ML23136B174

Comment (1746) of Patricia Marida on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License

ML23136B174
Person / Time
Site:	Triso-X
Issue date:	02/13/2023
From:	Marida P - No Known Affiliation
To:	Office of Administration
References
NRC-2022-0201, 87FR77146 01746
Download: ML23136B174 (1)

Text

SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: March 08, 2023 Received: February 14, 2023 PUBLIC SUBMISSION ADD: Jill Caverly, Robert Sun, Antoinette Walker-Smith, Mary Status: Pending_Post Neely Comment (1746) Tracking No. le4-dvu8-t9p5 Publication Date: 12/16/2022 Comments Due: February 14, 2023 Citation: 87 FR 77146 Submission Type: Web Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License Document: NRC-2022-0201-DRAFT-1746 Comment on FR Doc # 2022-27164 Submitter Information Name: Patricia Marida Address:

COLUMBUS, OH, 43229 Email: patmarida@outlook.com Phone: 16142864851 General Comment See attached file(s)

Attachments Docket ID NRC 2022 0201 Triso Scoping file:///C/...eDrive%20-%20U.S.%20NRC/Desktop/NRC-2022-0201%202023-03-08%2012-04-27_docs/NRC-2022-0201-DRAFT-1746.html[3/28/2023 11:20:50 AM]

Office of Administration, Mail Stop: TWFN-7-A60M Valentines Day U.S. Nuclear Regulatory Commission Feb. 14, 2023 Washington, DC 20555-0001 ATTN: Program Management TRISOX-EIS@nrc.gov Jill.Caverly@nrc.gov Stacy.Schumann@nrc.gov https://www.regulations.gov To: NRC Commissioners and Staff RE: Docket ID NRC-2022-0201

Dear Friends at the NRC,

The summary at the top of the Scoping FRN says: The U.S. Nuclear Regulatory Commission (NRC) received a license application by letters dated April 5, 2022, and September 23, 2022, from TRISO-X, LLC (TRISO-X) a wholly owned subsidiary of X-energy LLC. By its application, TRISO-X is requesting a license to possess and use special nuclear material for the manufacture of high-assay low-enriched uranium (HALEU) fuel at a fuel fabrication facility (FFF) to be located in Oak Ridge, Roane County, Tennessee. The proposed action is the issuance of a license for the possession and use of special nuclear material. The NRC staff will prepare an environmental impact statement (EIS) to document the potential environmental impacts from the proposed action. As part of the EIS development process, the NRC is seeking comments on the scope of its environmental review. This same statement is repeated later in the document text.

Our understanding is that HALEU fuel is slated to be manufactured elsewhere and shipped to Oak Ridge for fabrication into Triso fuel at a TRISO-X facility. The scoping statement would indicate that HALEU is also being planned to be manufactured at Oak Ridge. A full explanation of whether HALEU might be slated to be manufactured at Oak Ridge, including whether and/or how this scoping might in any way relate to the manufacture of HALEU fuel at Oak Ridge, must be immediately forthcoming from the NRC.

Specific comments on the scoping and EIS:

• The scoping and resulting EIS must include detailed research and subsequent reporting on the environmental impact of the uranium mining that will be required to produce the fuel.

• Claims of security concerns or proprietary information are far too broad. The scoping and EIS, with or without revealing design details, must indicate and eliminate all possibilities for criticality. Other vulnerabilities must also be indicated and eliminated.

• The scoping and resulting EIS must include detailed research and subsequent reporting on the disposition of the Triso-X facilitys manufacturing-created onsite waste, radioactive or otherwise toxic.

• The scoping and resulting EIS must include detailed consideration of the environmental impacts of the disposition of and ongoing need for isolation of used/spent Triso fuel. Claims of walkaway safe reactors are unfounded and are geared to remove responsibility and costs from private enterprise and foist them onto the public.

• Precipitation on and around the facility must be retained in ponds and regularly checked for radioactive contamination.

• The scoping and resulting EIS must determine the actual aging degradation patterns of used Triso fuel and from that determine a rigorous scientific protocol for short-, medium-, and long-term storage to prevent future criticality events.

• The scoping and resulting EIS must show clearly how facility will be able to prevent radioactivity from escaping, whether in solid, liquid, or aerosol/airborne states.

• The scoping and resulting EIS must show clearly how facility will be designed to withstand fires, including complicating factors like drought, extreme winds, and high temperatures.

• The scoping and resulting EIS must show clearly how facility will be secured from attacks by terrorists or vandals.

HALEU is defined as uranium enriched to 19.75% U-235. I would like to point out that this amount of precision is so glaringly unnecessary and unachievable as to only pass the straight-face test in a naked emperor/oligarchical regime. By definition, uranium enriched to 20% is High, not Low, Enriched. Please include in your scoping your research into changing the acronym to HAHEU. The first 4 letters also better describe what humanity should think of the idea of creating forever-deadly radioactivity which makes everything it touches become radioactive. And what Americans should think of this Triso Fuel proposal.

Thank you for consideration of these comments.

Sincerely,

/s/

Patricia A. Marida Columbus, Ohio