ML19016A096

Comment (3) of Kay Patrick on Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2

ML19016A096
Person / Time
Site:	Surry
Issue date:	01/14/2019
From:	Patrick K - No Known Affiliation
To:	Office of Administration
References
83FR65367 00003, NRC-2018-0280
Download: ML19016A096 (2)

Text

PUBLIC SUBMISSION As of: 1/16/19 9:12 AM Received:

January 14, 2019 Status: Pending_Post Tracking No.

1k3-97og-1i0sComments Due:

January 22, 2019 Submission Type:

Web Docket: NRC-2018-0280Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2 Comment On:

NRC-2018-0280-0001Virginia Electric and Power Company; Dominion Energy Virginia: Surry Power Station, Unit Nos. 1 and 2 Document:

NRC-2018-0280-DRAFT-0003 Comment on FR Doc # 2018-27547 Submitter InformationName: Kay Patrick General Comment Docket ID NRC-2018-0280 The thought of having the Surry reactors certified for another twenty year s frightens me. This seems totally irresponsible and perhaps is just a formality to underw rite Dominion's stock performance instead of an honest scientific assessment. As we are only into seven years of the current twenty year renewal, this seems

premature and highly speculative.

As I understand it, the required physical on site tests to support this extension till 2032 are still unfinished.

Obviously your Generic Lessons Learne d Report.(GALL) is a useful tool , but no replacement for any site specific inspection or testing of materials.

I am not a nuclear scientist and must rely on your expert s to make these assessments, but it is clear in your documents, this is not happening in a timely manner. The Surry NPP is one of many unique installations with its own challenges. As a citizen observer, there are many questions I have about the situation of this facility and how they are being addressed.

Surry is situated on an island of marsh land in a c onfluence of brackish water, highly exposed to harsh weather conditions and a constantly e volving shoreline in an area that ha s seen drastic change over a short period of time. It is hard to imagine it is different there from the more populated points that are being subsumed periodically and some permanently. When projecting thirty two years into the future, that the site will remain up on dry land seems highly speculative.

Also the matter of corrosive brackish water could be a fa ctor in the wearing of part

s. Metals oxidize, concrete Page 1 of 2 01/16/201 9 https://www.fdms.gov/fdms/get content?objectId=09000064839ef7fb&f ormat=xml&showorig=fals e

absorbs moisture and releases it changing its char acter yearly, insulated wires and hoses subject to temperature extremes, moisture and rode nts; so many things to evaluate cons tantly, but to project a safe future projected thirty years forward on ex trapolation seems highly suspect. Ther e is no way to do this, it is not reasonable to anticipate that data now will be consistent with real time change.

The biggest concern is the quality of the reactor vessel. This was engineered to have a life of forty years.

When it was made, there was no data on how the metal w ould react to the stress of heat and corrosion in the presence of nuclear fuels. I understa nd there are samples that are pulled and inspected periodically. This would be a linear observation, but is there assurance ther e is not an exponential degr adation that would create a danger of failure in doubling the length of service? This guess that it will remain sound for twice the length of prescribed time into the future is questionable.

Pre-qualifying this NPP for such a drastic period at this time seems irresponsibl e, and I would prefer any extension of service be delayed till there are more site specific physical inspections and testing over time.

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