ML23108A189
| ML23108A189 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/19/2023 |
| From: | Mattern J - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2022-0183, 87FR76219 01723 | |
| Download: ML23108A189 (1) | |
Text
SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: April 05, 2023 Received: January 25, 2023 PUBLIC SUBMISSION ADD: Tam Tran, Antoinette Walker-Smith, Ted Smith, Mary Status: Pending_Post Neely Comment (1723) Tracking No. ldc-99pn-58ik Publication Date: 12/13/2022 Comments Due: January 30, 2023 Citation: 87 FR 76219 Submission Type: Web Docket: NRC-2022-0183 Vistra Operations Company LLC Comanche Peak Power Company LLC Comanche Peak Nuclear Power Plant, Units 1 and 2 Comment On: NRC-2022-0183-0003 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; Vistra Operations Company LLC; Comanche Peak Nuclear Power Plant, Units 1 and 2 Document: NRC-2022-0183-DRAFT-1723 Comment on FR Doc # 2022-27025 Submitter Information Name: Janet Mattern Address:
Fort Worth, TX, 76132 Email: janet.lwvtc@gmail.com Phone: 8175970116 General Comment Please review my comments provided in the Attached Word file. My comments pertain to request for a public hearing and concerns that should be included in the NRC Environmental Assessment for the license renewal.
Thank you!
Attachments Janet Comments RE license renewal Comanche Peak R1 file:///nrc.gov/...omments/NRC-2022-0183%20NEW/NRC-2022-0183%202023-04-05%2010-26-49_docs/NRC-2022-0183-DRAFT-1723.html[4/6/2023 1:19:08 PM]
RE: Comments regarding license renewal of the Comanche Peak nuclear power plant reactors 1 and 2 in Glen Rose, Texas Docket ID: NRC-2022-0183 I live in southwest Fort Worth near Benbrook Lake, approximately 30 miles from the Comanche Peak nuclear power plants. My sister has two homes in Pecan Plantation about 7 miles from the nuclear power plant. My sister asked me to provide comments on her behalf, as well as my own.
The single virtual meeting held on January 17th was not sufficient to obtain input from the local community. After the introduction and questions on the presentation, less than 30 minutes were allotted for comments, and several attendees were never able to speak due to technical difficulties. It is important for the community to be informed about the Comanche Peak nuclear power plant and for public hearings to be held so that the local community can be better represented and so that the NRC can hear perspectives from more impacted residents.
For instance, I spoke to a neighbor of mine who didnt even know that there was a nuclear power plant in north Texas, let alone that it was only 30 miles away.
It is imperative that more media announcements are made so that the entire locally impacted community is aware of future public hearings, and this means that the DFW media outlets should be informed as well. I lived in a small community, where the paper is printed once a week, many residents do not take the local paper, they typically watch the news reported from DFW media outlets.
Environmental Impacts assessed by the NRC must include consideration of the following concerns:
- 1. Population increase Reviewing the population of counties surrounding Comanche Peak, the population has more than doubled in Hood and Johnson counties since 1990. The population increase adds an additional risk that must be considered when assessing several key factors and/or processes:
a) additional water usage needed for added populace, their homes/yards, farms, and usage of industry and mining, in addition to the nuclear plant. In particular, as both Hood and Johnson counties use Granbury Lake for their municipal water supply, b) emergency evacuation procedures - with more population, there needs to be additional communication (who uses phone books) and there is be a big concern now with increased traffic congestion, it will be worse if used for evacuation. Should probably send locals away from DFW, as the DFW area will be overextended already having to deal with their own impacted population from a calamitous event. DFW is the fastest growing area in the US. With recent COVID hospital bed and respirator shortages, these should be considered and included in new emergency procedures. Also, must consider the hospital closures in rural counties.
c) impacted population increase also increases the liability costs as more people will need emergency services, hospital rooms, long-term medical care and more people will be impacted by losing their homes, businesses, animals if a calamitous event were to occur at Comanche Peak.
d) local emergency services could be impacted by population as the local services may have more residents requiring service, in case of fire, tornado, flood, and there would be potentially fewer emergency services available to help if there was a need for their help at the Comanche Peak power plant.
- 2. Water Availability Water has quickly become the most valuable resource in Texas and in the world. Having availability to water is extremely important for nuclear reactors to operate. With the escalating climate crisis, water availability is a major threat, and this impact must be assessed in the NRCs impact assessment.
Monarch Partnership reports that a large nuclear power plants may use up to 1 billion gallons of water a day. (1) This is a tremendous amount of water, and the risk of having insufficient availability must be factored into the environmental assessment for renewal. I do not know if Comanche Peak would use this much water, but it seems very wasteful to use so much water in a part of the state that has such limited rainfall, and when the Brazos River basin beyond Glen Rose has had to experience drought conditions for years. So, water scarcity will continue to be a concern in the future and more water may be needed to keep the power plan operating. Per Appendix E, Comanche Peak can remove up to 49,350 Acre-Feet of water/year (16.3 billion gallons) from Granbury Lake. Although there is some water consumption data in Appendix E, it speaks more about the water consumption for Units 3 and 4, which are NOT INCLUDED as part of the license renewal. To compound the problem, water must continually be available to be cycled through the plant even when the reactor is shut-down for maintenance and to cool the stored fuel-rods. And increased population means increased water demands for the municipal water supply needs. Water is also being used for fracking in the north Texas area, another concern that reduces water availability.
In 2014, the reservoir levels along the Brazos River were very low. Per USGS records, Granbury Lake was below 50% capacity and Possum Kingdom Lake was below 30% capacity. With climate change, future years may bring more severe drought conditions, and with the increased population using the water the drought would not need to be as severe to reduce the water available in these reservoirs. I urge the NRC to please assess the impact of climate change conditions such as, water availability, and water temperature, and factor these with the increased population and their drain on this resource that is so critical to the operation and cooling of nuclear reactors.
It is imperative that an assessment of the risk of failing to have available sufficient water as a coolant be investigated. There is a possibility that with the current water rights afforded to the power plant, that that water supply may still prove to be insufficient for the demands required
to operate the plant safely. Comanche Peak has an agreement with BRA to withdraw water from Lake Granbury and Possum Kingdom Lake. However, that agreement does not include the full time span required for both the requested license renewal of 20 years PLUS an additional 20 years, which is the reported time required to decommission a nuclear power plant.
So, the scoping, planning and analysis should cover the requested 20 additional license years plus add the additional 20 years to decommission the plant. As such, coolant water supply must be available for the full life plus decommissioning time period, and the license renewal should include this full timespan in the scope.
- 3. Risks Attributed to Physical Aging of the Plant In 2014 the NRC approved a request from the owner of Comanche Peak to increase the energy production from the nuclear reactors. How has this increased workload impacted the aging of the Comanche Peak nuclear reactors? I ask this as a practical matter. If any facility increases its energy production from the original specifications, there probably will be additional wear and tear to be able to provide the increased energy output. It would be good to assess how this has impacted the aging and potential lifespan of the nuclear power plant.
Bulletin of Atomic Scientists (2016) reports that the nuclear industry and NRC are not putting sufficient emphasis on the impact of time (age), in the risk of a potential accident. This study stated that due to the aging of nuclear reactors in the US the overall probability of a meltdown in the next decade is almost 70%. (2) These odds are unacceptable and much more risk prevention is required.
iNRAG study reports (2021), that old nuclear power are unable to operate at the standards defined for new reactors built today. Their study provides a great deal of detail regarding the risk and physical issues associated with operating older nuclear reactors. (3)
Reuters states that Frances nuclear output is at a 30-year low, since many of its aging reactors had to be taken offline for maintenance after finding stress corrosion on pipes in some reactors.
(4)
Looking at some of the inspection reports from the plant, I saw several outages of the plant for routine maintenance, refueling, etc. which are a part of the operation. I was concerned however, that some reports identified that some repairs took almost two years to be completed after a prior NRC inspection identified the need for these repairs. Aging nuclear power plants will require more frequent inspections and must require the licensee to fix repairs more urgently.
There are many studies regarding all the issues that can negatively impact these power plants as they age. My biggest concern is with vigilance of the licensee and the regulatory agencies who are responsible for the communitys well-being. With the weakening of regulations at both federal and state levels, the public should rightly be concerned about the nuclear power
industry. Another reason that holding public hearings in the local Glen Rose community, and in neighboring communities around the power plant is necessary and will provide the necessary transparency so that residents can be informed about the risks involved with extending the license for Comanche Peak and so the residents can comment on how they may be impacted.
In the license renewal, the licensee identified certain areas that they identified to be in or out of scope for assessment of aging. There are several areas that were identified as out-of-scope that I would think should be in scope. Can the NRC include in the impact assessment information about how aging impacts these areas? I would have thought that these areas could be potentially impacted by aging:
a) The earthen dam(s) (identified as out-of-scope). Earthen dams also have a finite lifespan.
Earthen dams must also be assessed as to if additional maintenance or structural work may be required to ensure that these structures hold the water needed for the power plant to operate.
Even though the earthen dam may need to be assessed by another regulatory agency other than the NRC, it should be at least identified as such in the renewal application.
b) The meteorological equipment (identified as out-of-scope). This equipment must be checked and updated to ensure that it is functional as weather is likely to become much more severe over the next 20-40 years. The plant personnel must be informed quickly as weather in Texas changes drastically from one extreme to another.
c) The spent nuclear fuel radioactive waste containment (identified as out-of-scope). The storage containment must be inspected to ensure that it can hold not just the current waste, but has the capacity to store the additional waste that is planned with the license renewal request. There have been reports that nuclear plants have started storing the spent fuel rods at increased density, which could provide increased risk for a mistake. This must be assessed in the review of the plant for future use. There is also a need now for the waste containment structure to be able to withstand more catastrophic impacts than were considered during the initial application. As climate change may produce far more severe weather events, much stronger tornadoes, earthquakes, airplane as a projectile, and bombs (as seen recently in Ukraine). And consideration must be given that there will be much more high-level radioactive waste stored than was planned when the initial power plant was under construction.
d) emergency evacuation procedures (identified as out-of-scope). The initial procedures relied on local telephone books. These processes should be brought forward (if not done already) and modified to account for the increased population size and newer modes of communication.
There should also include communication measures to be taken if there is no internet.
- 4. High-Level Radioactive Waste The biggest issue is the high-level radioactive waste from the spent nuclear fuel rods. This waste will never go away, even when a nuclear power plant is decommissioned. What is the plan to handle and store the generated high-level radioactive waste. No one in the US wants this waste to be stored in their state. There is currently no solution, and it doesnt seem likely that a solution will be identified prior to the license renewal date. There are multiple concerns about having all the high-level radioactive waste located at one storage site for all US waste.
Having all this waste located at one site would be a potential catastrophe! An Interim-Storage
facility is also not the solution, as there is no way you can state a facility is interim until there is first an identified permanent location.
As a scientist, I have personally worked with radiolabeled materials. Even very small amounts of radioactivity (depending on the Isotope) can be quite dangerous.
High-level radioactivity, and actually even some low level gamma radioactivity can cause death or very serious health concerns. I will not go into all the negative health concerns, like increased incidence of cancer in children living within close proximity of nuclear power plants. This is well-reported and the statistics are known. As you know, you cant see radioactivity, or smell it, or taste it. You cant catch it from someone like COVID, so a mask means nothing. It can penetrate concrete walls. It can be carried in the wind, it can be in your drinking water, or contaminate the soil and vegetation to contaminate our food supply. Once an area is contaminated, that land is not longer able to be inhabited. This is a huge risk and a huge cost to those who live in the vicinity of a nuclear power plant.
The nuclear energy has had over 70 years to find a solution to the high-level radioactive waste that is a necessary product from operation of nuclear reactors. We must stop using this technology, if we have no way of properly and safely disposing of the generated waste.
In addition, many tax-payers do not realize that we are the ones who are paying for the costs to store the highly radioactive nuclear waste. Bloomberg reports that the US taxpayers paid $35 million/year just for radioactive waste storage at the Maine Yankee power plant, which hasnt produced a single watt of energy for more than 20 years. (5)
- 5. The Cost of Nuclear Power Another major concern is the cost of nuclear power. There are concerns that have reported regarding the licensees (VISTRA) significant liabilities. Seeking Alpha October 2022 article identified concerns with the Texas GRID reliability (due to state of Texas not forcing weatherization) and long-term debt and derivative exposure, with $32.1 billion in liabilities and
$37.5 billion in assets.
In 1957 Congress passed the Price-Anderson Act, which effectively protects the nuclear power industry from paying the full liabilities should an accident occur. So, the tax-payer is liable to compensate those that are harmed should an accident occur. And this is a major reason why we citizens, who are tax-payers should have the opportunity to state our case in a public hearing regarding our concerns for renewal of the license for operation of Comanche Peak.
1957 study by AEC Brookhaven National Laboratory indicated that a major accident at a large plant (for the time) could cause 3400 deaths and $7 billion in property damage - about $74 billion in todays money. Eight years later this was revised and stated that a meltdown could cause 45,000 deaths, with an area of radioactive contamination the size of the state of Pennsylvania. This report was suppressed until 1973. (6)
One of the main reasons we havent had new nuclear power plants built for over 34 years is because of economic realities, that construction and operating costs became untenable, even for utility companies allowed to pass the costs to consumers. But, now that government (tax-payer) subsidies are available, there is a big push for the energy industry to take this money, even if the risk to the people is greater than our reward.
Bloomberg in 2018 reported that of the 66 nuclear power plants operating in the US, 24 were scheduled for to close or wont make any money. Their thoughts are that the plants in the Midwest were vulnerable due to the availability of cheap wind power. (7)
So, looking at the 1957 study of the cost of a cataclysmic incident in todays money ($74 billion),
there is no way that VISTRA has assets to cover the cost of such an event. And we also know that Texas state agencies would not know how to handle such an event, nor would they have the resources.
- 6. Public Safety Union of Concerned Scientist report states when nuclear power plants were getting approved in the 80s and 90s, that the NRC underestimated the risk to public safety by a factor of at least 100. (8) Technically astute insiders at the AEC took it for granted that catastrophic accidents were possible; the key question was: What were the chances? They write that the experts just guessed, as they had no statistics to assure the public that the plants were safe enough to be approved for operation. In addition, the author states in his opinion, potential contribution to clean energy has been compromised by safety shortcuts taken by the industry, and by lax government regulation of day-to-day safety practices at the plants.(6)
Texas has extremely weak laws regarding safety of the public and the environment. At present, there is no one state agency with oversight of nuclear power plants. State agencies like, DSHS, TCEQ and RRC each have some role to play to ensure safety, and none have any real power. In addition, these state agencies rely on the industry to self-monitor for radiation exposure. These agencies by law, work more to protect business interests than for present or future Texans.
In summary, Vistra and the NRC have an obligation to educate the public about the risks of extending the life of Comanche Peak beyond the initial end-of-life date.
I am opposed the license renewal. I request a public hearing be provided so that the public can receive information about the environmental impacts and possible risks to the people and their community associated with living near aging nuclear power reactors. If this projects move forward, it should be with taking the publics concerns into consideration and ensuring that the community is made aware of the actual risks involved with having an aging nuclear reactor near ones home.
I also request that the NRC include in their assessment several of the concerns mentioned in my above comments.
References:
- 1. Nuclear Power and its Water Consumption Secrets, Kate Green, Monarch Partnership Jan. 2019.
- 2. Nuclear Power in the Future: Risks of a Lifetime, David Lochbaum, Bulletin of Atomic Scientists April 2016.
- 3. Risks of Life-Time Extension of Old Nuclear Power Plants, iNRAG April 2021.
- 4. Explainer: Why nuclear-powered France faces power outage risks, Reuters Dec. 9, 2022.
- 5. Americans are Paying More than Ever to Store Deadly Nuclear Waste as Plants Shut Down, Bill Wade, Bloomberg June 24, 2019.
- 6. How Safe are Nuclear Power Plants? Daniel Ford, The New Yorker Aug. 13, 2022.
- 7. One-Fourth of US Nuclear Plants are at Risk of Early Retirement, Tim Loh, Bloomberg May 15, 2018.
- 8. Nuclear Plant Risk Studies: Failing the Grade, David Lochbaum, Union of Concerned Scientists, Aug 2000.
/jm