ML23137A261
| ML23137A261 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/2023 |
| From: | Gosslee S - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2022-0183, 87FR76219 02576 | |
| Download: ML23137A261 (1) | |
Text
file:///nrc.gov/...omments/NRC-2022-0183%20NEW/NRC-2022-0183%202023-04-05%2010-26-49_docs/NRC-2022-0183-DRAFT-2576.html[4/6/2023 1:45:38 PM]
PUBLIC SUBMISSION As of: April 05, 2023 Received: March 13, 2023 Status: Pending_Post Tracking No. lf7-97vo-mcoc Comments Due: March 13, 2023 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-2022-0183-0248 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-2576 Comment on FR Doc # 2023-03668 Submitter Information Name: Susybelle Gosslee Address:
- Dallas, TX, 75238 Email:sgosslee@airmail.net Phone:214-732-8610 General Comment See Attached Document:
Attachments Testimony By Susybelle Gosslee to NRC in Glen Rose 23-2-23 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Tam Tran, Antoinette Walker-Smith, Ted Smith, Mary Neely Comment (2576)
Publication Date: 12/13/2022 Citation: 87 FR 76219
Comments on the Comanche Peak Nuclear Reactor Environmental Impact Review Docket ID: NRC-2022-0183 Office of Administration Mailstop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 I am Susybelle Gosslee. I thank you for accepting my comment on the Environmental Impact Study on Comanche Peak Nuclear Reactor.
The re-licensing decision concerning the Comanche Nuclear Reactor should be made after a full evaluation, not before a full evaluation is made of all aspects of the reactor and its on-and off-site systems, structures, threats, and management, to avoid a crisis, protect the publics health and the environment.
The Nuclear Regulatory Commission staff and Board of Directors should be aware that they are so close to the industry that there is a strong possibility of Confirmation Bias in the evaluation of the Comanche Peak Nuclear Reactor and all radioactive information for the EIS. Confirmation Bias is a tendency to listen more often to information that confirms existing beliefs. Because of this bias, people tend to favor information that reinforces the things they already think or believe.
Examples include:
When it comes to confirmation bias, there are often signs that a person is inadvertently or consciously falling victim to it. Unfortunately, it can also be very subtle and difficult to spot.
Some of these signs that might help you identify when you or someone else is experiencing this bias include:
Only seeking out information that confirms your beliefs and ignoring or discrediting information that doesn't support them.
Looking for evidence that confirms what you already think is true, rather than considering all of the evidence available.
Relying on stereotypes or personal biases when assessing information.
Selectively remembering information that supports your views while forgetting or discounting information that doesn't.
Having a strong emotional reaction to information (positive or negative) that confirms your beliefs, while remaining relatively unaffected by information that doesn't.
Types of Confirmation Bias There are a few different types of confirmation bias that can occur. Some of the most common include the following:
Biased attention: This is when we selectively focus on information that confirms our views while ignoring or discounting data that doesn't.4 Biased interpretation: This is when we consciously interpret information in a way that confirms our beliefs.
Biased memory: This is when we selectively remember information that supports our views while forgetting or discounting information that doesn't.
(Source: https://www.verywellmind.com/what-is-a-confirmation-bias-2795024)
In addition, almost everyone at every level of the research and evaluation of the Comanche Peak Nuclear Power Plant should be aware that: It is difficult to get a man to understand something when his salary depends on his not understanding it, states Upton Sinclair.
NRCs PUBLIC COMMENT AND MEETING PROCESSES The NRAs public comment process has not been adequate to fully meet the obligation of a public process and needs to be improved. The public meeting for Comanche Peak was totally inadequate and did not follow the principles of good government, or show accountability or transparency. An agency in a democratic government should have full disclosure.
Information about in-person and online meetings about the Comanche Peak Nuclear Reactor license review process has not been well publicized to inform the public about the process or invite the public to the Nuclear Regulatory Commission in-person or online meetings.
The NRCs publicity has not been done in a thorough manner in many broadly read publications or throughout the area counties where the Comanche Peak is located, to a broad population in Texas and elsewhere, and to be stated clearly for the general public to understand.
When the last online internet meeting was held, many people could not enter it to participate. An additional and considerable barrier in Texas is that twenty percent of the population does not have access to the internet. Media with a large readership needs to be used to communicate with the greatest number of people who are and will be affected by the reactor. In actuality, the whole state of Texas could be affected financially and environmentally, and the publics health could deteriorate if there is an accident. The Office of the Federal Register is not a good source of communication, except to certain audiences. The entire public should have access to information about meetings, the process, and to ask staff questions. The Register is unknown to most people in Texas. It is an inadequate notice location to invite the public to participate in a democracy and gives the appearance that the NRC is trying to hide the notification where the public should be informed and participate. Public participation, transparency, and accountability are key elements of Good Government and Making Democracy Work.
The Principles of Good Government should be met and include the following:
- 1. Participation, i.e., community participation in decision-making processes, freedom of association and opinion, and freedom to participate.
- 2. The rule of law, i.e., the law must be fair, indiscriminate, enforced, and adhered to, especially the rule of law on human rights.
- 3. Transparent, i.e., the freedom of the flow of information in various institutional processes must be easily accessible.
The NRCs meeting notices are basically hidden. Both the afternoon and evening public meetings were scheduled 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. The NRC took much of that time providing inadequate and incomplete information as if they were checking off some box as a public meeting being accomplished. Everyone cannot access online meetings, so meetings should be public, in-person meetings. There were poor exhibits that do not inform the public about the industry or about the NRC. Opportunities to speak directly with NRC staff at the in-person evening meeting.
EMERGENCY PROCEDURES AT THE REACTOR AND IN THE SURROUNDING AREA OF THE COUNTY AND NORTH TEXAS An investigation and written report should be done on the emergency procedures at the nuclear reactor and in the surrounding area to prepare for an accident or an intentional attack by foreign or domestic terrorists. All safety equipment should be in the report with results of tests and the history of investigations, including the technological, fire, flooding, tornado, or other extreme wind and water events, physical crashes into and on the site, and infiltration of the reactor and technology systems should occur. All safety systems and all safety manuals should be reviewed and updated with more best practices added to the safety equipment and manuals.
The NRC investigations should take place with additional ongoing training of personnel that should be documented in the report, and continually reviewed, updated, and reported. Usually, improvements and adjustments to emergency plans are made after an accident; however, after an accident is totally inadequate in the case of a nuclear accident or intentional attack on the reactor.
With technological advances developing rapidly, many new systems and threats will be developing. How will the existing reactor structure and systems be able to respond to these threats and opportunities rapidly, efficiently, and with the least amount of harm?
EMERGENCY PROCEDURES IN NORTH TEXAS The NRC staff should investigate the emergency equipment, resources, personnel, and emergency plans throughout the region. Texas A&M trains emergency personnel throughout the state of Texas. They should be contacted about what they do to train the emergency staff at the Plant and a report written and added to the EIS. Public emergency procedures in Texas are organized at the local, county, and state levels. Much of Texas emergency systems are volunteer and depend on contributions to operate and the use of retired equipment from the larger cities.
The equipment and personnel are limited by budget constraints at every level. Texas largest cities have the most equipped departments and trained personnel. The closest large city is Fort Worth which is located forty miles away if there is no traffic.
DEVELOPMENT OF FUTURE ARTIFICIAL INTELLIGENCE SYSTEMS AND TECHNOLOGY The NRC staff should be aware that Artificial Intelligence is a factor that needs to be researched. A.I. experts were asked in a 2022 survey, What probability do you put on human inability to control future advanced A.I. systems causing human extinction or similarly permanent and severe disempowerment of the human species? (Source:
https://www.nytimes.com/2023/03/12/opinion/chatbots-artificial-intelligence-future-weirdness.html)
The NRC staff will have difficulty determining how to address the A.I. advancements without consulting with those experts. There is enough foreign and domestic danger that needs to be documented, understood, and reported in the EIS report with continuous updates and training.
Existing internet and foreign and domestic terrorists should be investigated and included in the findings of the EIS report.
There are others who have malicious intent and are working for the destruction and/or takeover of the United States. There are some tech researchers in the Bay Area of California who are working on a technology that has a 10 percent chance of wiping out humanity, according to technology experts in the linked article. The NRC should do research with highly knowledgeable people in the A.I. field to identify the risks to Comanche Peak Nuclear Reactor and all other American reactors. The research findings should be in the EIS report. (Source:
https://www.nytimes.com/2023/03/12/opinion/chatbots-artificial-intelligence-future-weirdness.html)
ECONOMIC IMPACTS The NRC should have a thorough investigation and provide a report of the current and future economic impacts on the communities, the area counties surrounding the reactor, at least one hundred miles from the Reactor, including the northeast corner of Texas. An additional study should include the economic impact on the area if there is an accident or if it is infiltrated or attacked by extremists from the ground or air. The whole area of the state, public health, the environment, and the Texas economy will be affected and should be studied. The report should include the effect of all kinds of accidents on the surrounding states, and identify who will pay for the damages.
HEALTH RISKS The NRCs EIS report should include the health risks to employees and to the members of the communities surrounding the Comanche Peak Nuclear Reactor. The NRC staff should do an analysis of childhood leukemia cases near the reactor. The International Journal of Cancer established a causal link between the higher incidence of leukemia and living near nuclear power plants in France. (Source: https://www.reuters.com/article/nuclear-leukaemia-france-idUSL6E8CB5QY20120111#:~:text=The%20study%2C%20conducted%20by%20the%20Frenc h%20health%20research,2%2C753%20cases%20were%20diagnosed%20in%20the%20same%2 0period). The study found that between 2002 and 2007, fourteen children under the age of 15 living 5-kilometer radius of Frances 19 nuclear power plants had been diagnosed with leukemia.
This is double the rate of the rest of the country during the same period of time.
Because Comanche Nuclear Power Plant has been in operation for many years, the NRC staff should research childhood leukemia and other forms of cancer of all people living within a 5-kilometer radius of the reactor. Additional research should be done on the health outcomes of all past and current employees and their family members living in nearby communities. The 1990 U.S. National Institutes of Health-National Cancer Institute and the May 20212 report are
old and need to be more current to make a determination of risks to health. Technology is now available to perform a better analysis of cancer risks with larger populations now in the area and for those who have moved away from the area.
The EIS should include different processes and educational tools to inform the public about the health risks they face because of living near a nuclear reactor. The public is not informed of the radiation releases, though the NRC does get notification. The company, Vistra, has chosen to take profits as a priority over the health of the public. The risks faced by the public and opportunities for safer jobs could be available to the public if Vistra chose to switch to sustainable energy.
The Comanche Peak Reactors employees testified at the short meeting at the Glen Rose community center that the plant was clean. Their statements indicated that they thought it was well-swept and the bathrooms were clean. However, the public should be well-informed and understand that low-level radioactivity and high-level radioactivity at the reactor are dangerous and have health impacts that could cause cancer, and end their life, the lives of their family members and friends.
The EIS should include a plan to inform the public about the Environmental Impact Statement and its findings, including health outcomes.
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT Key data points are in the Annual Radiological Environmental Operating Report (https://www.nrc.gov/docs/ML2211/ML22118A088.pdf). This data should be included in the EIS Environmental Report/license Renewal application, and all Plant reports should be verified. CPNPP Technical Specification 5.6.2 and the CPNPP Offsite Dose Calculation Manual should be reviewed and analyzed to determine if all the past problems were addressed. This report covers the period from January 1, 2021, through December 31, 2021, and summarizes the results of measurements and analysis of data obtained from environmental samples collected during this same timeframe. When the January 1, 2022, through December 31, 2022, is released, it should be evaluated and a report written and made available. The two reports should be evaluated as to the progress made at the reactor plant. Copies of all reports should be given to the area County Judges and Commissioners and members of all the area city councils and placed in local libraries.
WASTE STORAGE AND TRANSPORTATION RISKS The NRC staff should investigate and report in the EIS the increased risks and costs of packaging and transporting all the radioactive waste and construction and building materials produced and used at the Plant, and transportation of all the radioactive waste produced and used at Comanche Peak Nuclear Reactor at the end of the first licensing period.
A second analysis should be made of the increased risks and costs of packaging and transporting all the radioactive waste and construction and building materials produced and used at the Plant, and transportation of all the radioactive waste produced and used at Comanche Peak Nuclear Reactor at the end of the 20 additional years of operation of the Plant. The EIS should recommend that Vistra pay for all these costs and take full liability at all stages of the operation.
There currently is no off-site permanent storage facility, and there is a proposed temporary storage site for high-level radioactive waste with the licensing waiting for a decision.
At the end of the life of Comanche Peak Reactor, the Plant will be shut down and decommissioned. If the high-level and low-level radioactive waste is transported to another temporary or permanent storage site, the EIS should evaluate the quality of the train cars and tracks to determine if they are fully capable of carrying the heavy loads, to determine if the safety equipment is sufficient, and trained personnel will work on the decommissioning process.
The transport of materials should not be transported if the rail system is inadequate.
The EIS should evaluate the expected amount of low-level and high-level radioactive waste at the end of Vistras 30-year license and the amount of low-level and high-level radioactive waste at the end of an additional 20 years of operation.
The EIS should evaluate and reveal the costs of temporary and permanent storage and transportation of the waste when the reactor is shut down. Another analysis should be made of the cost of keeping the high-level and low-level radioactive waste on the CPNPPs existing site.
In addition, the EIS should evaluate how Vistra will pay their Somervell County taxes when the plant is shut down during the next thousands of years of storage in the county. The County will have lost the use of the land where Comanche Peak Nuclear Power Plant is located.
The EIS should evaluate the amount of money that needs to be paid to ensure that there is enough assurance money. Vistra should pay the full number of assurances every year to ensure that the funds are available to cover the total costs of the decommissioning process and to cover all costs of an accident.
Another cost is repackaging the existing and the additional waste to ensure that people and the environment are safe. The NRC staff should do this analysis and put the information in the EIS. The company, Vistra, must demonstrate its intention of paying for the repackaging or re-containerizing of the waste in perpetuity. The EIS should evaluate Vistras well-thought-out and financed plan for transitioning to shut the plant down if it closes in 2030 or after additional 20 years. Since the company created and profited from the waste, they are responsible for how to secure and store it. There is no permanent storage site for high-level radioactive waste, so the production of more waste should be stopped and not dumped into the world with no safe place for it to be stored for longer than human beings have been on the earth.
The high-level and low-level radioactive waste will eventually be placed in a storage site.
No permanent radioactive waste storage site has been identified. The temporary storage site that has been identified is located in Andrews County. The site will have waste in casks that leak, according to the NRC website. The Andrews County, Texas site does not provide the best-practice method of storage for high-level radioactive waste. The casks will be placed on top of the ground, not in deep geological formations, as is best practice. Since the site is on the surface, it is accessible and vulnerable to sabotage. Because many saboteurs have access to high-powered weapons, drones, and airplanes, there is no guarantee that the transportation routes or the storage site will be safe or last forever. Everyone along the transportation routes and near the nuclear reactors is and will continue to be placed in danger so that a few men at the top of the company will be rich and shareholders will be paid. That risk is too high for most people, especially if they
know the risks of nuclear energy, waste, and reactors, both in operation and after the closure of the reactor. Repurposing a reactor is not an option at this time and probably will never be an option.
Storage of high-level radioactive waste on the reactor site is less risky than being transported and stored at the Andrews County site which is run by Waste Control Specialists (WCS). How much will this cost? Transportation of high-level radioactive waste is risky by train as is demonstrated in the East Palestine, Ohio train accident on February 3, 2023. For example, better braking systems for trains carrying hazardous materials were overturned during the last Presidential Administration. Other deregulatory measures were put in place that made railroads less safe for the public, the economy, and the environment, and made railroads more profitable and less safe.
Future generations will be paying for the high cost of high-level radioactive waste for thousands of years. What will they be saying about the short-sighted NRC staff who approved the re-licensing of the power plant and Vistra which created the dangerous material they and their children have to deal with in perpetuity?
INCREASED SAFETY AND FINANCIAL RISKS Scoping should investigate the safety and financial risks of the continued operation of the Comanche Peak Nuclear Reactor in the area. Accidents cost money and sometimes lives. What additional safety and financial procedures should be developed to allow another safe 20 years of Comanche Peak Nuclear Reactor operation? Risks from stress corrosion, cracking, metal fatigue, and embrittlement could all increase, thereby potentially increasing accident and financial risks, and the potential radiation releases. Everything at the Comanche Nuclear Power Plant should be inspected, to ensure its excellent operation.
Technology has advanced. What improvements should the company make in its technology to increase security and efficient operation of the Plant and at what cost? The EIS should evaluate and have this information in its report.
There are 7.76 million residents in nearby Dallas/Ft. Worth. Public health and safety should come first in the re-licensing decision.
Scoping should consider that there is no need for 20 more years of nuclear power and the nuclear plant in the area. Renewable solar and wind generation are the most affordable and safest way to meet Texans energy needs WITH NO HAZARDOUS WASTE. Texas has abundant renewable resources to tap and a grid to move the power as needed. Problems of nuclear reactors include radiation-releasing nuclear accidents, the problems of radioactive waste disposal, and the possibility of contributing to nuclear weapon proliferation, causing financial risks.
INCREASED SEISMIC RISKS TO THE REACTOR, SQUAW CREEK RESERVOIR, AND THE DAM Seismic concerns of both the reactors and the Squaw Creek Reservoir need to be re-examined in light of recent earthquakes, drilling, and fracking activity nearby. Comanche Peak is within the Barnett Shale, a region with extensive fracking and numerous injection wells. There
are fault lines in the area and a magnitude 3 earthquake had its epicenter only 20 miles from the site. The integrity of the earthen dam must be included in the scoping, including the past and anticipated future impacts on the dam from past, current, and future seismic activity. Drilling with hydrofracking is close to the nuclear reactor. The EIS should have a thorough investigation of the effect of earthquakes and oil and gas drilling in the area, coupled with the drought conditions.
The erosion on the dam is evident from miles away. This erosion should be repaired immediately. Since the erosion is so evident, it appears that Comanche Peak Nuclear Reactor personnel are not ensuring the safety of the dam or the people in the area. This should be documented with pictures and other inspections of the quality of the dam.
WATER AND DROUGHT RISKS Water should have a thorough investigation in the environmental impact statement. The nuclear reactor plant relies on Squaw Creek Reservoir for cooling water. The reservoir water contains radioactive tritium, and The majority of Texas is currently experiencing a drought that started in October 2010.
Most of the state has been under drought conditions for over three years. The Chalk Mountain Fire, in Somervell County, destroyed sixteen homes, damaged five others, and burned an estimated 6,339 acres during the summer of 2022. According to drought.gov USGS Earthquake data current to Revised Map of Texas Earthquakes by Jerry 01/06/20 Base Map is Geological Map of All of the mapped area is in Barnett 2
5 10 0
Comanche Peak Reactor Magnitude/Dat M 3.3 M
07/28/20 M
06/04/20 M
06/29/20 M
06/26/20 All other small red M 2 0 to 6 /07/2009 11/12/201 Coupled with 5 quakes in 2012 that approximately 20 miles from Comanche there are more 8 additional quakes curred June 2009 November Closest Earthquakes to Comanche Peak Reactor Site
(https://www.drought.gov/states/texas/county/somervell), one hundred percent of the people in Somervell County are affected by drought. The Paluxy River which flows through Glen Rose dried up almost entirely in most parts of Dinosaur Valley State Park revealing 113-million-year-old dinosaur tracks in August 2022.
Comanche Peak is dependent on water. What is the proof that water will be in the area for use by the nuclear plant, agriculture, and the people in the area for the next 30 years and beyond when the area has been in drought for years in the past? Projections are that the area will be in drought for many years. What is the plan for the Reactor when there is little or no water in the future?
Links to U.S. Drought Monitor: (https://droughtmonitor.unl.edu/CurrentMap.aspx https://www.drought.gov/states/texas)
AIR QUALITY RISKS The EIS should investigate the air quality in and around the Comanche Peak Nuclear Power Plant. While nuclear reactors dont produce air pollution, such as carbon dioxide while operating, there are periodic radiation releases from Comanche Peak. In addition, the processes for running a nuclear power plant do create pollution and contaminants. Mining and refining uranium ore and making reactor fuel all require large amounts of energy. Nuclear power plants also have large amounts of metal and concrete, which require large amounts of energy to manufacture. If fossil fuels are used for mining and refining uranium ore, or if fossil fuels are used when constructing the nuclear power plant, then the emissions from burning those fuels could be associated with the electricity that nuclear power plants generate, reports the U.S.
Energy Information Administration. (https://www.eia.gov/energyexplained/nuclear/nuclear-power-and-the-environment.php) Cement batch plants are a very large emitter of pollution:
particulate matter, greenhouse gas emissions directly and indirectly, CO2 emissions, etc.
Nuclear power plants have routine releases of radiation into the air. They are called planned releases. The NRC relies on self-reporting and computer modeling by each reactors operator in an attempt to track radioactive releases and their projected dispersion. When the planned release of radiation is emitted into the air, some fall into the water and on the soil.
FIRE AND TORNEDO RISKS The EIS should evaluate the old reactor equipment that could lead to fires at the reactor and demand that it be replaced before an accident. One of the Comanche Peak nuclear power plants two units was offline for more than a week following a June 7, 2022, fire in the main transformer, putting pressure on the Texas power grid and contributing to a week for statewide conservation. (As sustainable energy increases, nuclear energy will become less relevant.) On June 7 around 3:30 p.m., the fire was extinguished within around twenty minutes without major injuries. The fire took place in the plants main transformer, which is located outside of the buildings that house the pressurized water reactors.
With increased droughts, the land around Comanche Peak could become a grass fire with sparks even flying from trucks on the road that could spread for miles in any direction depending
on the wind. The wind often shifts in Texas, which has caused people to be encircled in fire and burned to death.
Texas is part of the Tornado Alley section of the U.S. The state experiences the most tornadoes in the nation, averaging 132 per year. North Texas and the Panhandle have the most tornadoes. They appear most often in the late spring and early summer months between 4 and 8 p.m. There have been 8,007 funnel clouds between 1951 and 2011. There were 232 tornadoes recorded in 1967. Tornadoes have occurred also in the winter.
OPERATING LICENSE FOR COMANCHE PEAK NUCLEAR REACTOR I urge the NRC staff to think outside the box in evaluating and reporting on Comanche Peak Nuclear Reactors EIS. The world of technology is changing rapidly, and changes in the climate in Texas are evident. Cyber and physical attacks have been on the power grid and infrastructure from foreign and domestic extremist groups and terrorists. Some news reports identify neo-Nazis and white supremacists who now represent the most significant terrorist threats to the U.S. The indication is that there is normal wear and tear of equipment and systems at the plant in addition to the threat of terrorists.
Concerns rise that if these trends continue, the future is not completely known. What will the future be like in the next 20 years and thereafter? Technology creates a different dynamic that raises a different set of questions when re-licensing Vistra to extend the operating licenses for the Comanche Peak Nuclear Power Reactors Units 1 and 2 for an additional 20 years. There are other options to create energy. Sustainable energy could be another option for Vistra.
The reason for permitting and re-licensing is to protect the public health, safety, security, environmental, and financial health of the area near the reactor and throughout Texas. The regulations require that nuclear power plants be designed, constructed, and operated to keep levels of radioactive materials in effluents to unrestricted areas as low as reasonably achievable (ALARA); yet, Comanche Peak has not met this standard. Nuclear power plants conduct both controlled and uncontrolled releases of radiation as one example. High-level radioactive waste is another tremendous hazard.
The reactors should retire as originally licensed and as planned. They were built to last for about 30 years which would be on or before 2030 and 2033. Quality assurance, accountability, and high cost remain to be significant issues. Sustainable energy now provides 45% of Texas energy at a lower cost per kilowatt hour and does not have extremely dangerous high-level radioactive waste that has to be stored for thousands of years in deep geological formations. No permanent deep geological site has been identified since the 1940s, and most community members do not want it in their areas.
DIVERSIFICATION TO SUSTAINABLE ENERGY IS LESS RISKY AND CREATES JOBS The NRC should investigate the cost of Vistra transforming into sustainable energy.
There are many good jobs are in the sustainable energy industry which does not have radiation emitted into the air, radioactive waste, or risks of a nuclear accident. Comanche Peak Nuclear Reactor is not the only opportunity to create jobs in Somervell County. Vistra has an option of recreating itself in the renewable energy field during the next ten years during which the reactor
should be retiring. People who live in the area near the reactor can get jobs in the sustainable energy industry which has no dangerous waste, produces energy at a lower cost and is safer for the whole community. One difference is that there is no hazardous waste going into the air, soil, or water with the creation of sustainable energy and there is money to be made with sustainable energy.
Subsequent license renewals cover a further 20 years of operation beyond 60 years and focus on the management of plant aging during the 60-80-year operating period, especially the effects of extended operation and high radiation exposure on reactor parts, concrete containment structures, piping, and electrical cables, among other things.
LOBBYING BY VISTRA AND THE INDUSTRY The nonpartisan, independent nonprofit, The Center for Responsive Politics -
OpenSecrets, is the U.S. premiere research group tracking money in American politics and its effect on elections and public policy. Their mission is to track the flow of money in American politics and provide the data and analysis to strengthen democracy. Vistra and other nuclear industry companies lobby spending may go up and down depending on the legislation in Congress each year. In 2020, Vistra spent $690,000 for lobbying expenditures. In 2022, Vistra spent $510,000 in the first quarter, 310,000 in the second quarter, $270,000 in the third quarter, and $220,000 in the fourth quarter.
https://www.opensecrets.org/federal-lobbying/clients/summary?cycle=2020&id=D000068592 The purpose of lobbying is to influence an action. In the context of government, lobbyists work on behalf of third parties to influence whether a politician will steer a bill in a certain direction, create a particular piece of legislation, or perhaps overturn the existing policy. They are lobbying to argue their own beliefs and political views.
(https://study.com/academy/lesson/lobbying-definition-purpose-methods.html) The companys interest is to make money not to protect the people or the environment.
The mission of the Nuclear Regulatory Commission stated on its website is:
The NRC licenses and regulates the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and to protect the environment.
CLOSING Glen Rose, Somervell County, and all of this area of the state are beautiful with a rich history going back centuries and into millennia. Everything works until it doesnt, as was seen with the East Palestine, Ohio train wreck. Systems were deregulated in the railroad industry and shortcuts were taken. Less oversight created more profits, but the people did not profits. They have been devastated by the calamity. Accidents happen all the time.
The longer Comanche Peak Nuclear Power Plant operates, the risk of accidents increases.
Already, radiation releases are emitted and have been emitted into the air in the area. Do the people in the area know about those emissions and the risks they face due to the emissions?
The water in Squaw Reservoir is polluted. Do the people in the area know that?
The dam shows erosion that can be seen from a distance. Do the people in the area know that?
An accident happened in East Palestine, Ohio, and at Fukushima, even though many knowledgeable experts warned of a potential accident. Are the experts being heard?
Norfolk Southern, the owner of the train that wrecked in Ohio, advocated for lowering the safety measure and regulations, knowing that they were taking risks, but their profits went up. Vistra also has advocated for lowering standards and regulations.
It is difficult to get a man to understand something when his salary depends on his not understanding it, stated Upton Sinclair states.
I urge the staff at the Nuclear Regulatory Commission to do their research with integrity and in the interest of the Common Good of all people, to protect public health, the environment, and the economy in this area and in the Southwest.
I urge you to reject the application submitted by Vistra to extend the operating licenses for the Comanche Peak Nuclear Power Reactors Units 1 and 2 for an additional 20 years. My research indicates that Comanche Peak Nuclear Reactor should not have its operating license extended by 20 years to ensure the safety of the people in this area and the state of Texas.
Thank you for reading my remarks.
Susybelle L. Gosslee 9511 Faircrest Drive Dallas, Texas 75238 214-732-8610 sgosslee@airmail.net Link: https://www.nrc.gov/docs/ML2227/ML22276A082.pdf