. Burack, Commissioner, N.H. Dept. of Environmental Services Glenn D. Normandeau, Executive Director, N.H. Dept. of Fish and Game