ML24295A103
| ML24295A103 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/14/2024 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 89FR72901 | |
| Download: ML24295A103 (6) | |
Text
From:
Pat Marida <patmarida@outlook.com>
Sent:
Monday, October 14, 2024 9:04 PM To:
Lance Rakovan Cc:
Subject:
[External_Sender] Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement Attachments:
Perry Nuclear Reactor, ONFN.docx (1).pdf; Pat Marida Comments Perry Draft GEIS 10-2023.docx TO: U.S. Nuclear Regulatory Commission (NRC)
Via: Lance Rankovan, lance.rankovan@nrc.gov RE: Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement FROM: Patricia Marida
Dear Mr. Rankovan and NRC staff and administrators,
For my comments I submit the two attached documents. Each has considerable documented analyses of immediate environmental threats from the operation of the Perry reactor, as well as the storage of its spent nuclear fuel close to Lake Erie.
Please let me know that you have received this message Thank you.
Patricia Marida Columbus, Ohio
Federal Register Notice:
89FR72901 Comment Number:
5 Mail Envelope Properties (PH7PR11MB6698BCF6688E06EBE1A6E53AAB452)
Subject:
[External_Sender] Response to NRC comment meetings and Perry Draft Generic Environmental Impact Statement Sent Date:
10/14/2024 9:04:05 PM Received Date:
10/14/2024 9:04:27 PM From:
Pat Marida Created By:
patmarida@outlook.com Recipients:
"Ted Smith" <Theodore.Smith@nrc.gov>
Tracking Status: None "Lance Rakovan" <Lance.Rakovan@nrc.gov>
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PH7PR11MB6698.namprd11.prod.outlook.com Files Size Date & Time MESSAGE 659 10/14/2024 9:04:27 PM Perry Nuclear Reactor, ONFN.docx (1).pdf 986522 Pat Marida Comments Perry Draft GEIS 10-2023.docx 22324 Options Priority:
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ThePerry Nuclear Reactor (a commercial nuclear power plant)sits on the shore of Lake Erie 40 miles east of Cleveland, Ohio. Perry is a single 1260-megawatt General Electric Boiling Water Reactor. Construction for two units began in 1977. Unit2 was canceled in 1994 after all major buildings and structures were completed, including the 500-foot cooling tower. Unit 1 beganoperations in 1987 and was licensed to March 2026.
Liability relief: Perry was owned by FirstEnergy before they put their energy-generating subsidies into bankruptcy in 2018. A new company, Energy Harbor, LLC, emerged as owner, absolving both FirstEnergy (now only delivering electricity) and new reactor owner (limited liability corporation) of many previous liabilities.
Vistra bought Energy Harbor in March, 2024, making Vistra the nations second largest nuclear fleet owner.
License expiration relief: $1.3 billion in subsidies for FirstEnergys nuclear plants (see Ohio House Bill 6 -
page 2) made the owners change their minds about not renewing Perrys license. In 2020 the Nuclear Regulatory Commission (NRC) extended Perrys license expiration date by 8 months to Nov. 2026. The NRC also changed the deadline for requesting an extension from 5 to 3 years before expiration. This made the owners eligible to request a 20-year license renewal.
License renewal: A renewal application was made in July, 2023. That December, ONFN and Beyond Nuclear filed a Petition to Intervene, citing large and continuing tritium releases and a serious accident potential.
The petition contains a report by Geologist Dr. Rice on Bedrock, Earthquakes, and Flooding at Perry, saying the Perrys buildings can slide into Lake Erie sooner rather than later, as part of a nearby park did. An outdated geotechnical analysis of the Perry site is not predictive of actual site conditions including earthquakes, lake erosion, and leaks from wet and dry storage moving to the lake.
Solution of the underlying Salina (salt)
Formation could destabilize the entire site.
Construction cost was 11 times the estimate: When the twin reactor plant was announced in 1971, it was to cost
$632 million. The final cost was $7.4 billion. Unit 2 never opened, likely due to economics including costs to finish construction, interest on borrowing, poor projected revenues, and increasingly on back taxes due.
Seismically active area: Perry lies within 40 miles of two faults. Whistleblowers reported that a geologic fault line was identified while Perry was under construction, and that workers were instructed to keep quiet as they filled the fissure with thousands of tons of concrete. In 1986, a 5.0 earthquake hit 10 miles to the south. It was felt in 11 states and Ontario. A citizen group sued to block Perry from opening, citing future earthquake risk, but was turned down by the Supreme Court. In 2019 an AP analysis of government data revealed Perrys risk of severe earthquake damage to be 24 times as high as previously thought. Addressing multiple quakes in Lake County in 2022, a geologist noted that the ground is riddled with faults. See Dr. Rices report above.
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 revise the methodology for flood hazard analysis.
Shoreline erosion: Perry sits on a 40-foot bluff overlooking Lake Erie. Wave activity is undercutting the bluffs, creating shoreline recession. According to the Ohio Dept. of Natural Resources Lake Erie Shore Erosion Management Plan for Eastern Lake County, 3,500 feet (about half) of the Perry site shoreline is armored with stone and steel. Recession along the unarmored shore east of the plant resulted in the removal of several homes before Perry was constructed. Average recession rates of unarmored shore reach 4.9 feet per year in the area.
First Energy/Energy Harbor/Vistra Cut Corners on Nuclear Maintenance: ONFN outlines 30+ requests made to or granted by the Nuclear Regulatory Commission for waivers on inspections, standards, maintenance, repairs, and upgrades for Perry and Davis-Besse. Exemptions given due to planned closure in 2021 continue.
Regular radioactive releases, accident concerns: The nuclear industry fails to mention that all nuclear plants make regular radioactive releases into the air and water. An accident at Perry poses the risk of contaminating the drinking water of millions of people. A Perry tritium leak made the news in 2014.
Other incidents:
Twice in 2021, the NRC reduced Perrys emergency planning requirements, including for fires.
In 2017 it was found that Perry had been operating without access to its emergency diesel generators.
NRC inspections also failed to notice this. Later, the NRC issued a White Finding.
In 2017, twenty-seven Perry workers failed drug tests. Perry was the target of NRC safety inspections for more than three years because of human performance issues in safety management.
In 2011 the Union of Concerned Scientists documented a Near-Miss at Perry involving multiple issues.
In a 1991 Mistake by the Lake, the rupture of a 36-inch pipe carrying water critical for cooling flooded the Perry site with 3 million gallons of water. Water flowed into vaults containing electrical cables.
The Ohio House Bill 6 bribery scandal: In 2018 FirstEnergy claimed its two Ohio nuclear plants, Perry and Davis-Besse, were unprofitable and threatened to close them. In response, the Ohio legislature passed the infamous House Bill 6 in July 2019, giving FirstEnergy $1.3 billion in ratepayer money to keep the plants running. A year later, the Dept. of Justice made arrests, alleging that FirstEnergy had bribed lawmakers and others to the tune of $60 million. The U.S. Attorney described House Bill 6 as likely the largest bribery and money laundering scheme ever perpetrated against the people of Ohio." The legislature rescinded $1.3 billion gift, but a large coal bailout and the gutting of Ohios renewable energy standards remains in place. No FirstEnergy officials have been charged with a crime, and the nuclear plants continue to operate - what happened to being unprofitable? See the ONFN factsheet on FirstEnergy deception before the scandal broke: Ohio House Bill 6, the FirstEnergy Bailout.
NUCLEAR REGULATORY COMMISSION: A CAPTURED AGENCY The NRC has been captured by the industry it was set up to regulate. They have handed out safety exemptions and approved the following three technologies:
High Level Radioactive Waste stored in thin canisters: NRC has licensed stainless steel dry storage canisters for nuclear waste that are a mere 5/8-inch thick.They are welded shut and cannot be inspected, maintained, or repaired. Peak radiation levels from their air vents are kept from the public. Thin canisters could crack, causing major radioactive leaks and explosions. Scratches and gouges can compromise the outer layers, precipitating cracking. Thick-walled casks are required in Europe. They are designed to be monitored and maintained and are transportable, while thin-walled canisters are not.
High Burnup Nuclear Fuel (HBF) has been permitted by the NRC for over 20 years. It has more fissile material and is burned longer and hotter, saving utilities money. Perry went to 100% HBF in 2019. Spent (used) HBF is more radioactive and thermally hot, requiring longer water cooling in fuel pools before dry storage. Higher temperatures damage the fuel, increasing explosion risk and making it unstable for transport. Substantial HBF safety risks have been documented since 2014. NRC responded by allowing shorter, not longer, cooling times for spent fuel, exempting some canisters from verifying cooling. NRC is considering allowing even higher fuel burnups. For financial viability, new nuclear reactors will require much higher burnups and enrichment - greatly increasing fuel storage challenges.
Dangerously overcrowded fuel pools: Spent (used) fuel comes out so hot it must be cooled in fuel pools for years. Because fuel pools are expensive, utilities are overcrowding existing pools.U.S. fuel pools now hold up to 5 times more fuel than they were designed to handle. Outside electricity is needed to cool the pools for refueling or for a weather incident or electric outages. Backup generators have limited fuel and are notorious for failure. A pool fire caused by loss of electricity or a terrorist act could dwarf the Fukushima disaster.
Updated October 2024. Contact Pat Marida patmarida@outlook.com.
10-14-2024 TO: U.S. Nuclear Regulatory Commission (NRC)
Via: Lance Rankovan, lance.rankovan@nrc.gov RE: Response to NRC comment meetings and the Perry Draft Generic Environmental Impact Statement FROM: Patricia Marida
Dear Mr. Rankovan and NRC staff and administrators,
For my comments I submit the following documents. Each has considerable documented analyses of immediate environmental threats from the operation of the Perry reactor, as well as the storage of its spent nuclear fuel so close to Lake Erie. Perry did not need to be built so near the lake, but it has a good view.
DOCUMENT 1: The Ohio Nuclear Free Network factsheet: The Perry Nuclear Reactor (also attached separately).
DOCUMENT 2 (54 pages): Dr. Julie Weatherington-Rices Declaration on Perry Geological Problems 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 deliberately 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.
DOCUMENT 3: Perry License Extension Intervention Press Release 12-11-2023 DOCUMENT 4: Perry Relicensing Petition to Intervene-ONFN-BN.
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.
Sincerely, Patricia Marida Columbus, Ohio