ML14041A118

Issuance of Environmental Scoping Summary Report Associated with the Staff'S Review of Application by Tennessee Valley Authority for Sequoyah Nuclear Plant, Units 1 and 2 (Tac Nos. MF0057 and MF0058)- Page Continue

ML14041A118
Person / Time
Site:	Sequoyah
Issue date:	04/24/2014
From:	Brian Wittick License Renewal Projects Branch 2
To:	John Carlin Tennessee Valley Authority
Drucker D
Shared Package
ML14041A118	List: ML14041A118
References
TAC MF0057, TAC MF0058
Download: ML14041A118 (143)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 24, 2014 Mr. John T. Carlin Site Vice President Sequoyah Nuclear Plant, Units 1 and 2 Tennessee Valley Authority P 0 Box 2000 Soddy-Daisy, TN 37384

SUBJECT:

ISSUANCE OF ENVIRONMENTAL SCOPING

SUMMARY

REPORT ASSOCIATED WITH THE STAFF'S REVIEW OF THE APPLICATION BY TENNESSEE VALLEY AUTHORITY FOR SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MF0057 AND MF0058) Dear Mr. Carlin The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted an environmental seeping process and solicited public comments from March 8 to May 3, 2013. This process determined the scope of the staff's environmental review of the application for renewal of the operating licenses for Sequoyah Nuclear Plant, Units 1 and 2 (SQN). The seeping process is the first step in the development of a plant-specific supplement to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS), for SQN. As part of the seeping process, the staff held two public meetings in Soddy-Daisy, TN on April 3, 2013, to solicit public input regarding the scope of the review. The staff also received written comments by letter, e-mail, and through www.Regulations.gov. The staff prepared the enclosed environmental seeping summary report identifying comments received during the sea ping period. In accordance with Section 51.29(b) of Title 10 of the Code of Federal Regulations {1 0 CFR) the staff will send a copy of the sea ping summary report to all participants in the seeping process. The transcripts of the public seeping meetings are available for public inspection in the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http://www.nrc.gov/reading-rm/adams.html. The transcripts for the afternoon and evening meetings are listed under ADAMS accession numbers ML13108A137 and ML13108A138, respectively. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr resource@nrc.gov.

J Carlin The draft supplement to the GElS is scheduled to be issued in July 2014. A notice of the availability of the draft document and the procedures for providing comments will be published in the Federal Register. If you have any questions concerning the staff's environmental review of this license renewal application, please contact Mr. David Drucker, Project Manager, at 301-415-6223 or by e-mail at David. Drucker@nrc.gov. Sincerely,

                                            ~~

Brian D. Wittick, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

As stated cc w/encl: Listserv

• .. ML14041A118 OFFICE LA:RPB2/DLR PM:RPB2/DL OGC BCRPB2/DLR R

NAME IKinQ DDrucker BMizuno BWittick DATE 3/5/14 3/5/14 3/11/14 3/28/14 OFFICE BC:RERB/DLR DD:DLR BC:RPB2/DLR NAME DWrona Jlubinski BWittick DATE 4/2/14 4/7/14 4/24/14 Environmental Impact Statement Scoping Process Summary Report Sequoyah Nuclear Plant Soddy-Daisy, TN April 2014 U.S. Nuclear Regulatory Commission

Introduction The U.S Nuclear Regulatory Commission (NRC) received an application from Tennessee Valley Authority (TVA), dated January 15, 2013, for renewal of the operating licenses for Sequoyah Nuclear Plant, Units 1 and 2 (SQN). SQN is located in Soddy-Daisy, TN, about 25 miles from Chattanooga, TN. The purpose of this report is to provide a concise summary of the determinations and conclusions reached, including the significant issues identified, as a result of the seeping process in the NRC staff's environmental review of TVA's license renewal application. As part of the application, TVA submitted an environmental report (ER) (TVA 2013) prepared in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 51, which contains the NRC requirements for implementing the National Environmental Policy Act of 1969 (NEPA). The requirements for preparation and submittal of ERs to the NRC are outlined in 10 CFR 51.53(c)(3). The requirements in Section 51.53(c)(3) were based upon the findings documented in NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (GElS) (NRC 2013). In the GElS, the staff identified and evaluated the environmental impacts associated with license renewal. Some impacts were determined to be generic to all nuclear power plants (or, in some cases, to plants having specific characteristics such as a particular type of cooling system). These generic issues were designated as "Category 1" impacts. An applicant for license renewal may adopt the conclusions contained in the GElS for Category 1 impacts unless there is new and significant information that may cause the conclusions to differ from those of the GElS. Other impacts that require a site-specific review were designated as "Category 2" impacts and are required to be evaluated in the applicant's ER. The Commission determined that the NRC does not have a role in energy-planning decision making for existing power plants. Therefore, an applicant for license renewal need not provide an analysis of the need for power or the economic costs and benefits of the proposed action. On June 20,2013, the NRC published a final rule (78 FR 37282) revising 10 CFR Part 51. The final rule updates the potential environmental impacts associated with the renewal of an operating license for a nuclear power reactor for an additional 20 years. The revised GElS, which updates the 1996 GElS, provides the technical basis for the revised rule. The revised GElS specifically supports the revised list of NEPA issues and associated environmental impact findings for license renewal contained in Table 8-1 in Appendix B to Subpart A of the revised 10 CFR Part 51. The final rule consolidates similar Category 1 and 2 issues, changes some Category 2 issues into Category 1 issues, and consolidates some of those issues with existing Category 1 issues. The revised rule also adds new Category 1 and 2 issues. The final rule became effective 30 days after publication in the Federal Register. Compliance by license renewal applicants is not required until1 year from the date of publication (i.e., license renewal environmental reports submitted later than 1 year after publication must be compliant with the new rule). Nevertheless, under NEPA, the NRC must now consider and analyze, in each license renewal Supplemental Environmental Impact Statement (SEIS), the potential significant impacts described by the final rule's new Category 2 issues and, to the extent there is any new and significant information, the potential significant impacts described by the final rule's new Category 1 issues. Additionally, regarding spent nuclear fuel, the NRC has made changes to the "Onsite storage of spent nuclear fuel" issue and the "Offsite radiological impacts of spent nuclear fuel and high-

level waste disposal" issue as a result of the United States Court of Appeals decision in New York v. NRC, 681 F. 3d 471 (D.C. Cir. 2012), which vacated the NRC's 2010, waste confidence decision and rule (75 FR 81032 and 81037; December 23, 2010). The Category 1 "Onsite storage of spent nuclear fuel" issue was revised to limit the period of time covered by the issue to the license renewal term. Similarly, the NRC revised the Category 1 "Offsite radiological impacts of spent nuclear fuel and high-level waste disposal" issue by reclassifying the 1ssue from a Category 1 issue with an impact level of small to an uncategorized issue with an impact level of uncertain. These issues will be discussed in Chapter 4 of the draft SEIS. On March 8, 2013, the NRC initiated the seeping process for the SON license renewal application environmental review by issuing a Federal Register Notice (78 FR 15055). This notified the public of the staff's intent to prepare a plant-specific supplement to the GElS regarding the application for renewal of the SON operating licenses. The plant-specific supplement to the GElS is also referred to as the Supplemental Environmental Impact Statement or SEIS. The SEIS will be prepared in accordance with 10 CFR Part 51. The seeping process provides an opportunity for public participation to identify issues to be addressed in the SEIS and to highlight public concerns and issues. Consistent with 10 CFR 51.29(a), the notice of intent identified the following objectives of the seeping process:

• Define the proposed action,
• Determine the scope of the SEIS and identify significant issues to be analyzed in depth,
• Identify and eliminate peripheral issues,
• Identify any environmental assessments (EAs) and other environmental impact statements being prepared that are related to the SEIS,
• Identify other environmental review and consultation requirements,
• Indicate the schedule for preparation of the SEIS,
• Identify any cooperating agencies,
• Describe how the SEIS will be prepared.

The NRC's proposed action is whether to renew the SON operating licenses for an additional 20 years. The scope of the SEIS includes an evaluation of the environmental impacts of license renewal and reasonable alternatives to license renewal. The "Seeping Comments and Responses" section of this report includes specific issues identified by the seeping comments. The subsequent NRC responses explain if the issues will be addressed in the SEIS and, if so, where they will be addressed. Throughout the seeping process, the NRC staff identified and eliminated peripheral issues. This report provides responses to comments that were determined to be out of the scope of the license renewal application environmental review. Those that were considered to be in scope will be evaluated and documented in the SEIS. In September 2011, the U.S. Department of Energy (DOE) announced its intent to prepare a supplemental environmental impact statement (EIS) to update the environmental analyses contained in its EIS examining tritium production at SON and other commercial light water reactors (76 FR 60017). The NRC staff is required to consult with the National Marine Fisheries Service and U.S. Fish and Wildlife Service under the Magnuson-Stevens Fisheries Conservation and Management Act

and Section 7 of the Endangered Species Act to evaluate the potential impacts of continued operation on the affected endangered species. In order to fulfill its obligations under the National Historic Preservation Act, the NRC initiated consultation with the Advisory Council on Historic Preservation. The NRC staff expects to publish the draft SEISin the summer of 2014. The NRC staff did not identify any cooperating agencies for this review. The NRC, as an independent regulatory agency, routinely and extensively consults with Federal, State, Tribal, and local entities during development of environmental impact statements and environmental assessments. The SEIS will be prepared by NRC staff with contract support from Pacific Northwest National Laboratory and the Center for Nuclear Waste Regulatory Analyses. The seeping process included two public meetings which were held on April3, 2013, at the Soddy-Daisy City Hall, 9835 Dayton Pike, Soddy-Daisy, Tennessee. The NRC issued press releases, purchased newspaper advertisements, and distributed flyers locally to advertise these meetings. Approximately 80 people attended the meetings. Each session began with NRC staff members providing a brief overview of the license renewal process and the NEPA environmental review process. Following the NRC's prepared statements, the floor was opened for public comments. The official transcripts for both meetings are publicly available at the NRC Public Document Room (PDR), located at One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852, or from the NRC's Agencywide Documents Access and Management System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at http:/lwww.nrc.gov/reading-rm/adams.html. The transcripts for the afternoon and evening meetings are found at ADAMS Accession Nos. ML13108A137 and ML13108A138 respectively. A summary of the seeping meetings was issued on May 8, 2013, and is found at ADAMS Accession No. ML13108A127. Persons who encounter problems in accessing documents in ADAMS should contact the NRC's PDR staff by telephone at 1-800-397-4209 or 301-415-4737 or by e-mail at pdr.resource@nrc.gov. The NRC invited the applicant; Federal, State, and local government agencies; Tribal governments; local organizations; and individuals to participate in the seeping process by providing oral comments at the scheduled public meetings or by submitting written comments before the end of the seeping comment period on May 3, 2013. At the conclusion of the seeping period, the NRC staff reviewed comments, transcripts, meeting notes, and all other material submitted to identify individual comments. Individual comments were given identifiers which provide for tracking in this report. Figure 1 explains how the comments are labeled. Figure 1. Key to Identifiers "My name is John Doe (aJ and this comment relates to Aquatic Ecology.} 11b1-1-AE "I would also like to discuss Energy Alternatives ... "} 1-2(c1-AL "My name is Jane Doe and 1 would like to discuss Noise concerns.} 2-1-SWtdJ (a) Commenter name identified in Table 1. (b) Commenter ID specified in Table 1. (c) Sequential comment number. (d) Technical Category, presented in Table 2. Table 1 identifies the individuals providing comments and the assigned Commenter ID. For oral comments, the individuals are listed in the order in which they spoke at the public meeting.

Table 1 also includes the accession numbers of each source of comments in order to locate the original reference in ADAMS. Comments were consolidated and categorized according to the topic within the proposed SEIS or according to the general topic if outside the scope of the GElS. Comments were placed into 1 of 12 categories, which are based primarily on topics that will be contained in the SEIS for SQN. These categories and their abbreviation codes are listed in Table 2. Once the comments were grouped according to category, the NRC staff determined the appropriate action for each comment. The action or resolution for each comment is described in the NRC staff's responses in this report. Table 3 represents the location where the response to each category begins. In those cases where no new environmental information was provided by the commenter, a brief response has been provided to the comment and no further evaluation will be performed. Table 1. Individuals Providing Comments During the Seeping Comment Period Each commenter is identified alona with their affiliation and how their comment was submitted. Commenter Affiliation (if stated) ID Comment source ADAMS Accession David Lochbaum Union of Concerned 2 Web ML13101A117 Scientists Adelle Wood 3 Web ML13116A292 Jeannie Hacker* University of Tennessee at 4 Web ML13116A293 Cerulean Chattanooga Sylvia D. Aldrich 5 Web ML13116A295 Eric Blevins 6 Web ML13116A296 Tara Pilkinton 7 Web ML13116A294 Brian Paddock Res1dent 8 Email ML13119A111 Evening meeting ML13108A138 Tim Anderson 9 Email ML13142A389 Evening meeting ML13108A138 Gretel Johnston Bellefonte Efficiency & 10 Email ML13119A113 Sustainability Team Afternoon meeting ML13108A137 Mothers Against Tennessee River Radiation Sandra Kurtz Resident 11 Email ML13119A203 Afternoon meeting ML13108A137 Evening meeting ML13108A138 Unknown name 12 Web ML13121A158 Initials: CS Yolanda Moyer 13 Web ML13130A238 Judith Canepa New York Climate Action 14 Web ML13130A239 Group Tom Clements Friends of the Earth 15 Mail ML13149A008 Hardie Stulce Resident 16 Afternoon meeting ML13108A137 Don Safer Resident 17 Afternoon meeting ML13108A137 Evening meeting ML13108A138 Kathleen Ferris Resident 18 Afternoon meeting ML13108A137 Evening meeting ML13108A138 Jimmy Green Resident 19 Evening meeting ML13108A138 Garry Morgan Non-Resident 20 Evemng meeting ML13108A138 Ann Harris Resident 21 Evening meeting ML13108A138 Kristina Lambert BREDL 22 Mail ML13130A244

Table 2. Issue Categories Comments were divided into the 12 categories below, each with a unique abbreviation code. Code Technicallssue AL Alternatives AE Aquatic Ecology CC Climate Change GW Groundwater HH Human Health LR License Renewal and NEPA Process OR Opposition to license Renewal OS Out of Scope 0 PA PostUlated Accidents and SAMA RW Radiological Waste SR Support for license Renewal SW Surface Water 0 Out of Scope comments pertain to issues that are not evaluated as part of the environmental review of the license renewal application. Out of Scope comments include, but are not limited to aging management, safety concerns, emergency preparedness, spent fuel pools, dry cask storage, independent fuel storage installations, long-term radioactive waste storage, waste confidence rule, deregulation, energy costs, need for power, non-license renewal ~ctions, and other topics that are not specifically addressed as part of the identified environmental issues in the GElS Table 3. Comment Response Location in Order of Issue Category Technical Category Page Alternative Energy Sources 7 Aquatic Ecology 7 Climate Change 7 Groundwater 7 Human Health 6 License Renewal and NEPA Process 6 Opposition to License Renewal 6 Out of Scope 9 Postulated Accidents & SAMA 30 Radiological Waste 30 Support for License Renewal 31 Surface Water 32 The comments received as part of the seeping process are documented in this section, and the disposition of each comment is discussed. The meeting transcripts and written comments are included in their original form at the end of this report. The preparation of the SEIS will take into account all the relevant issues raised during the seeping process. The SEIS will address both Category 1 and 2 issues, along with any new information identified as a result of the sea ping process. The SEIS will rely on conclusions supported by information in the GElS for Category 1 issues and will include analysis of Category 2 issues and any new and significant information. The NRC will issue a draft SEIS for public comment. The comment period will offer the next opportunity for the applicant, interested Federal, State, and local government agencies, Tribal governments, local organizations, and other members of the public to provide input to the NRC's environmental review process. The comments received on the draft SEIS will be considered in the preparation of the final SEIS. The final SEIS, along with the staffs Safety Evaluation Report (SER), will provide much of the basis for the NRC's decision on the TVA application to renew or not renew the licenses for SON.

Sequoyah Nuclear Plant- Seeping Comments and Responses

1. Alternative Energy Sources (AL)

Comment: The following comments express concerns with alternatives to renewal of the SQN operating licenses. Identifiers: 8-4-AL, 8-6-AL, 8-11-AL, 9-7 -AL, 9-1 0-AL, 10-1-AL, 10-1 0-AL, 10-11-AL, 10-14-AL, 10-21-AL, 11-19-AL, 11-26-AL, 11-38-AL, 14-7-AL, 17-8-AL, 17-11-AL, 17-12-AL, 17-22-AL, 19-1-AL Response: The NRC staff will evaluate and identify reasonable alternatives to the license renewal of Sequoyah Nuclear Plant, Units 1 and 2 (SQN), including the no-action alternative, in Chapter 2 of the Supplemental Environmental Impact Statement (SEIS). In Chapter 4 of the SEIS. the NRC staff will examine the potential environmental impacts of alternatives_ These comments wiff be addressed further in Appendix A of the SEIS. 2, Aquatic Ecology (AE) Comment: The following comments express concerns with aquatic ecology. Identifiers: 8-1-AE, 9-11-AE, 11-9-AE, 11-11-AE, 11-34-AE Response: The NRC staff will describe the aquatic ecology associated with SQN in Chapter 3 of the SEIS and will address impacts to aquatic ecology associated with renewal of the SQN operating licenses and alternatives to renewal in Chapter 4 of the SEIS. These comments will be addressed further in Appendix A of the SEIS. 3, Climate Change (CC) Comment: The following comments express concerns with climate change. Identifiers: 11-8-CC, 11-13-CC, 11-22-CC, 11-35-CC Response: The NRC staff will describe the climate associated with SQN in Chapter 3 of the SEIS. NRC staff will address impacts from climate change on the environment and impacts to climate change from renewal of the SQN operating licenses and alternatives to renewal in Chapter 4 of the SEIS. These comments will be addressed further in Appendix A of the SEIS.

4. Groundwater (GW)

Comment: The following comments express concerns with groundwater resources. Identifiers: 3-7-GW, 9-15-GW, 11-16-GW Response: The NRC staff will describe the groundwater associated with SQN in Chapter 3 of the SEIS, and will address impacts to groundwater from renewal of the SQN operating licenses and alternatives to renewal in Chapter 4 of the SEIS. These comments will be addressed further in Appendix A of the SE/S.

5. Human Health (HH)

Comment: The following comments express concerns with human health risks. Identifiers: 3-5-HH. 4-6-HH. 5-6-HH. 9-2-HH. 9-3-HH. 9-5-HH. 9-8-HH, 9-16-HH, 10-2-HH, 11-20-HH, 11-27-HH, 11-39-HH, 12-6-HH, 17-7-HH, 17-18-HH, 18-1-HH, 18-2-HH, 18-4-HH, 18-5-HH Response: The NRC staff will describe human health risks associated with SON in Chapter 3 of the SEtS and will address impacts to human health risks associated with renewal of the SQN operating licenses and alternatives to renewal in Chapter 4 of the SEIS. These comments wilf be addressed further in Appendix A of the SEtS.

6. License Renewal & NEPA Process (LR)

Comment: The following comments express concerns with the license renewal process or the National Environmental Policy Act (NEPA). Identifiers: 4-1-LR, 5-1-LR, 8-2-LR, 9-1-LR, 9-6-LR, 9-12-LR, 9-14-LR, 10-20-LR, 11-2-LR, 11-29-LR, 12-1-LR, 14-1-LR, 17-20-LR, 21-10-LR Response: A summary of the license renewal process and NEPA will be provided in Chapter 1 of the SEtS. These comments will be responded to in Appendix A of the SEJS.

7. Opposition to License Renewal (OR)

Comments: 3-9-0R: The Sequoyah Nuclear Plant should not be relicensed based on the very real threats to public safety that have existed in the past and would continue to exist if relicensing were to be approved. 6-1-0R: Please do not renew the permits for this nuclear plant. It has been operating longer than it was intended to, and as these plants get older, problems and meltdowns become more likely. 10-9-0R: And I think what it's going to take is us demanding that the dollar not be counted above our health and safety. And 1, of course, call for the decommissioning of Sequoyah. 11-1-0R: We have a long, long list of concerns and reasons why we think that this should not-- the relicensing should not happen. 11-25-0R: I talked about the alternatives that were offered by TVA's draft EIS here. Application talking about two alternatives, none of which mentioned the alternative of just shutting it down. That would be an alternative that would be --we think would be good. 14-6-0R: Our recommendations are that the license renewal application be denied and that nuclear materials be interred on site. 17-13-0R: We don't need this plant. We need to get away from it. They're doing it in Germany. After Fukushima, the Germans decided to shut down all of their nuclear plants. 18-3-0R: Now Hamilton County contains 134,000 people. I'm sure there are many, many more; I'm not sure of the exact number within a 50-mile radius. I urge you not to put these people at

further risk by approving a plant that's already-- reapproving, relicensing a plant that's 40 years old that has a poor record of operations with repeated scrams and that has a design that has been called faulty, maybe not by the NRC or local people. 18-6-0R: There are 134,000 people who live only in Hamilton County and probably approximately a million in a five-mile radius-- 50-mile radius. I would urge you for the sake of those children not to renew this license and to protect the people who live here. Response: These comments are general in nature and provide no new and significant information. These comments will not be evaluated further in the development of the SEIS. Outside of Scope (OS) The following comments were determined to be outside of the scope of the environmental review. The original formatting from the source documents may not be completely retained, as the comments have been received from various sources of media. Decommissioning Funding Comments: 17-24-0S: The decommissioning hasn't been talked about. There's a plant in Illinois that's going to cost a billion dollars at least to decommission, the Zion Nuclear Plant in Illinois. TVA has about a billion or less in its decommissioning fund, but they have six reactors to be decommissioned at this point. There's not money for decommissioning. I would submit to the people of this Soddy-Daisy area that you should get in line first and start the decommissioning process while there is still money in that fund because once that first billion is spent I don't know where the money is going to come from. And we've all seen the problems that the federal government has with funding, sequestration, everything else. So if you have confidence in 2040 that there's going to be money to decommission, then you're living in a different world than the one I see. 21-8-0S: Decommissioning funds -this is kind of like reading Bugs Bunny. "Decommissioning funds, a hundred million dollars disappeared from the decommissioning funds in 2012." This is reported in the report to the SEC, so it's not my opinion. I'm still quoting from you all's documents. At that rate in another five years there won't be any funds to exist because if everybody keeps pulling out a hundred million dollars and this is their slush fund that they're using which they've done it before, there won't be anything here to decommission anything regardless accident or no accident. Response: These comments concern TVA's decommissioning funding for SON, and decommissioning funding for nuclear power plants in general. These comments were provided to NRC headquarters staff responsible for regulatory oversight of operating reactor decommissioning funds and the following response was provided. The total cost of decommissioning a reactor facility depends on many factors, including the timing and sequence of the various stages of the program, type of reactor or facility, location of the facility, radioactive waste burial costs, and plans for spent fuel storage. The NRC estimates costs for decommissioning a nuclear power plant range from $28D-$612 million. To ensure that funds will be available for the decommissioning process, the NRC requires power reactor licensees to establish and maintain a Decommissioning Trust Fund (DTF) for each reactor unit. The funds accumulated in these DTFs are to be used for radiological decommissioning after permanent shutdown of the reactor unit. According to 10 CFR 50. 75, except for withdrawals being made for radiological decommissioning activities under

10 CFR 50.82(a)(8) or for payments of ordinary administrative costs and other incidental expenses of the fund, no disbursements may be made from the DTF without notice to and approval from the NRC. After decommissioning has begun and wt1hdrawals from the OTF are made under 10 CFR 50 82(a)(8), no further notification need be made to the NRC. SQN Units 1 and 2 are currently operating reactors; therefore any disbursements from the OTFs would require notice and approval from the NRC. In 2012, the NRC was not notified of any withdrawals of funds dedicated to radiological decommissioning from either SQN DTF that would result in the dispersal of "a hundred million dollars". Furthermore, pursuant to 10 CFR 50. 75(f)(1), each power reactor licensee is required to report on the status of its decommissioning funding for each reactor or part of a reactor that it owns at least once every two years. The latest report for SQN was submitted to the NRC for review on Apn! 1, 2013 (ADAMS Accession No. ML13093A372). The analysis of the report showed that the DTFs for SQN Units 1 and 2 increased by 16.8% or $38,121,393 and $36,264,808, respectively from the previous amounts reported in 2010. This level of increase was greater than the average DTF percent increase of 13.1% across a/1104 operating reactors in 2012. Based on this analysis, the NRC found the licensee demonstrated reasonable assurance that sufficient funds will be available for the decommissioning process. These comments are not in the scope of the environmental portion of the license renewal and will not be evaluated further in the development of the SEtS. Emergency Preparedness Comments: 3-8-0S: Other concerns include ... evacuation plans for a growing population in the area, and TVA's history of poor management practices. 11-5-0S: And that certainly is an analysis that has to be done to assess the risk to a growing urban population. When Sequoyah was first built, it was pretty rural out here and now it isn't. And so we have a growing population. 17-3-0S: They evacuated permanently a 19-mile circle with Chernobyl in the center. So just imagine. Take a 19-mile circle from Sequoyah and that's what's possible in the event of a severe accident. And that is not even being considered in this process. And I ask the NRC in going through this in a post-Fukushima time to take that into account in the decision to relicense or not. 20-1-0S: I wanted to talk to you a little bit today, not necessarily about the river, but about emergency planning and evacuation zones. One of the lessons from Fukushima was the discovery that, "Hey, radiation just does not stay within- when there is a catastrophic failure of a system such as occurred at Fukushima, which has occurred at Three Mile Island, which occurred at Chernobyl, and the many near misses which has occurred within the United States. And that radiation gets out of that containment, it doesn't say, "Oh, Iockie here Here's that 10-zone." No, it don't do that. It goes where the wind blows it. And in Fukushima we learned that may be a 120 miles downwind. It may be 160 miles downwind. That is a concern. And this is the reason one of the lessons of Fukushima was consider the EPZs, the Emergency Planning Zones, the Emergency Evacuation Zones. Currently the TVA sends out and NRC approves these Emergency Evacuation Zones. And this is critical. There is nothing more critical in the environment than us, the people. We are the most critical. We are.

You got Resident Inspectors here. And I'm sure they do not want to see TVA employees, NRC employees that work here, plus the citizens, the good police that's here, the mayor, the City Council, everybody, the citizens of the community. Nobody wants to see a serious accident But Lord forbid if that accident does occur, you want to be ready for it. And one of the lessons of Fukushima has came out and has been very latently (sic) we are not ready. And I'm talking about we as Americans. And the regulator, the power providers, we're not ready to deal with that unexpected accident Because in our emergency planning, we tell them radionuclides, "Oh, you can't go out of this 10-mile zone." Well, ladies and gentlemen, I'm here to tell you it just don't work that way. I am asking the NRC before they go forward with any relicensing, whether it be Sequoyah or anybody else, you better make improvements. I highly suggest you make improvements on your emergency planning and your emergency evacuation zones. It is required. And this is being considered in the various tiers of the Nuclear Regulatory Commission. Please include is as a high priority at Sequoyah. We don't like to think about the unthinkable. And we know that everybody does the best job that they can to ensure that that nuclear reactor over across the ridge over there next to the river is very safe. But if that unthinkable does happen, you want to be prepared. You want to be ready for it. The emergency planning zones, the emergency evacuation zones, 10 miles is not sufficient. Fukushima has shown this. Other accidents have shown this. The NRC's own planning has shown this. The weather shows it. And climate change is very important factor. Extend the 10 miles zones out to 25, the food intake zone which is currently 50 needs to be extended out to a 100 miles. You need to train. You need to plan and be ready for that unforeseen accident. Defense in depth, good program. The other programs that the NRC ensures that the power providers implement, good program. But if you're not ready for that unforeseen accident, that which you cannot fathom in your minds, then you're going to kill people. And nobody in this room wants to see that happen. Be prepared, think about-- NRC, please, think about extending the Emergency Planning Zones and the Emergency Preparedness Zones in this community. And that includes, of course, I was reading in documents where the NRC passes out the potassium iodine. Down in Chattanooga, NRC passed potassium iodine since you're 15 miles away. No, you only think about that 10 mile zone. Think about outside that zone. I mean if you think about where you're going to get help right here? The local police and local fire are going to be very busy. That's where they're going to get help is through their neighbors. Because l know that all communities in the Tennessee Valley have reciprocity agreements where they can call in for extra help. But if you don't plan, if you don't bring in Chattanooga, if you don't bring in the other areas over to the west into this area, then you're failing in your planning. That is something I have noticed. Many years in the military has shown me, has demonstrated that one of the greatest-- and Fukushima showed that one of the greatest failures is the failure to plan adequately for emergency. I ask you to pay specific attention to the EPZ and Emergency Preparedness. Thank you. Response: These comments concern emergency preparedness in general and the size of the emergency planning zone (EPZ) in specific. With respect to emergency preparedness in general, the NRC regulatory requirements under 10 CFR Parl50 ensure that licensees have adequate emergency planning and evacuation programs in place in case of an accident/emergency scenario. Such plans are evaluated by the NRC and coordinated with the Federal Emergency Management Agency (FEMA) and local authorities for implementation. Drills and exercises are conducted periodically to verify the adequacy of the plans. Issues identified during such exercises are resolved within the context of the current operating license and are not reevaluated as parl of license renewal.

FEMA After Action Reports and Communication Related to Specific Emergency Exercises document the Radiological Emergency Preparedness Program exercises for nuclear power plants. The most recent FEMA report documents a SQN exercise conducted in October 2012 (ADAMS Accession No. ML13085A038). This report states: "Based on the results of the October 3, 2012, exercise, and the Atlanta Regional Office's review of Tennessee's 2011 Annual Letter of Certification, the offsite radiological emergency response plans and preparedness for the State of Tennessee and the affected local jurisdictions, site-specific to the Sequoyah Nuclear Power Plant, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site." With respect to the size of the EPZ, one of the Tier 3 recommendations of the NRC's Fukushima accident lessons learned effort is a plan to evaluate the basis of the EPZ size. This plan is Enclosure 3 to SECY-12-0095 dated July 13, 2012, found at hffp:llwww.nrc govlreading-rmldoc-col/ections/commission/secys/201212012-0095scy.pdf, and it states: In the coming years, there are extensive plans to further study the potential health effects for the released radioactivity from the Fukushima site. The United Nations Scientific CommtUee on the Effects of Atomic Radiation (UNSCEAR) plans a two-year assessment of Fukushima impacts; and a major initiative is planned, the Fukushima Health Survey, that wiff infonn future more detailed dose assessments by recreating the whereabouts of every Fukushima prefecture resident from the time of the March 11 nuclear accident onwards. The NRC staff will continue to monitor the results of these efforts, and their potential implications regarding the U.S. regulatory approach to emergency planning around nuclear power plants, including the EPZ size. In addition, the NRC is conducting a Level 3 Probabilistic Risk Assessment (PRA) to gain a better understanding of potential radiological effects of postulated accident sequences including sites with multiple units. The staff believes that the existing basis for the EPZ size remains valid (including for multiunit events). With regard to this recommendation, the staff plans a longer-term action that is already being evaluated by existing activities. The staff will use insights from the current Leve/3 PRA study as well as information obtained from the UNSCEAR assessment to infonn the evaluation of the potential impacts that a multiunit event may have on the EPZ. Additional information regarding NRC's emergency preparedness and response efforts can be found on the NRC public website at http:llwww.nrc.gov/about-nrclemerg-preparedness_ html. These comments are not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SE/S. Energy-Planning Decision Making Comments: 4-3-0S: Monies must be used to develop safer means of energy harvesting. 5-3-0S: Monies must be used to develop safer means of energy harvesting. 12-3-0S: Monies must be used to develop safer means of energy harvesting. 13-2-0S: Start investing in renewable energies such as solar on every new construction of homes and businesses including school.

Response: These comments concern energy-planning decision making. The NRC does not have a role in energy-planning decision making for existing power plants. The NRC has no authority or regulatory control over the ultimate selection of future energy alternatives. The NRC makes a decision to renew or not to renew a license based on safety and environmental considerations. These comments are not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SE/S. Financial Insurance Comments: 9-4-0S: TVA also does not have adequate insurance to cover a major event. Nor is there a public procedure in place on how local and regional business will be compensated for loss of business related income, relocation of businesses, residents, loss of personal items, homes, and cost of relocation_ How does TVA propose to relocate an entire city in the event of a major event? How do they plan on paying for a complete economic shutdown of the evac zone? These are the risks we as citizens in the effected region have to burden so that the TVA can continue to generate energy through nuclear reactors. The world thinks --we don't have these risks with solar energy or other viable renewable energy forms. Where do I go when I can't go home? Where do I go when my bank is closed? Who notifies the elderly and disabled that they need to get out of the area? Where's your plan and where's your money? 21-11-0S: Now for those of you people that live in this community and around these nuclear plants, TVA does not have any insurance to take care of your problems if there is a nuclear incident. They call -only if a reactor blows up, do they call it an accident. Look for the words "unplanned event" and "unexpected." That's called nuke's speak. Now the only compensation from any accidents will come from the U.S. taxpayer. You're going to pay not wan maybe get it later. Homeowner policies do not cover any nuclear issues. Do not cover any nuclear issues. Go home and read your homeowner's policy because it explicitly says, "This is exempt from any nuclear accident or issues surrounding them." Response: These comments primarily concern a potentia/Jack of financial insurance in the event of a nuclear accident. The Price Anderson Act requires that NRC licensees maintain at all times the maximum level of primary insurance avatlable from private sources (currently $375 million) and also participate in a Secondary Financial Protection program. Under this program, should an incident at any power reactor exceed $375 million in damages, all power reactor operators wHI be charged a retrospective premium, up to a maximum of $121.3 million per reactor per incident, for a total of approximately $12 billion. Furlher information on nuclear insurance is available at http://www. nrc. qovlreading-rmldoc-collectionslfact-sheetslfunds-fs.html. These comments are not within the scope of the environmental porlion of the license renewal review and will not be evaluated furlher in the development of the SE/S.

Fire Comment: 21-12-0S: One of the things that was a discussion here just a few minutes ago and whenever this gentleman here whenever we had the discussion about the fire, if he would look at the February 13th Inspection Report on Sequoyah, he would find on page-- it's in the summary of Findings, Enclosure 2, on Page 1 and 2 and 3. It says, 'They were issued a violation for failure to implement procedures required for fire protection program implementations. And Inspectors found multiple examples of where fire watches were not conducted in accordance with NRC standards. A failure to establish adequate procedures required for fire protection program implementation cause compensatory measure. The program implementation caused compensatory measures, fire watches, to not be adequately completed and could have potentially compromised the ability to safely shutdown the plant in the event of a fire in any of the fire zones where the fire watches were required." Maybe you, Region II, maybe you ought to give this up to these boys up in D.C. They probably would appreciate it since this has to be something that is not on their radar screen. Response: This comment concerns NRC inspection findings associated with fire protection at SON found in Enclosure 2 of Inspection Report 0500032712012005, 0500032812012005 available on NRC's website 'ROP List of Inspection Reports' found at http l!adamswebsearch. nrc. qovlwebSearch21doccontent.isp ?doc={05D848C9-A6CB-460A-A940-2EAC55F49F11 In this inspection report, NRC inspectors identified the licensee's failure to implement procedures required for fire protection program implementation. The inspectors found multiple examples of where fire watches were not conducted in accordance with procedure NPG-SPP-18.4.6, Control of Fire Protection Impairments, Revision 1, when required. The licensee entered this issue into the Corrective Action Program (CAP) as problem event reports (PERs) 635934 and 635934. NRC inspectors concluded that the finding was of very low safety significance. Also in this inspection report, NRC inspectors identified the licensee's failure to establish adequate procedures required for fire protection program implementation. Specifically, NPG-SPP-18.4.6, Control of Fire Protection, Revision 1, Impairments was determined to be inadequate because it did not provide any guidance on what a fire watch was supposed to do when they came to a protected door. The licensee entered this issue into the CAP program as PER 652672. The NRC inspectors concluded that the finding was of very low safety significance. This comment is not in the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SEIS. This comment was provided to the NRC staff conducting the SQN license renewal safety review. Fukushima-related comments Comments: 1-1-0S: NRC needs to inform TVA that to grant a 20 year operating license renewal they must commit to comply with all NRC's Fukushima Daiichi Lessons Learned.

1-2-0S: I am concerned about Station Blackout capability for much more than the current 4 to 8 hours of the Class 1E batteries. 1-3-0S: I am concerned about Containment venting with filtration to essentially eliminate fission products releases after a core melt accident. 1-4-0S: I am concerned about New seismic evaluation of the entire nuclear island based on the new geological information developed in the last few years. 3-2-0S: Risks include flooding from the potential failure of dams upstream from the plant; earthquake risk; and a plant design that is inherently dangerous. There are important cost considerations as well. 3-3-0S: I do not believe that a nuclear plant that has received 6 NRC safety citations related to possible flooding is a good bet for future compliance. We certainly need to bear in mind the frightening results of the Fukushima incident, especially considering that flooding at Sequoyah has the potential to rise 2.4 feet above that which the plant can handle and could cost more than a billion dollars in modifications if such damage is to be avoided. 3-4-0S: Earthquake risk is also an issue because of Sequoyah's location in the Eastern Tennessee Seismic Zone, which has experienced large quakes within recent years. An earthquake of a feasible magnitude would cause severe damage and possible catastrophic results. 7-1a-OS: TVA's Sequoyah is at risk from flooding which could result from the failure of upstream dams. The Eastern Tennessee Seismic Zone, which extends from southwest Virginia to northeast Alabama, is considered to be one of the most active seismic areas east of the Rocky Mountains. It has the potential to produce large magnitude earthquakes. Recent large earthquakes include a magnitude 4.6 that occurred in 1973 near Knoxville and the Fort Payne Earthquake, also a magnitude 4.6, that occurred in 2003 near Scottsboro, Alabama. The containment buildings of nuclear reactors must do two things without fail: contain radioactive emissions during an accident and prevent intrusion from outside forces such as wind driven objects and man-made missiles. 8-3-0S: And quite frankly, we have to express some discomfort with confidence in the NRC. For example, recently there was a discussion of the venting that needed to be available in post Fukushima circumstances. And the Commissioners voted to say, yes, the staff should go ahead and prepare a regulation to require vents, but it would not require the filtrations of radioactive materials through those vents. In other words, the vents will be- if the regulations is finally adopted and if the operators finally instal\ those vents, the current policy posture of the Commissioners is that they will not be required to filter radioactives out of that, and thus, you are going to permit- obviously. in a very unusual circumstances, the release of radiation. So you might look which way the wind is blowing where you live from this plant 10-6-0S. The TVA dams are aging and they were not built to with stain earthquakes in the way that big power plants were. They don't have --they're not up to those standards and they are aging And there have been many, many failures of dams in America and TVA has suffered some as well. And we're concerned that there could be a dam failure that could trigger a domino effect above Sequoyah and that numerous dams could break. And the integrity of the cooling systems could be compromised no matter how much planning we do. As we found at Fukushima, we cannot foresee everything: we are human. 1 0-13-0S: Article to be considered during the environmental review: "Leaked Report Suggests Long-Known Flood Threat To Nuclear Plants, Safety Advocates Say."

10-17-0S: Other concerns are potential non-deliberate "beyond-design-basis events," such as floods and tornadoes. TVAs dams are aging and maintenance has been spotty at best. Many valley residents are concerned over the possibility of a catastrophic flood being caused by one or more dam failures. Dams were not built to the same earthquake safety standards as the power plants and one dam failure could trigger a domino effect upstream of nuclear power plants, possibly overwhelming the planned backup systems should 'all hell break loose'. 10-19-0S: Another lesson of Fukushima is the necessity of preparedness for multiple events or even compound disasters. In the Tennessee Valley, we have what many here call a tornado corridor. Please note the submission, for the record, of the map of TVA nuclear power plants 50 mile radii superimposed on the NOAA Tornado Track of the April 2011 outbreak in this area. The Safety Evaluation Report for Sequoyah needs to identify and evaluate not only the dual dangers of floods and tornadoes, but also the potential consequences of combined and compound disasters on the environment of our valley. National Severe Storms Forecast Center reported 29-31 tornadoes within a 30 nautical mile radius of Sequoyah in the 37 year period between 1950 and 1986. Within the next fifteen year period ending in 2002, they reported 23 tornadoes in that same area 9 nearly doubling the incidence of tornadoes in the 30 nautical (34.5 U.S. mile) radius. This record was up to the year 2002, and does not appear to address the increased incidence, size, and ferocity of tornadoes associated with the ongoing problem of climate change. According to the NOAA tornado track of the April 2011 outbreaks, here entered into the record, there appear to be about 15 tornadoes within that same radius,' 0 and according to the SEIS. three tornadoes touched down within 10 miles of Sequoyah (according to Kenneth Wastrack, TVA, personal communication)." The increasing frequency, size, and severity of tornadoes due to climate change is a potential environmental hazard that needs to be identified and evaluated in the SEIS and Safety Evaluation Report. 11-4-0S: There's concern over flooding. In the light of lessons learned from Fukushima and the fact that TVA has discovered with their own calculation that they are well- they're too low. They need to put in flood protection in case the earthen dams upstream give way. 11-6-0S: And I think we need to assess the risk should those darns upstream break or an earthquake occurs. Because we now also find out that we live in a possibly seismically active area. We had the Knoxville earthquake recently in and around Knoxville. And just was today a lady here was telling me we have a little small earthquake here in this area just today. So if- I think we need to figure out if the design for Sequoyah is strong enough to withstand a heavy earthquake. And I understand that magnitude 5 would be a good number to shoot for protecting. 11-21-0S: We - I talked about- you've heard something about the flooding, the flooding concerns, the flooding mitigation concerns, possibility of an earthquake, climate disruption patterns which should be updated. We were concerned about that. 11-31-0S* There is concern over flooding in the light of lessons learned from Fukushima and the TVA discovery that their own calculations on flood risk at both Watts Bar and Sequoyah were too low. Analysis must be done to assess the risk to the urban population in and around Chattanooga should dams upstream break or an earthquake occur. Flooding mitigation must be done and is bound to be costly. 11-32-0S: It is not out of the question for an earthquake to occur that would impact Sequoyah should it be above a seismic level of 4.9. With new information and Fukushima recommendations, an updated analysis is needed rather than relying on the original EIS.

17 0S: Flooding - I'm from Nashville. Two years ago we had a flood. I think it was two years ago, or maybe now it's three, I'm sorry. We had a flood, 500 or 1,000 year flood. It was simply unbelievable. We had 17 inches of rain over a two-day period. Little bitty streams were flooding people out of their homes, washing homes off their foundations. The Corp of Engineers lost vehicles next to the dam they operate in Cheatham County, the Cheatham Dam below Nashville and the Cumberland River. The Old Hickory Dam, which is the one directly above Nashville on the Cumberland River, had to be opened wide open and that's why downtown Nashville flooded because that dam was in danger of being overtopped. Had it been overtopped, the dam would have been washed away. It was not designed to be overtopped. If that type of rain event had happened here, I believe Sequoyah would be in great danger. There is nobody that dreamt that much rain was possible in that short of a time. I encourage you all at the NRC to take into account some of the types of floods we've had like that. That Nashville flood is not the only one that has happened. These rain storms come in and they sit in one area and they just dump and dump and dump. Please, take into account not just dam failure but a rain event of 17 or more inches in a 24 or 48 hour period. It simply will overwhelm and that's the type of thing --you can't have a tsunami here, but you could sure have a flood of that sort. And believe me, the first responders in this community are going to be hard-pressed getting people out of their homes and rescuing people from the highways. We even had one policeman that was washed downstream, who was trying to stop people from going on a flooded street, West End Avenue, one of the major streets in Nashville in Belle Meade, a high-class neighborhood. So flooding is not to be taken lightly in this day and age. 19-3-0S: Vulnerability to flooding obviously has been in the news recently and still seems to be an issue that hasn't been resolved. Well, I guess technically it has been revolved but not in your favor. 21-5-0S: The earthen dams, now, NRC, you're going to tell me that this only concerns Watts Bar. Watts Bar and Sequoyah both are on the same reservoir. Both of them will go down if that dam at Watts Bar goes down. That allegation of a problem with -of earthen dam being a problem has been on the books since the late 1980s because I was the one that put it on the books as a concern because I lived in that community. And for you to extend from the 1980s to 1998, 2004 or 2005, and now here in your current Inspection Report, of which I'm carrying here which is about an inch thick, here it is. It comes to my house on a regular basis from you guys. 21-7-0S: So what are you going to do about backup electricity whenever those things go down because there was a flood in this town -- in the city of Chattanooga --in the mid-80s that put underwater massive amounts of this end of the state of Tennessee. Go back and look. You can look through your history books. Go down to the local library and you'll find pictures of it because it was a major disaster. Things that had never been underwater since TVA had built their first dam was automatically underwater due to those rains. Response: These comments concern safety issues with a nexus to the NRC's continuing activtfies associated with the Fukushima nuclear accident. On March 11, 2011, a 9 a-magnitude earthquake struck Japan and was followed by a 45-foot tsunami, resulting in extensive damage to the nuclear power reactors at the Fukushima Dai-ichi facility. The NRC has taken significant action to enhance the safety of reactors in the United States based on the lessons learned from this accident. The NRC continues to evaluate and act on the lessons learned from the accident in order to ensure proper safety enhancements are made at U.S. nuclear power plants.

On March 12, 2012, the NRC issued the first regulatory requirements for the nation's operating reactors based on lessons learned from the Fukushima nuclear accident. Three orders requiring safety enhancements of operating reactors, combined license holders, and construction permit holders were issued. These three orders implement safety enhancements related to mitigation strategies for response to extreme natural events resulting in loss of power, reliable hardened containment vents, and spent fuel pool implementation. Plants are required to implement these enhancements within two refueling outages or by December 31, 2016, whichever comes first. The NRC has also issued requests for information from each reactor to reevaluate flooding and seismic hazards, conduct walk-downs, and reevaluate emergency communications systems and staffing levels_ Operating reactor sites are using present-day information to reevaluate the flooding and earthquake effects-or hazards-that could impact their site. These newly reevaluated hazards, if worse than what the plant had originally calculated, will be analyzed to determine if plant structures, systems, and/or components need to be updated to protect against the new hazard. The NRC will review each step in the analysis process and take action to require plant changes as necessary. As applicable, the lessons learned from the accident at Fukushima will be applied to all operating nuclear power reactors, regardless of a license renewal application. Reactors undergoing initial license application are a/so subject to these findings_ For further information on the NRC's continued response to the Japan Nuclear Accident visit: http: I fwww _nrc. g ovIre actors/operating/ops-experie nce/j a pan-info_ htm I In addition, on July 5, 2013, an Atomic Safety and Licensing Board (Board) issued decision (LBP-13-08) in response to a petition for intervention and hearing request (Petition) filed by the Blue Ridge Environmental Defense League (BREDL), Bellefonte Efficiency and Sustainabi/ity Team (BEST), and Mothers Against Tennessee River Radiation (MATRR) regarding the license renewal application for SQN. BREDL, BEST, and MA TRR filed their Petition on May 6, 2013. The Petition put forward eight proposed contentions. The Board ruled that Contention A, regarding flooding risks, was beyond the scope of the license renewal proceeding and insufficiently supported and, therefore, inadmissible. The Board's decision may be found at ADAMS Accession No_ ML13186A103. These comments are not in the scope of the environmental porlion of the license renewal and will not be evaluated furlher in the development of the SEIS. Ice Condenser Comments: 3-6-0S: ... while the containment of an ice condenser reactor such as Sequoyah's would surely fail in an accident that involved hydrogen ignition. As noted by the Blue Ridge Environmental Defense League, ice condenser plants are exceptionally vulnerable, up to a factor of one hundred times or more. 4-4-0S: These Ice Condenser Reactors are out of date and dangerous. 5-4-0S. These Ice Condenser Reactors are out of date and dangerous. 7-1 b-08: Ice condenser reactors economize on concrete and are less robust because of this construction method. 8-9-0S: 1 would associate the club's comments with also the comments made by the Southern Alliance for Clear Energy and those that have been made earlier on the ice condenser problem.

12-4-0S: These Ice Condenser Reactors are out of date and dangerous. 14-5-0S: As has been seen in other nuclear power plants, cutting a massive hole in the containment structure, already subjected to the high stressors of SCRAMS and simple aging, endangers the integrity of the structure itself and thus the ability of the ice- condenser system to keep the radiation out of the surrounding environment 17 0S: Just the design, I think later I'll get into the design of the ice condenser units which are remarkable except they're really wacky. I mean you've got a lot of ice in there. But the ice condenser design just briefly was identified after Three Mile Island as being the most likely of all the United States reactors for the containment to fail in a serious accident in a loss of- a coolant water accident where the fuel rods are exposed. 17-6-0S: Before I get started, I'd like to recommend to everybody, especially the young people working on the NRC on this project. It's called Tritium on Ice. It gives a great history of the NRC, not totally, but in regard to the ice condenser design and the tritium question. And this man worked at the Sandia Lab for 25 years. He was highly respected until the truth finally got to him, especially on this particular issue. And in here he says that there are serious grounds for worry that ice condenser plants could undergo catastrophic accidents exposing nearby populations to fatal doses of radioactivity. And he goes on to say --this is a dispassionate outside observer-- The fact that the operator of the plants is the Tennessee Valley Authority, a federal agency with a long history of compromising nuclear safety, exacerbates the potential danger. Now the history of TVA and nuclear is long and it's not so pretty. And we've been very lucky that we haven't had a major accident. Browns Ferry almost went up because of the famous candle fire in 1974. And if you don't know about it, you should look it up because it's pretty scary. There have been improvements, but his main point in here is that the ice condenser design is fundamentally flawed from the get-go. It was originally designed as a way to put-- make the containment vessel less robust, not as thick, not as strong, not as big. So it costs less. This is nuclear power on the cheap. That's not the kind of nuclear power that we really want. We don't want any nuclear power, but on the cheap is the worst. That's why he says it's more likely to fail. The description of the ice condenser system is very well done by Dave Lochbaum in his book. And the ice condenser is a large vault-like structure which encircles the base of the reactor containment building. The ice condenser is subdivided into 24 bays. Each bay has two hinged doors at the bottom of the wall between the reactor containment building and the ice condenser. Each bay contains 81 large 45-foot-tall baskets filled with ice. Those doors, in a major accident those doors are supposed to open. The ice is supposed to absorb the heat. It's supposed to be chipped ice. And I would like to ask the Resident Inspector of the NRC maybe privately or maybe publicly to establish whether that ice stays chipped or whether it becomes solid blocks of ice and they dealt with the subsidence issue. 17-14-0S: So we should have a phase-out at least. And the beginning of the phase-out is to stop licensing, relicensing these old plants that have a much higher likelihood of problems, especially these ice condenser designs. 17-19-0S: And that's where the ice condensers came out as the very most likely to fail. And that again was a study conducted by the NRC. And it needs to be part of the debate about whether this reactor should continue. 19-4-0S: So the ice condenser design is a problem. 21-4-0S* The ice condenser story knows no bounds. The buckling floors, the sublimation, the hardware, the basket, the screws, nobody knows because nobody is minding the store around the ice condenser. And we certainly know that the ice condenser was not designed to fit

another 20 years. It's not going to make it another 20, so everybody needs to start getting to higher ground. 22-1-0S: The design of the Sequoyah reactors has a particular weakness in its construction which reduces its ability to withstand accidents. Only nine such reactors have ever been completed in the United States. Aging of the plant may only increase the danger. Response: These comments voice concerns with the performance of the ice condensers at SQN and ice condenser plant safety in general. The ice condensers at SQN are inspected by NRC Resident Inspectors and NRC Regional staff as required by several regulatory requirements. The latest inspection that included consideration of an ice condenser is NRC Inspection Report 0500032712013005 available at ADAMS Accession No. ML14038A346. No safety significant findings associated with the ice condenser were identified in this inspection. In addition, the ice condenser system, structure, and structural components were identified in the license renewal application as within the scope of license renewal and are subject to aging management. On December 17, 2013, NRC Region II staff completed a license renewal inspection in which the aging management programs credited for managing the aging effects of the ice condenser system were reviewed to verify that there was reasonable assurance that the programs will maintain the intended function of the in-scope systems during the period of extended operation. The results of this inspection are documented in Inspection Report 0500032712013012 and 05000328/2013012, dated January 31, 2014 (ADAMS Accession No. ML14031A291). The exit meeting for this inspection was open to public obseNation and the meeting summary can be found at ADAMS Accession No. ML13361A155. No safety significant findings associated with ice condensers were identified in this inspection. Ice condenser plant containment was assessed for risk and for potential plant and containment modifications to improve containment performance under the Containment Performance Improvement Program (CPIP) the results of which are found at: http:llwww.nrc.govlreading-rmldoc-collectionslnureqslstafflsr09331sec31157r1.htmf Ice condenser plants were expected to address CPIP findings in the "Individual Plant Examination for Severe Accident Vulnerabilities" (November 23, 1988), a risk analysis that considers the unique aspects of a particular nuclear power plant, identifying the specific vulnerabilities to severe accident of that plant. Ice condenser plants are in compliance with 10 CFR 50. 44, "Combustible gas control for nuclear power reactors," which requires licensees to demonstrate the containment's structural integrity for loads associated with combustible gas generation. These plants have igniter system requirements in their technical specifications for controlled burning of hydrogen. As applicable, the lessons teamed from the accident at Fukushima will be applied to alf operating nuclear power reactors, including ice condenser plants, regardless of a license renewal application. In addition, on July 5, 2013, an Atomic Safety and Licensing Board (Board) issued decision (LBP-13-08)(ADAMS Accession No. ML13186A103) in response to a petition for inteNention and hearing request (Petition) filed by the Blue Ridge Environmental Defense League (BREDL), Bellefonte Efficiency and Sustainability Team (BEST), and Mothers Against Tennessee River Radiation (MA TRR) regarding the license renewal application for SQN. BREDL, BEST, and MA TRR filed their Petition on May 6, 2013. The Petition put fotward eight proposed contentions. The Board rejected Contention F-1 that claimed there were, design flaws, inspection failures, and inadequate aging management programs with respect to ice

condensers. The Board held that the contention failed to provide sufficient information to establish a genuine dispute on a material issue of law or fact. These comments are not in the scope of the environmental portion of the license renewal and will not be evaluated further in the development of the SE/S. Integrity of Containment Comments: 10-3-0S: One of them that is specific to Sequoyah is what I consider, our group considers, a compromised integrity of the containment and that we consider it beyond the design basis of this nuclear power plant That the TVA sawed through the containment, the concrete and the metal secondary containment, of the building the reactor is in and took out a broken generator and replaced it with a giant crane. And this was not designed to be done. This power plant was not designed for this. So this is a beyond design basis issue. And I hope that the evaluators will consider that in the light of the integrity of the unit itself, but also in the light of what it means in terms of TVA's willingness to cut into the containment structure, thereby compromising it in order to cut costs to continue the program. We think this is an unacceptable lack of quality control at the very least and it shows little concern for the safety and health of the citizens in this area. 1 0-15-0S: Our next area of concern is the compromised integrity of reactor containment at Sequoyah. This is a basic line of defense for the environment against nuclear contamination, and the very fact that the reactor designers did not allow for the replacement of the generators is cause for concern -along with the design fault issue of the ice- condensers being placed too near the reactors causing them to jam up in the baskets and not perform their designed cooling functions. TVA cut through the concrete and metal containment and lifted the top off the reactors secondary containment vessel in order to replace a generator that was not designed to be replaced. We consider this a "beyond- design- basis event" that was created, rather than mitigated, by the utility company. The fact that TVA was willing to cut into and compromise the nuclear containment, in order to cut costs for their nuclear program, shows an unacceptable lack of quality control and little concern for the safety and health of the environment for well over a million people in the area. Response: These comments concern the cutting of the reactor containment systems at SQN. It is not uncommon for reactor containment systems to be cut through to replace equipment such as a steam generator. For example, in 2012 SQN cut through containment to replace the Unit 2 steam generators. The NRC inspection of this effort is documented on pages 45-47 of Inspection Report No. 0500032712012005, 0500032812012005 available at ADAMS Access1on No. ML13050A394. These comments are not in the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SEtS. These comments were provided to the NRC staff conducting the SQN license renewal safety review for consideration.

Miscellaneous Comment: 8-1 0-0S: Articles to be considered in the environmental review: 1) NRC, Industry say reactor life longer than 40 years. Response: NRC staff read this article. This article is general in nature and provides no new and significant information. This article will not be evaluated further in the development of the SEIS. Comment: 9-9-0S: While we're on the subject of notification, we would like the TVA and the NRC to provide an org chart and a process chart so that the citizens have full knowledge as to the process and the actually people at these agencies that have the authority to disclose or not disclose, release information to the public, also who makes the call to evacuate and how quickly is that decision made. We want to know who has that power over the citizens and have a right to know.

Response

In the unlikely event of a serious emergency involving an NRC-licensed facility or material, the agency is prepared to respond immediately. Trained personnel continuously monitor licensee activities and are available to take information about a variety of threats from other federal agencies. In addition, specially trained responders in a variety of disciplines are always on call and able to respond quickly. Equipment, policies, and procedures for these response activities are regularly tested, re-evaluated, and updated so that the agency is ready at all times. If a significant inc1dent occurs, the NRC activates ds Headquarters Operations Center (HOC) and one or more of its four Regional Incident Response Centers (IRCs). Specially trained and qualified personnel work in the HOC at all times. They take emergency information from a licensee and immediately notify key NRC managers and staff. These managers and staff are trained as responders in their areas of expertise and assemble in the HOC and IRC to support NRC response activities. Only the governor has the authority to require the public near the plant to take protective actions which include evacuations. For further information on incident response go to the NRC's Fact Sheet on Incident Response found at: http :1Jwww. nrc. qovJreading-rm/doc-coffectionslfact-sheets/fs-incident-response. h tml. For information regarding public interactions with TVA associated with emergency preparedness contact the TVA Public Affairs Officer (contact information provided at http://www. tva. com/news/contacts. htm J. This comment is not in the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SEIS. Comment: 9-17-0S: From 1946 to 1970 approximately 90,000 canisters of radioactive waste were jettisoned in 50 ocean dumps up and down the East and West coasts of the U.S., including prime fishing areas, as part of the early nuclear waste disposal program from the military's atomic weapons program. The waste also included contaminated tools, chemicals, and laboratory glassware from weapons laboratories, and commercial/medical facilities. Any study should include the effects that these waste dumps have had on the water, air, and food supply including physiological changes to any human, mammal or sea faring creature.

Response: This comment is not in the scope of the environmental portion of the license renewal review and wifl not be evaluated further in the development of the SEJS. Mixed Oxide Fuel (MOX) Comments: 4-5-0S: By no means will MOX fuel be made at these Tennessee Plants that are close to Chattanooga. 5-5-08: By no means will MOX fuel be made at these Tennessee Plants that are so close to Chattanooga. 11-36b-OS: Then there is the possible use of radioactive mixed oxide fuel (MOX) being considered for use at the request of Dept. of Energy. It is experimental and never been used in a commercial nuclear plant and this one not designed for it 12-5-0S: By no means will MOX fuel be made at these Tennessee Plants that are so close to Chattanooga_ 11-17-0S: The other issue, too, is about radioactive mixed oxide fuel. That's another thing the Department of Energy wants TVA to be using here. It's experimental in commercial nuclear plants, never been used in the United States in a commercial nuclear plant and Sequoyah is not designed for it. So to say that TVA- TVA to agree to that, to using that mixed oxide fuel that's so radioactive, more so that plain old uranium, I don't think we should think about that. And that too, of course, would be a significant environmental impact if that leaks, gets loose, or we have an accident. 15-2-0S: Likewise, TVA is actively considering use of plutonium fuel (MOX) made from weapons -grade plutonium in the Sequoyah reactors. While there is no NRC license request by TVA for MOX testing or use, the review of TVA concerning MOX must be taken into account during the review of the Sequoyah license extension. 17-15-0S: The idea of putting MOX in this reactor which is under consideration --TVA is the only utility that's thinking about using it-- is phenomenally ridiculous. 19-5b-OS: it has also been mentioned as a possible plant- the possibility to use the Sequoyah Plant to burn MOX fuel, the mixed oxide fuel. I think Browns Ferry was the first choice, but Sequoyah was mentioned on that, too. So when you go into this Environmental Impact thing, I think that's something you really have to take into account, the possible use of MOX fuel in this thing. Response: These comments concern the potential use of mixed oxide fuel (MOX) at SQN. TVA has not submitted an application to use MOX at SQN to the NRC. In the event that TVA were to submit an application to use MOX, the NRC staff would evaluate the impacts at that time. In addition, on July 5, 2013, an Atomic Safety and Licensing Board (Board) issued decision (LBP-13-08) in response to a petition for intervention and hearing request (Petl1ion) fl1ed by the Blue Ridge Environmental Defense League (BREDL), Bellefonte Efficiency and Sustainability Team (BEST), and Mothers Against Tennessee River Radiation (MATRR) regarding the license renewal application for SQN. BREDL, BEST, and MA TRR filed their Petition on May 6, 2013. The Petition put forward eight proposed contentions. The Board ruled that Contention E, regarding the potential use of MOX at SQN, was inadmissible for failing to raise a genuine dispute with the current license renewal application. The Board's decision may be found at ADAMS Accession No. ML13186A103.

These comments are not in the scope of the environmental portion of the license renewal and wifl not be evaluated further in the development of the SEIS_ Need For Power Comment: 8-5-0S: Now the first issue, that bridge that needs to be crossed has to be the need for electricity. As a matter of fact, TVA sold fewer kilowatt hours in 2011 than it did in 2010. And then is sold fewer kilowatt hours in 2012 than it did in 2011. And the projection for 2013 is that it may decline again. People are, in fact, adopting efficiency and despite TVA's extremely lame attempts to push energy efficiency. With respect to energy efficiency, I would offer for the record two items. One is TVA's Commission by Contract Energy Partner Study, which shows it's doing about a third of the one percent year-over-year reduction in energy usage that it could accomplish. Response: This comment concerns the need for power. The need for power falls within the jurisdiction of the states and to some extent within the jurisdiction of the Federal Energy Regulatory Commission (FERC). For this reason, the purpose and need for the proposed action (t:e., license renewal) is defined in the GElS as follows: The purpose and need for the proposed action (renewal of an operating license) is to provide an option that allows for power generation capability beyond the term of a current nuclear power plant operating license to meet future system generating needs, as such needs may be determined by State, licensee, and, where authorized, Federal (other than NRC) decision-makers. 10 CFR 51.95(c)(2) states the supplemental environmental impact statement for license renewal is not required to include discussion of need for power or the economic costs and economic benefits of the proposed action except insofar as such benefits and costs are either essential for a determination regarding the inclusion of an alternative in the range of alternatives considered or relevant to mitigation. This comment is not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SE!S. Replacement Parts Comments: 14-2-0S: An alarming number of parts that were replaced are considered non~ compliant under your own standards. 21-1-0S: NRC, I request that you identify and evaluate the following items for potential environmental impacts prior to any extension of the Sequoyah Nuclear Plant license request for another 20 years. Substandard parts in the area of parts associated with the Watts Bar parts issue. There is evidence of shared parts. This is a longstanding issue that's been on the books since Unit 1. I was instrumental in putting this on Region ll's list in the mid-1980s. Response: These comments concern the safety of replacement parts at SQN and Watts Bar. For safety-related spare parts, the NRC requires licensees to use venders that have a quality assurance program that is in compliance with Appendix B of 10 CFR 50.

The NRC's vendor inspection program (VIP) verifies that reactor applicants and licensees are fulfilling their regulatory obligations with respect to providing effective oversight of the supply chain. It accomplishes this through a number of activities, including: performing limited scope targeted vendor inspections of the vendor's quality assurance program, establishing a strategy for vendor identification and selection which sample the effectiveness of the domestic and international supply chains for the current fleet and new reactor construction, and; ensuring vendor inspectors obtain necessary knowledge and skills to perform inspections. In addition, the VIP addresses interactions with nuclear consensus standards organizations, industry and external stakeholders, and international constituents. More information on the NRC's Vendor Quality Assurance Program can be found at http://www.nrc qovlreactorslnew-reactors/oversiqhtlquality-assurancelvendor-insp.html. In 2013, the NRC proposed a $70,000 civil penalty against the Tennessee Valley Authority for violations related to the commercial grade dedication program during the construction of Watts Bar Nuclear Plant, Unit 2. Commercial grade dedication is a process that provides reasonable assurance that components purchased from a commercial supplier are equivalent to nuclear grade (i.e. safety-related) items. This assurance is achieved through documented inspections, tests or analyses. As part of its response to the NRC's violations, TVA has been required to identify all the substandard parts resulting from improper dedication, and take appropriate corrective actions. Specifically, TVA was required to provide a written response that included: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted, and if denied, the basis for denying the validity of the violation; (3) the corrective steps that have been taken and the results achieved; {4) the corrective steps that will be taken; and (5) the date when full compliance will be achieved. TVA has been addressing these issues through the NRC's enforcement process The NRC is monitoring TVA's progress, and will continue to do so until the violations have been adequately addressed. The NRC is aware of the potential effects of substandard parts affecting TVA's supply chain, including potential effects at its other plants. As such, the NRC plans to conduct follow-up inspections to ensure that appropriate corrective action have been taken. These comments are not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SEJS. These comments were forwarded to the NRC's Quality Assurance Vendor Inspection Branch for consideration. Safety-related Issues Comments: 3-1-0S: As you are well aware, there are important safety issues, especially considering the advanced age of the Sequoyah Plant. 8-7 -OS: On the 40 year design life, I offer you a copy of the AP Report as it was summarized in our local paper in Chattanooga saying historically everyone thought the plants were designed at best to last 40 years. So the basic theory that the aging hardware is the only thing that we really should be looking at and control is far too narrow. 8-8-0S: 1 would just point to a personal experience where I went to the hearing on Browns Ferry 1 Red Status and the Chief Inspector for NRC came. And I have never seen a plant Chief Inspector, and l"ve been to a lot of hearings, stand there and for an hour list what was wrong in the plant. And essentially say that TVA had shown that it was very good at making lists of

things that needed to be fixed, of safety problems that needed to be addressed, of equipment that was not operating properly, but all it did was make lists. It could never seem to get any of the significant including safety related equipment and problems addressed and that's why now they've been in a Red Status for so long. And this is TVA's nuclear management's typical situation. They can do one thing right as a time, maybe. 10-7-0S: Okay, another issue is maintenance. TVA's record-- and I found out when the tornadoes came in 2001 and we had the outbreak of tornadoes in April, there were two of the eight backup generators that were inoperable at Browns Ferry that day. One of those EF-5 tornadoes, the strongest tornadoes known to man, touched down very close to Browns Ferry within visual distance. And it was a very close call because those are different kinds of cooling pools. They're raised up in the air and all they have is overhead containment or sheet metal roofs. It's the same as Fukushima. That's what built up and you saw those roofs blow off in Fukushima. It's the same design. Okay, so two of those were inoperable on that day. The next day another one had to be shut down. That's three of eight; that's a 40 percent failure rate in the backup emergency systems. 10-18-0S: Responsible maintenance is another issue of concern. When tornados took out power to Browns Ferry for several days in 2011, two of the eight backup power generators were inoperable when the tornado hit and a third generator was shut down the next day. That is a 40% failure rate. If TVA maintenance is not keen for nuclear power plants, where NRC oversight is physically in effect daily, one wonders about the quality of maintenance at the aging TVA dams upstream from Sequoyah. Multiple dam failure scenarios need to be identified and evaluated for the Safety Evaluation Report We all know, from watching the Fukushima helicopters desperately dropping water on the reactors and cooling pools stranded without power backup generators, that nuclear power plants ironically must have a constant supply of power and of pumped water in order to prevent the environmental horror of reactor and/or cooling pool meltdowns. 11-3-0S: Aging is a real issue here. We have an old, old, old, old plant. It's been operating with poor technology, outdated technology. Now consider the ice condenser design, which you all know is a bunch of ice baskets to cool off- in case of an accident it's going to cool off the containment building of the reactor itself. And that's old. And furthermore, there's also- there's always concrete decay. There's pipes that have been broken that are leaking. And I know TVA will say, well, we've been replacing these parts. And I know they just put in the new steam generator. But there are parts you can't get to. They are buried; they're buried in concrete. You don't know when they're going to leak. You don't know what's happening. And they are- they're aging. And I think that's a very big concern to think that we are going to give a license to continue on for 20 years without worrying a lot about that aging situation. 11-14-0S: Further shut-downs-- every time there's a shut-down, that is really, really expensive. That costs a lot for NAto be operating shut-down and they have planned shut-downs. But every time there's a scram --that's an emergency shut-down. And by the way, Sequoyah has been cited by NRC for having too many of these emergency shut-downs in a year. I think that happened last year. So that is a problem. 11-28-0S: The other thing that I wanted to emphasize here was that with the numerous accidents, scrams, shutdowns, leaks, dishonesty, and equipment monitoring, lack of proper reports filed, ignoring safety procedures, poor nuclear employee education as Browns Ferry fire thing, and the installation of non-certified equipment parts, we learned of just the other day, does not assure the public that TVA can properly run their nuclear plants.

And that and ice condenser technology, we should not renew the license. 11-30a-OS: Sequoyah Nuclear Plant Reactors 1 and 2 opened respectively in 1981 and 1982. By the time relicensing for 20 more years of operation is granted they will be 40 years old. They were actually designed for only 30 years of life. Aging increases risk of leaks and accidents that cause costly shutdowns. 11-30b-QS* This past year NRC issued a notice of violation for too many shutdowns in a year (SCRAMS) at Sequoyah. 11-40-0S: Numerous accidents, incidents, SCRAMS, shutdowns, leaks, dishonesty in equipment monitoring, lack of proper reports filed, ignoring safety procedures, poor nuclear employee education, and the installation of non-certified equipment, does not assure the public that TVA can properly run their nuclear plants. Ice-condenser technology is old and more subject to hydrogen explosions and meltdowns than other designs. There can never be enough so-called failsafe measures to avoid human error. We can and should move on to other ways to produce electricity. 13-1-0S: Lets put stipulations as to how long Nuclear Plants that are outdated are allowed to operate. 14-3-0S: Your agency cited the company for failure to perform corrective actions for problems with their other reactors. Indeed, TVA has flagrantly ignored NRC standards for safety for decades. We cannot trust this company to ensure the safety of the surrounding communities. 14-4-0S: TVA has had to perform emergency shutdowns of other reactors a shockingly high number of times. We cannot assume that the Sequoyah plant is handled differently from their usual way of running operations. However, we must have access to information related to how many SCRAMs have taken place at this facility before being able to comment knowledgeably about this concern. 17-4-0S: The other issue I think that is important that I'll get into right now-- if I can find my note -- is this issue about the life expectancy. I have an AP article that was just written in the last year. I remember when these-- as I said, these plants were first licensed. They said 40 years was it. The engineers that designed these things designed them for 40 years. Adding another 20 years is really suspect. And it's largely an economic decision. So this article says they're rewriting history saying that these things can go easily another 20 years. The metal embrittlement is a question. 17-23-0S: The age factors, when these plants were built and designed, they were designed for a 30 year life and then they went to 40 and now it's 60. It's rewriting history to say these can go safely on and on and on. 21-3-0S: The number of scrams being so bad you identified them in an Inspection Report tells me that the stress on hardware has to be terrible. What happens to those items that crumbles and no one is looking or there is not a pre-announced happening? What about the concrete? What about the floors? What about the sirens? What about the Control Room? 21-6-0S: You give them another five years to fix the problem which in effect makes NRC a party to the dangers to the hardware at both Watts Bar and Sequoyah because both emergency diesel generators there won't be an issue. They won't even work. 21-9-0S: And remember that all of these issues have safety implications and must be in the SER, the Safety Evaluation Report. All of these items must be identified and evaluated prior to you giving a license extension because, if they're not, that makes you, NRC, culpable in whatever happens.

Response: These comments concern issues related to NRC's safety review of the license renewal application as well as issues related to other safety concerns and past safety performance at SQN. The NRC performs an environmental review of an applicant's license renewal application to determine the environmental effects of operating the nuclear power facility for an additional 20 years. The Commission determined that the NRC would prepare an environmental impact statement for each license renewal action to fulfill its responsibilities under the National Environmental Policy Act of 1969 (NEPA). The NEPA process focuses on environmental impacts rather than on issues related to the safety of an operation. Because the NEPA regulations do not include a safety review, the NRC has codified the regulations for conducting an environmental impact statement separate from the regulations for reviewing safety issues during license renewal. The regulations governing the environmental review are in 10 CFR Part 51 and the regulations covering the safety review are in 10 CFR Part 54. For this reason, the license renewal process includes an environmental review that is distinct and separate from the safety review. Because the two reviews are separate, operational safety issues and safety issues related to aging are considered outside the scope for the environmental review, just as the environmental issues are not considered as part of the safety review. However, safety issues that are raised during the environmental review are forwarded to the appropriate NRC organization for consideration and appropriate action. The intent of the NRC's safety review is to determine if the applicant has adequately demonstrated that the effects of aging will not adversely affect any systems, structures, or components, as identified in 10 CFR 54.4. When the plant was designed, certain assumptions were made about the length of time the plant would be operated. During the renewal process, the applicant must also confirm whether these design assumptions wifl continue to be valid throughout the period of extended operation or whether aging effects will be adequately managed. The applicant must demonstrate that the effects of aging will be managed in such a way that the intended functions of "passive" or "long-lived" structures and components (such as the reactor vessel, reactor coolant system, piping, steam generators, pressurizer, pump casings, and valves) will be maintained during extended operation. For active components (such as motors, diesel generators, cooling fans, batteries, relays, and switches) on-going surveillance and maintenance programs will continue throughout the period of extended operation. For safety issues outside of scope of license renewal, the NRC's regulatory requirements governing a plant offer reasonable assurance of adequate protection. The NRC evaluates plant safety performance by analyzing two distinct inputs: inspection findings resulting from NRC's inspection program and performance indicators (Pis) reported by the licensee. Both inspection findings and Pis are evaluated and given a color designation based on their safety significance. Green inspection findings indicate a deficiency in licensee performance that has very low risk significance and therefore has little or no impact on safety Green Pis represent acceptable performance and likewise have little or no impact on safety Both green inspection findings and Pis allow for licensee initiatives to correct performance issues before increased regulatory involvement is warranted. White, yellow, or red inspection findings or Pis each, respectively, represents a greater degree of safety significance and therefore, trigger increased regulatory attention. NRC Inspection Findings for each plant are documented in inspection reports and posted on the plant public website along with the Pis. Performance results for SQN are available at hffpJ/wWW.nrc gov!NRRIOVERS/GHT!ASSESS!SEQI!seqt chart. him/ and, httpJ/www.nrc.gov!NRRIOVERSIGHTIASSESS!SEQ21seq2 chart. him/. The NRC addresses performance issues as necessary.

These comments are not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SEIS. Tritium Production Comments: 11-15-0S: Apparently TVA-- well, 1know TVA has already entered into an agreement with the Department of Energy to produce tritium until 2035. And tritium is a radioactive form of hydrogen that becomes a radioactive form of water. If it's ingested, inhaled, or absorbed through the skin, tritium can permeate living cells and cause damage at the cellular leveL So in both 2003 and in 2011, tritium was found in the ground water at Sequoyah. It's also leaking from the Watts Bar 1, where they're making it, cause the-- absorbed with the rod cladding. It's being absorbed into the rod cladding and then it's leaking into the river. So since we get our drinking water primarily from the Tennessee downstream from Watts Bar and Sequoyah, we've been exposed to that for these now, these, what will be 40 years when the license expires. And I don't think we need another 20 years of that just so the Department of Energy can have tritium made in a commercial --supposedly a commercial nuclear plant. And they're using it for military use because, as you all know surely, tritium is used to boost military bombs, making of bombs. And it's used for that purpose and so the Department of Energy wants those. But I don't think we should be supporting the making of bombs while we're poisoning our water. 11-23-0S: The idea that tritium is being made because of the Department of Energy's request so they can take that tritium to boost the making of their bombs in a commercial nuclear facility. Which the line between military and commercial nuclear facilities is getting really, really fuzzy. The radioactive mix oxide fuel use, also experimental, that's a problem. 15-1-0S: Attached you will find that the Tennessee Valley Authority (TVA) is considering production of tritium for nuclear weapons in the Sequoyah reactors. As the Nuclear Regulatory Commission has already licensed this activity, this issue clearly must be involved in any relicensing considerations of the Sequoyah reactors. 21-2-0S: Tritium issues for weapons for DOE and DOD are beyond the design basis not only of Sequoyah but for Watts Bar. Sequoyah was not designed for the t- bars and the numbers that are needed to produce the amount of tritium needed to fulfill the DOE contract. 11-36a-OS: The SEIS document states that extending Sequoyah operations continues 'potential availability' to support TVA's agreement with Dept. of Energy to produce tritium until 2035. Tritium is a radioactive form of hydrogen that becomes a radioactive form of water. If ingested, inhaled, or absorbed through the skin, tritium can permeate living cells and cause damage at the cellular level. In both 2003 and in 2011, tritium was found in the groundwater at Sequoyah. Tritium is also made at Watts Bar 1 where it has been leaking through the absorber rod cladding and where it has also leaked into the river. Chattanooga drinking water derives primarily from the TN River downstream from Watts Bar and Sequoyah. We have been exposed for 40 years and don't need another 20 years to satisfy the Department of Energy's desire to make tritium in a supposedly commercial power plant in order to boost fission in nuclear bombs for military use. 19-5a-OS: And the fact that I'm not sure how this is going to play into it, but the Sequoyah Plant has been mentioned as a possible producer of tritium. Response: These comments primarily concern potential tritium production at SQN. TVA has not submitted an application to produce tritium at SQN to the NRC. In the event that TVA was to submit an application to produce tritium, the NRC staff would evaluate the impacts at that lime.

These comments are not within the scope of the environmental portion of the license renewal review and will not be evaluated further in the development of the SE/S. Waste Confidence Comments: 9-13-0S: The NRC's environmental review process must calculate the environmental effects of not having a permanent storage facility; to properly examine future dangers and key consequences" of prolonged on-site nuclear waste storage. 17-16-0S: So the waste confidence, the waste, it was supposed to already be somewhere else. In the very beginning, they said, "Oh, don't worry about the waste." And there've been oh so many different ways to deal with it theoretically. But the reality is it's almost insoluble problem that nowhere in the world have they really answer. 17-17 -OS: So this licensing procedure can't even be finished until the NRC figures out what to do with the waste. They did something called waste confidence_ They said, Trust us. We have confidence we'll figure out what to do with the waste." Some of the independent environmental groups took the NRC to court and actually won. And the court said you got to have a plan. And that process is going on concurrently with this process. I think the feeling is that the NRC, oh, we'll get the waste confidence thing done and we'll get the Sequoyah thing done. And they'll all go together. But they can't relicense this plant until that waste is adequately addressed and there are a lot of plans to do that. Response: These comments concern Waste Confidence and waste storage issues. Historicafly, Waste Confidence has been the NRC's generic determination regarding the environmental impacts of storing spent nuclear fuel beyond the licensed life for operation of a nuclear power plant. This generic analysis has been incorporated into the Commission's NEPA reviews for new reactor licenses, license renewals, and Independent Spent Fuel Storage Installation (ISFSI) licenses through the Waste Confidence Rule. The Waste Confidence GElS and rule satisfy the NRC's obligations under NEPA with respect to post-licensed-life storage of spent nuclear fuel. On June 8, 2012, the US. Court of Appeals for the DC Circuit found that some aspects of the 2010 rulemaking did not satisfy the NRC's NEPA obligations and vacated the rulemaking. [New York v. NRC, 681 F. 3d 471 (D.C. Cir. 2012)]. The court indicated that in making either a Finding Of No Sigmficant Impact based on an Environmental Assessment or in an Environmental Impact Statement supporting the rulemaking, the Commission needed to add additional discussions concerning the impacts of failing to secure permanent disposal for spent nuclear fuel, and concerning the impacts of certain aspects of potential spent fuel pool leaks and spent fuel pool fires. In response to the court's ruling, the Commission, in CU-12-16 (NRC 2012a), determined that it would not issue licenses that rely upon the Waste Confidence Decision and Rule until the issues identified in the courl's decision are appropriately addressed by the Commission In CU-12-16, the Commission also noted that the decision not to issue licenses only applies to final license issuance; all licensing reviews and proceedings should continue to move fofl.Nard. The NRC created a Waste Confidence Directorate within the Office of Nuclear Material Safety and Safeguards to oversee the development of a Waste Confidence Generic Environmental Impact Statement and revised Rule. The final Generic Environmental Impact Statement and Rule will be issued in 2014.

For further information on Waste Confidence, refer to the NRC website at: http:llwwwnrc.gov!waste!spent-fuel-storaqelwcd.html Additionally, regarding spent nuclear fuel, the NRC has made changes to the "Onsite storage of spent nuclear fuel" issue and the "Offsite radiological impacts of spent nuclear fuel and high-level waste disposal" issue as a result of the United States Court of Appeals decision in New York v. NRC, 681 F. 3d 471 (D.C. Cir. 2012}, which vacated the NRC's 2010 waste confidence decision and rule (75 FR 81032 and 81037, December 23, 2010). The Category 1 "Onsite storage of spent nuclear fuel" issue was revised to limit the period of time covered by the issue to the license renewal term. Similarly, the NRC revised the Category 1 "Offsite radiological impacts of spent nuclear fuel and high-level waste disposal" issue by reclassifying the issue from a Category 1 issue with an impact level of small to an uncategorized issue with an impact level of uncerlain. These issues will be discussed in Chapter 4 of the draft SEIS. Furlhermore, on July 5, 2013, an Atomic Safety and Licensing Board (Board) issued decision LBP-13-08 in response to a petition for intervention and hearing request (Petition) filed by the Blue Ridge Environmental Defense League (BREDL), Bellefonte Efficiency and Sustainability Team (BEST), and Mothers Against Tennessee River Radiation (MATRR) regarding the license renewal application for SON. BREDL, BEST, and MA TRR filed their Petition on May 6, 2013. The Petition put forward eight proposed contentions. Contention 8 of this Petition asserled that "NRC cannot grant the Sequoyah license renewal without conducting a thorough analysis of the risks of the long-term storage of irradiated nuclear fuel generated by Sequoyah Units 1 and 2." The Board denied the safety porlion of Contention B and held the environmental porlion of Contention B in abeyance (without admitting or denying it) pending further direction from the Commission. The Board's decision may be found at ADAMS Accession No. ML13186A103. These comments are general in nature and prov1de no new and significant information. These comments will not be evaluated furlher in the development of the SEIS.

8. Postulated Accidents & Severe Accident Mitigation Analysis (SAMA) (PA)

Comments: The following comments express concerns with postulated accidents and Severe Accident Mitigation Analysis (SAMA). Identifiers: 2-1-PA, 10-4-PA, 10-5-PA, 10-8-PA, 10-16-PA, 11-24-PA, 17-1-PA, 17-2-PA, 17-10-PA, 17-21-PA. 22-2-PA Response: The NRC staff will address postulated accidents and SAMA in Chapter 4 and Appendix F of the SEIS. These comments will be addressed in Appendix A of the SEIS.

9. Radiological Waste (RW)

Comments: The following comments express concerns with radiological waste. Identifier: 4-2-RW, 5-2-RW, 10-12-RW, 11-18-RW, 11-37-RW, 12-2-RW, 17-9-RW Response: The NRC staff will describe the radiological waste associated with SON in Chapter 3 of the SEIS and will address impacts to radiological waste associated with renewal of the SON operating licenses and alternatives to renewal in Chapter 4 of the SE/S. These comments will be addressed further in Appendix A of the SEIS.

10. Support for License Renewal (SR)

Comments: 16-1-SR Our town and this region has benefitted from this facility, not only from a financial standpoint as to a standard of living that it provides for the people who reside here. 16-2-SR: Everything at Sequoyah Nuclear Plant that I have been affiliated with as either a representative of the city as a fire fighter or through city government has been totally open, totally above board. There've never been any secrets. I was in the facility during its construction, flew over it in the late1960s when they were digging the holes out in the rock underneath the ground cover. It's a magnificent facility. I have no concerns as far as the type of neighbor that Sequoyah Nuclear Plant has always been as far as safety. Yes, in any industry that is fairly new and the nuclear industry starting in the 1950s, yes, it's an old design. It's a well-proven design. I think I'm correct if I say that Sequoyah has broken the majority of the records in the United States for sustained power production and efficiency. Even though it is a branch of the federal government to that extent which is often identified with waste, it leads the industry in the reliability and sustainability of the power that it produces. And I would like to go on record not only as a citizen of this area, a lifelong resident, but I speak, I think, for the entire City Council and the vast majority of residents who reside in this area who would be affected in a negative aspect were there a problem there. We trust TVA. We trust their decisions and the fact that they have always kept us in the loop in any situation, whether it be good or bad. And that we wholeheartedly support their request for a license extension of the plant. Response: These comments are general in nature and provide no new and significant information. These comments will not be evaluated further in the development of the SEJS.

11. Surface Water (SW)

Comments: The following comments express concerns with surface water resources. Identifiers: 11-7-SW, 11-10-SW, 11-12-SW, 11-33-SW, 19-2-SW Response: The NRC staff will describe the surface water resources associated with SQN in Chapter 3 of the SEIS and wilf address impacts to surface water resources associated with renewal of the SQN operating licenses and alternatives to renewal in Chapter 4 of the SEtS. These comments will be addressed further in Appendix A of the SEIS. References 10 CFR 2. Code of Federal Regulations, Title 10, Energy, Part 2, "Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders." 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of Production and Utilization Facilities." 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."

National Environmental Policy Act of 1969. 42 U.S. C. 4321, et seq. [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, NUREG-1437, Volumes 1 and 2, Washington, D.C., ADAMS Accession Nos. ML040690705 and ML040690738. [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Main Report, "Section 6.3- Transportation, Table 9.1, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C., ADAMS Accession No. ML040690720 [NRC] U.S. Nuclear Regulatory Commission. 2005. NRC Management Directive 8.11, Review Process for 10 CFR 2.206 Petitions. ADAMS Accession No. ML041770328 [NRC] U.S. Nuclear Regulatory Commission. 2011 "Recommendations for Enhancing Reactor Safety in the 21s1 Century, The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." July 12, 2011 ADAMS No. ML111861807 [NRC) U.S. Nuclear Regulatory Commission. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Washington, DC. Office of Nuclear Reactor Regulation NUREG-1437, Revision 1, Volumes 1, 2, and 3. June 2013. ADAMS Accession Nos. ML13106A241, ML13106A242, and ML13106A244. Price-Anderson Nuclear Industries Indemnity Act, as amended, 42 U.S. C. 2210. [TVA] Tennessee Valley Authority 2013. Sequoyah Nuclear Plant, Units 1 and 2, License Renewal Application, Appendix E, Applicant's Environmental Report, Operating License Renewal Stage. January 2013. ADAMS Accession No. ML130240007, Part 2-8 of 8.

Comment Letters and Meeting Transcripts The following pages contain the comments, identified by the commenter's 10, comment number, and comment issue category. The comments are from the public seeping meeting transcripts, emails, and letters. The comments are presented in the following order:

1) Afternoon Sea ping Meeting

2) Evening Seeping Meeting

3) Comments received via mail or web, ordered by commenter 10 number

26 1 And the speaker after that will be Hardie 2 Stulce. Is that right? Okay. 3 Then, Sandy and Hardie and we're going 4 to ask that you limit your comments to five minutes to 5 start until we've gotten through everyone. And if 6 there's time left, we' 11 give you additional time after 7 the last speaker. 8 So, Sandy, go ahead. 9 And again we want you to say your name and 10 what organization you represent. And if your name 11 unusual or spelled in kind of an unusual way, please spell 12 it. Thank you. 13 MS. KURTZ: Am I close enough? Okay. I am 14 Sandy Kurtzi it's K-u-r-t-z. And I am an environmental 15 education consultant, but I'm here as a volunteer for 16 Bellefonte Efficiency and Sustainability Team and 17 Mothers Against Tennessee River Radiation. And we are 18 chapters of the Blue Ridge Environmental Defense League. 19 And I serve on that board as well. 20 we have a long, long list of concerns and 11-1-OR 21 reasons why we think that s should not the 22 relicensing should not happen. And so we certainly want 23 these to be reviewed and considered during this 24 Supplemental Environmental Impact Statement review, the 25 scoping session here. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

27 1 The original Environmental Impact 2 Statement was done when the plant was first opened back 3 in the 1980s and it seems like it's time to really start 4 from scratch, not just say that there's been no 11-2-LR 5 significant environmental impact at this point because 6 it's operating for all this time and, gosh, we haven't 7 really had an accident yet. So we can just, we can just rely on that same Environmental Impact Statement and we 9 can say that it's going to be the same way for the next 10 20 years, 20 years starting in 2020, because that's when 11 the first license expires. I know there was one 12 extension in between. 13 So it's questionable to think that there's 14 going to be no significant environmental impact in the 15 future just because -- and I don't think it's even 16 reasonable to say there's been no significant 17 environmental impacts in the past 32 years. But still 18 that's what NRC is saying. So I think that we need to 19 really begin from scratch again on that. 20 Aging is a real issue here. We have an old, 21 old, old, old plant. It's been operating with poor 11-3-OS 22 technology, outdated technology. Now the ice condenser 23 design, which you all know is a bunch of baskets to 24 cool off -- case of an accident it's going to cool off 25 the containment building of the reactor itself. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

28 1 that's old. 2 And furthermore, there's also there's 3 always concrete decay. There's pipes that have broken 4 that are 1 eaking. And I know TVA wi 11 say, well, we 've 5 been replacing these parts. And I know they just put in 6 the new steam genera tor. But there are parts you can' t 7 get to. They are buried; they're buried in concrete. 8 You don't know when they're going to leak. You don't 11-3-OS 9 know what's happening. cont'd 1 And they are they're aging. And I think 1 that's a very big concern to think that we are going to 12 give a license to continue on for 20 years without 13 worrying a lot about that aging situation. 14 There's concern over flooding. In the 15 light lessons learned from Fukushima and fact that 11-4-OS 17 are well -- they're too low. They need to put in flood 18 protection in case the earthen darns upstream give way. 19 And that certainly is an analysis that has to be done to 20 assess the risk to a growing urban population. When 11-5-OS 2 Sequoyah was first built, it was pretty rural out here 22 and now it i sn' t . And so we have a growing population. 23 And I think we need to assess the risk should 11-6-OS 24 those darns upstream break or an earthquake occurs. 25 Because we now also find out that we 1 in a possibly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

29 1 seismically active area. We had the Knoxville 2 earthquake recently in and around Knoxville. And just 3 was today a lady here was telling me we have a little small 4 earthquake here in this area just today. 11-6-OS cont'd 5 So if -- I think we need to figure out if 6 the design for Sequoyah is strong enough to withstand a 7 heavy earthquake. And I understand that magnitude 5 8 would be a good number to shoot for for protecting. 9 It's also I'm especially concerned about water 11-7-SW 10 use. And we have climate disruption -- more storms, more 11-8-CC 11 problems that way. And we also have growing industry, 12 business people that use the water in addition to the 13 drinking water, most of which comes from the Tennessee 14 River for Chattanooga. 15 And a nuclear plant uses seven -- if it's 16 a 1,000 megawatt and Sequoyah is a little bigger than 17 seven thousand fourteen hundred -- 714,740 gallons per 18 minute. So I'm concerned about the use of that water, 19 two-thirds of which does not go back into the river after 20 it's used to cool. The rest of it is hot and so we worry 21 about the fish and the aquatic community there in that 22 whole ecosystem. 11-9-AE 23 Thank you. 24 MR. HAGAR: Sandra, do you have more to say? 25 MS. KURTZ: Yes. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

30 MR. HAGAR: Then I'll add your name to the 2 last of the 1 t and you'll have another opportunity. 3 The next speaker will be Hardie Stulce. 4 Did I say that right? 5 MR. STULCE: Stulce. 6 MR. HAGAR: And the speaker after that will 7 be Don Safer. 8 MR. STULCE: My name is Hardie Stulce, 9 s-t-u-1-c-e. Employed by the city of Soddy-Daisy at 10 present. I have been associated with the ty either 11 through the volunteer fire department since 1972 till the 12 present. Have served on the City Council for four years, 13 two years of which I was Mayor. The comments that I'm 14 going to make are qualified to the point of from direct 15 experience. 16 Sequoyah Nuclear Plant and this is 17 unsolicited by anybody there. And I have a number of 18 ends that work there as you would expect in any small 19 community. Our town and this region has benefitted from 20 this facility, not only from a financial standpoint as 21 to a standard of living that it provides for the people 22 who reside here. 16-1-SR 23 But as far as the valley as a whole or the 24 Southeastern United States has directly benefitted from 25 1 of the endeavors of the Tennessee Valley Authority NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

31 1 since the 1930s. And to that case in point, there are 2 dams that were built in the 1930s that still don't have 3 any problems today. 4 Everything at Sequoyah Nuclear Plant that 5 I have been affiliated with as either a representative 6 of the city as a fire fighter or through city government 7 has been totally open, totally above board. There've 8 never been any secrets. I was in the facility during its 9 construction, flew over it in the late 1960s when they 10 were digging the holes out in the rock underneath the 11 ground cover. It's a magnificent facility. 16-2-SR 12 I have no concerns as far as the type of 13 neighbor that Sequoyah Nuclear Plant has always been as 14 far as safety. Yes, in any industry that is fairly new 15 and the nuclear industry starting in the 1950s, yes, it's 16 an old design. It's a well-proven design. I think I'm 17 correct if I say that Sequoyah has broken the majority 18 of the records in the United States for sustained power 19 production and efficiency. Even though it is a branch 20 of the federal government to that extent which is often 21 identified with waste, it leads the industry in the 22 reliability and sustainability of the power that it 23 produces. 24 And I would like to go on record not only 25 as a citizen of this area, a lifelong resident, but I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

32 speak, I think, for the ent City Council and the vast 2 majority of residents who reside in this area who would 3 be affected in a negative aspect were there a problem 4 there. We trust TVA. We trust their decisions and the 5 fact that they have always kept us in the loop in any 6 situation, whether it be good or bad. And that we 7 wholeheartedly support their request for a license 8 extension of the plant. 16-2-SR cont'd 9 Thank you. 1 MR. HAGAR: Thank you Hardie. 11 The next speaker is Don Safer. And after 12 that we'll have Kathleen Farris. 13 MR. SAFER: Thank you. I've already 14 introduced myself, but I'm Don Safer from Nashville with 15 the Tennessee Environmental Council and State Sierra 16 Club. I want to raise specific issues in the first five 17 minutes and I will want to speak again. Thank you. 18 The plant safety and security in the TVA 19 document that was sent out back in 2010 says that, "Severe 17-1-PA 20 accidents are defined as accidents with substantial 21 damage to the reactor core and degradation of containment 22 systems. Because the probability of a severe accident 23 is very low, the NRC considers them too unlikely to 24 warrant normal design controls to prevent or mitigate the 25 consequences. Severe accident analyses consider both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

33 1 the risk for the severe accident and the offsi te 17-1-PA 2 consequences." cont'd 3 What that means is that they just dismiss 4 out of hand the possibility of a severe accident and don't consider it at all in the Environmental Impact Statement. 6 Now at Fukushima two years ago/ they had a 7 severe accident. It was an accident that - and I was 8 around the first time this plant was licensed. And we 9 were promised that it wasn't possible to have that type 10 of accidenti that it was just impossible. And that was 11 the words that were used on many occasions when those 12 questions were raised. 13 Now at Fukushima 160,000 people have been 14 permanently evacuated from their homes. The cost is 15 going to be anywhere from fifty -- I've seen figures as 16 high as 500 billion dollars of economic cost to Japan. 17 I've seen figures that go up to around 11/ 000 square miles 18 of land that is permanently contaminated for human use 19 evacuated - farms/ homes, businesses. So 20 that's the kind of thing that a severe accident actually 21 has done two years ago. And that accident is ongoing. 22 They've still not got it under control. And there are 23 serious issues with the fuel that's -- the irradiated 24 fuel that's in the fuel pools there. 25 And we have a lot of irradiated fuel at 17-2-PA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

34 1 Sequoyah. Every single bit of it that's been there since 2 the -- that's been made there is still there, much of it 17-2-PA 3 in fuel pools. cont'd 4 At Chernobyl 200,000 people were evacuated 5 and the amount of deaths are anywhere from 4,000 to a 6 million, depending on who you ask. And the million is 7 actually quite well documented by Ukrainian doctors. 8 The tremendous - the people, I'm sorry, that are the most 9 likely to know. They evacuated permanently a 19-mile 1 circle wi Chernobyl in the center. 17-3-OS 11 So just imagine. Take a 19-mile c 12 from Sequoyah and that's what's possible in the event of 13 a severe accident. And that is not even being considered 14 in this process. And I ask the NRC in going through this 15 in a post-Fukushima time to take that into account in the 16 decision to relicense or not. How much time 17 do I have? 18 MR. HAGAR: You have five minutes now. 19 MR. SAFER: The other issue I think that is 20 important that I'll get into right now if I can find 21 my note is this issue about the li expectancy. I 22 have an AP article that was just written in the last year. 17-4-OS 23 I remember when these - as I said, these plants were 24 first licensed. They said 40 years was it. The 25 engineers that designed these things designed them for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .* N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

35 1 40 years. Adding another 20 years is really suspect. 2 And it's largely an economic decision. So this article 3 says they're rewriting history saying that these things 4 can go easily another 20 years. The metal imbrittlement 17-4-OS 5 is a question. cont'd 6 Just the design, I think later I'll get into 7 design of the ice condenser units which are remarkable except they're really wacky. I mean you've 9 got a lot of ice in there. But the ice condenser design 10 just briefly was identified after Three Mi Island as 1 being the most likely of all the United States reactors 12 containment to fail in a serious accident a 17-5-OS 13 loss of a coolant water accident where the fuel rods 14 are exposed. You get hydrogen buildup. They had to go 15 back and retrofit hydrogen igniters. 16 But this design was done in the a!60s. 17 There's a reason why only nine of these were built, 10 18 if you count Watts Bar 2. There's a reason why they're 19 s than 10 percent of the United States reactor f 20 and why not a single new one has been built. TVA did 2 the ones at Watts Bar that they had started. 22 But thank you. And for the record, I don't 23 see why we can't go on a little longer first. But thank 24 you. And I'd like to speak again. 2 MR. HAGAR: Understand, Don, you want NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

36 1 another opportunity. So you'll have that. 2 Kathleen Ferris. And then following 3 Kathleen will be Gretel Johnson. 4 MS. FERRIS: Good afternoon. My name is Kathleen Ferris. I *m from Murfreesboro/ Tennessee. 6 Cofounder of the organization called Citizens to End 7 Nuclear Dumping in Tennessee. I am speaking today 8 primarily/ however/ as a mother and a grandmother. 9 I gather that most of the people that I'm 10 speaking to here who are scientists are in the field of 11 physics or chemistry. And what I would like to ask you 12 to do today is to consider these issues in terms of the 13 biological perspective as opposed to the more I don't 14 know what the word would be for that. But the other 15 branches of science. 16 For many decades we have been warned by 17 physicians and public health officials 1 people like 18 Helen Caldecott and Dr. John Gofman and Rosalie Bertell 19 have told us the dangers of ionizing radiation to human 20 health. We have been told that it damages DNA and causes 21 mutations and that it is carcinogenic and especially to 22 children. Now there's no debating the issue that 23 nuclear reactors do emit radiation. There are routine 18-1-HH 24 emissions; there are spills; there are accidents/ some 2 more serious than others. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

37 1 However, TVA and the NRC, I have yet to see 2 a report that does not say, "No risk to the public," after 3 one of these things occurs. These reactors pollute the 4 environment, the water, the air. The rain rains down 5 radionuclides onto the grass, gets into our plants, into 6 our food chain. 7 There are many studies that have been done 8 mostly abroad that show that people, especially 9 children, who live near nuclear reactors have a higher 18-1-HH 1 incidence of cancer than the national averages or than cont'd 11 people who live at a greater distance. Back in the 1980s 12 there was one by at Sella eld in England that found 13 clusters of leukemia and cancer. In Germany around the 1 year 2010 was a government sponsored study that showed that the reactors tested there was almost double the rate 1 of leukemia - well, over double the rate of leukemia and 17 double the amount of other cancers in children. Another 18 study at Chepstow, Wales, a very recent one, shows that 19 three and a half times the risk of cancer to children than 2 the national average. 21 Now just this past week another study came 22 out from Sacramento. It was done at Sacramento County, 23 California, where there are approximately 1.4 million 24 people living. Rancho Seco is a reactor that has been 2 closed for 23, over 23 years. This study shows -- by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

38 1 going through all the cancer records of the state of 2 California, they have shown that there is a drop of cancer 18-1-HH cont'd 3 incidents in the 20 years since the closing. A very 4 precise number, 4,319 fewer cases over that 20 year 5 period. And many of these are women, Hispanics, and 6 children. Again children are some of the worst victims 7 of radiation poisoning. 8 National Academy of Sciences is currently 9 carrying on a study of reactors in this country to see 10 whether the cancer incidence is indeed higher or not. 11 The NRC is sponsoring that study and it's not yet 12 completed. Yet the NRC is going ahead with relicensing 18-2-HH 13 before knowing all the facts regarding human health in 14 the vicinity of these plants. 15 Now Hamilton County contains 134,000 16 people. I'm sure there are many, many more; I'm not sure 17 of the exact number within a 50-mile radius. I urge you 18 not to put these people at further risk by approving a 19 plant that's already -- reapproving, icensing a plant 18-3-OR 20 that's 40 years old that has a poor record of operations 2 with repeated scrams and that has a design that has been 22 called faulty, maybe not by the NRC or local people. 23 We have all seen horrors of somebody 24 dying of cancer. I know I have. And it's even much 25 worse if it happens to be a child. And I ask you, please, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross .com

39 1 to focus on not just - our society needs to focus not 2 just on cures for cancer but on prevention of cancer. 3 And this is one way that you can help do it. 4 Thank you. 5 MR. HAGAR: Thank you, Kathleen. 6 Gretel. 7 And after that, Sandy Kurtz, you'll have 8 another opportunity. 9 MS. JOHNSTON: I'd like to this into the 10 record. This is my comments and supporting documents. 11 MR. HAGAR: I understand you want this into 12 the record. 13 MS. JOHNSTON: Yes, sir. 1 MR.HAGAR: I'llturnitovertoDave. I'm 1 sure he'll make that happen. 16 MS. JOHNSTON: Okay, thank you. 17 Hi, my name is Gretel Johnston. That's 18 G-r-e-t-e-1. And I'm with a group called Mothers 19 Against Tennessee River Radiation and we're part of 20 Bellefonte Efficiency and Sustainability Team and the 21 Blue Ridge Environmental Defense League. 22 I come here today, first of all, I'd like 23 to challenge a basic assumption that's in this 24 Environmental Report. And that that the only 10-1-AL 25 alternative to extending this license is either to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

40 1 nothing and decommission, which I would recommend, or 2 to -- the other option is called, in your own words, as 3 the "reasonable alternative energy sources" as an 4 option. But the only options that are given this 10-1-AL 5 study are nuclear and gas powered power plants. cont'd 6 And many, many studies -- and I've included 7 them in the literature - have addressed the issue of how 8 to replace -- as we retire coal plants and nuclear plants, 9 how we replace dirty energy with clean energy. And the 10 first and foremost choice that we advocate is energy 11 efficiency. 12 Energy efficiency cannot only replace all 13 the power that's being generated by Sequoyah at this time 14 and quickly. It does not come on line slowly; it comes 1 on line quickly and creates a lot of jobs and it's less 16 expensive by far than nuclear. But it also will improve 17 the homes of the people of the Tennessee Valley. It will 1 improve your lives by giving you smal electric bills every month and as well as creating jobs and not fouling 2 our nest and putting dangerous radioactive poisons into 21 our ecosystem or fossil fuels either. 22 So our first line we recommend is that this 23 basic assumption that the only alternatives are dirty 24 fuels being looked at carefully and examined and that 25 that assumption be renegotiated for the power plant. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

41 1 That, if in fact another option is taken, that that could 2 be renewable energy or the first line we would recommend 10-1-AL 3 is energy efficiency. cont'd 4 In a study by Georgia Tech and Duke 5 University a couple years ago asserted that energy 6 efficiency programs in one decade in the South alone 7 could create 380,000 new jobs. That Is between 2010 and 8 2020, 380,000 new jobs. It would lower ectricity 9 bills by 41 billion dollars. And 1 while eliminating 1 the need for new power plants for two decades and saving 11 8. 6 billion gallons of fresh water. Now that's a major 12 environmental concern. And if this truly is an 13 environmental study, I think that this has to be taken 14 into consideration and considered as a viable modern 15 alternative. 16 As David Freeman says about the nuclear 17 technology and TVA, he says, "TVA is building yesterday Is 18 technology tomorrow. " And I have to agree 19 wholeheartedly with him on that. And I want to see us 2 looking towards the future and especially the future of 21 our children and grandchildren by providing them with a 22 clean and healthy environment to live and grow in. 23 And allowing radionuclides into our 24 environment not only affects the food chain, but it 10-2-HH 25 fects our very DNA. It changes the structure of our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

42 1 genetic makeup. That's a long range issue, you know, 2 just one of these radionuclides -- the power plant 3 creates 200. When the uranium goes in, it creates 200 10-2-HH 4 poisons that don't exist in nature. cont'd 5 Our body doesn't know what to do with them, 6 so they try and find the things that they most closely 7 resemble, whether it be iodine or potassium or calcium. 8 It tries to find that and it takes it up that way in the 9 bones, in the thyroid, and different parts of the body. 10 That's what it does with these radionuclides. 11 And they last for a very long time; some of 12 them are short lived. But we're talking about 200. And 13 some of them are extremely long lived. 14 What is it? The iodine 129 lasts 15 for-- what is it, 570,000,000 years is the half life? 16 That's 570,000,000 years, you know, that it's dangerous. 17 We can't even begin to absorb what that means. But it's 18 just not fair to the future of our planet, to future 19 generations, to living beings to impose this upon them. 20 So we call first of all for energy 10-1-AL 21 efficiency. cont'd 22 Thank you. 23 MR. HAGAR: Well, at this point all of the 24 speakers who signed up to speak have had the opportunity 25 to speak and so now we'll give the speakers who wanted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

43 1 to say more a second opportunity. 2 And, Sandy, Kurtz, you were the first. 3 And if it's all right with everybody for the 4 second go around, we' 11 expand the time available to 10 5 minutes per speaker. And perhaps that will give the 6 speakers an opportunity to finish. 7 Is that okay with you? MS. KURTZ: Sure. MR. HAGAR: Okay, 10 minutes. 1 MS. KURTZ: Where was I? I was talking to 11 you earlier about the water usage and how much water comes 12 out of the , every minute, 714,740 gallons per 13 minute when the plant is operating. And two thirds of 14 that goes up into the air through the cooling towers that 11-10-SW 15 we're all so familiar with. 16 And the rest goes back into the river and 17 is hot. There are regulations about how hot it can be, 18 but it is hot and it goes back into the river and affects 19 the fish. Although as I've been told, fish can swim 20 around the hot parts. But there are other macro 11-11-AE 21 invertebrates and small critters in water that are 22 called the dri community and they cannot swim around. 23 They are subject to whatever they run into. so that's 24 a problem. 2 And in fact, it's water that's going to be 11-12-SW NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

44 1 the constraining resource in the future. We cannot have 11-12-SW cont'd 2 nuclear plants using all that water that could be used 3 for other uses. And it Is just evaporating into the air 4 for the most and that that so causes climate change, climate disruptions as well. So I think we need 6 to -- I think that we are going to continued drought 7 conditions in between storms if predictions are 8 correct about that. 11-13-CC 9 And we are also going to have hotter water 10 and that has caused some shutdowns of nuclear plants 1 already here in the Tennessee Valley. I know that 12 Sequoyah and Watts Bar have both shut down because the 13 water in the river was too hot to take the hot water that 14 the nuclear plants were putting into it. So those 15 shut-downs that are caused by should be a 16 significant environmental impact and should be 17 considered as one of the possible things to analyze as 1 to how that's going to work. 19 Further shut-downs -- every there's a 20 shut-down, that is really, ly expensive. That costs 21 a lot for TVA to be operating shut-down and they have 22 planned shut-downs. But every time there's a 11-14-OS 23 scram-- that Is an emergency shut-down. And by the way, 24 Sequoyah has been cited by NRC having too many of 25 these emergency shut-downs in a I think that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

45 11-14-OS 1 happened last year. So that is a problem. cont'd 2 The other thing that I wanted to talk about 3 a little bit was the extension of the license. 4 Apparently TVA -- well, I know TVA has already entered 5 into an agreement with the Department of Energy to 6 produce tritium until 2035. And tritium is a 7 radioactive form of hydrogen that becomes a radioactive 8 form of water. If it's ingested, inhaled, or absorbed 9 through the skin, tritium can permeate living cells and 11-15-OS 1 cause damage at the lular level. 11 So in both 2003 and in 2011, tritium was 11-16-GW 12 found in the ground water at Sequoyah. It's also leaking 13 from the Watts Bar 1, where they're making it, cause 14 the -- absorbed with the rod cladding. It's being 15 absorbed into the rod cladding and then it's leaking into 16 the river. So since we get our drinking water primarily 17 from the Tennessee downstream from Watts Bar and 18 Sequoyah, we've been exposed to that for these now, 19 these, what will be 40 years when the license expires. 2 And I don' t think we need another 2 0 years 21 of that just so the Department of Energy can have tritium 22 made in a commercial supposedly a commercial nuclear 23 plant. And they're using it for military use because, 24 as you all know surely, tritium is used to boost military 25 bombs, making of bombs. And it's used for that purpose NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

46 1 and so the Department of Energy wants those. But I don't 2 think we should be supporting the making of bombs while 11-15-OS 3 we're poisoning our water. cont'd 4 The other issue, too, is about radioactive 5 mixed oxide fuel. That's another thing the Department 6 of Energy wants TVA to be using here. It's experimental 11-17-OS 7 in commercial nuclear plants, never been used in the United States in a commercial nuclear plant and Sequoyah 9 is not designed for it. So to say that TVA-- TVA to agree 10 to that, to using that mixed oxide fuel that's so 11 radioactive, more so than plain old uranium, I don't 12 think we should think about that. And that too, of 13 course, would be a significant environmental impact if 14 that leaks, gets loose, or we have an accident. 15 Spent fuel storage, you know, spent fuel 16 radioactive fuel that uranium that has been used in 17 reactor and then it becomes actually more radioactive and 18 it is taken out of the reactor and put into this fuel pool. 19 And the rods that where the uranium fuel is s is 20 highly radioactive rods --are put into the fuel pool. 21 And what's happening is it Is getting more and more 11-18-RW 22 crowded because they don 1 t know what to do with the waste. 23 Where shall we put the radioactive waste 24 there I s no place to ship it to? There ' s no setup 25 for that. And ides why have two places that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

47 1 radioactive when you can just leave it on site here at 2 Sequoyah? But how much more should we be making? So the 11-18-RW 3 crowding of the rods is a problem. cont'd 4 And when they take the rod density, there's 5 more opportunity for accidents when the rods are so much 6 closer together and fission can happen. So where do we 7 put it? These are the things that I think that the scoping should include. Where are we going to put those rods and keep the crowding smaller? And is 1 the Watts Bar radioactive waste also going to be 11 supported to Sequoyah, which has -- I think is true. 12 And has the proposed independent spent fuel 13 storage building been put in place and is it secure 14 enough? 15 Further, are there plans to put things into 16 hardened cask storage so that they are safer than they 17 are in the fuel pool? 1 I know that Gretel had just spoken about the decommissioning plans and the t that there are only 2 two alternatives mentioned, both of which either say 21 decommission -- and we would recommend that -- or and 22 build a new -- but the al ternat also says if you want 23 a new 40-year licensed nuclear plant. But you can't do 11-19-AL 24 it on the Sequoyah nuclear site. It's already poisoned 25 actually. So that doesn't sound like a good plan. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

48 1 wouldn't recommend any more nuclear plants. 2 The other is the gas fired generators to 3 replace Sequoyah Nuclear Plant, but again not on the 4 Sequoyah Nuclear Plant site because it's sort of no man's 5 land when you get a nuclear plant. People can't go there 6 again. It's kind of like a land grab, it seems to me, 7 kind of giving away your land which can never be entered 8 again because it always -- even in decommissioning, 11-19-AL cont'd 9 because it always has to be protected from the radiation. 10 So you're giving away to land to think about having 11 nuclear plants. But if they're going to be 12 decommissioned, it has to be certainly safe, too. 13 There are alternatives and I, too, would 14 suggest that NRC consider other alternatives besides 15 just those two. 16 I want to talk about radiation doses and you 17 have -- NRC has radiation doses. They have established lB standards and those standards for radiation tell all the 19 nuclear plants what level of dosages are okay, in their 11-20-HH 20 opinion, okay for you to receive. Some small amount that 21 they consider absolutely safe and below that there's no 22 problem. And that's how they figure out what the dosage 23 is going to be and how they say there's no public risk. 24 But we all know that there is no safe dose of radiation 25 because it's cumulative. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .. N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

49 1 I'll do the rest at the evening meeting or 2 maybe another time here. 3 MR. HAGAR: All right. Thank you, Sandy. 4 Don Safer, did you have some more to say? MR. SAFER: Yes, sir. 6 MR. HAGAR: Ten minutes, please. 7 MS. SAFER: Once again thanks for the 8 opportunity. Before I get started, I'd like to 9 recommend to everybody, especially the young people 10 working on the NRC on this project. It's called Tritium 11 on Ice. It gives a great history of the NRC, not totally, 12 but in regard to the ice condenser design and the tritium 13 question. And this man worked at the Sandia Lab for 25 14 years. He was highly respected until the truth finally 1 got to him, especially on this particular issue. 17-6-OS 16 And in here he says that there are serious 17 grounds for worry that ice condenser plants could undergo 18 catastrophic accidents exposing nearby populations to 19 fatal doses of radioactivity. And he goes on to 20 say - this is a dispassionate outside observer - "The 21 fact that the operator of the plants is the Tennessee 22 Valley Authority, a federal agency with a long history 23 of compromising nuclear safety, exacerbates the 24 potential danger. " 25 Now the history of TVA and nuclear is long NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 INWW.nealrgross.com

50 1 and it's not so pretty. And we've been very lucky that 2 we haven't had a major accident. Browns Ferry almost 3 went up because of the famous candle fire in 1974. And 4 if you don't know about it, you should look it up because 17-6-OS 5 it's pretty scary. cont'd 6 There have been improvements, but his main 7 point in here is that the ice condenser design is 8 fundamentally flawed from the get-go. It was originally 9 designed as a way to put make the containment vessel 1 less robust, not as thick, not as strong, not as big. So 11 it costs less. This is nuclear power on the cheap. 12 That 1 s not the kind of nuclear power that we really want. 13 We don t want any nuclear power, but on I cheap is 14 worst. That's why he says it's more likely to l. 15 The description of the ice condenser system 16 is very well done by Dave Lochbaum in his book. And the 17 ice condenser is a large vault-like structure which 18 encircles the base of the reactor containment building. 19 The ice condenser is subdivided into 24 bays. Each bay 20 has two hinged doors at the bottom of the wall between 21 the reactor containment building and the ice condenser. 22 Each bay contains 81 large 45 foot-tall baskets filled 23 with ice. Those doors, in a major accident those doors 24 are supposed to open. The ice is supposed to absorb the 25 heat. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

51 1 It's supposed to be chipped ice. And I 2 would like to ask the Resident Inspector of the NRC maybe 3 privately or maybe publicly to establish whether that ice 4 stays chipped or whether it becomes solid blocks of ice 5 and they dealt with the subsidence issue. But not on my 17-6-OS 6 10 minutes here, please. cont'd 7 The other major issue it's been mentioned 8 about the children. In doing research on this in a 9 Reuter's article from March 15th, 2011, it quoted, it 10 said between 12,000 and 83,000 children were born with 17-7-HH 11 congenital deformities according to the German 12 physicians group IPPNW, between 12, 000 and 83, 000 13 children born with deformities. Some of the deformities 14 of these children, if you have the stomach for it, they're 15 horrible. They're hardly human. 16 Chernobyl? 17 MR. SAFER: At Chernobyl, I'm sorry, 18 Chernobyl. What did I say? At Chernobyl, anyway at 19 Chernobyl. And so that's going back there. 20 The other thing that I would like -- next 21 thing I'd like the NRC to consider this application 17-8-AL 22 is the need for the power from this risky type of power. 23 Last year alone in 2012, according to the USA Today there 24 was over 13, 000 megawatts of wind power installed the 25 United States. That's 13 reactors like Sequoyah. In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 VYWW.nealrgross.com

52 1 one year without hearings l this, without the need to 2 go through these types of procedures, without the risk 17-8-AL 3 to the public, without the evacuation plans, without the cont'd 4 radioactive waste. At Sequoyah there's currently 5 1,174 metric tons of this high level radioactive waste. 6 It's easily one to three million times more radioactive 17-9-RW 7 than when the fuel went into the reactors. This is not 8 just spent fueli this stuff is a nightmare. 9 At Fukushima Unit 4, which is teetering and 10 if it falls there are concerns by scientists that it will 11 be a global environmental catastrophe if that Unit 4 if 17-10-PA 12 all the cesium in there spills and is spread. Well, the 13 amount of cesium -- amount of fuel rods in that pool is 14 far less than the 796 metric tons in the pools at Sequoyah 15 right now. There's also 378 metric tons in casks there. 16 So back to the need for it, the wind 17 potential, the solar potential in the valley, at this 18 point TVA is putting a restriction on the amount of solar 17-11-AL 19 that can be installed. *s so much more potential 20 to ins tall solar and it won' t even cost TVA anything but 21 the feed-in ff. People are willing to spend their 22 own money, put these solar panels on their roofs. And 23 TVA is putting a limit on how much solar power can go on 2 people's roofs. 25 I think it's to justify continuing to build NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

53 1 Watts Bar 2, continuing to operate Sequoyah, doing the 2 small modular reactors. They're doing everything they 3 can to slow down the renewables. 4 And there are credible sources. The 5 National Renewal Energy Lab in Colorado, it's a 6 Department of Energy funded think tank on renewable 7 energy. It says we can get all of our power in a reliable 8 grid by 2040 -- or 80 percent of our power in a reliable 17-12-AL 9 grid by 2040 from all renewable sources. And that's not 1 with -- that's without even evolving renewable 1 technology like it's going to evolve. 12 We don't need this plant. We need to get 17-13-OR 13 away from it. They're doing it in Germany. After 14 Fukushima, the Germans decided to shut down all of their 15 nuclear plants. They're going to do it by 2020, when 16 this license is set to extend the li another 20 years. 17 Certainly we can make plans and get rid of it. In Japan 18 after Fukushima, they had maybe one reactor operating. 19 They had to go cold turkey off of nuclear because the 2 people won't accept it anymore ter they've seen the 21 cost. 22 So we should have a phase-out at least. And 23 the beginning of the phase-out to stop licensing, 17-14-OS 24 relicensing these old plants that have a much higher 25 likelihood of problems, especially these ice condenser NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

54 17-14-OS cont'd designs. The idea of putting MOX in this reactor which 2 is under consideration TVA is the only utility that's 17-15-OS 3 thinking about using it -- is phenomenally ridiculous. 4 And this was tried in two ice condensers that Duke Power 5 owns. And those experiments failed, and Duke Power ran 6 away from it screaming. They won't touch the stuff. 7 And TVA now is the only utility that's even considering it. 9 So the waste confidence, the waste, it was 10 supposed to already be somewhere else. In the very 11 beginning, they said, "Oh, don't worry about the waste." 17-16-OS 12 And there 've been oh so many different ways to deal with 13 it theoretically. But the reality is it's an almost 14 insoluble problem that nowhere in the world have they 15 really answered. 16 Reprocessing is an environmental 17 nightmare. Ask the people in West Valley, New York where 18 they tried reprocessing. And this was years and years 19 ago - 20 or 30 years ago. And they're still cleaning 20 up the mess. The DOE is still cleaning up the mess. 21 And there's a plume of radioactive water that's headed 22 to the Great Lakes underground. And it's an 23 environmental nightmare for the people. 24 So this licensing procedure can't even be 17-17-OS 25 finished until the NRC figures out what to do with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

55 1 waste. They did something led waste confidence. 2 They said, "Trust us. We have confidence we'll figure 17-17-OS 3 out what to do with the waste." cont'd Some of the independent environmental groups took the NRC to court and actually won. And the court said 6 you got to have a plan. And that process is going on 7 concurrently with this process. I think the feel is that the NRC, oh, 9 we'll get the waste confidence thing done and we'll get 10 the Sequoyah thing done. And they'll all go together. 11 But they can't relicense this plant until that waste is 12 adequately addressed and are a lot of plans to do 13 that. But some of the best minds in the world have been 14 trying to figure that out for 50 years and have not 1 figured it out. 16 It's a nightmare stew of toxic substances 17 that absolutely have to be protected from the biosphere. 18 And we are not doing a good job of that. And that's why 17-18-HH 19 the background radiation levels are increasing. 20 If you want to find out more about the ice 21 condenser design again for the NRC, please read New Reg 22 1150. That was something that was developed in the 1980s 23 after Three Mile Island when there was a very serious 24 attempt at the NRC to study the reactors. And that's 17-19-OS 25 where the ice condensers came out as the very most likely NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

56 1 to fail. And that again was a study conducted by the NRC. 17-19-OS 2 And it needs to be part of debate about cont'd 3 whether this reactor should continue. It should have 4 been part of the debate about Watts Bar 2 and the 5 licensing there. 6 But I believe that there's a renewed 7 interest by the people of the country and at the NRC 8 in safety because of the tragedy at Fukushima. And I 9 trust that that spirit will infuse this process. 1 It is a fact that not one of renewal 11 applications has been denied. And I have people who have 12 called it rubber stamped. I hope that rubber 13 stamping stops and this will be a very serious 17-20-LR 14 consideration. 15 And thank you. 16 MR. HAGAR: Okay, I need to address an 17 administrative detail. One of the speakers has picked 1 up my clipboard off of this lectern. Oh, never mind, the 19 NRC speaker got it. 20 All right, we have all of the speakers who 21 signed up to speak have spoken, some twice. Is there 22 anyone else like to speak twice? Gretel? 23 Okay, Gretel. And you have 10 minutes, 24 please. 25 MS. JOHNSTON: Thanks, okay. A lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .* N.W. (202) 234-4433 WASHINGTON. D.C. 20005-3701 www.nealrgross.com

57 1 issues have come up. Let me see. t, I' 11 just 2 address some of the ways that - oops, uh-oh -- before 3 I address anything, I need to make sure that's not going 4 to -- can you all hear me all right? Good, okay. 5 I would like to talk about a number of issues 6 I have concerns about that are to Sequoyah. 7 Some of them apply to other nuclear power plants as well. 8 One of them that is specific to Sequoyah is what I 9 consider, our group considers, a compromi integrity 1 of the containment and that we consider it beyond the 11 design basis of this nuclear power plant. 10-3-OS 12 That the TVA sawed through the containment, 13 the concrete and the metal secondary containment, of the 14 building the reactor is in and 15 took out a broken generator and replaced it with a giant 16 crane. And this was not designed to be done. This power 17 plant was not designed for this. So this a beyond 18 design basis issue. 19 And I hope that the evaluators wi consider 2 that in the light of the integrity of the unit itself, 21 but also in the light of what it means in terms TVA's 22 willingness to cut into the containment structure, 23 thereby compromising it in order to cut costs to continue 24 the program. We think this is an unacceptable lack of 25 quality control at the very least and it shows li NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

58 1 concern for the safety and health of the citizens in this 10-3-OS 2 area. cont'd 3 Which by the way someone was wondering about 4 that. Within a 50-mile radius of Sequoyah, there are 5 over a million people, thanks to Pam Sann (phonetic) I 6 know that, and that is a major concern. 7 Another deliberately fabricated beyond design 8 basis ongoing event that has been mentioned earlier is 9 this extended use of cooling pools to store the 10 irradiated, spent -- it's called spent fuel, but it's 11 actually much more toxic than the uranium that goes into 12 the reactors because it has been enriched in the process, 10-4-PA 13 creating these radionuclides I talked about earlier. 14 In that the Homeland Security and Congress 15 asked the National Academy of Sciences to do a study on 16 this to decide whether it was dangerous, this overloading 17 of the cooling pools 1 and they recommended that all of 18 the fuel going into these cooling pools be removed after 19 five years and put into dry cask storage which is 20 considerably safer for all of us. 21 The ones in Fukushima, that's a lesson of 22 Fukushima, the dry cask storage/ came out unscathed. 23 The cooling pools we still don It know. That Is what they 24 were dropping water from the helicopters to try and 25 prevent a fire at the cooling pools. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

59 According to a very well respected Robert 2 Alvarez at the -- I'm sorry, I've forgotten where he 3 is -- the Policy Institute of some sort. Anyway he wrote 4 a study in 2012 and he quoted something that I think is 5 worth requoting, "A severe pool f they 6 said -- first let me preface it that they had known for 7 decades that severe accidents can occur cooling pools. 8 They've known that for decades. And he said, "A severe 9 pool fire could render about 188 square mi around the 10 nuclear reactor uninhabitable. Could cause as many as 11 28,000 cancer fatalities and cause 59 billion dollars in 12 damage according to a 1997 report the NRC by 13 Brookhaven National Laboratory." Sequoyah has 1 well over 1,000 metric tons of this higher irradiated 10-5-PA 1 radioactive trash and it's very, very dangerous stuff. 16 And it's stored in these cooling pools. In fact, 75 17 percent has been piling up in these cooling pools for 30 1 years now. They've only moved a quarter of it into dry cask storage. Now that Is a better rate than Watts Bar, 2 which is 100 percent in the cooling pools and Browns 21 Ferry, which is 88 percent in the cooling pools. 22 But basically they Ire just saving a buck by 23 keeping it in the pools and not putting it in the 2 dry cask storage. Okay, that 1 s beyond the potential 25 these concerns. They're potential non-deliberate beyond NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

60 1 design basis events such as floods or tornadoes. 2 The TVA dams are aging and they were not 3 built to withstain earthquakes in the way that big power 4 plants were. They don It have -- they Ire not up to those 10-6-OS standards and they are aging. And there have been many, 6 many failures of dams in America and TVA has suffered some 7 as well . And we ' re concerned that there could be a dam 8 failure that could trigger a domino effect above Sequoyah 9 and that numerous dams could break. And the integrity 10 of the cooling systems could be compromised no matter how 11 much planning we do . As we found at Fukushima, we cannot 12 foresee everythingi we are human. 13 Okay, another issue is maintenance. TVA Is 10-7-OS 14 record - and I found out when the tornadoes came in 2001 1 and we had the outbreak of tornadoes in April, there were 16 two of the eight backup generators that were inoperable 17 at Browns Ferry that day. One of those EF-5 tornadoes, 18 the strongest tornadoes known to man, touched down very 19 close to Browns Ferry within visual distance. And it was 20 a very close call because those are different kinds of 21 cooling pools. They're raised up in the air and all they 22 have is overhead containment or sheet metal roofs. 23 It's the same as Fukushima. That's what 24 built up and you saw those roofs blow off in Fukushima. 25 It's the same design. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 WWIN.nealrgross.com

61 1 Okay, so two of those were inoperable on 2 that day. The next day another one had to be shut down. 3 That's three of eight; that's a 40 percent failure rate 10-7-OS 4 in the backup emergency systems. con't And the irony of nuclear power plants is 6 that you have to have incoming power from another source 7 to keep them from being -- (Noise in background) 8 Is that me? 9 THE REPORTER: That's not you. 10 MS. JOHNSTON: Okay, I 'm glad. So you have 11 to have a backup power system for you power system and 12 that's a sad reality with nuclear power. 13 And, okay, I want to show you something 14 here. I notice in the ACRS that tornadoes were mentioned 15 and they talked about their study. Basically they did 16 their statistical work around two major periods. One 17 was a 37-year period from 1950 to 1986 and there were 31 18 tornadoes during that period in a 34-mile radius. And 19 then the next period was the next 15 years up to 2002 and 20 there were 23 tornadoes during that period. That is 10-8-PA 21 nearly doubling the rate in that period time. And this 22 only goes up to 2002. Okay, well, in 2011, as 23 you can see, this is NOAA track of the tornadoes that came 24 through the Tennessee Valley on April 27th, 2011. And 2 those circles are the 50-mile radius of our nuclear power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

62 plant in this valley. And Sequoyah had around 15 of 2 them, it looks like here. Someone else may count it 3 differently, but that's what it looked like to me. 10-8-PA cont'd 4 And I noticed in your report that you did 5 mention that and that TVA reported that three of them 6 touched down within 10 miles of Sequoyah. Your 7 statisticians predict unlikely odds of a direct hit on 8 Sequoyah. But I tell you, I'm not real confident with 9 gambling on this. There's a lot of people whose lives 10 are involved in this and I think we need to take it 11 seriously. 12 And I think what it's going to take is us 13 demanding that the dollar not be counted above our health 14 and safety. And I, of course, call for the 10-9-OR 15 decommissioning of Sequoyah. 16 Thank you very much. 17 MR. HAGAR: Thank you, Gretel. 18 Now is there anyone who wants another 19 opportunity to speak that's already spoken? 20 And there anyone in the audience that has 21 not yet spoken who wants to? 22 (Background comment} 23 MR. HAGAR: Okay, I understand we'll hear 24 from you later then. 25 I would remind everyone that we're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

44 1 microphone over to the next person. 2 And let me , though, if you're going 3 to quote from a document, if you're going to come up and 4 quote from a document, than quote from the 5 document, just identify the document. Because I know 6 from experience the NRC sta will pull that document and 7 validate those quotes. So don't spend a lot of time 8 quoting from a document, just the document. Just 9 a hint to you. 10 All right, Jimmy Green will be the first 11 speaker. And then Garry Morgan will follow that. 12 And Jimmy, you'll have-- what did we say, 13 six minutes? 14 MR. GREEN: Hello, I am Jimmy Green. I am 1 Clean Energy in Knoxville, Tennessee. We are a regional 17 non-profit conservation and energy consumer 18 organization with members in Tennessee and throughout 19 the Southeast. We focus on energy poli luding 20 nuclear issues since 1985. I'd like to thank you for 21 holding these public hearings today. 22 The main point I want to make is we wanted 23 to make sure that the NRC is aware that TVA is 24 to enter into the process of developing an updated, 19-1-AL 25 ed resource plan. Probably at the end of this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

45 1 year they're going to get started seriously on that. 19-1-AL cont'd 2 This will inform the question of whether or not the power 4 And so we would recommend that you closely 5 low the IRP process of TVA to see how that calculation ays out. Clearly not using this energy is going to be 7 the most efficient way to go and the least environmental 8 ct . And that ' s thing we're always recommending, efficiency and renewable energy as a and 10 ferred alternative. There's some other 11 ronmental issues I just wanted to mention that are 12 tied specifically to Sequoyah Plant. One is the 13 water requirements. That's been a big issue recently, 14 the amount of water that these plants take and the 19-2-SW 15 temperature rise. I'm sure you're looking at that. 1 Vulnerability to ooding obviously has 17 been in the news recently and still seems to be an issue 18 that hasn't been resolved. Well, I guess technically 19-3-OS 19 has revolved but not in your favor. 20 So the ice condenser ign is a problem. 19-4-OS 21 And the fact that I'm not sure how this is 19-5a-OS 22 going to play into it, but the Sequoyah Plant has been 23 mentioned as a possible producer of tritium and it has 24 also been mentioned as a poss plant the 19-5b-OS 25 possibility to use the Sequoyah Plant to burn MOX fuel, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

46 1 the mixed oxide 1. I think Browns Ferry was the rst 2 ice, but Sequoyah was mentioned on that, too. So when 19-5b-OS you go into this ronmental Impact thing, I think cont'd 4 t 's something you really have to take into account, 5 the possible use of MOX fuel in this thing. 6 And that's about all I have. Thank you. 7 MR. HAGAR: All right, thank you. Ga 8 Morgan will be next then Tim Anderson will follow 9 Gary. 10 MR. MORGAN: My name is Morgan. I am 11 from Scottsboro, Alabama. I'm here senting the 12 Blue dge Environmental Defense League. You might say, 13 well, what's this guy down river a hundred miles 14 concerned about up here at Sequoyah? 15 Well, the one factor other than the air we 1 breathe maybe the atives that we may have that 17 connects us all is the river back over here. What 18 happens up river affects ks down , whether 19 it be a nuclear power plant or a coal fired lity or 20 dumping that river. 21 I want to talk to you a little bit today, 22 not necess ly about the r r, but about emergency 23 planning and evacuation zones. One of the lessons from 20-1-OS 24 Fukushima was the discovery , "Hey, radiation just 25 does not stay within -- when there is a catastrophic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

47 1 failure of a system such as occurred at Fukushima, which 2 has occurred at Three Mile Island, which occurred at 3 Chernobyl, and the many near misses which has occurred 4 within the States. And that ion gets out 5 of that cont , it doesn't say, "Oh, lookie here. Here's that 10 zone." No, it don't do that. It 20-1-OS 7 goes where the wind blows it. cont'd 8 And Fukushima we learned may be a 9 120 miles downwind. It may be 160 miles downwind. That 10 is a concern. And s is the reason one of lessons 11 of Fukushima was consider the EPZs, Emergency 12 Planning Zones, Emergency Evacuation Zones. 13 currently TVA sends out and NRC approves 14 these Emergency Evacuation Zones. And this is ical. 15 There is nothing more tical in the environment than 16 us, the people. We are the most critical. We are. 17 I have a background in the mil in 18 nuc assurity and personal liability. We talk about 1 nuc assuri ty and personal liability, we always talk 20 about a pyramid. And the bottom of that pyramid and all 21 things nuclear is the people. This community and the 22 surrounding communi ties, at Sequoyah or any nuclear 23 plant is the people that support that pyramid. 24 You got Resident ors here. And I'm 20-1-OS 25 sure do not want to see TVA empl s, NRC employees cont'd NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

48 1 that work here, plus the citizens, the good police that's 2 here, the mayor, the City Council, everybody, the 3 citizens of the community. Nobody wants to see a serious 4 accident. But Lord forbid if that accident does occur, 5 you want to be ready for it. And one of the 6 lessons of Fukushima has came out and has been very 7 latently (sic) we are not ready. And I'm talking about 8 we as Americans. And the regulator, the power 9 providers, we're not ready to deal with that unexpected 10 accident. Because in our emergency planning, we tell 11 them radionuclides, "Oh, you can't go out of this 10-mile 12 zone." Well, ladies and gentlemen, I'm here to tell you 20-1-OS 13 it just don't work that way. cont'd 14 I am asking the NRC before they go forward 15 with any relicensing, whether it be Sequoyah or anybody 16 else, you better make improvements. I highly suggest 17 you make improvements on your emergency planning and your 18 emergency evacuation zones. It is required. And this 19 is being considered in the various tiers of the Nuclear 20 Regulatory Commission. Please include is as a high 21 priority at Sequoyah. 22 We don't like to think about the 23 unthinkable. And we know that everybody does the best 24 job that they can to ensure that that nuclear reactor over 25 across the ridge over there next to the river is very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

49 1 safe. But if that unthinkable does happen, you want to 2 be prepared. You want to be ready for it. 3 The emergency planning zones, the emergency 4 evacuation zones, 10 miles is not sufficient. Fukushima 5 has shown this. Other accidents have shown this. The 6 NRC's own planning has shown this. The weather shows it. 20-1-OS 7 And climate change is very important factor. cont'd 8 Extend the 10 miles zones out to 25, the food 9 intake zone which is currently 50 needs to be extended 10 out to a 100 miles. You need to train. You need to plan 11 and be ready for that unforeseen accident. Defense in 12 depth, good program. The other programs that the NRC 13 ensures that the power providers implement, good 14 program. 15 But if you're not ready for that unforeseen 16 accident, that which you cannot fathom in your minds, 17 then you're going to kill people. And nobody in this 18 room wants to see that happen. Be prepared, think 19 about-- NRC, please, think about extending the Emergency 20 Planning Zones and the Emergency Preparedness Zones in 21 this community. 22 And that includes, of course, I was reading 23 in documents where the NRC passes out the potassium 24 iodine. Down in Chattanooga, NRC passed potassium 25 iodine since you're 15 miles away. No, you only think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

50 1 about that 10 mile zone. Think about outside that zone. 2 I mean if you think about where you're going to help right here? The local police and local fire 4 are going to be very busy. That's where they're going 5 to get help is through their neighbors. Because I know 6 that all communities in the Tennessee Valley have 7 reciproc y agreements where they can call for extra 8 help. But if you don't plan, if you don't bring in 9 Chattanooga, if you don't bring in other areas over 10 to the west into this area, then you're failing in your 11 planning. That is something I have noticed. 20-1-OS cont'd 12 Many years the military has shown me, has 13 demonst that one of the greatest -- and Fukushima 14 showed that one the t failures is the failure 15 to plan adequately for emergency. I ask you to pay 1 specific attention to EPZ and Emergency 17 Preparedness. 18 Thank you. 19 MR HAGAR: Tim Anderson is our next speaker 20 and Sandy Kurtz will follow Tim. 21 TIM ANDERSON: Hello, my name is Tim 22 Anderson. I'm from Chattanooga, Tennessee. I'm here 23 today for Docket ID NRC-2013 0037. The c izens the 9-1-LR 24 United States have a right under the National 25 Environmental Protection Act 1969 to request that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

51 2 a third party comprehensive sk analysis that takes all 3 elements at such risks to the community, to our commerce, 4 to the environment into account. A report that truly 5 defines the human health ef s low dose exposures 6 and mental stress to the population living under such 9-1-LR 7 sks. cont'd 8 What are the true e s of cancer causing 9 agents reaching into our environment? 10 What are the true s of increased 11 storage or production of high level nuclear 12 waste? Due to the permanent storage issue this proposed 13 action should be considered a major action and, 14 there , require a new Environment Statement 15 under Section 102 42 USC 4332. 16 NEPA, the Environmental Quality 17 Improvement Act of 1970, has amended Sect 42 usc 4371 18 and Section 309 Clean Air Act as amended under 4 2 1 USC 7609, and we hereby request the study. 20 Also any study under these rules should so 21 include a comprehens study to determine if there 22 this speculative demand and whether it could 23 met through other sources that are now viable, including 24 renewable energy. 2 And the answer to that is, yes, we can, and, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 INWW.nealrgross.com

52 1 no, we don't have a true need to build more reactors and 2 can certainly phase out these 25 mile evac zones over the 9-1-LR 3 next decade. cont'd 4 Maybe decision needs to be postponed for 9-2-HH 5 five years to reassess the needs and the dangers based upon real time, up-to-date health studies. In any 7 event, I'm sure it's the goal of the Agency to move 8 forward. 9 We would ask that any study include the 10 long-term health s of low, mid, and high level 11 radiation on the surrounding community and the health 12 ef s on humans, born and unborn, and the s on 9-1-LR 13 human and the environment now and in the future. cont'd 14 In addition, any action by the 15 requiring a large burden on the area water 16 supply should provide a comprehensive study as to the 17 ef of the massive water u , including the s 18 to marine and human l associated with scheduled 19 re ses of various radioact isotopes and proposed 20 water temperature ses on the surrounding 21 water supplies and how that relates back to human 22 consumption, rights, and long-term environment impacts. 23 We also ask that Commission include 9-3-HH 24 following internationally zed study as a bas 25 for any comprehensive human lth impact studies. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

53 1 These reports show a positive link between increased 2 cancer rates and the release of low, mid, and high level 3 releases. 4 There are many studies regarding the fallout of Chernobyl 5 and the true effects to the population that are not being 6 considered. These reports even by the most conservative 7 estimates state that over one million additional cancer 8 cases have been attributed to that disaster. 9 And the studies that should be included are 10 the American Academy of Sciences 2008 Biological Effects 11 of Ionizing Radiation reports there's no safe level of 9-3-HH 12 radiation. cont'd 13 European Committee on Radiation Risk argues 14 that the existing risk model used by the NRC does not take 15 internal exposure into account. High rates of internal 16 exposure will mean a dramatic increase in cancer risks 17 for Fukushima residents with as many as 400,000 18 additional cases predicted by this model by 2061. 19 The Office of Science and Financial 20 Assistance Program Notice 9914, Low Dose Radiation, 21 says, "Each unit of radiation, no matter how small, can 22 cause cancer." 23 The German Federal Office of Radiation 24 Protection titled Epidemiology Study of Childhood Cancer 25- in the Vicinity of Nuclear Power Plants shows a causative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW (202) 234-4433 WASHINGTON, D,C, 20005-3701 www_nealrgross,com

54 1 link to young children developing cancer more ly 2 when they live near nuclear power plants. 9-3-HH cont'd 3 The American Cancer y states that 4 iz radiation is a proven human And 5 they go on to say that people living near or down-wind 6 of a plant are known as down-winders. 7 Any EI S should include a comprehensive 8 study as to the effects on the citizens and the commerce 9 and environment of having onsi te above 10 ground storage of high level nuclear waste. 11 lly the dangers of such storage and the fact 12 the storage site is already s its designed 13 city. 14 TVA also does not insurance 15 to cover a major event. Nor is there a public procedure 9-4-OS 1 place on how local and regional bus s will be 17 compensated for loss of bus s related income, 18 relocation of businesses, res s, loss of personal 19 items, homes, and cost of relocat 20 How does TVA propose to relocate an entire 21 in the event of a major event? How do they plan on 22 paying for a complete economic shutdown of the evac zone? 23 These are the s we as tizens in the 24 effected region have to burden so that the TVA can 25 continue to generate energy through nuclear reactors. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

55 1 The world thinks -- we don't have these 2 risks with so energy or other viable renewable energy 9-4-OS 3 forms. cont'd 4 Where do I go when I can't go home? Where 5 do I go when my bank is closed? Who noti s the elderly and disabl they need to get out of the area? 7 Where's your plan and where's your money? 8 World Bank projects that the evacuation 9 of the 19 mile radius implemented by the Japanese 10 government cost 225 llion dollars. 11 Please take these into cons ion. 12 Thanks. 13 MR. HAGAR: Sandy Kurtz, you' re up and 14 following Sandy will be Don Safer. 15 MS. KURTZ: Hi, everyone. I spoke earlier 16 today and I just want to summarize some of those 17 statements that I made so those who weren't at the 18 ea ier session might hear a our concerns -- a very 19 long st of people. 20 By the way, I'm with Bellefonte Efficiency 21 and Sustainability Team and Mothers Against Tennessee 22 River Radiation. We have a t outside, so if you want 23 to pi up some information after this, feel free to stop 24 by 25 We I tal ked about you've heard 11-21-OS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

56 1 something about the flooding, the flooding concerns, the 11-21-OS possibility of an cont'd 2 flooding mitigation concerns, 3 earthquake, climate disruption patterns which should be 11-22-CC 4 updated. We were concerned about that. 5 The idea that tritium is being made because 6 of the Department of Energy's request so they can take 7 that tritium to boost the making of their bombs in a 11-23-OS 8 commercial nuclear facility. Which the line between 9 military and commercial nuclear facilities is getting 10 really, really fuzzy. The radioactive mix oxide fuel 11 use, also experimental, that's a problem. 12 And the crowding of the radioactive fuel 13 rods and the so called spent fuel pool which is actually 14 a higher end radiation than when it started out in the 15 reactor --when the rod started out in the reactor. That 11-24-PA 16 is a concern and we would advocate for moving those, the 17 used fuel rods, after they cool and it takes about five 18 years for them to cool. To remove those and put them in 19 hardened cask waste cask storage. This radioactive 20 trash doesn't need to be in the pools where it actually 21 has more chance of exploding. 22 I talked about the alternatives that were 23 offered by TVA's draft EIS here. Application talking 24 about two alternatives, none of which mentioned the 11-25-OR 25 alternative of just shutting it down. That would be an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

57 11-25-OR cont'd 1 alternative that would be -- we think would be good. And 2 the idea that we don't need to that energy or that 3 it could be replaced with solar alternative or other 11-26-AL 4 alternative es. 5 I wanted to talk a little bit here though 6 about radiation doses. Apparently it seems that the 7 statement that public will continue at current ls 8 associated with normal operations and that these doses 9 also for the occupational doses to employees are going 10 to remain the same when the 1 is renewed. So we 11 don't need to worry about that, butt doses are all 12 well below the regulatory limits, they say. And so we 13 don't need to worry. 11-27-HH 14 Anot 20 years of this is not good because 15 ct no dose of radiation is safe and 's cumulative. 1 the additional time there is going to continue to 17 us citizens in a growing population, urban 19 ted on a daily basis from a nuc r power plant. 20 The thing that happens is those daily 21 radiation doses levels that they recommend seem to go up 22 if there is more in the air and then they call 23 background radiation. But at Fukushima that's what 24 happened. When the accident happened, suddenly the 25 people that were supposedly not suppos to receive a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

58 1 dose at a certain level, suddenly it was okay for those 2 people to receive a higher level and that was the standard 3 that they set. 4 So the radiation standard seemed to change 5 depending on how much is actually in the air. And our 6 radiation background-- so called background level --has 7 been rising over these years. So it is cumulative. 11-27-HH 8 There is cancer risks even without the accident. cont'd 9 And I think the other thing is that the 10 radiation standard -- and maybe NRC can look at this in 11 overall -- the standard for how much dosage you could get 12 is based on a what they call, the Reference Man. And the 13 Reference Man is a German white male, about five foot nine 14 and-- five foot four and 150, 170 pounds, something like 15 that. 16 Anybody qualify here? 17 The truth is that the studies now show that 18 it is women and infants and fetuses that are more subject 19 to radiation dose and cancer events. 20 So the problem is that the standard 21 themselves are not right. And I think that really needs 22 to be looked at. 23 The other thing that I wanted to emphasize 11-28-OS 24 here was that with the numerous accidents, scrams, 25 shutdowns, leaks, dishonesty, and equipment monitoring, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

59 1 lack of proper reports led, ignoring safety 2 procedures, poor nuclear education as Browns 3 Ferry fire thing, and allation of non-certified 4 equipment parts, we just the other day, does 5 not assure the publ TVA can properly run their 11-28-OS nuclear plants. cont'd 7 And that ice condenser technology, we 8 should not renew license. 9 MR. HAGAR: Thank you. 10 11 Don. 12 MR. SAFER: I spoke at length on the record 13 this a ernoon, but I appreciate the opportunity to k 14 again. 15 I'm from Nashville. And so I'll briefly go over some 16 things benefit of those that were not 17 afternoon, recognizing it will be repetitive s 18 ss. 19 The plant safety issues do not take into the 20 s take into account the ef s of serious 21 s that's beyond design basic accidents. And 17-21-PA 22 they just reject considering those out of hand in all of 23 the Environmental Impact s. So never gets 24 considered what the possibility in terms of a massive 25 ease of radiation. That's not of .this process. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

60 1 It's ifically excluded because it's to be so 17-21-PA 2 unli as to happen, but we've already seen happen cont'd 3 twice in our lifetimes. The lack of , just 4 this year 2012, over 13,000 megawatts of wind power 5 was put in place in the United States. It required no scoping ngs about mass releases of radiation. 7 That's 13 nuclear power plants the size of Sequoyah that 8 have gone online in the U.S. 17-22-AL 9 TVA has a propos in front of them today 10 for 3,500 megawatts of wind power to be brought in from 11 Oklahoma by a private company on a direct current line 12 through Arkansas and put into TVA grid in Memphis to 13 be used. That's 3, 500 megawatts. That's both Sequoyah 14 Plant and the Gallatin Steam Plant. That's just 15 scratching surface of what wind can do. 16 Solar energy is - TVA is putting the brakes 17 on solar every way that can every poss 18 situation. look it up. 's a budding solar 19 energy industry in the Valley. A of jobs, a lot 20 installers, it's jobs that can't be exported. It's jobs 21 that will cont And the people who have put solar 22 on their roofs guaranteed what r cost is going 23 to be for 30 TVA needs to encourage that instead 24 of this license renewal. 25 The factors, when se plants were 17-23-OS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

61 1 built and designed, they were designed for a 30 year life 2 and then they went to 4 0 and now it's 60. It's rewriting 17-23-OS 3 history to say these can go safely on and on and on. cont'd 4 The decommissioning hasn't been talked 5 about. There's a plant in Illinois that's going to cost a billion dollars at least to decommission, the Zion 7 Nuclear Plant in Illinois. 17-24-OS 8 TVA has about a billion or less in its 9 decommissioning fund, but they have six reactors to be 10 decommissioned at this point. There's not money for 11 decommissioning. 12 I would submit to the people of this 13 Soddy-Daisy area that you should get in line first and 14 start the decommissioning process while there is still 15 money in that fund because once that first billion is 16 spent I don't know where the money is going to come from. 17 And we've all seen the problems that the federal 18 government has with funding, sequestration, everything 19 else. So if you have confidence in 2040 that there's 20 going to be money to decommission, then you're living in 21 a different world than the one I see. 2 <-') Flooding-- I'm from Nashville. Two years 17-25-OS 23 ago we had a flood. I think it was two years ago, or maybe 24 nowit'sthree, I'msorry. Wehadaflood, 500or1,000 year flood. It was simply unbelievable. We had 17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

62 1 inches of rain over a two-day period. Little bitty 2 streams were flooding people out of their homes, washing 3 homes off their foundations. The Corp of Engineers lost 4 vehicles next to the darn they operate in Cheatham County, 5 the Cheatham Darn below Nashville and the Cumberland 6 River. 7 The Old Hickory Darn, which is the one 8 directly above Nashville on the Cumberland River, had to 9 be opened wide open and that's why downtown Nashville 10 flooded because that darn was in danger of being 11 overtopped. Had it been I overtopped, the darn would have 12 been washed away. It was not designed to be overtopped. 13 If that type of rain event had happened 14 here, I believe Sequoyah would be in great danger. There 15 is nobody that dreamt that much rain was possible in that 17-25-OS 16 short of a time. cont'd 17 I encourage you all at the NRC to take into 18 account some of the types of floods we've had like that. 19 That Nashville flood is not the only one that has 20 happened. These rain storms come in and they sit in one 21 area and they just dump and dump and dump. 22 Please, take into account not just darn 23 failure but a rain event of 17 or more inches in a 24 or 24 4 8 hour period. It simply will overwhelm and that's the 25 type of thing-- you can't have a tsunami here, but you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

63 1 could ~ure have a flood sort. 17-25-OS cont'd 2 And believe me, t responders in this 3 community are going to be hard-pres getting people out 4 of their homes and rescuing people from the highways. We even had one policeman that was washed downstream, who was trying to stop people from going on a ooded street, 7 West End Avenue, one of the major streets in Nashville 8 in Belle Meade, a high-class neighborhood. So flooding 9 is not to be taken lightly in this day and age. 10 I think I'll save the rest my time to 11 those who have not spoken before, but I thank you the 12 opportunity. 13 MR. HAGAR: Okay, Kathleen s, you're 14 next and then Brian Paddock will be the next speaker. 15 KATHLEEN FERRIS: My name is Kathleen 16 s and I'm from Murfreesboro, Tennessee. I'm 17 cofounder of a group called Citizens to End Nuclear 18 Dumping in Tennessee. But I speak here today as a mother 19 and as a grandmother. 20 I'm asking those of you who are ists mostly 21 physics and chemistry I suppose are your of 22 rtise -- to consider this renewal, license renewal, 23 terms of biological perspective. 24 For decades the public has been warned by 18-4-HH 25 physicians and public health officials of of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

64 1 ionizing radiation. And people like Doctor Helen 2 Caldecott and Doctor Samuel Epstein are continuing to 18-4-HH 3 warn us of the dangers. cont'd 4 We know that it causes changes in DNA that 5 cause mutations. We know that it is carcinogenic and especially for children. And I suppose as a 7 grandmother, the children are one of my main concerns. 8 I've got two little daughters who live near Philadelphia, 9 Pennsylvania and they are surrounded by nuclear 10 reactors. So the things I've learned about cancer 11 really are close to my heart. 12 It doesn't take a major accident for 13 reactors to emit radiation. There are routine emissions 14 that are required just to operate them safely, safer, 15 more safely. There are spills. There are accidents and 16 every time there are these -- not catastrophic, but 17 sometimes very close to catastrophic-- events, TVA and 18 NRC reassure the public there's no danger. There's no 19 risk to the public. I don't know how many times I've read 20 that on the NRC website. 21 What these reactors are doing is polluting 22 the environment. They pollute the water. They pollute 23 the air. When rain falls through polluted air, the 24 radiation is washed down into the ground. The plants 25 become radioactive. The cows eat the plants. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

65 1 radioactive iodine goes into the cows' milk. The 2 children drink the milk. It is not safe. This 3 radiation is getting into our food chain. And since we 4 eat lots of meat at the top of the food chain, we're 5 getting a lot of radiation just without the catastrophic 6 event. 18-4-HH cont'd 7 Now there are several studies, as Mr. 8 Anderson pointed out. There was one back in the 1980's 9 in Sellafield, England that showed that clusters of 10 cancers and leukemia. More recently around 2010, the 11 Germany government sponsored a study of the reactors in 12 Germany and they found for children under five years old 13 they had more than doubled the incidents of leukemia and 14 almost double for other types of cancer. Another study 15 more recent from that is from Chepstow in Wales. They 16 found that children were at three and one-half times the 17 risk if they lived close to a nuclear reactor as the 18 national average. 19 Now these are instances of cancers close to 20 the nuclear reactors, but there's another study that came 21 out; just last week it was released. It's from 22 California, Sacramento County, which has a population of 23 1.4 million. 24 Rancho Seco Reactor closed over 23 years ago and some 25 scientists have been going through the cancer registry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

66 1 for California trying to determine what has happened to 2 the cancer rate. They used the last two months of the 3 reactor's operation and then they've been studying 18-4-HH 4 what's been happening in the intervening 20 years. cont'd 5 And what they found is that a very 6 considerable drop in the cancer incidents since that 7 time. They have found 4,319 fewer cancer cases over a 8 20 year period. That's more people than died in the Twin 9 Towers. And of the people who are most effected are 10 women, Hispanics, and children. 11 An NAC study -- there is a National Academy 12 of Science study being sponsored by the NRC right now to 13 try to determine what the cancer incidence is around 14 nuclear reactors. And of that study which is continuing 15 now -- I'm sorry, I've lost my train of thought -- okay, 16 that study is not yet completed. And it probably won't 17 be for several years. 18-5-HH 18 So in addition to other questions asked 19 about the timing for this relicensing, my question is why 20 not wait until that study is in to determine whether we 21 should be relicensing aging reactors. 22 There are 134,000 people who live only in 23 Hamilton County and probably approximately a million in 24 a five-mile radius -- 50-mile radius. I would urge you 18-6-OR 25 for the sake of those children not to renew this license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

67 to pr?tect the people who live here. 18-6-OR 1 cont'd 2 Thank you. 3 MR. HAGAR: an Paddock. And lowing 4 will be Ann s. 5 Is that right? Ann Harris? MS. HARRIS: Yes. 7 MR. HAGAR: Okay, good. 8 MS. JOHNSTON: Bob, I would like to o 9 my t to Brian and Ann. They were not here the 10 session to speak. 11 MR. HAGAR: Well, there's three more 12 spea s to speak. 13 Gretel, you're the st person that signed 14 up? 15 MS. JOHNSTON: Yes. 1 MR. HAGAR: All right, I think we can do 17 that. 18 MR. PADDOCK: I'll take an extra minute. 19 MR. HAGAR: You'll have nine minutes 20 a piece. 21 MS. FERRIS: Thank you, Bob. 22 MR. HAGAR: You're come. 23 MR. PADDOCK: And I 1 so blessed not to 24 have to llow Ann, which is a very hard act to follow. 25 My name is Brian Paddock. I'm an attorney. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

68 1 I happen to also be the Tennessee Local Counsel for a 2 Challenge to the Environmental Impact Statement for the 3 Watch Bar 2 Unit, which is still under construction and 4 for which there are still legal contentions pending as 5 to the impact on water temperature and aquatic resources. 6 I suggest that the NRC staff take a close 7 look at this because all of the aquatic impacts 8-1-AE 8 heretofore in the licensing of these reactors was done, 9 based on modeling and not based on any real world 10 measurements. Since then TVA has gone back and done. a 11 considerable amount of real world biological assessment 12 and quite frankly, they have done a pretty good job of 13 it. 14 And you might look at what they've done in 15 terms of dealing with the Watts Bar 2 litigation contest 16 and see if you don't think they need to do the same thing 17 with respect to the impacts of the cooling water and 18 resulting hot water from the plants under consideration 19 here. 20 I cheer the legal committee for the 21 Tennessee Chapter of the Sierra Club. I was a Sierra 22 Club representative to the last integrated resource 23 plan, stake holder group. I've spent more than 14 full 24 days in meetings with TVA staff, with many other stake 25 holders, including industrial users and so on. So I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

69 1 fairly famil with TVA's pattern of generation 2 act ies. 3 I've so many NRC hearings, in 4 particular those NRC comes down and talks to 5 TVA about things, including whether it's ever going to be able to finish the Watts Bar 2 Plant and what went wrong 7 there. 8 I have a direct personal interest because while I'm now l Jackson County, I do own 10 a condominium on Manufacturers Road south of here. And 11 that's where my wife and I intend to retire. I'm not sure 12 what that means; it probably means a continuation of not 13 getting paid. And also having my grandchildren visit me 14 there. 15 First, I would call to your attention-- and 1 I think this has was rai in the questions. We 8-2-LR 17 seriously challenge that a ions in the Generic 18 EIS are still valid. I think many of them are out date 1 and I was glad to hear that the GEIS is ng 20 It's not clear to me how that fits and how well that 21 will be done to provide, in fact, an adequate 22 for the SEIS. And if the GEIS is still in rment or is 23 out of date, building an SEIS on a s is 24 on top of it, it seems to me, is legally tionable 25 under the National Environmental Policy Act. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

70 1 And quite frankly, we have to express some 2 discomfort with confidence in the NRC. For example, 3 recently there was a discussion of the venting that 4 needed to be available in post Fukushima circumstances. 5 And the Commissioners voted to say, yes, the staff should 6 go ahead and prepare a regulation to require vents, but 7 it would not require the filtration of radioactive 8 materials through those vents. 8-3-OS 9 In other words, the vents will be -- if the 10 regulation is finally adopted and if the operators 11 finally install those vents, the current policy posture 12 of the Commissioners is that they will not be required 13 to filter radioactives out of that, and thus, you are 14 going to permit obviously, in very unusual 15 circumstances, the release of radiation. So you might 16 look which way the wind is blowing where you live from 17 this plant. 18 NEPA requires a hard look and that's a very 19 interesting test for a lawyer. What's a hard look? 20 And I've read hundreds of NEPA cases and it 21 varies, but it does not appear here that there has been 22 or so far an active consideration of what would be called 8-4-AL 23 the no action option which would be not to issue a license 24 extension and to put the plant into a posture where it 25 would be decommissioned at the termination of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

71 8-4-AL 1 existing license period. cont'd 2 That would be very interesting when this 3 SEIS comes out. I would just -- and I mean this 4 respectfully -- remind the NRC and TVA that any federal 5 litigation challenging the SEIS will probably be tried 6 in Chattanooga. The judge will live downwind of this 7 plant. He may be very interested in the quality of the 8 environmental assessment that is done with respect to 9 this license extension. 10 Now the first issue, that bridge that needs 11 to be crossed has to be the need for electricity. As a 12 matter of fact, TVA sold fewer kilowatt hours in 2011 than 13 it did in 2010. And then it sold fewer kilowatt hours 14 in 2 012 than it did in 2 011. And the projection for 2013 8-5-OS 15 is that it may decline again. 1 People are, in fact, adopting efficiency 17 and despite TVA's extremely lame attempts to push energy 18 efficiency. With respect to energy efficiency, I would 19 offer for the record two i terns. One is TVA's Commission 20 by Contract Energy Partner Study, which shows it's doing 21 about a third of the one percent year-over-year reduction 22 in energy usage that it could accomplish. 23 I've sat on stake holder groups. We've 24 been promised for two years running we would see new, 25 better, and different energy efficiency programs out of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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                                -100-1 TVA and that's all been frozen.                   And it's been frozen 2 partly for a lack of revenue and partly because they don't 3 know how to do anything but sell kilowatts.

4 And secondly, the GAO did a similar study, 5 full consideration of energy efficiency and better 6 capital expense for planning. GAO, when they say we 7 don't think that TVA has really looked at the realistic 8 potential for energy efficiency. So those are yet 8-6-AL 9 unoffered. 10 One other factor you should look at is that 11 the USEC, the United States Enrichment Corporation, 12 which is a shuck and a boondoggle and has been for years, 13 to create nuclear fuel, has announced that it is closing 14 this year. That represents five percent of the entire 15 load and production of electricity. So we're going to 16 have a five percent decline this year apart from any other 17 energy efficiency. 18 On the 40 year design life, I offer you a 19 copy of the AP Report as it was summarized in our local 20 paper in Chattanooga saying historically everyone 8-7-OS 21 thought the plants were designed at best to last 4 0 years. 22 So the basic theory that the aging hardware is the only 23 thing that we really should be looking at and control is 24 far too narrow. 25 We will also be offering for the written NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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                             -101-1 comments and we would point to the problems of TVA's 2 nuclear management much of which has been mentioned in 3 these comments up to this point.

4 I would just point to a personal experience 5 where I went to the hearing on the Browns Ferry 1 Red 8-8-OS 6 Status and the Chief Inspector for NRC came. And I have 7 never seen a plant Chief Inspector, and I've been to a 8 lot of hearings, stand there and for an hour list what 9 was wrong in the plant. And essentially say that TVA had 10 shown that it was very good at making lists of things that 11 needed to be fixed, of safety problems that needed to be 12 addressed, of equipment that was not operating properly, 13 but all it did was make lists. 14 It could never seem to get any of the 15 significant including safety related equipment and 16 problems addressed and that's why now they've been in a 17 Red Status for so long. And this is TVA's nuclear 18 management's typical situation. They can do one thing 19 right at a time, maybe. 20 They managed to install the new steam 21 generators in the plant at issue here, but while they were 22 at it they fell behind in trying to get rid of the red 23 tag on Brown's Ferry, for example. 24 I would associate the club's comments with 8-9-OS 25 also the comments made by the Southern Alliance for Clear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 WW'N. nealrgross.com

74

                                 -102-1 Energy and those that have been made earlier on the ice 8-9-OS 2 condenser problem.

cont'd 3 Thank you. 4 MR. HAGAR: Ann Harris, you're up. 5 MS. HARRIS: I brought my documents with 6 me. They're all NRC documents, so I don't expect them 7 to be disputed. 8 My name is Ann Harris and I live in Rockwood, 9 Tennessee. 10 MR. HAGAR: Ann, could you move the 11 microphone a little closer to you. 12 MS. HARRIS: The feedback knocks me down. 13 Surely you all can hear me. Trust me, you're getting 14 what I say. 15 NRC, I request that you identify and 16 evaluate the following items for potential environmental 17 impacts prior to any extension of the Sequoyah Nuclear 18 Plant license request for another 20 years. Substandard 19 parts in the area of parts associated with the Watts Bar 20 parts issue. There is evidence of shared parts. This 21 is a longstanding issue that's been on the books since 22 Unit 1. I was instrumental in putting this on Region 21-1-OS 23 II's list in the mid-1980s. 24 And I'm going to go through these pretty 25 fast, so if you've got questions, you'll have to hit me NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

75

                                   -103-1 up at home next week.

2 Tritium issues for weapons for DOE and DOD 3 are beyond the design basis not only of Sequoyah but for 4 Watts Bar. Sequoyah was not designed for the t-bars and 5 the numbers that are needed to produce the amount of 6 tritium needed to fulfill the DOE contract. 21-2-OS 7 And why should we have a fight with Iran and North 8 Korea for doing the same thing that we're doing here at 9 Watts Bar and Sequoyah? 10 The number of scrams being so bad you 11 identified them in an Inspection Report tells me that the 12 stress on hardware has to be terrible. 21-3-OS 13 What happens to those items that crumbles 14 and no one is looking or there is not a pre~announced 15 happening? What about the concrete? What about the 1 floors? What about the sirens? What about the Control 17 Room? 18 The ice condenser story knows no bounds. 19 The buckling floors, the sublimation, the hardware, the 20 basket, the screws, nobody knows because nobody is 21-4-OS 21 minding the store around the ice condenser. And we 22 certainly know that the ice condenser was not designed 23 to fit another 20 years. It's not going to make it 24 another 20, so everybody needs to start getting to higher 25 ground. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

76

                                   -104-1                    The                    , now, NRC, you 1 re going to 2 tell me that this only concerns Watts Bar.                  Watts Bar and 3 Sequoyah both are on the same reservoir.                     Both of them 4 will go down if that dam at Watts Bar goes down.                            21-5-OS That a             ion of a problem with                    of earthen dam being a problem has been on the books since 7 the late 1980s                     I was the one that put it on the 8 books as a concern because I lived in that community.

And for you to from the 1980s to 1998, 2004 or 2005, 1 and now here in your current Inspection Report, of which 11 I'm carrying which is about an inch thick, 12 is. It comes to my house on a regular basis from you 13 guys. 14 You give them another five years to X t 15 problem which effect makes NRC a party to the dangers 16 to the hardware at both Watts Bar and Sequoyah e 17 both emergency diesel generators there won 1 t be an sue. 18 They won't even work. 21-6-OS 19 So what are you going to do about backup 20 e city whenever those things go down because there 21 was a flood in this town the city of 22 tanooga -- in the mid-8Os that put underwater massive 23 amounts of this end of the state Tennessee. Go back 21-7-OS 24 and look. You can look through your history books. Go 25 down to the local library and you' 11 find pictures of it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

77

                                -105-1 because        was a major disaster.             Things that had never 2 been underwater s              TVA had built their first dam was 21-7-OS 3 automatical         underwater due to those rains.                               cont'd 4                  Decommissioning funds -- this is kind of 5 like reading              Bunny.        "Decommissioning funds,                a hundred        mill         dollars        disappeared         from        the 7 decommissioning funds in 2012."               This is reported in the 8 report to the SEC, so              's not my opinion.           I'm still 21-8-OS 9 quoting from you all's documents.                      At  that    rate in 10  another five years                   won't be any funds to exist 11  because if everybody keeps pull                   out a hundred million 12  dollars and this is their slush fund that they're using 13  which they've done it before,                         won't be anything 14  here to decommission anything                           s      dent or no 15  accident.

1 And remember that all se issues have 17 safety implications and must be in SER, the Safety 21-9-OS 18 Evaluation Report. All of these ems must 19 identified and evaluated prior to you giving a l 20 extension because, if they're not, that makes you, NRC, 21 culpable in whatever happens. 22 Delay in this extension will serve to show 21-10-LR 23 that the NRC has thrown away their rubber stamp. 24 Now for those of you people that l in this 21-11-OS 25 community and around these nuclear plants, TVA does not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

78

                                 -106-1 have any insurance to take care of your problems if there 2 is a nuclear incident.               They call -- only if a reactor 3 blows up, do they call it an accident.                    Look for the words 4 "unplanned         event"    and     "unexpected."           That's     called 21-11-OS 5 nuke's speak.

cont'd 6 Now the only compensation from any 7 accidents will come from the U.S. taxpayer. You're 8 going to pay now and maybe get it later. 9 Homeowner policies do not cover any nuclear 10 issues. Do not cover any nuclear issues. Go home and 11 read your homeowner's policy because it explicitly says, 12 "This is exempt from any nuclear accident or issues 13 surrounding them." 14 One of the things that was a discussion here 15 just a few minutes ago and whenever this gentleman here 16 whenever we had the discussion about the fire, if he would 17 look at the February 13th Inspection Report on Sequoyah, 18 he would find on page-- it's in the summary of Findings, 19 Enclosure 2, on Page 1 and 2 and 3. 21-12-OS 20 It says, "They were issued a violation for 21 failure to implement procedures required for fire 22 protection program implementations. And Inspectors 23 found multiple examples of where fire watches were not 24 conducted in accordance with NRC standards. A failure 25 to establish adequate procedures required for fire NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

                                -107-79 1 protection program implementation caused                     co~pensatory 2 measures.             The     program         implementation          caused 3 compensatory         measures,        fire      watches,      to    not       be 4 adequately         completed        and    could       have   potentially 5 compromised the ability to safely shutdown the plant in 6 the event of a fire in any of the fire zones where the 21-12-OS 7 fire watches were required."                                                     cont'd 8                    Maybe you,       Region II, maybe you ought to 9 give this up to these boys up in D.C.                       They probably 10 would appreciate it since this has to be something that 11 is not on their radar screen.

12 And my comments will be in writing and I will 13 send them in to the appropriate place. 14 Thank you. 15 MR. HAGAR: Thank you, Ann. 16 Well, at this point everyone who told us 17 they wanted to speak has had an opportunity to speak. So 18 let me ask again. Is there anyone in the audience who 19 wants to say something that has not yet had a chance to 20 do so? 21 Well, then let me thank everyone. Thanks 22 to everyone who prepared a presentation, delivered it. 23 Thanks to everyone who made statements on their 6wn. And 24 thanks to everyone who asked a clarifying question 25 because good exchange of information is what this meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

Page 1 of 1

                                                  -108-As of: March 26, 2013 Received: March 16, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                   Tracking No. ljx-848q-geyw Comments Due: May 03,2013 Submission Type: Web Docket: NRC-20 13-003 7 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority                                                             ;;~<,    , I              0*

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Penngrove, CA, 94951 0 .J:: 00 rn (/) General Comment 1-1-OS NRC needs to inform TV A that to grant a 20 year operating license renewal they must commit to comply with all NRC's Fukushima Daiichi Lessons Learned. I am concerned about: 1-2-OS

1. Station Blackout capability for much more than the current 4 to 8 hours of the Class IE batteries.

1-3-OS

2. Containment venting with filtration to essentially eliminate fission products releases after a core melt accident.

3. New seismic evaluation of the entire nuclear island based on the new geological information developed in the last few years.

1-4-OS SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM -03 /.~ ) Add= ~*:5~C:.. ~(!;.5 ?L. https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=09000064 ... 03/26/2013

Page 1 of2

                                                            -109-As of: April 08, 2013 Received: April 04, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                                  Tracking No. 1jx-8415-fca2 Comments Due: May 03, 2013 Submission Type: Web Docket: NRC-20 13-003 7 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-20 13-003 7-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority@

Document: NRC-2013-0037-DRAFT-0002 3/~fl/c9-CJ/:3 ~ Comment on FR Doc# 2013-05491 ""h

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                                                                                           ,..           -o Submitter's Representative: David Lochbaum                                                -........   :::;;::      :c ;::;:~

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co General Comment Environmental Report Section 4.21 addresses Severe Accident Mitigation Alternatives. As stated in Section 4.21.3, a SAMA analysis is required for license renewal unless one has previously been performed for other reasons. The Limerick nuclear plant in Pennsylvania did a SAMA analysis as part of its initial licensing process. When its owner applied for license renewal, it did not submit another SAMA analysis. Page 4-65 explains TVA reviewed 309 SAMA candidates. 262 candidates were screened out as either not being applicable to Sequoyah. 2-1-PA 47 SAMA candidates underwent further analysis and TV A identified 9 potentially cost-beneficial SAMAs for Unit 1 and 8 on Unit 2. As explained on page 4-66, because none of these potentially cost-beneficial safety upgrades is related to aging management - the focus of license renewal - none are required in TV A's view. Page 4-67 reports that TV A's analysis of SAMAs 286 and 288 for both units concldued that the "total averted cost risk from the senstivity analyses is greater than the implementation cost...". But Section 4.21.6 concludes that "None of the SAMAs are related to adequately managing the effects of aging during the period of extended operation. Therefore, they do not need to be implemented as part of license renewal pursuant to 10 CFR Part 54." SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM -03 / __ '- Add= /C* 59 )"()e c£es~ .J https://www.fdms.gov/fdms-web-agency /component/contemstreamer?objectld=090000648126a 73d&for... 04/08/2013

Page 2 of2

                                                         -110-As demonstrated by the Limerick case, SAMA analyses are not required for license renewal unless a SAMA analysis has not yet been done. Thus, the SAMA analysis is not linked solely to aging management during a license renewal period.                                                                                    2-1-PA cont'd The SAMA analysis is done for the environmental report. The environmental report considers alternatives to the proposed activity; namely, operating these reactors for 20 more years.

The environmental report's evaluation shows that operating these reactors without these safety upgrades for 20 years is the wrong thing to do from a legal and moral perspective. The Sequoyah licenses should not be renewed without these safety upgrades. https://www. fdms.gov/fdms-web-agency /component/contentstreamer?objectld=090000648126a73d&for... 04/08/2013

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                                                                -111-3/Ej~/_3 7%'/L. '/5ZJ65 As of: April24, 2013 Received: April16, 2013 Status: Pending_Post PUBLIC SUBMISSION
                                                                    @)                           Tracking No. 1jx-84t9-eceh Comments Due: May 03, 2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0003 Comment on FR Doc# 2013-05491 IJ                     =

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rr1 C) Nashville, TN, 37215 < 0 ~ nl i1 General Comment Please enter the following in opposition to the renewal of the relicensing of the Sequoyah Nuclear Plant. 3-1-OS As you are well aware, there are important safety issues, especially considering the advanced age of the Sequoyah Plant. Risks include flooding from the potential failure of dams upstream from the plant; earthquake risk; and a plant design that is inherently dangerous. There are important cost considerations as well. 3-2-OS I do not believe that a nuclear plant that has received 6 NRC safety citations related to possible flooding is a good bet for future compliance. We certainly need to bear in mind the frightening results ofthe Fukushima incident, especially 3-3-OS considering that flooding at Sequoyah has the potential to rise 2.4 feet above that which the plant can handle and could cost more than a billion dollars in modifications if such damage is to be avoided. Earthquake risk is also an issue because ofSequoyah's location in the Eastern Tennessee Seismic Zone, which has experienced large quakes within recent years. An earthquake of a feasible magnitude would cause severe damage and 3-4-OS possible catastrophic results. 3-5-HH Certainly foremost in the public's mind is the fear of harmful radiation exposure to the public; while the containment of an ice condenser reactor such as Sequoyah's would surely fail in an accident that involved hydrogen ignition. As noted by the Blue Ridge Environmental Defense League, ice condenser plants are exceptionally vulnerable, up to a factor of one 3-6-OS hundred times or more. 3-7-GW Other concerns include safety of drinking water, evacuation plans for a growing population in the area, and TV A's history of poor management practices. 3-8-OS The Sequoyah Nuclear Plant should not be relicensed based on the very real threats to public safety that have existed in the past and would continue to exist ifrelicensing were to be approved. SUNSI Review Complete 3-9-OR Template= ADM- 013 E-RIDS= ADM -03 Add= ~- :5~ (. 42-C.£"4-) https://www. fdms.gov /fdms-web-agency /component/contentstreamer?objectld=0900006481297 4ee&for... 04/24/2013

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                                                          -112-7~?1( /6Z<§~-              As of: April 24, 2013 Received: April17, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                               Tracking No. 1jx-84tz-s88z Comments Due: May 03,2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0004 Comment on FR Doc# 2013-05491 Submitter Information Name: Jeannie Hacker-Cerulean                                                                     t'->

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(f) General Comment SEND YOUR COMMENTS BY MAY 3, 2013

• ONLINE: http://www.regulations.gov and search for Docket ID NRC-2013-0037. Click "Comment Now" to enter your comments.
• MAIL comments to: Cindy Bladey, Chief~ Rules, Announcements, and Directives Branch (RADB), Office of Administration, Mail Stop: TWB-05-BOIM, U.S. Nuclear Regulatory Commission, Washington, DC 20555 0001.
• FAX comments:RADB at 301-492-3446 Nuclear Regulatory Commission:

4-1-LR It is important that TV A retire the permits on Sequoyah 1 & 2. The pem1its are already I 0 years past their 4-2-RW original (recommended) termination dates. We require that all nuclear material be interred in casks and left on site. Monies must be used to develop safer means of energy harvesting. 4-3-OS 4-5-OS 4-4-OS Ice Condenser Reactors are out of date and dangerous. By no means will MOX fuel be made at these These Tennessee Plants that are so close to Chattanooga. We look forward to a decline in Leukemia rates after all the spent fuel is in casks. 4-6-HH SUNSI Review Complete Template= ADM -*013 E-RIDS= ADM -03 Add= ~*vo/o~(ee_s~) https://www.fdms.gov /fdms-web-agency /component/contentstreamer?objectld=09000064812990bd&for... 04/24/2013

Page 2 of2

                                                          -113-Thank you for retiring the permits, Sign here:

Print Name: Address:

Contact:

P.S. TVA will be required by the citizens of Tennessee to redirect the funds being taken from our electric bills into developing cleaner technology: sun come up solar, passive solar, insulation, smart grid, small wind, slow rivers. There are better ways to turn the wheel of energy generation. This generation will have it their way! https://www.fdms.gov /tams-web-agency /component/contentstreamer?objectld=09000064812990bd&for... 04/24/2013

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                                                          -114-G/{)e/c;7t)J3 70'~;e_/0?:00-0 As of: April 24, 2013 Received: April 17, 20 13 Status: Pending_Post PUBLIC SUBMISSION                                                               Tracking No. 1jx-84u1-hs81 Comments Due: May 03,2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-20 13-003 7-DRAFT-0005 Comment on FR Doc# 2013-05491 Submitter Information

0 Name: Sylvia D Aldrich c:

r-Address: m (/) 8221 Fallen Maple Drive Chattanooga, TN, 37421-1243 General Comment Nuclear Regulatory Commission: 5-1-LR It is important that TV A retire the permits on Sequoyah 1 & 2. The permits are already 10 years past their 5-2-RW original (recommended) termination dates. We require that all nuclear material be interred in casks and left on site. Monies must be used to develop safer means of energy harvesting. 5-3-OS 5-5-OS These Ice Condenser Reactors are out of date and dangerous. By no means will MOX fuel be made at these 5-4-OS Tennessee Plants that are so close to Chattanooga. We look forward to a decline in Leukemia rates after all the spent fuel is in casks. 5-6-HH Thank you for retiring the permits, Sylvia Aldrich 8221 Fallen Maple Drive Chattanooga, TN 37421 615.604.1160 SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM -03 Add= _,;C* 6ct,YtJC!_ (-e<!_s¢-) https://www.fdms.gov /fdms-web-agency /component/contentstreamer?objectld=090000648129954d&for... 04/24/2013

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                                                          -115-y~p;£-/~~-6 As of: April24, 2013 Received: April 19, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                                Tracking No. ljx-84ut-rk8s Comments Due: May 03,2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal ofSequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0006 Comment on FR Doc# 2013-05491 Submitter Information                                         .........,
                                                                                         =rJ            =                      :n I..J,J                 c r-Name: Eric Blevins                                                                   ill            J>                      rn C)
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General Comment ......., *. (/) Please do not renew the permits for this nuclear plant. It has been operating longer than it was intended to, and as these plants get older, problems and meltdowns become more likely. 6-1-OR SUNSI Review Complete Template= ADM - 013 E-RIDS= ADM -03 Add= ,K."* 5c;_,YOC! (ees¥) https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=090000648129bd26&for... 04/24/2013

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                                                           -116-7~    ?J< g-/230 (i)

As of: April 24, 2013 Received: April 19, 20 13 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 1jx-84v7-twii Comments Due: May 03,2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0007 Comment on FR Doc# 2013-05491 Submitter Information .-...) 9  ::IJ

                                                                                          =rJ          VJ               cr-Name: Tara Pilkinton                                                                  rn            :t*;;n.
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General Comment 0 0 (/) Based on the age of the SEQUOYAH NUCLEAR PLANT plant and critical safety factors including flooding, earthquake and plant design Sequoyah' s license should not be extended. TV A's Sequoyah is at risk from flooding which could result from the failure of upstream dams. The Eastern Tennessee Seismic Zone, which extends from southwest Virginia to northeast Alabama, is considered to be one of the most active seismic areas east of the Rocky Mountains. It has the potential to produce large magnitude earthquakes. Recent large 7-1a-OS earthquakes include a magnitude 4.6 that occurred in 1973 near Knoxville and the Fort Payne Earthquake, also a magnitude 4.6, that occurred in 2003 near Scottsboro, Alabama. The containment buildings of nuclear reactors must do two things without fail: contain radioactive emissions during an accident and prevent intrusion from outside forces such as wind driven objects and man-made missiles. Sequoyah's nuclear reactors utilize "ice condenser" containment structures. Ice condenser nuclear reactors utilize baskets office to reduce heat and pressure in the event of an accident, preventing damage to the containment and leaks of radioactive steam. Typical nuclear power plants have concrete containment several feet thick, but ice condenser reactors substitute a steel shell of smaller volume and less ability to withstand pressure. Ice condenser reactors economize on concrete and are less robust because of this construction method. 7-1b-OS SUNSI Review Complete Template =ADM - 013 E-RIDS= ADM -03 Add= £*:5<7)/t)(! (~s-fL~ https://www.fdms.gov/fdms-web-agency /component/contentstreamer?objectld=090000648129db06&for... 04/24/2013

                                              -117-
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                                                                                               .c Paddock & Mastin Articles to be considered in the environmental review 8-10-OS

1) NRC, Industry say reactor life longer than 40 years.

2) GAO Report GA0-12-107- Tennessee Valley Authority, Full Consideration of Energy Efficiency and Better Capital Expenditures Planning Are Needed. 8-11-AL

3) Global Energy Partners' Study Identifies Significant Energy Savings Potential for TVA Customers.

SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM -03 . Add= /::* .~a/?C (-Cz/S"Y)

                                              -118-Sequoyah License Renewal Comment NRC-2013-0037 From:

Tim Anderson Chattanooga, TN Articles to be considered in the environmental review

1) The preparation of a plant specific supplement to the NRC's Generic Environmental Impact Statement

2) Any EIS Study should consider the findings of the following internationally recognized studies

3) Any study should include the impact of the more than thirty documented spills of radioactive material into the water and food supply that have already occurred in the Tennessee Valley by this operator

4) Storage of nuclear material and waste on site

5) Effects of waste dumps

                                                          -119-Nuclear Regulatory Commission - Docket ID NRC-2013-0037 April 3~ 2013 Re: The preparation of a plant specific supplement to the NRC's Generic Environmental Impact statement - comments Tim Anderson of Chattanooga,Tn The citizens of the United States, have a right under the National Environmental Protection Act of 1969 - to request that the "generic Environmental Impact Statement be thrown out and a third party comprehensive risk analysis that takes all of the elements of such risk to the community to our commerce, to the environment into account, a report that truly defines the human health effects of low dose exposeures and the mental stress to the population for living under such risk, 9-1-LR what are the true effects of cancer causing agents leaching into our environment. What are the also found true impacts of Increase permanent storage or production of high level nuclear waste; due to the in evening the permanent storage issue this proposed action is considered a major f ederal action, and transcipt therefore requires a new environmental impact statement under Section 102 (42 USC § 4332].

Authority: NEPA, the Environmental Quality Improvement Act of 1970, as amended (42 U.S.C. 4371 et seq .), sec. 309 of the Clean Air Act, as amended (42 U.S.C. 7609) And we hereby request a new study Any study under these rules s hould also include a comprehensive study done to determine if this 1

    ' speculative energy demand" could be met by other sources including the now viable renewable energy market, this is a c ritical part of any EIS provided, can we produce this energy without the constant risk of exposures to citizens within the 25 mile evac areas., the answer is yes we can, and no we don't have to have a true need to build more reactors and can certainly phase out these 25 mile evac zone " risk" over the next decades. Maybe the decision needs to be postponed for five years to re assess the needs and the dangers based upon real time up to date health studies. 9-2-HH In any event, lm sure it's the goal and the plan of these agencies' to move forward at all cost with also found in minimal concern of future generations. In that case -                                                      evening transcript We demand that Any EIS Studies will include - the long term health effects of low, mid and high level radiation on the surrounding community and the health effects on humans, born and unborn, and the effects to humans on the environment now and in the future- in addition, any action by a federal agency requiring a large burden on the area water supply should provide a comprehensive study as the effects of this massive water usage, including the effects to the       9-1-LR marine and human life associated with the "scheduled releasesn of various radioactive isotopes, and proposed average water temperature increases on the surrounding water supplies and how cont'd that relates back to human consumption, rights and the long term environmental impacts.

We demand that the commission include the following internationally recognized studies as a basis for 9-3-HH any comprehensive human health impact studies, these reports show a positive link between increased also found cancer rates and the release of low mid and high level releases- there are hundreds of studies regarding in evening the fallout of Chernobyl and the TRUE effects to the population, that are not being considered, these transcript reports even by the most conservative estimates state that over 1,000,000 additional cancer cases can be attributed to that disaster- FOR YOU EIS TO SHOW NO HARMFUL EFFECTS can't even be true due to the fact that even your own reports define an acceptable risk margin, to the population of one in 500 people therefore the fact is there are additional cancer rates that your report uses as a baseline and thus marginalizes. We just want the public to know the truth. I ..

                                                  -120-Any EIS Study should cons ider the findings of the following internationally recognized studies:                                                                               9-3-HH cont'd Any study cannot and will not be considered comprehensive unless it includes the results and processes of these studies among others -

The American Academy of Sciences 2008 "Biological Effects of Ionizing Radiation" report claims that there is no safe level of radiation exposure. The European Committee on Radiation Risk argues that existing risk models used by the NRC do not take internal exposure into account. High rates of internal exposure will mean a dramatic increase in cancer risk for Fukushima residents, w ith as many as 400,000 cases predicted by 2061. The Office of Science Financial Assistance Program Notice 99-14; Low Dose Radiation Research Program states, "each unit of radiation, no matter how small, can cause cancer and most of the projected radiation exposures associated with human activity over the next 100 years will be low dose and low dose-rate radiation from medical tests, waste clean-up, and environmental isolation of materials associated with nuclear weapons and nuclear power production. " A study commissioned by the German Federal Office for Radiation Protection titled "Epidemiological Study of Childhood Cancer in the Vicinity of Nuclear Power Plants" proves that young children develop cancer more frequently when they live near nuclear power plants. The American Cancer society states "Ionizing radiation" is a proven human carcinogen (cancer causing agent). The evidence for this comes from many different sources, including studies of atomic bomb survivors in Japan, people exposed during the Chernobyl nuclear accident, people treated with high doses of radiation for cancer and other conditions, and people exposed to radiation at work, such as uranium miners and nuclear plant workers. "They go on to say, 9-5-HH "people living near or downwind (also known as down winders) of nuclear facilities may also be exposed to radioactive byproducts. Levels of radiation are likely to be higher near these sites, but some radioactive particles enter the atmosphere and travel great distances, landing thousands of miles away from the facility."

• In addition to a comprehensive study of the effects of these reactors to the public health, commerce and environment, I call for a comprehensive action plan to be presented to the public covering risk, and instructions on how to keep our families safe, how to manage our food supply and what we can do in the event of an event - all residents within the 25 Mile Evac Zone should be included in this education process- through all forms of media and psa's 9-6-LR

                                                   -121-We also request an evaluation process as to whether this "proposed" increase in demand for energy could not be met with any other form of energy, such as solar or hydro, an energy source that doesn't carry the threat of a 25 mile dead zone for hundreds of years.                                        9-7-AL 9-3-HH ANY EIS should include a comprehensive study as to the effects on the citizens, commerce and also in the environment of having on-site storage "above ground" storage of high level nuclear waste, evening specifically the dangers of such storage and the fact that the storage at the site is already three transcript times the design capacity. The TVA does not have adequate insurance to cover a major event, nor is t here a public procedure on how local and regional business will be compensated for loss 9-4-OS of business related income, relocation of business, residents, loss of personal items, homes and also in cost of relocation . How does TVA propose to relocate an entire city, in the event of a major evening event, how do they plan on paying for a complete economic shutdown of a 50 mile EVAC zone. transcript These are the risk we as citizens in the effected region have to burden so that the TVA can continue to generate energy through nuclear reactors - we don't have these risk with solar energy or other viable renewable forms of energy- Where do I go when I can't go home, where do I go when my bank is closed, and who notifies the elderly and disabled that they need to get out of the area? Where is your plan? Where is your money?

The World Bank Projects the evacuation of the 19 Mile radius implemented by the Japanese Government and the subsequent cost of decontamination, medical cost and cost to relocate its citizens will cost $225 Billion dollars. Do you have 225 Billion is reserve for each plant that you operate? We need a real time public access monitoring systems, surrounding the plant in a concentric grid, showing the actual real time readings of radiation in the area, this needs to be done via the internet, through local government agencies and concerned citizens, in this manner we will not rely on the board or brass of TVA to let us know when there is an event or a release. There should be billboard size signs place on major thoroughfares that shows real time radiation levels for that sign location, so that daily commuters can become aware as to what's the background levels and when there are unsafe levels in the area. 9-8-HH While we're on the subject of notification, we would like the TVA and the NRC to provide an org chart and a process chart so that the citizens have full knowledge as to the process and the actua lly people at these agencies that have the authority to disclose or not disclose, release information to the public, also who makes the call to evacuate and how quickly is that decision made. We want to know who has that power over the citizens and have a right to know. 9-9-OS In accordance with NEPA and Section 309 of the clean air act, we ask for an evaluation of alternative modes of facility operations, including answering the question, can a portion or even all of this "proposed" energy demand be met more cost effective with environmentally friendly renewable energy, and ask that you evaluate alternative technologies and mitigation measures, and the environmental impact of these alternatives. 9-10-AL

                                                      -122-We need a detailed report as to the entrainment and impingement impacts on marine life; the impacts of the cooling water discharges and thermal backwash operations and fish return systems, we ask that 9-11-AE you look at retrofitting the current open loop cooling systems to mitigate these impacts. We also request an impact statement from the United States Department of the Interior as and the department of justice as to the legitimacy of the generic impact study and we consider these actions a major event which would constitute and more through study under Section 102 [42 USC§ 4332). Of NEPA.                9-12-LR The NRC's environmental review process must calculate the environmental effects of not having a permanent storage facility; to properly examine future dangers and key consequences" of prolonged on-site nuclear waste storage.                                                 9-13-OS At the end of the day the with the expiration of the operating license set to expire in 2020 and 2021, I feel these actions are premature, and are being aggressively pushed upon the citizens without adequate time for discussions, without time to study the health and impacts of 9-14-LR fukishima, and therefore again request additional public hearings on this issues as well as, something other than a generic impact study that hasn't been updated properly since like 1940 Any study should include the impact of the more than thirty documented spills of radioactive material into the water and food supply that have already occurred in the Tennessee Valley by this operator.

9-15-GW A local history of radioactive leaks into the groundwater and Tennessee River 20100407 Browns Ferry Unit 3 Approximately 1,000 gallons of radioactively contaminated water leaked from Condensate Storage Tank No. 5 as workers were transferring water between condensate storage tanks. A worker conducting routine rounds observed water leaking from an open test valve near the top of CST No. 5. 20080105 Browns Ferry Unit 3 The condensate storage tank overflowed due to failed tank level instrumentation. The spilled water flowed into the sump in the condensate piping tunnel, triggering a high level alarm that prompted workers to initiate the search that discovered the overflow condition. Some of the spilled water may have permeated through the pipe tunnel into the ground. 20060700 Sequoyah Unit 1 An investigation to identify sources of tritium in groundwater found detectable levels of tritium in the Unit 1 and Unit 2 refueling water storage tank moat water. 20060700 Sequoyah Unit 2 An investigation to identify sources of tritium in groundwater found detectable levels of tritium in the storage tank moat water. 20060200 Browns Ferry Unit 3 A soil sample taken from underneath the radwaste ball joint vault (located outside the radwaste doors) indicated trace levels of cobalt-60 and cesium-137.

                                                     -123-20060200 Browns Ferry Unit 1 A soil sample taken from underneath the radwaste ball joint vault (located outside the radwaste doors) indicated trace levels of cobalt-60 and cesium-137.

20060200 Browns Ferry Unit 2 A soil sample taken from underneath the radwaste ball joint vault (located outside the radwaste doors) indicated trace levels of cobalt-60 and cesium-1 37. 20051100 Browns Ferry Unit 1 Tritium levels greater than baseline values were detected in an underground cable tunnel between the intake structure and the turbine building. Samples taken in January 2006 identified gamma emitters in addition to tritium (beta emitter). 20051100 Browns Ferry Unit 2 Tritium levels greater than baseline values were detected in an underground cable tunnel between the intake structure and the turbine building. Samples taken in January 2006 identified gamma emitters in addition to tritium (beta emitter). 20051100 Browns Ferry Unit 3 Tritium levels greater than baseline values were detected in an underground cable tunnel between the intake structure and the turbine .building. Samples taken in January 2006 identified gamma emitters in addition to tritium (beta emitter). 9-15-GW 20050000 Watts Bar Unit 1 The radwaste line was discovered to be leaking. 20050300 Browns Ferry Unit 1 A leak in a pipe elbow on the east side of the cooling tower and an overflow of the cooling tower basin caused by malfunction of the system level indicators resulted in radioactive contamination of the concrete pad and ground around the tower. 20050300 Browns Ferry Unit 2 A leak in a pipe elbow on the east side of the cooling tower and an overflow of the cooling tower basin caused by malfunction of the system level indicators resulted in radioactive contamination of the concrete pad and ground around the tower. 20050300 Browns Ferry Unit 3 A leak in a pipe elbow on the east side of the cooling tower and an overflow of the cooling tower basin caused by malfunction of the system level indicators resulted in radioactive contamination of the concrete pad and ground around the tower. 20040000 Watts Bar Unit 1 The radwaste line was discovered to be leaking. 20030000 Watts Bar Unit 1 Beginning in 2003, tritium leaching into the ground from the plant has been found in site monitoring points. 20020400 Sequoyah Unit 1 Prior to excavation for the steam generator replacement crane foundation, sampling identified contaminated soil surrounding the Unit 1 refueling water storage tank moat drain. 20010100 Browns Ferry Unit 3 Tritium levels greater than baseline values were detected in an onsite monitoring well west of the Unit 3 condenser circulating water conduit in the radwaste loading area. 19981200 Watts Bar Unit 1 Radioactively contaminated soil was discovered beneath the concrete

                                                      -124-radwaste pad. 19980100 Sequoyah Unit 2 Radioactively contaminated water overflowed the Unit 2 additional equipment building sump and out the doorway to the ground outside.

19970500 Sequoyah Unit I Approximately 3,000 gallons of radioactively contaminated water spilled from the modularized transfer demineralization system when a conductivity probe failed. An estimated 600 to 1,000 gallons flowed through the railroad bay door to the ground outside. 19970500 Sequoyah Unit 2 Approximately 3,000 gallons of radioactively contaminated water spilled from the modularized transfer demineralization system when a conductivity probe failed. An estimated 600 to 1,000 gallons flowed through the railroad bay door to the ground outside. 19950500 Sequoyah Unit 2 Workers identified contaminated soil at the outfall of the Unit 2 refueling waterstorage tank moat drain pipe. 19850000 Sequoyah Unit 1 Radioactively contaminated water leached through a concrete wall of the condensate demineralizer waste evaporator building into the ground. 19850000 Sequoyah Unit 2 Radioactively contaminated water leached through a concrete wall of the condensate demineralizer waste evaporator building into the ground. 19830116 Browns Ferry Unit 3 A leaking tube in a residual heat removal heat exchanger allowed radioactive water from the reactor coolant system to be released to the river at levels exceeding technical specification limits. 19780715 Browns Ferry Unit 1 After the unit was shut down for maintenance, the residual heat removal system was placed in operation to assist shut down cooling of the reactor vessel water. Workers determined that a residual heat removal heat exchanger had a tube leak and that radioactively 9-15-GW contaminated water was being discharged to the Tennessee River "at a rate above permissible limits." 19770104 Browns Ferry Unit 1 A leak in a residual heat removal heat exchanger allowed radioactive water to be released to the river at levels exceeding technical specification limits. 19731019 Browns Ferry Unit 1 About 1,400 gallons of liquid radwaste of unknown, unanalyzed concentration was inadvertently discharge to the river due to personnel error. The liquid radwaste tank was intended to be placed in recirculation mode but was mistakenly placed in discharge mode. Source; Union of concerned scientist and NRC 15-16 January 1983 Nearly 208,000 gallons of water with low-level radioactive contamination was accidentally dumped into the Tennessee River at the Browns Ferry power plant. August 1979 Highly enriched uranium was released from a top-secret nuclear fuel plant near Erwin, Tennessee. About 1.000 people were contaminated with up to 5 times as much radiation as

                                                 -125-would normally be received in a year. Between 1968 and 1983 the plant "lost" 234 pounds of highly enriched uranium, forcing the plant to be closed six times during that period.

1983 The Department of Energy confirmed that 17200 tons of mercury had been released over the years from the Y-12 Nuclear Weapons Components Plant at Oak Ridge, Tennessee, the U.S.'s earliest nuclear weapons production plant In 1987, the DOE also reported that PCBs, heavy metals, and radioactive substances were all present in the groundwater beneath Y-12. Y-12 and the nearby K-25 and X-10 plants were found to have contaminated the atmosphere, soil and streams in the area. December 1984 The Fernald Uranium Plant, a 1,050-aere uranium fuel production complex 20 miles northwest of Cincinnati, Ohio, was temporarily shut down after the Department of Energy disclosed that excessive amounts of radioactive materials had been released through ventilating systems. Subsequent reports revealed that 230 tons of radioactive material had leaked into the Greater Miami River valley during the previous thirty years, 39 tons ofur.mium dust had been released into the atmosphere, 83 tons had been discharged into surface water, and 5,500 tons of radioactive and other hazardous substances had been released into pits and swamps where they seeped into the groundwater. In addition, 337 tons of uranium hexafluoride was found to be missing, its whereabouts completely unknown. In 1988 nearby residents sued and were granted a $73 million settlement by the government The plant was not permanently shut down until 1989. July 2000 Wildfires in the vicinity of the Hanford facility hit the highly radioactive "B/C" waste disposal trenches, raising airborne plutonium radiation levels in the nearby cities of Pasco and Richland to 1,000 above normaL Wildfires also threatened the Los Alamos National Laboratory in New Mexico and the DOE's Idaho National Engineering and Environmental Laboratory. In the latter case, the fires closely approached large amounts of stored radioactive waste and forced the evacuation of 1,800 workers. [See also 1986 and Mav 1997 .] Any EIS study sh ould include the effects of storing nuc lear material and waste on a s ite that is well over its design capacity, it should include a study as to how much the "background" radiation of the area will be increased based upon the increase in waste material and what is the long term and s hort effects as for the air, drinking water and food supply. In addition the study s hould include the 9-16-HH health ris k of and security ris k of transporting the materials to other locations. From 1946 to 1970 approximately 90, 000 canisters ofradioactive waste were jettisoned in 50 ocean dumps up and down the East and West coasts ofthe U S., including prime fishing areas, as part ofthe early nuclear waste disposal program from the military's atomic weapons program. The waste also included contaminated tools, chemicals, and laboratory glassware from weapons laboratories, and commercial/medical facilities 9-17-OS

                                                        -126-9-17-OS (Any study should include the effects that these waste dumps have had on the cont'd water, air and food supply including any physiological changes to any human, mammal or sea faring creature.

How It Doesn't Work - Risks and Dangers of Nuclear Energy

• Proliferation Risks
• Plutonium is a man-made waste product of nuclear fission, which can be used either for fuel in nuclear power plants or for bombs.
• In the year 2000, an estimated 310 tons (62o,ooo pounds) of civilian, weapons-usable plutonium had been produced.
• Less than 8 kilograms (about 18 pounds) of plutonium is enough for one Nagasaki-type bomb.

Thus, in the year 2000 alone, enough plutonium was created to make more than 34,000 nuclear weapons.

• The te-chnology for producing nuclear energy that is shared among nations, particularly the process that turns raw uranium into lowly-enriched uranium, can also be used to produce highly-enriched, weapons-grade uranium.
• The International Atomic Energy Agency (IAEA) is responsible for monitoring the world's nuclear facilities and for preventing weapons proliferation, but their safeguards have serious shortcomings.

Though the IAEA is promoting additional safeguards agreements to increase the effectiveness of their inspections, the agency acknowledges that, due to measurement uncertainties, it cannot detect all possible diversions of nuclear material. (Nuclear Control Institute)

• Risk ofAccident
• On April26, 1986 the No. 4 reactor at the Chernobyl power plant (in the former U.S.S.R., present-day Ukraine) exploded, causing the worst nuclear accident ever.
• 30 people were killed instantly, including 28 from radiation exposure, and a further 209 on site were treated for acute radiation poisoning.
• The World Health Organization found that the fallout from the explosion was incredibly far-reaching. For a time, radiation levels in Scotland, over 1400 miles (about 2300 km) away, were 10,000 times the norm.
• Thousands of cancer deaths were a direct result of the accident.
• The accident cost the former Soviet Union more than tlrree times the economical benefits accrued from the operation of every other Soviet nuclear power plant operated between 1954 and 1990.
• In March of 1979 equipment failures and human error contributed to an accident at the Three Mile Island nuclear reactor at Harrisburg, Pennsylvania, the worst such accident in U.S. history.

Consequences of the incident include radiation contamination of surrounding areas, increased cases of thyroid cancer, and plant mutations.

• According to the US House of Representatives, Subcommittee on Oversight & Investigations, "Calculation of Reactor Accident Consequences (CRAC2) for US Nuclear Power Plants" (1982, 1997), an accident at a US nuclear power plant could kill more people than were killed by the atomic bomb dropped on Nagasaki.
• Environmental Degradation
• All the steps in the complex process of creating nuclear energy entail environmental hazards.
• The mining of uranium, as well as its refining and enrichment, and the production of plutonium produce radioactive isotopes that contaminate the surrounding area, including the groundwater, air, land, plants, and equipment. As a result, humans and the entire ecosystem are adversely and profoundly affected.

 "  Nuclear Waste

• A typical reactor will generate 20 to 30 tons of high-level nuclear waste annually. There is no known way to safely dispose of this waste, which remains dangerously radioactive until it naturally decays.
• The rate of decay of a radioactive isotope is called its half-life, the time in which half the initial amount of atoms present takes to decay. The half-life of Plutonium-239, one particularly lethal component of nuclear waste, is 24,000 years.
• The hazardous life of a radioactive element (the length of time that must elapse before the material is considered safe) is at least 10 half-lives. Therefore, Plutonium-239 *will remain hazardous for at least 240,000 years.

                                              -127-3/z f )d-i3/3                                   ........,

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(/) Mothers Against Tennessee River Radiation Articles to be considered in the environmental review 10-11-AL

1) Sequoyah License Extension , Docket 10 NRC-2013-0037 10-10-AL also found in

2) Executive Summary Energy Efficiency in the South comment

3) GAO Report GA0-12-107- Tennessee Valley Authority , Full Consideration of Energy 8-11-AL Efficiency and Better Capital Expenditures Planning Are Needed .

4) Improving Spent-Fuel Storage at Nuclear Reactors 10-12-RW

5) Leaked Report Suggests Long-Known Flood Threat To Nuclear Plants, Safety Advocates Say 10-13-OS

6) Nuclear Tornadoes SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM -03 Add=  ;~ cJ- <-:J'ze-v(_e...(; 5.-!/)

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                                                         -128-                         (:_..,YB-    * !)~'\ AS i}vn Bellefonte Efficiency & Sustainability Team B.E.S.T.

A local chapter of Blue Ridge Environmental Defense League IT April3, 2011 Cindy Bladey, Chief, Rules, Announcements, and Directives Branch (RADB), Office of Administration, Mail Stop: TWB-05-B01M, U.S. Nuclear Regulatory Commission , Washington, D.C. 20555-0001 re: Sequoyah License Extension, Docket ID NRC-2013-0037

Dear NRC Environmental Impact Analysts:

As a representative of Mothers Against Tennessee River Radiation (MATRR), I come to this scoping session to express our concerns about Tennessee Valley Authority's (TVA) requested 50% beyond-design-life-span license extension for their Sequoyah Nuclear Power Plant (SQN) and about the Environmental Impact Statement they have submitted for Nuclear Regulatory Commission (NRC) and National Environmental Protection Act (NEPA) review. First, we think it is important to challenge the stated assumption that, "Possible alternatives to the proposed action (license renewal) include no action and reasonable alternative energy 10-14-AL sources," given that only nuclear and gas power plants are considered as "reasonable alternative energy sources." 1 We assert that Energy Efficiency and Renewable Energy are "reasonable alternative energy sources" that need to be identified and evaluated in the Supplemental Environmental Impact Statement (SEIS). To support our claim, we enter into the record multiple studies showing that Energy Efficiency Programs are definitively more economically viable and environmentally "reasonable alternative energy sources" than nuclear or gas power plants. All of the power generated by Sequoyah can be replaced by energy efficiency alone and new power can be generated with renewable sources, such as wind or solar. In fact, Energy Efficiency Programs can readily replace the existing power and provide for future power needs -offering significantly more jobs, coming 'on-line' more quickly, and enhancing the quality of life of TVA rate-payers by improving the efficiency of our homes, reducing monthly electric bills, and improving our environment by not emitting toxic waste. According to a Georgia Tech and Duke University study, assertive energy efficiency programs in one decade in the south alone can create 380,000 new jobs and lower utility bills by $41 billion, while eliminating the need for new power plants for two decades, and saving 8.6 billion gallons of fresh water. 2 And if more energy does need to be generated, solar is now less expensive than nuclear, and a 2012 federal report on renewable energy states that Tennessee alone has the technical potential of generating well over 2 million GWh of utility scale solar power.3 BEST/MATRR MATRR.org- Because It Matters 1 of 5

                                                  -129-10-14-AL cont'd Rather than "reasonable alternative energy sources", we believe this false assumption of limited options is biased toward environmentally unsound choices requiring the use of dirty nuclear and fossil fuels rather than the best replacement of existing power- which is first and foremost that of demand reduction through energy efficiency and heat recycling, and secondly through environmentally sustainable renewable energy such as wind and solar. That the SEIS has not included these options with its nuclear and gas generation alternatives indicates how behind-the-times TVA seems determined to remain, no matter what the cost to rate-payers or the environment.4 The NRC should not accept this assessment of environmental impact without studying and reasonably adjusting these basic assumptions about viable alternatives.

Our next area of concern is the compromised integrity of reactor containment at Sequoyah. This is a basic line of defense for the environment against nuclear contamination , and the very fact 10-15-OS that the reactor designers did not allow for replacement of the generators is cause for concern - along with the design fault issue of the ice-condensers being placed too near the reactors causing them to jam up in the baskets and not perform their designed cooling functions. TVA cut through the concrete and metal containment and lifted the top off the reactors secondary containment vessel in order to replace a generator that was not designed to be replaced. We consider this a "beyond-design-basis event" that was created, rather than mitigated, by the utility company. The fact that TVA was willing to cut into and compromise the nuclear containment, in order to cut costs for their nuclear program, shows an unacceptable lack of quality control and little concern for the safety and health of the environment for well over a million people in the area. Another deliberately fabricated "beyond-design-basis" ongoing event is the extended use of spent fuel cooling pools as storage tanks , rather than th~rc'Ul~ting cooling pools they were designed to be. As originally designed, and as recommended by a National Academy of Sciences study commissioned for Congress and Homeland Security in 2005, radioactive trash (or spent fuel) should be moved from the cooling pools into dry cask storage after 5 years , not continually packed into the vulnerable cooling pools. As Robert Alvarez states in the 2012 submitted article, "Improving Spent-Fuel Storage at Nuclear Reactors," nuclear safety studies for decades have said severe accidents can occur at spent fuel pools and the consequences could be catastrophic. "A severe pool fire could render about 188 square miles around the nuclear reactor 10-16-PA uninhabitable, cause as many as 28,000 cancer fatalities, and cause $59 billion in damage, according to a 1997 report for the NRC by Brookhaven National Laboratory." s Sequoyah has well over a thousand metric tons (about 2.5 million pounds) of highly radioactive waste with a history of improper storage.6 In 2010, for example, about 75% of 30 years of spent fuel was being stored in cooling pools. While this is better than the 100% pool storage record at Watts Bar and the 88% record at Browns Ferry, this clearly indicates the lack of attention by the corporate culture of TVA to the maintenance and security warranted by a nuclear power utility, which indicates a potential threat to our environment. The concentration of fuel, transfer and storage plans, and scheduled implementation of those plans needs to be identified and evaluated in the Safety Evaluation Report. Other concerns are potential non-deliberate "beyond-design-basis events," such as floods and 10-17-OS tornadoes. TVAs dams are aging and maintenance has been spotty at best. Many valley residents BEST/MATRR MATRR.org - Because It Matters 2of 5

                                                 -130-10-17-OS cont'd are concerned over the possibility of a catastrophic flood being caused by one or more dam failures. Dams were not built to the same earthquake safety standards as the power plants and one dam failure could trigger a domino effect upstream of nuclear power plants , possibly overwhelming the planned backup systems should 'all hell break loose'.

Responsible maintenance is another issue of concern. When tornadoes took out power to Browns Ferry for several days in 2011, two of the eight backup power generators were inoperable when the tornado hit and a third generator was shut down the next day. That is a 40% failure rate. If TVA maintenance is not keen for nuclear power plants, where NRC oversight is physically in effect daily, one wonders about the quality of maintenance at the many aging TVA dams upstream from Sequoyah. Multiple dam failure scenarios need to be identified and evaluated for the Safety Evaluation Report.? 10-18-OS We all know, from watching the Fukushima helicopters desperately dropping water on the reactors and cooling pools stranded without power backup generators, that nuclear power plants ironically must have a constant supply of power and of pumped water in order to prevent the environmental horror of reactor and/or cooling pool meltdowns. Another lesson of Fukushima is the necessity of preparedness for multiple events or even compound disasters. In the Tennessee Valley, we have what many here call a tornado corridor. Please note the submission, for the record, of the map of TVA nuclear power plants 50 mile radii superimposed on the NOAA Tornado Track of the April 2011 outbreak in this area. 8 The Safety Evaluation Report for Sequoyah needs to identify and evaluate not only the dual dangers of floods and tornadoes , but also the potential consequences of combined and compound disasters on the environment of our valley. 10-19-OS National Severe Storms Forecast Center reported 29-31 tornadoes within a 30 nautical mile radius of Sequoyah in the 37 year period between 1950 and 1986. Within the next fifteen year period ending in 2002, they reported 23 tornadoes in that same area 9 nearly doubling the incidence of tornadoes in the 30 nautical (34.5 U.S. mile) radjus. This record was up to the year 2002, and does not appear to address the increased incidence , size, and ferocity of tornadoes associated with the ongoing problem of climate change. According to the NOAA tornado track of the April 2011 outbreaks , here entered into the record, there appear to be about 15 tornadoes within that same radius,I 0 and according to the SEIS , three tornadoes touched down within 10 miles of Sequoyah (according to Kenneth Wastrack , TVA , personal communication) .II The increasing frequency, size, and severity of tornadoes due to climate change is a potential environmental hazard that needs to be identified and evaluated in the SEIS and Safety Evaluation Report. Although your statisticians predict unlikely odds of a direct tornado hit on Sequoyah, we are not confident with TVA gambling on the odds of a nuclear tornado disaster any more than we are comfortable with predicted cancer mortality rates around each nuclear power plant. It appears that the TVA SEIS staff as well as the concerned citizen activists who have focused on this 10-20-LR request for a renewal license can only address a percentage of the issues that need to be identified and evaluated for our safety. The very volume of issues necessary to mitigate the hazards and BEST/MATRR MATRR.org - Because It Maners 3 of 5

                                                      -131-Environmental Impact of extending the Sequoyah Nuclear Power Plant operating license another 50% beyond its design-basis life span, indicates the number of potential and known problems 10-20-LR with this inherently dangerous radioactive technology -and its potential and already known          cont'd deleterious impacts on the human environment.

We know that energy efficiency programs can 'supply' the energy we need at less cost for TVA 10-21-AL and at greater benefit to the people of this valley. We also know that renewable electricity can be generated for less money and with significantly less risk to human habitat. What we do not know is why the NRC continually enables an industry that is willing to gamble with human lives and habitats, despite the "reasonable alternative energy sources" of energy efficiency and renewables. Thank you for your consideration of our concerns and for your service at the Nuclear Regulatory Commission. ton, co-founder gainst Tennessee River Radiation for BEST/MATRR Bellefonte Efficiency & Sustainability Team (BEST) Mothers Against Tennessee River Radiation (MATRR) Encls:

/,<Executive Summary Energy Efficiency in the South.pdf>,

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From: 0 \J1 o-. rn (/) Sandra Kurtz Chattanooga, TN Comments to the Nuclear Regulatory Commission for Seeping regarding the Re-licensing for Sequoyah Nuclear Reactors 1 and 2 SUNSI Review Complete Template= ADM- 013 E-RIDS= ADM -03 ,::_ *._< '.**-/ *.\) Add= ,::. --~::_;CL-*t--:l<:::~_, (__ - ..... l

                                               -133-COMMENTS TO THE NUCLEAR REGULATORY COMMISSION FOR SCOPING REGARDING RECLICENSING FOR SEQUOYAH NUCLEAR REACTORS 1 AND 2 11-29-LR The Supplemental Environmental Impact Statement should not be supplemental given that the original EIS goes back to the 1980s. I dont think that NRC and TVA can say that in that time there has been no significant environmental impact and not really start from scratch. To say because its been operating for 32 years without significant environmental impact which is questionable in itself, is enough reason to give it a go ahead for another 20 years is faulty reasoning.

11-30a-OS Sequoyah Nuclear Plant Reactors 1 and 2 opened respectively in 1981 and 1982. By the time relicensing for 20 more years of operation is granted they will be 40 years old. They were actually designed for only 30 years of life. Aging increases risk of leaks and accidents that cause costly shutdowns. This past year NRC issued a notice of violation for too many shutdowns in a year (SCRAMS) at Sequoyah. 11-30b-OS There is concern over flooding in the light of lessons learned from Fukushima and the TVA discovery that their own calculations on flood risk at both Watts Bar and Sequoyah were too low. Analysis must be done to assess the risk to the urban population in and around Chattanooga should dams upstream break or an earthquake occur. Flooding mitigation must be done and is bound to be costly. 11-31-OS It is not out of the question for an earthquake to occur that would impact Sequoyah should it be above a seismic level of 4.9. With new information and Fukushima recommendations, an updated analysis is needed rather than relying on the original EIS. 11-32-OS In this age of climate disruption, water quality and quantity is of prime importance. 11-33-SW Nuclear Plants use inordinate amounts of water each day when operating and about twothirds is evaporated through the cooling towers and is not returned to the river. The Union of Concerned Scientists tells us that the typical 1,000 MWelectric nuclear power reactor can use up to a whopping 714,740 gallons per minute. This is water that could be used by other businesses, industries, and for drinking water. The water 11-34-AE returned to the river is carrying heat that has impacts for the aquatic ecosystem. While fish can move to avoid heated water plumes, the aquatic drift community and certain macroinvertebrates upon which fish feed cannot. In a climate unstable world, water will be THE ultimate constraining resource. We have already seen TVAs nuclear plants shut down because of summer temperatures that prevented proper cooling. With temperatures rising scientists predict periods of excessive rain, severe drought conditions, and hotter temperatures in the summer here. Climate change must be addressed as an environmental impact for this SEIS. 11-35-CC The SEIS document states that extending Sequoyah operations continues potential availability to support TVAs agreement with Dept. of Energy to produce tritium until 2035. Tritium is a radioactive form of hydrogen that becomes a radioactive form of water. If ingested, inhaled, or absorbed through the skin, tritium can permeate living cells and cause damage at the cellular level. In both 2003 and in 2011, tritium was 11-36-OS

                                               -134-11-36a-OS cont'd found in the groundwater at Sequoyah. Tritium is also made at Watts Bar 1 where it has been leaking through the absorber rod cladding and where it has also leaked into the river.      Chattanooga drinking water derives primarily from the TN River downstream from Watts Bar and Sequoyah. We have been exposed for 40 years and dont need another 20 years to satisfy the Department of Energys desire to make tritium in a supposedly commercial power plant in order to boost fission in nuclear bombs for military use. Then there is the possible use of radioactive mixed oxide fuel (MOX) being considered for use at the request of Dept. of Energy. It is experimental and never been used in a commercial nuclear plant and this one not designed for it. 11-36b-OS cont'd Spent fuel storage is inadequately protected as rod density in the fuel pool increases.

This rod crowding is a serious safety concern. Why have 20 more years of radioactive spent fuel? There are many questions that should be adequately analyzed and answered: Where do we put it and how will it be monitored and managed? Is the Watts Bar radioactive waste going to be transported to SQN as well? Has the proposed Independent Spent Fuel Storage Building been put in place and is it secure enough? 11-37-RW The SEIS states that there are only two feasible alternatives to consider meeting the need for power in the future? Alternatives: 1. Decommission SQN and build a new nuclear plant replacement with a 40year license somewhere besides the SQN site. 2. Construct new natural gasfired generators and infrastructure in place of SQN, but not 11-38-AL on the SQN site. Can it be that TVA and NRC cannot think of any other alternatives such as shutting SQN down and meeting power demand and even baseload with solar, wind, energy efficiency, demandside management, and other nowviable energy alternatives to name some? These will be cheaper, healthier and safer. Consider other alternatives. NRC found that radiation doses to the public will continue at current levels associated with normal operations and also for occupational doses to employees. We are told that the range of doses are all well below regulatory limits. Thus, it was concluded that since the range of dosages are well below regulatory limits, there is no significant additional impact if the license is renewed for another 20 years. The idea that we are all safe forever once one sets radiation exposure standards is not true. We know now that there is no safe dose of radiation and that those standards are likely to change as was done after Fukushima to protect the nuclear industry from public outrage. In fact, ionizing radiation is cumulative. There is cancer risk even without an accident. We have enough background radiation as is. A license to add human made radiation for another 20 years should not be granted. 11-39-HH Numerous accidents, incidents, SCRAMS, shutdowns, leaks, dishonesty in equipment monitoring, lack of proper reports filed, ignoring safety procedures, poor nuclear employee education, and the installation of noncertified equipment, does not assure the public that TVA can properly run their nuclear plants. Icecondenser technology is old and more subject to hydrogen explosions and meltdowns than other designs. There can never be enough socalled failsafe measures to avoid human error. We can and should move on to other ways to produce electricity. 11-40-OS Submitted by Sandra Kurtz, 3701 Skylark Trail, Chattanooga, TN 37416

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                                                         -135-1C6r/G /5~s6                      As of: April 26, 2013 Received: April 24, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                               Tracking No. ljx-84yh-5tuz Comments Due: May 03, 2013 Submission Type: Web Docket: NRC~2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-20 13-003 7-0003 License Renewal Application for Sequoyah Nuclear Plant, Units I and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0008 Comment on FR Doc# 2013-05491 Submitter Information Name: C S Address:

Talley Rd Chattanooga, TN, 37411 rn CJ (./) General Comment 12-1-LR It is important that TV A retire the permits on Sequoyah 1 & 2. The permits are already 10 years past their 12-2-FC original (recommended) termination dates. We require that all nuclear material be interred in casks and left on site. Monies must be used to develop safer means of energy harvesting. 12-3-OS 12-5-OS 12-4-OS These Ice Condenser Reactors are out of date and dangerous. By no means will MOX fuel be made at these Tennessee Plants that are so close to Chattanooga. We look forward to a decline in Leukemia rates after all the spent fuel is in casks. 12-6-HH SUNSI Review Complete

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                                                         -136-
                                                               ;a)rs)~1_3           As of: May 02,2013 Received: May 01, 2013 PUBLIC SUBMISSION 7Yr~;a-o30-                                                   Status: Pending_Post Tracking No. 1jx-8530-xtqb Comments Due: May 03,2013 Submission Type: Web Docket: NRC-20 13-003 7 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0010 Comment on FR Doc# 2013-05491 1'-.J Submitter Information                          :rJ            ==
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                                                                                                      "'9 w                   en General Comment 13-1-OS Lets put stipulations as to how long Nuclear Plants that are outdated are allowed to operate. Start investing in renewable energies such as solar on every new construction of homes and businesses including school.

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                                                            -137-
                                                 /~?/<./...?V66-As of: May 02, 2013 Received: April30, 2013 Status: Pending_Post PUBLIC SUBMISSION                                                                 Tracking No. 1jx-852e-6088 Comments Due: May 03, 2013 Submission Type: Web Docket: NRC-2013-0037 Receipt and Availability of Application for Renewal of Sequoyah Nuclear Plant Comment On: NRC-2013-0037-0003 License Renewal Application for Sequoyah Nuclear Plant, Units 1 and 2, Tennessee Valley Authority Document: NRC-2013-0037-DRAFT-0009 Comment on FR Doc# 2013-05491 Submitter Information Name: Judith Canepa Address:

716 East 11th Street #2P New York, NY, 10009 Organization: New York Climate Action Group IG General Comment The New York Climate Action Group strongly opposes the application by the Tennessee Valley Authority to renew the license for Sequoyah Nuclear Plant, Units 1 and 2, in light of the following grave concerns: 14-1-LR

1. The plant has aged ten years past its intended lifespan. An alarming number of parts that were replaced are considered non-compliant under your own standards. 14-2-OS

2. Your agency cited the company for failure to perform corrective actions for problems with their other reactors. Indeed, TV A has flagrantly ignored NRC standards for safety for decades. We cannot trust this company to ensure the safety of the surrounding communities. 14-3-OS

3. TV A has had to perform emergency shutdowns of other reactors a shockingly high number of times. We cannot assume that the Sequoyah plant is handled differently from their usual way of running operations.

However, we must have access to information related to how many SCRAMs have taken place at this facility before being able to comment knowledgeably about this concern. 14-4-OS

4. As has been seen in other nuclear power plants, cutting a massive hole in the containment structure, already subjected to the high stressors of SCRAMS and simple aging, endangers the integrity ofthe structure itself and thus the ability of the ice-condenser system to keep the radiation out of the surrounding environment. 14-5-OS Our recommendations are that the license renewal application be denied and that nuclear materials be interred

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                                                           -138-on site. 14-6-OR cont'd We support the swift transfer to renewable energy technologies. Such a transfer is not only possible, it is possible now, and absolutely essential for the sustainability of human life. If Germany, Denmark, and other countries can do it, so can the United States. See the work of Mark Z. Jacobson, professor at Stanford University:

Shifting the world to 100% clean, renewable energy by 2030 http://news.stanford.edu/news/2009/october 19/j acobson-energy-study-1 02009 .html 14-7-AL https://www.fdms.gov/fdms-web-agency /component/contentstreamer?objectld=09000064812adc5 f&for... 05/02/20 13

                                                      -139-Friends of                                      ****._}

the Earth April 26, 2013 Chief, Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration 3/~/02-t'J£3 7fr-;c_ /o{}36-Mailstop TWB-05-BOl M U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: SCOPING COMMENT CONCERNING THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REVIEW rl> . 7--

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15-1-OS Attached you will find documentation that the Tennessee Valley Authority (TVA) is considering production of tritium for nuclear weapons in the Sequoyah reactors. As the Nuclear Regulatory

• Commission has already licensed this activity, this issue clearly must be involved in any relicensing considerations of the Sequoyah reactors.

Likewise, TVA is actively considering use of plutonium fuel (MOX) made from weapons-grade plutonium in the Sequoyah reactors. While there is no NRC license request by TVA for MOX 15-2-OS testing or use, the review of TVA concerning MOX must be taken into account during the review of the Sequoyah license extension. Thank you for including in the scoping document that an analysis of all aspects tritium production and MOX testing and use must be included in license renewal documents. Please add me to any distribution list you prepare on the scoping and/or license renewal; tomclements329@cs.com. Sincerely, ~c~ Tom Clements Southeastern Nuclear Campaign Coordinator SUNS! Review Complete Template= ADM- 013

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E-RIDS= ADM-03 Add= 1112 Florence Street* Columbia, SC 29201 803.834.3084 phone & fax

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                                                         -140-7~?~ /J/-3 ~,2)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION :D

                                                                                                         !ll BEFORE THE SECRETARY                                          ()

m 1n the Matter of Tennessee Valley Authority < m Scquoyah Nuclear Plant Units 1 and 2 License Nos. DPR-77 and DPR-79 0 Docket Nos. 50-327 and 50-328 NRC-2013-0037 DECLARATION OF STANDING Under penalty of perjury. I declare as follows:

1. My name is J<.~ I S TIN t1 L t1 A-11!/ E.~ r and I am a member of Print yt>UT fi{Urf~

the Blue Ridge Environmental Defense League.

2. Ilivcat 129 ftrPPL£ SrDN'£1 (J_() D~;tNl-4.? TN Plr~.1ic:aladdr~

3. My home lies within 35 miles of the site in Soddy-Daisy. Tennessee in Hamihon County where Tennessee Valley Authority operates two nuclear power plants and for which the U.S. Nuclear Regulatory Commission has received a license renewal application for an additional20-year period of operation.

22-1-OS

4. The design of the Sequoyah reactors has a particular weakness in its construction which reduces its ability to withstand accidents. Only nine such reactors have ever been completed in the United States. Aging of the plant may only in"'Tease the danger.

5. Based on historical experience with nuclear reactors, I believe that these facilities are inherently dangerous. An accident at these nuclear reactors so close to my home could 22-2-PA pose a grave risk to my property, health and safety. In particular. I am concerned that if an accident involving release of radioactive material were to occur, I could be killed or become very ill.

6. Therefore, I have authorized Blue Ridge Environmental Defense League to represent my interests in this proceeding as to whether good cause exists for the renewal of the operating licenses to the Tennessee Valley Authority.

OS-DMe ____________ 01- 2013 __ {Signature) FRN v.78, n. 43, p. 14362, S Mardl2013 SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 /'~ ~ Add= --M *_/t?t!J ~"", 7 LY.)}}