Citizens File in Opposition to South Texas Project Reactors 3 and 4

Raises Health, Safety and Financial Risks to the Public
Austin, TX On April 21st, citizens submitted a filing to the Nuclear
Regulatory Commission opposing NRG's proposed South Texas Project nuclear reactors.
Petitioners included the Sustainable Energy and Economic Development (SEED)
Coalition, Public Citizen and the South Texas Association for Responsible Energy.
Problems with the License Application
"Our contentions laid out the many defects in the South Texas Project license application,
including inadequate fire protection, the lack of viable radioactive waste disposal plan, an
inability to secure against airplane attacks, vast water consumption, water contaminantion
risks, the failure to analyze clean, safe alternatives and an array of other financial, health
and safety risks." said Karen Hadden, Executive Director of the SEED Coalition.
Safety and Security Risks
New regulations took effect this March that require proposed nuclear plants to plan for
fires and explosions of the magnitude that would result from a jetliner crash. South Texas
Project's design does not meet the new requirements. New reactors are now required to
show that even if large areas of the plant were lost, the reactor core would remain
contained and the spent fuel pool would still have enough water to prevent an
uncontrolled radioactive chain reaction. These are reasonable safety requirements in a
post-911 world, but the license application falls short on this front.
Radioactive Waste
The license application assumes that high-level radioactive waste, such as fuel rods,
could be disposed of at a federal site, presumably Yucca Mountain, a plan that has no
basis in reality. The Yucca Mountain site isn't likely to open. Even if it did, it would
rapidly fill up with waste from existing reactors. After more than 50 years of promises
from the nuclear industry, there is still no authorized national repository and no solution
for high- level radioactive waste disposal. Radioactive waste is dangerous now and some
of the radionuclides remain dangerous for millions of years. The license application fails
to adequately address the public health consequences of accidents and releases related to
off-site radioactive waste disposal, wrongly assuming there would not be risks during
processing and transport.
Water Concerns
The South Texas Project license application fails to evaluate the increasing levels of
groundwater tritium, a radioactive isotope of hydrogen that can be dangerous if inhaled,
ingested or absorbed through the skin. Tritium has been detected in two of the pressure
relief wells that collect water leaking from the unlined bottom of the existing main
cooling reservoir. Concentrations of tritium have been increasing in both wells, and these
concentrations could rise if two more nuclear reactors are built at the site.
A state water permit proposed for the site fails to address radionuclides such as tritium,
and doesn't require monitoring for total dissolved solids, some metals or the chemicals
added by the facility, such as biocides, sulfuric acid, and anti-scalants. There are no sulfur
or sodium limits for the wastewater discharges.
The application's Environmental Report relies upon a dilution factor of 10 to meet
discharge standards, but fails to provide information about how much the waste discharge
loads would change with two additional nuclear reactors, and the consequences of the
load increases into a system with only a small change in the dilution factor, since the
storage volume would increase only 7.4%.
The application admitted that "5,700 acre-feet per year leaks through the unlined bottom
of the main cooling reservoir into the underlying Gulf Coast Chicot Aquifer" and 68% of
it is recovered. The rest migrates underground, seeping into nearby surface water bodies,
into pumped wells or the estuaries of the Gulf of Mexico. Dr. Lauren Ross of Glenrose
Engineering stated in a report submitted with this filing that "failure to monitor and
regulate leakage through the MCR (main cooling reservoir) bottom constitutes a failure to
protect groundwater and surface water from plant operations."
Nuclear reactors require vast quantities of water, an increasingly precious resource with
existing drought conditions. The application states that over 42,000 gallons per minute
would be required for the two proposed reactors under normal operating conditions, and
up to 44,000 gallons per minute could be required.
The water needed from the Colorado River to replace evaporated water would be about
74,500 acre feet per year for all four reactors, but water can only be taken from the river
when the flow is high enough, since low flow conditions leave the river water too salty to
use for reactor purposes. While the South Texas Project has backup water rights, the
application fails to discuss whether the volume could be delivered reliably during a
drought. The percentage of flow withdrawn from the river has been equal to or greater
than one quarter of the entire river flow at times, and even up to 48% of river flow at one
point. This problem could increase with more reactors.
Dr. Ross found that estimated groundwater use would more than double from an average
of 798 gallons per minute for the existing facility over the last five years to a level of
2040 gallons per minute for all four reactors, but the applicant wants to wait on analyzing
groundwater availability until after the permit is issued.
Financial Concerns
The applicant fails to provide cost estimates for the proposed reactors. In fact, CPS
Energy, a partner in the planned expansion project, has also refused to provide cost
estimates for their share of the project. The municipal utility had to reduce a recent rate
hike and take out funding for nuclear power as a result of citizen outcry. An analysis by
Dr. Arjun Makhijani has estimated costs for the two reactors at between $12.5 - $17
billion and the Federal Energy Regulatory Commission rates nuclear power as the most
expensive form of electric generation.
Decommissioning Funding Assurance described in the application is inadequate to fully
decontaminate and decommission South Texas Projectd Units 3 and 4. Neither the federal
or state law related to funding of decommissioning will be met if NRG proceeds as
Clean Safe Energy Alternatives Analysis Inadequate
The license application for South Texas Project Units 3 and 4 fails to demonstrate that the
reactors are needed.
"Wind energy is booming in Texas, solar costs are coming down, the legislature supports
efficiency and more renewable energy, transmission lines for renewable energy have
been approved and with efficiency improvements, projected demand needs to be reexamined"
said Karen Hadden, director of the Sustainable Energy and Economic
Development (SEED) Coalition. The nuclear reactor license application (page 9.2-18)
states that "it is conceivable that a mix of alternatives might be cost-effective and may
also provide a better environmental solution...STPNOC has not exhaustively evaluated
each combination." It is a massive failure that they did not explore clean, safe, affordable
options thoroughly.
Whooping Crane / Endangered Species Concerns
Whooping cranes winter only 35 miles from the reactor site, and get closer yet during
migration times. This past winter was the worst in twenty years, with an 8.5% mortality
rate. A USFWS biologist has described the birds as looking thin with disheveled
plumage. The license application should, but doesn't, adequately research the possibility
of radionuclides bioaccumulating and biomagnifying in the ecosystem and impacting the
birds. Nor does it address the impacts that a nuclear accident could have on the whooping
cranes and other endangered species in the region.
In summary, there are numerous flaws and serious inadequacies in the license for the
proposed reactor. The licensing process should be halted until these inadequacies are
addressed. The next step in the licensing process will be for the NRC to respond to our
petition and contentions. ###