ML23046A451
| ML23046A451 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/30/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR76219 | |
| Download: ML23046A451 (11) | |
Text
From: Susybelle Gosslee <sgosslee@airmail.net>
Sent: Monday, January 30, 2023 3:36 PM To: ComanchePeakEIS Resource Cc: Susybelle L Gosslee; Susybelle L Gosslee
Subject:
[External_Sender] Comments to Regulation Government Document ID NRC-2022-0183-0003 Attachments: Testimony from me 23-1-17.docx 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 Regulations.gov Document ID NRC-2022-0183-0003 AgencyNRC Comment PeriodDec 13, 2022 to Jan 30, 2023 RE: Docket ID NRC-2022-0183
Dear NRC:
Email: comanchepeakeis@nrc.gov I urge you to reject the application by Vistra to extend the operating licenses for the Comanche Peak nuclear power reactors for an additional 20 years. The reactors should retire as licensed, on or before 2030 and 2033 to protect the public health, safety, security, and financial health of Texas.
Follow principles of good government in a Democracy.
I request transparency to ensure that the democratic principles apply to all Americans. In-person scoping meetings were to be held in Texas but were canceled due to Covid, which had no cases or deaths reported in the County of Glen Rose on the day of the scheduled meeting. In-person scoping meetings should be held in Texas, as originally planned. Our democracy is being undermined and pushed aside by the NRC.
Hold public in-person hearings in North Texas.
I request a public in-person hearing opportunity be scheduled for those seeking to intervene and the public. I request that several hearings be held in the north Texas area and in Glen Rose during the 90 days past the current January 30
deadline. Afternoon, evening, and weekend in-person public meetings NEED to be scheduled to ensure the principles of good government. Because the Nuclear Regulatory Commission is an agency of the United States government, Democratic principles should be followed. A hearing was scheduled on one day in the afternoon and one in the evening but then postponed at the last moment, without adequate public notice. Four hours of in-person meeting time were reduced to only two hours online. Two million Texas households have no access to high-speed internet, according to the Texas Comptroller. There are no plans to improve access to the internet in the state. There was no evening opportunity to participate for people who work during the day, and not everyone can access online meetings. There were no exhibits or opportunities to speak directly with NRC staff.
Participants on the call were not able to see the other speakers during the phone conversation or computer. That demonstrates a total lack of transparency in the limited hearing process. A list of names of participants was provided, but this is completely inadequate to meet the criteria of transparency and meeting a standard for judging and evaluating the entire process. For example, was the list of participants complete? No participants could see each other.
Texans cannot afford nuclear accidents.
Safety should come first. Neither the federal government nor the state of Texas can afford a nuclear accident. Texas poverty rate for Texas children is one in five.
20Race%20and,population%20swelled%20from%2028.1%20million%20to%2028.
4%20million. Overall, the Texas poverty rate in 2021 about 14.2 percent of Texas population lived below the poverty line.
https://www.statista.com/statistics/314935/poverty-rate-in-texas/
Major concerns with Comanche Peak and its re-licensing.
Population and financial risks should be in the scoping process. Increased safety and financial risks could result if the life of the reactor were extended another 20 years. Risks from stress corrosion cracking, metal fatigue, and embrittlement would all increase, thereby increasing accident risks and the potential for
radiation releases. There are 7.76 million residents in and near Dallas/Ft. Worth.
Public health and safety should come first in this decision.
- a. Seismic concerns Seismic concerns should be investigated. Seismic concerns of both the reactors and the Squaw Creek Reservoir need to be re-examined in light of recent earthquake activity. Comanche Peak is within the Barnett Shale, a region with extensive fracking and numerous injection wells. Fracking can cause earthquakes that can damage nuclear power plants. There are fault lines in the area and a magnitude 3 earthquake had its epicenter only 20 miles from the site.
- b. Water concerns The areas water resources should be in the scoping. The reservoir water contains radioactive tritium, and the integrity of the earthen dam must be included in the scoping, including the extent of inspections and past and anticipated impacts to the dam from seismic activity.
Somervell Couty, the location of Comanche Peak Nuclear Reactor, has been identified as an extreme drought county. The scoping of the county should consider drought conditions and their impact on the availability of water for future reactor operations during the next half-century at least.
Drought can cause wildfires. Is there enough firefighting equipment and water on the reactor site to extinguish wildfires in the area? Are the firefighters on the reactor site and in the city of Glen Rose adequately trained to deal with and extinguish fires in the county?
The absence of cooling water leads to core danger, containment failure, and release of harmful radiation into the environment. The scoping process must evaluate the availability of water during the next century.
- c. Nuclear energy produces hazardous and dangerous nuclear waste.
What to do with the high-level radioactive waste should be in the scoping process. High-level radioactive waste is the most dangerous material in the world.
Certain radioactive element (such as plutonium-239) is spent fuel that will remain hazardous to humans and other living beings and the environment for hundreds
of thousands of years. Other radioisotopes will remain hazardous for millions of years. These wastes must be shielded for centuries and isolated from the living environment for hundreds of millennia. The scoping process should evaluate the existing and future tools available for use.
- d. Radioactive or nuclear waste is a byproduct of nuclear reactor facilities.
The scoping process should include an evaluation if the agency is meeting the mission, as an independent agency of the United States government to protect public health and safety related to nuclear energy. In 2018, there were just over 80,000 metric tons of high-level radioactive level waste in the United States. The tonnage has increased since 2018, even though there is no deep geological storage site identified to store it in perpetuity. The time is now to stop the production of high-level radioactive waste so that there is not a greater problem with what to do with the waste. Creating more waste at Comanche Peak Nuclear Reactor does not protect the public, and is not in the best interest of the public good.
- e. Security The vulnerability of Comanche Peak Nuclear Reactors should be included in the scoping process. Nuclear reactors are vulnerable to sabotage. Physical attacks on power grids have surged to new peaks with shootings, sabotage, and vandalism.
Domestic extremism has increased at an unseen pace in the last decade. The reactor is vulnerable to attack.
Does Comanche Peak have policies in place that ensure accountability of the security staff and that there is no nepotism.
- f. Sustainable energy is increasing productivity to meet the electricity needs of Texas Scoping should consider that there is no need for 20 more years of nuclear power.
Renewable solar and wind generation are the most affordable and safest way to meet energy needs without producing nuclear waste that could contaminate the area for thousands of years and need safe storage at an undetermined deep geological site. Texas has abundant renewable resources to use that is reliable and increasing in volume. Sustainable energy creates 25% of Texas energy now and continues to increase production and jobs. There is no need to lengthen the
time period for Comanche Peak to operate. Sustainable energy does not create high-level radioactive waste which needs a permanent deep geological storage site.
- g. An aging reactor creates more problems.
An old reactor structure of any kind tends to have more brittle metal, pipes, valves, all infrastructure, etc. creating more safety and security concerns. These issues raise questions about Comanche Peaks longevity and safety and should be investigated.
- h. Health impacts Address health impacts in the scoping process. Even small amounts of radiation release cause cancer, according to studies, and affect the animal life around the nuclear reactor. Periodic low-level releases of radiation should be investigated to determine the health effect on the area near and far. Even x-ray centers in clinics and hospitals have warning signs prominent to warn pregnant women of the danger. Animals in the area are affected by radiation releases and should be in the scoping process.
- i. Final points.
Please extend the deadline for intervention and host in-person meetings and hearings in Somervell County, Texas with NRC staff available to answer questions..
Additional high-level radioactive waste is a danger to public health and the environment and is not safe or cost-effective. Sustainable energy is reliable, safe, and more cost-effective than nuclear energy production.
Is the company prepared to address major costs to address the upgrades and replacements to meet current and future needs for updates, repairs, and replacements within the facility to ensure the safety of its operations?
Who will pay for the damage done if there is a nuclear accident?
Potential negative impacts of an accident and release of radiation are an injustice to the health of the people who live in the area and the environment. Reactors are known to have planned periodic releases of radiation without informing the
people who live nearby and far from the nuclear reactor. Children and pregnant women are particularly vulnerable to exposure to radiation but arent warned.
How can this be changed to alert the community members immediately of radiation releases?
Terrorists and radical groups are becoming more prevalent in attacking the U.S.
power grid, causing fires, long-term blackouts, and deaths. Experts fear that security is so poor at many points in the nation's sprawling network of transmission lines, transformers, and other critical nodes that terrorist groups could easily cause massive disruptions.
There is no need for an extension of the Comanche Peak Nuclear Power Plan due to the increase of affordable and sustainable energy created in Texas. Therefore, I oppose the proposed 20-year extension for Comanche Peak Nuclear Reactors and ask that you deny the re-licensing of the reactor. I also ask for an extension of the public comment period and public in-person hearings.
Thank you for reading this paper.
Sincerely, Susybelle Gosslee 9511 Faircrest Drive Dallas, Texas 75238 sgosslee@airmail.net 214-732-8610
Federal Register Notice: 87FR76219 Comment Number: 16 Mail Envelope Properties (8b850d83-2d96-c5ff-7901-8c0dcf1b79d8)
Subject:
[External_Sender] Comments to Regulation Government Document ID NRC-2022-0183-0003 Sent Date: 1/30/2023 3:35:43 PM Received Date: 1/30/2023 3:36:00 PM From: Susybelle Gosslee Created By: sgosslee@airmail.net Recipients:
"Susybelle L Gosslee" <sgosslee@airmail.net>
Tracking Status: None "Susybelle L Gosslee" <sgosslee@airmail.net>
Tracking Status: None "ComanchePeakEIS Resource" <ComanchePeakEIS.Resource@nrc.gov>
Tracking Status: None Post Office: airmail.net Files Size Date & Time MESSAGE 11321 1/30/2023 3:36:00 PM Testimony from me 23-1-17.docx 20728 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
I am Susybelle Gosslee, Dallas, Texas.
First, I am requesting transparency of all information and meetings held by the Nuclear Regulatory Commission. For example, this meeting does not allow the participants to see all the people participating in this zoom meeting. It gives the appearance that the NRC is trying to block important information from the public.
Please switch the meeting now so that everyone can see who is in this zoom meeting today and make every online NRC meeting totally public.
I also request that there be at least one in-person public hearing on the re-licensing of the Comanche Peak Nuclear Reactor.
Transparency is critical to ensuring that you, the NRC staff, follow good governance principles and democratic processes. We all, You and I both, have a responsibility as citizens of this country to ensure good governance.
The NRCs mission, as an independent agency of the United States government, is to fulfill its mission to protect public health and safety related to nuclear energy. It is created, as an independent agency by Congress, to ensure the safe use of radioactive materials for beneficial civilian purposes while protecting people and the environment. You are the oversight agency to protect the public.
Sustainable energy creates 25% of Texas energy now and continues to increase production and jobs. There is no need to lengthen the time period for Comanche Peak to operate. Sustainable energy does not create high-level radioactive waste which needs a permanent deep geological storage site. No permanent geological storage site is available.
Additional high-level radioactive waste is a danger to public health and the environment, is not safe or cost-effective. Sustainable energy is reliable, safe, and more cost-effective than nuclear energy production.
Therefore, I oppose the proposed 20-year extension for Comanche Peak Nuclear Reactors and ask that you deny the re-licensing of the reactor.
Other concerns are:
- In the beginning, Comanche Peak was delayed in starting operations, because of its inadequate construction, causing great expense to TXU. Examples are:
- 1. The steel frames supporting the steam pipes were hanging on lightweight steel frames that were very flimsy and bolted into the side of the concrete walls.
They were inadequate and had to be replaced, along with many other upgrades, thus delaying the projects opening. This caused increased costs. Through the years many of these have surely been replaced, but what about the other weak areas in a nuclear reactor? What is the plan to ensure the maintenance is properly done in a timely manner?
- 2. Pools to store the spent rods are lined with stainless steel, which is difficult to weld, and need to be 100% perfect. Originally, there was difficulty in making the pools secure. Considerable delay was caused by this issue. Has this issue been solved? Is a reactor really safe?
- 3. Valves always need to be checked and replaced.
- 4. An old reactor structure of any kind tends to have more brittle metal, pipes, infrastructure, etc. creating more safety and security concerns.
These issues raise questions about the Comanche Peaks longevity and safety.
In addition, other concerns are:
- Injection wells, horizontal drilling, and fracking throughout the state have been known to cause earthquakes. The large number of injection and horizontal wells surrounding the nuclear reactor creates more of a hazard for earthquakes which in turn creates more stress on the metal, the cooling pools, etc.
- A recent analysis of projected drought areas in the state identified Somervell County to have an extreme drought in the coming years. Access to water for a nuclear reactor is critical, but with little to no water, there is a potential problem. Droughts also increase the likelihood of fires in the area as have occurred in other areas of Texas and the U.S.
- Is the company prepared to address major costs to address the upgrades and replacements to meet current and future needs for updates, repairs, and replacements within the facility to ensure the safety of its operations?
- Potential negative impacts of an accident and release of radiation are an injustice to the health of the people who live in the area and the environment. Reactors are known to have planned periodic releases of
radiation without informing the people who live nearby and far from the nuclear reactor. Children and pregnant women are particularly vulnerable to exposure to radiation but arent warned.
- Terrorists and radical groups are becoming more prevalent in attacking the U.S. power grid, causing fires, long-term blackouts, and deaths. Although the recent attacks have been mostly small in scale, experts fear that security is so poor at many points in the nation's sprawling network of transmission lines, transformers, and other critical nodes that terrorist groups could easily cause massive disruptions even at Comanche Peak Nuclear Reactor.
There is no need for an extension of the Comanche Peak Nuclear Power Plan due to the increase of affordable and sustainable energy created in Texas. Deny the re-licensing of Comanche Peak Nuclear Reactor.
Thank you for listening. I will be sending written comments.
When construction on Comanche Peak began in 1974, TU Electric (the former name of EFH) estimated that it would take five years to build and cost $779 million. It took 15 years and $9.1 billion.
The construction took so long because some regulators and activists had safety concerns. TU was about to load fuel in 1984 when regulators stopped them. Engineers had to go back and tweak plans.
"There were days there in 1984, '85, I wasn't sure how long it was going to take to finish Comanche Peak," said Flores, who began working at the reactor site in 1983.
"Most of the [staff] of Comanche Peak believed we would operate the plant and that day would come."
When the plant finally got regulatory approval to fire up in 1990, Betty Brink, a member of a Fort Worth-based anti-nuclear group, Citizens for Fair Utility Regulation, predicted the plant would never operate at full power.
"If it does operate at full power for very long, I fear the worst for the area," she said at the time.
Brink said last week that she's happy she was wrong.
She continues to oppose nuclear plants because another of her predictions did come true:
Comanche Peak ended up storing nuclear waste long term. Without a permanent storage site in the U.S., nuclear plants might have to keep their waste forever in facilities designed for temporary storage.
"The waste is in the cooling ponds and the storage facilities, but it is there all these years later and still no place to take it. And with every passing year, the dangers increase for those who live around the plant because of the enormous amounts of this very toxic waste in their backyards,"
she said.
The band of activists who worked in the '70s and '80s to prevent nuclear power plants in Texas has shrunk.
"I think people were more aware at that time of the risks involved," said Hadden, who has fought nukes continuously. She said just because Comanche Peak hasn't had a serious accident doesn't mean the risk is gone. She also warns about cost escalation for the new reactors and finding a place to store nuclear waste for the long term.
"The promise of nuclear power, which sounds good on paper, is not reality," she said.