ML23129A122
| ML23129A122 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/29/2023 |
| From: | Hadden K Sustainable Energy and Economic Development Coalition (SEED) |
| To: | Office of Administration |
| References | |
| NRC-2022-0183, 87FR76219 02547 | |
| Download: ML23129A122 (1) | |
Text
SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: April 05, 2023 Received: January 29, 2023 PUBLIC SUBMISSION ADD: Tam Tran, Antoinette Walker-Smith, Ted Smith, Mary Status: Pending_Post Neely Comment (2547) Tracking No. ldi-a5rc-wdge 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-2547 Comment on FR Doc # 2022-27025 Submitter Information Name: Karen Hadden Address:
Austin, TX, 78748 Email: karendhadden@gmail.com General Comment Please extend the comment period and the deadline for requesting a public hearing and/or a petition to intervene regarding Docket ID NRC-2022-0183, the License Renewal Application for Comanche Peak Nuclear Power Plant Units 1 & 2.
I have tried to participate in the scoping meetings but have encountered numerous difficulties and frustrations. I have participated in many NRC proceedings in the past, on behalf of the non-profit organization, Sustainable Energy & Economic Development (SEED) Coalition, but have had more difficulty with this one than ever before. The timing of the notices, right at the start of the Christmas season was among the many problems. I wrote a complaint, along with a request for investigation to the NRC Office of the Inspector General, which I will attach here. It details many of the problems and frustrations I've had, as well as others who are concerned about the license extension. I know that at least one Congressional Representative, Lloyd Doggett, has made a request to extend the deadline, and hope you will take action. Extending the deadline would be only fair under the circumstances. With the current deadline of Jan. 20, 2023, I ask that you please let me know right away of your decision, as I may choose to petition to intervene. Thank you, Karen Hadden, SEED Coalition, Austin, TX 78748.
Attachments Complaint - regarding Comanche Peak LRA file:///nrc.gov/...omments/NRC-2022-0183%20NEW/NRC-2022-0183%202023-04-05%2010-26-49_docs/NRC-2022-0183-DRAFT-2547.html[4/6/2023 1:43:58 PM]
From Karen Hadden, SEED Coalition Re: Docket Nos. 51-0445 and 50-446 Comanche Peak Nuclear Power Plant Units 1 & 2, re-licensing application / inadequate public process
Dear Sabrina Allen and Office of the Inspector General,
I tried to submit this through the NRC Office of Inspector General portal late on January 17, 2023, but it apparently did not go through. Your help is appreciated.
As director of the Sustainable Energy & Economic Development (SEED) Coalition, based in Texas, I work on nuclear issues and education, coordinating with concerned citizens and media representatives.
So far, the NRC administrative process for the public meeting for Comanche Peak license extension has been appalling and unfair to the public at every turn, with last minute changes and inadequate notice. It has been hard enough for people with computer skills and equipment, including myself and numerous others, to participate. Those with fewer resources and language barriers have had no voice whatsoever.
Please investigate the due process problems relayed here and whether open-meeting criteria were met.
Please press those involved to hold at least in-person public meeting, in the evening, and to extend the deadline to request a hearing for 90 days past the Jan. 30 deadline. The Federal Register notice came out on December 1st, the start of the holiday season, when few people were likely to see it and be able to respond. It takes a fair amount of time and effort to arrange attorneys and expert witness testimony, especially during the holidays.
Two public meetings were originally scheduled for January 10, 2023, one in the afternoon and one in the evening. Many people put this on their schedules and were ready to attend, including local residents.
Others made travel arrangements and hotel reservations. On Friday, January 7, 2023, a reporter told a concerned citizen that NRC had rescheduled the Jan. 10th meeting, the first anyone had heard of this, including myself. I called NRC offices and couldn't get anyone. I finally reached Victor Dricks of Region IV in the evening. He said the NRC had tweeted a message, which is not adequate public notice. I hadn't realized I had to follow the NRC on Twitter to get basic news from the federal agency. Mr. Dricks also said that the meeting change would be announced on Monday in a press release. I looked all day Monday on the website for this release and it finally appeared at 4 PM for a meeting starting at 1 PM the next day.
This is very inadequate notice, and instead of in-person meetings, four hours of meeting time got condensed into a webinar with only two hours, cutting out the opportunity to participate for anyone who couldn't get away from work in the daytime due to work or school. Dricks said that the reason for this change was high Covid rates in Somervell County, but I have seen no evidence of any official notice to this effect, and local businesses tell me that nothing was shut down during this time frame, including schools, restaurants and offices. County data shows no new cases during the timeframe. While caution about Covid makes sense, in this case, it appears to be a lame excuse.
I subsequently registered early for the Jan. 17 meeting so that I could be sure to get the full information, be able to participate and let others know about the online meeting. I spent a great deal of time reading as much as I could of the 2200 page application document and researching topics I wanted to comment on. I wanted to make the most of the 3 minutes or so I would be given.
It was very difficult to get on to the Jan. 17 Microsoft Teams meeting - for me and for many others, most of whom are computer literate. Speakers were called upon numerous times who would raise their hands in the webinar but could not be heard. This happened in the Q&A session to about six speakers, including myself. A staff person for the NRC said something to the effect of "oh, not this Microsoft Teams problem
again." I never got to ask the questions that I had, as did others who were not able to answer when their name was called.
I spent most of the remaining 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> trying to raise my hand and get recognized, making it difficult to fully concentrate on what the speakers were saying. Meantime, the facilitator moved right on from Q&A without resolving the problem, to comments, leading off with the local judge and two proponents he'd brought in. They spoke at length, making unrelated comments that had nothing to do with scoping, but using up valuable time. Speakers were called upon several more times whos couldn't get their microphones to work. An announcement was made about how to turn your microphone on, which involved checking settings and clicking on the microphone icon. I did that numerous times. It did not work, and it did not work for several others. The microphone was not active so nothing happened when the icon was clicked, even when I was unmuted by the NRC facilitator, I have been able to get on several other NRC meetings and never had this problem, using the same settings on my computer.
Announcements had to be made numerous times about how to be able to be heard, taking up more of the valuable remaining time. Then was suggested that people who couldn't get on should try to call in instead of using their computer. I did that and could hear, but when I pressed Star 5 as instructed, I still could not get recognized to speak. I tried numerous times and "raised" my hand in the video as an additional to attempt to be called upon. Two others that I know of had this experience as well. I texted people to ask on my behalf that I be acknowledged, hoping maybe the phone would allow access, as opposed to the computer. Paul Gunter made that request, but the facilitator couldn't find me on their phone list. This is stange, because I believe that phone numbers were gathered as part of registration.
It is really infuriating to try for two hours to get in on a supposedly public meeting. I believe the Microsoft Teams software and / or meeting facilitation is to blame. Again, I have not had a problem being heard on other NRC meetings, although access is typically challenging. Others I know of that were unable to be heard include Former State Representative Lon Burnam of Ft. Worth, Texas, Tom "Smitty" Smith, Leona Morgan and Jan Boudart. I saw raised hands from some of them on several occasions.
Again, we were told several times to click the microphone icon on the computer screen to be able to speak, which would happen after someone from the NRC unmuted us. I tried to do this (repeatedly) and the icon would not click. It was not lit up like the camera icon, and was unresponsive. I believe this is a problem on the NRC end of things, not with my computer, especially since my computer was fine with the same settings on other NRC webinars.
The end result is that several of us were denied what is currently the only public scoping meeting opportunity available for a major action that is of great concern to me and others, one which will have impacts on public health, safety, security and financial health.
I would still like to request (1) real public meetings, held in-person so that you can see who is speaking and the faces of NRC representatives, unlike much of the Jan. 17 online meeting. At least one should be held in the evening so that families and those who work or go to school in the day can participate.
- 2) a 90-day extension from the January 30 deadline for the opportunity to intervene. The December 1, 2022 Federal Register notice did not provide adequate time to prepare for submitting requests for a hearing, especially since it came at the start of a holiday season. For me I was preparing for her arrival and then spent a month caring for my elderly mother, which is wonderful but time intensive. There was little time left to focus on the issue of Comanche Peak re-licensing. Attorneys and expert witnesses were hard to reach during this time period. Then, the rescheduling of public meetings took up a great deal of time, figuring out what was actually happening and getting the word out.
The public deserves better and Open Meetings Act policies should be followed. The licensing of nuclear reactors to operate twenty additional years is an important matter. Incorrect information had to be corrected in the printed material presented during the webinar. A wrong date (January 27) was given on the slides for requesting a hearing, which should have been January 30th. No mention was made of the fact that it can take ten days to get the digital ID needed for legal filings.
These meetings appear to have been rushed. It also appears that the NRC is afraid to meet with members of the public in-person, and that every opportunity is being taken to cut out public participation. Rushing this process is ridiculous since the reactors are licensed until 2030 and 2033. An aging management study of Comanche Peak is underway now, and it would be good for the public to be able to have that information to comment on for the scoping process. Re-licensing the plant seems inadvisable due to the extent of aging impacts. Repairs and replacement may be exceedingly expensive.
I will also be submitting comments in writing, but online webinars are not an adequate replacement for oral comments and real public meetings.
Please investigate the fact that NRC was unable to hear from people who were present and wanted to comment in the Jan, 17th online "public meeting." It has been my experience that many NRC meetings have technical glitches and sometimes facilitation problems, but this is the most egregious yet.
Please recommend immediately that the NRC host an additional in-person evening scoping meeting near the reactor community and that the deadline to request an intervention be extended 90 days. I look forward to hearing from you.
Thank you, Karen Hadden SEED Coalition, karendhadden@gmail.com