Open Letter to the NRC--July, 4, 2014

U.S. Nuclear Regulatory Commission Region I                              July 4, 2014
Glenn T. Dentel, Chief                                 Certified Mail Return Receipt Requested
Division of Reactor Projects, Branch 3                                 
2100 Renaissance Boulevard, Suite 100
King of Prussia, Pennsylvania 19406-2713

Dear Mr. Dentel,

First I want to thank you for attempting to address my concerns it certainly has not been my experience always from many past officials including Commissioners of the Nuclear Regulatory (NRC) commission.  I will say Richard Barkley so far has been very helpful endeavoring to address my questions and requests for information and documents.

I do have additional questions and concerns as they relate to your replies to my oral and written testimony I gave December 18, 2013 at the NRC hearing in Hampton New Hampshire. As you stated in you letter to me this meeting was held to discuss the concrete degradation experienced at Seabrook station as it relates to whether the NRC will approve an extension of Seabrook’s operating license from 2030 to 2050. 

In my letter to you I will be addressing my additional concerns and questions as they relate to your letter to me dated February 12, 2014 (enclosed) you numbered 1-11.

1. NRC (Wrongdoing)   you provided a number of quotes allegedly raised to you suggesting wrongdoing by unnamed members of the NRC staff (e.g., claims that allegations are penciled away, that NRC engineers do not “rock the boat.” And that an NRC staff member was demoted for talking about his boss, among others.)  No names or specific incidents were provided.

NRC Response:-

As your concerns do not provide specifics regarding who is involved, and alleged possible NRC staff wrongdoing, we have forwarded your concerns to our NRC Office of Inspector general in accordance with the NRC’s internal policies.  We urge you to contact the Office of Inspector General at (301) 415-5930 to discuss your concerns in further detail.

Stephen B. Comley Sr. Responses to NRC replies to quotes (enclosure A) he provided during the testimony he gave orally and written during the Seabrook Nuclear Plant hearing conducted by the NRC December 18, 2013. :


Quote # 1 “Seabrook is in the wrong location.” 

My Response:
This quote comes directly from NRC Staff  I have spoken with – and including N.H and MA State Troopers and Chiefs of Police from the towns within the 10 mile radius...
Page 2 of Stephen Comley’s responses to NRC’s letter of 2/12/14 to him.

Quote # 1 response continued: , former Governor Dukakis, Former Attorney General Shannon of MA, U.S. Senator Edward Markey, Former U.S. Senators Edward Kennedy, John Kerry and hundreds of citizens I have met and talked with in NH and MA.

Quotes # 2 & 3 “If people let Seabrook open, it is their own fault” “But the NRC has not been playing a fair game.”  Whenever safety allegations come into the NRC, which may pose a threat to the further operation or licensing of a nuclear plant, those allegation are penciled away.” 

Stephen B. Comley Sr. response: There are many instances I have seen the NRC pencil away safety concerns including down grading the standards for nuclear parts built in U.S Nuclear Civilian and Weapons Plants including Seabrook.  Another NRC penciling away safety concerns is making special needs citizens expendable when former NRC Executive Director Victor Stello suggested I leave a paralyzed resident behind in our family owned and run health care facility and give her Potassium Iodide (KI) to drink to be administered by our nursing staff who would be willing to stay behind in the event of an accident at Seabrook Nuclear Plant.  This is a violation of U.S. Law which I will address further in this letter.

Quote 4. “Members of the NRC are mostly engineers so they do not rock the boat because the only place to go after working for the NRC is to work in the industry.” 
  .  . 
Stephen B. Comley Sr. response.
I know if the NRC researched NRC employment records you would find many confirmations of this quote where former employees of the NRC or former Congressmen or their former staff members elected to become nuclear lobbyists like former Chief legal counsel to former Senator Kostmayer, John O’Donnell (Enclosure B) chose to do.     :

Quote 5 “Over the years I have looked at how rotten our agency is in my view.  How pro-industry it is.  Hey look, if they play it straight and you get stuck with your plant, so be it.  Does that make sense?  You may not like it but that is the American way, the majority rules.  But when I see a system that is designed to thwart the majority or keep the majority ignorant and then one day it happens and you wonder how it happened.  That is not fair. That is what turned me off.  It is a shame to make you think you are getting a voice. “

Stephen B. Comley Sr. response:  This certainly applies to Seabrook when the NRC licensed Seabrook while making a mockery of our Democratic process in preventing the people from having a say in our government in locating a Nuclear Plant in ones backyard.  Here again the NRC bowed to the Industry and even Former Governor Sununu a buddy of the Nuclear Industry and Victor Stello got into the act of penciling away safety concerns when John suggested the 10 mile radius be reduced to (Encloaure C) l mile.   In addition while John Sununu was White House Chief of Staff under former President George Bush it was suggested in a leaked Department (DOE) of Energy Memo to have
Page 3 of Stephen Comley’s replies to NRC latter of 2/12/14 to him.

Comley Sr response Continued: John Sununu (Enclosure D with two parts) to pressure NRC Chairman Selin into supporting one-step licensing of nuclear power plants, a measure supported by nuclear plant advocates because it eliminates interventions by citizens’ groups. Part of this DOE Memo stated, “Chairman Selin might more quickly fall in line for Governor Sununu than he would for Admiral Watkins. “Have Governor Sununu tell NRC Commission Chairman Selin to say nothing further to the Congress than support of S.1220 and its specific provisions. Ignore the past.” This memo is interesting because it makes clear that Sununu is the person to go to if anyone wants something done for the benefit of the nuclear industry.

Without a doubt from reading this memo the DOE and the White House under the President George Bush’s Administration conspired to topple democracy in America by pushing one-step licensing through the people’s very courts system in getting Seabrook licensed while making a mockery of our democratic system of government in circumventing the very voice of the American people

Quote 6.
When a member of the NRC staff was demoted he went to the present chairman and asked “why?”   He was told “What do you expect when you talk about your boss.”

Stephen B. Comley’s response. Boss then was NRC Executive Director Victor Stello.

Quote 7 “The NRC protects the industry more than they protect the people.”

Stephen B. Comley’s response: If I listed all the people who have responded to me in this way it would include volumes.  I will give you one though, see former Commissioner James Asselstine’s response to his answer to my question 6 of the 14    (Enclosure E) responses I got during my interview with him August 19.1986. My question 6 to him was, “Do you feel that the NRC has represented the people as well as it has represented the nuclear industry?” Mr. Asselstine reply was, “I believe that in some cases, the NRC has acted more as the protector of the nuclear industry than the protector of the public.”   

Quote 8 “We will have a nuclear disaster in the U.S. worse than Chernobyl.  It can happen any day because of the way our plants have been constructed and the way they are run.” 

Stephen B. Comley Sr. response” NRC Bulletin 88-05 dated May 6, 1988 confirmed existence of Counterfeit Substandard Parts in U.S. Nuclear plants across the country which WTP informants first brought to light when I first handed this very troubling information to former President Reagan October 26, 1987 (Encloasure F is my  Chronology of Cover-ups by the NRC  and the additional involvement by President Reagan and others in the Counterfeit Substandard Nuclear Parts Scandal)  which President Reagan and his Administration ignored for almost a year.

Page 4 of Stephen Comley’s replies to the NRC letter to him of 2/12/14.

Comley Sr. continued response of # 8: It wasn’t until I sent two separate Certified Return Receipt letters in August of 1988 to then President Reagan and a separate one to Vice President Bush did the White House finally react. So for every everyday President Reagan ignored the concerns I outlined in the letter I wrote and handed him October 26, 1987 he was jeopardizing the safety of the American People. It should be noted, former Washington Associated Press Reporter, Chris Callahan who wrote a national article from one of the 700 press releases continuing the letter I sent out October 25, 1987 from WTP’s office in the National Press Building.  Mr. Callahan  upon getting a phone call from me confirming I had been able to give my letter to President Reagan, contacted the White House about the content of my letter but not only did the White House Staff deny the President had received any letter but also said no exchange ever took place between President Reagan and me.

Because of WTP’s contact with former U.S. Attorney Giuliani, Victor Stello was forced to come out with NRC Bulletin 88.05 and release on May 6, 1988 confirming there were 39 U.S. Plants built with Counterfeit Substandard Parts.  WTP took the next step by sending my letter out of July 18, 1988 to then NRC Executive Director, Victor Stello. requesting when did the NRC first learn of the Counterfeit Substandard Parts being sold to U.S. Nuclear Plants by Piping Supplies of Folsom New Jersey. Instead of Mr. Stello replying to my letter he directed Thomas Murley to become the Oliver North or scapegoat by directing him to reply my letter.  Mr. Murley stated in his letter to me the NRC first learned of the Counterfeit Substandard Parts being sold by Piping Supplies on January 18, 1988.  This was a lie and cover-up due to the fact I knew of this information when I hand delivered it to Ronald Reagan October 26, 1987. Senator John Glenn and some of his staff also knew of these Substandard Nuclear Parts from me.  In addition a 60 minutes representative who met with Senator Glenn and  his Staff spoke of this troubling information which could cause a Nuclear Disaster. . 

In addition James Asselstine also alluded to a possible nuclear disaster in response to my question 13 to him during my interview with him (Enclosure E) August 19, 1986.    

Since WTP first brought to light the existence of Counterfeit Substandard parts in most U.S. Nuclear Plants the NRC has been downgrading these bogus  parts by justification of a  Memorandum entitled, Differing Professional View concerning 10 CFR 50.69, “Risk informed Categorization (Enclosure G) and Treatment of structures, systems, and components.”  Just another example of the NRC penciling away of safety concerns. 

2. NRC (Counterfeit/Substandard Parts)   
You provided a number of historic references to concerns and allegations you raised, principally in the 1987 – 1990 timeframe, regarding alleged counterfeit and substandard parts used by the nuclear Industry at that time.  These concerns were raised by individuals in the industry whose identity you were not willing to reveal.  You further stated that your concerns were ignored by the NRC staff as well as by most of the commissioners serving at that time, and by senior representatives in the Department of Justice and the
Page 5 of Stephen B. Comley Sr. Replies to NRC letter to him of 2/12/14.

2. Continued NRC (Counterfeit Substandard Parts) Administration of Former President Regan.  You also asked for the name of the staff member who was in charge of the NRC inspection program for parts vendors during that time period.  No information on specific counterfeit or substandard parts, or licensees that might have installed such parts, was provided in the materials submitted at the December 18, 2013, meeting.

You also requested a list of counterfeit, and or substandard parts replaced or not replaced at Seabrook.

NRC Response: 
When fraudulent or counterfeit parts were believed to be supplied to NRC licensees, principally nuclear power plants, the NRC has taken action to notify the nuclear industry of these events and take corrective actions.  For example, in April 2008, the NRC issued an information Notice to the industry regarding counterfeit parts, a copy is enclosed.  In 1989, the NRC staff issued Generic Letter 68-02, “Actions to improve the Detection of Counterfeit and Fraudulently Marketed Products.”  In that Generic Letter, It also lists a number of communications made in preceding years regarding this issue.  Furthermore 10 CFR Part 21 requires that suppliers or NRC licensees promptly report to the NRC component defects or noncompliances that could create a substantial safety hazard so that appropriate action can be taken.

We have reviewed the materials you provided, but noted that most of your concerns in this area seem to date to the 1987 – 1990 time period, or shortly thereafter.  Absent any specific information in this matter, such as the parts involved, their suppliers or the licensee (s) which used such parts, and given the historic nature of your concerns. The staff cannot take any further action in this matter without more information from you.  We recognize that this is a significant concern to you given your protracted and costly legal involvement with the agency and the Department of Justice in this matter in the early 1990s.  However, we cannot take further action at this time without specific
information.

As for the NRC vendor inspection program, those efforts are continuing and have expanded in recent years with the construction of four new nuclear reactors in Georgia and South Carolina.  Those efforts are being conducted by the Division of Construction Inspection and Operational Programs in the NRC Office of New Reactors.  Prior efforts in this area were the responsibility of the Office of Nuclear Reactor Regulation.  However, given significant changes in personnel and the NRC organization since the 1989-1990, few if any, staff form that organization remain with the agency.

Regarding your request for a list of counterfeit and/or substandard parts replaced or not replaced at Seabrook station, the NRC does not retain such a list.  NextERA has a corrective action system to address the identification and correction of any such equipment.  The NRC has unfettered access to this system for inspection and enforcement purposes, but does not develop lists of the type you describe.  

Page 6 Stephen Comley Sr. Replies to NRC letter sent to him 2/12/14.
 
Comley Sr. Responses to NRC’s. 2) Counterfeit Substandard Parts.

  
Historic references are enclosed to concerns and allegations I raised, from 1987 - 1990 time frame, regarding Counterfeit and Substandard parts used by the nuclear industry at that time.  My concerns were indeed ignored by the NRC staff including Victor Stello, former NRC Executive Director, all of the Commissioners serving at that time, by Senior representatives of the Department of Justice including Attorney General Thornburg,
Former U.S. Attorney Rudolph Giuliana, Former Chief Legal Counsel, John O’Donnell to Senator Peter Kostmayer, Senator John Glenn and his Former Legal Counsel Stephen Ryan, Feral Bureau of Investigation, most members of Congress, most Governors of U.S. and the Administrations of President Reagan and President George Bush Senior.

I was informed by informants from NRC staff investigations of unsafe conditions at nuclear plants were to be kept a PUBLIC SECRET always controlled by Victor Stello inside the NRC and away from the public eye as much as possible. The Counterfeit Substandard Scandal was a prime example of this like what happened with the investigation of the Three Mile (TMI) Island accident in 1979 which Victor Stello had a hand into. Evidence of this TMI Cover –up I found when I read the Investigative interview conducted by Alan Rosenthal March 22, 1989 in behalf of the NRC of former NRC OI Deputy Director, Roger Fortuna, who stated on Pages 170 – 174 (Enclosure H) when Mr. Fortuna makes several references to the investigation he was directed to conduct with his team of allegations of masking the radiation count during the TMI disaster,  Mr. Fortuna at that time worked for the DOJ and was in charge of conducting this investigation which to this day DOJ has yet to release to the public.

 I am in hopes when President Obama elects to honors the many request to meet with which I outlined in the 3 letters I sent to our President and the two I mailed to Michelle Obama (which the White House signed for all) will assist me in getting a copy of this investigation the Amerian People have a right to see.  I say this because I recall when President Obama was on his Presidential Campaigns he stated, “I am going to make it a lot easier to obtain Freedom of Information Requests. “

NRC Responses: In reference to your Statement, the NRC has taken actions to notify the nuclear industry of these events and take corrective actions.  For example, in April 2008, you also note in 1989, the NRC staff issued Generic Letter 89-02.  “Actions to improve the detection of counterfeit and fraudulently Marketed Products.”  In that Generic Letter, it also lists a number of communications made in preceding years regarding this issue.  Furthermore, 10 CFR Part 21 requires that suppliers or NRC licensees promptly report to the NRC component defects or noncompliances that could create a substantial safety hazard so that appropriate action can be taken.”    



Page 7 Stephen Comley Sr. Replies to NRC letter to him 2/12/14.

Stephen Comley’s responses to NRC’s
.

I want to point out in the April 2008, NRC information Notice to the industry regarding counterfeit parts: it states, “PURPOSE the suggestions contained in this IN are not NRC requirements, therefore no specific action or written response is required.” 

Certainly anyone reading this could get the impression this “IN NOTICE” is like the old saying WE WON’T ASK IF YOU DON’T TELL. Or put it another way NRC WON’T REQUIRE U.S. NUCLEAR PLANT OWNERS TO REPLACE COUNTERFEIT SUBSTANDARD PARTS IF THEY CHOOSE NOT TO REPORT ANY.

I strongly recommend from now on that NRC IN notices like what was sent out in 2008 and 2011 (Enclosure I) be updated to the language used in NRC notices 1989 Generic Letter 89-02 and 10 CFR Part 21 which “requires that suppliers or NRC licensees promptly report to the NRC component defects or noncompliance’s that could create a substantial safety hazard so that appropriate action can be taken.” 

Question:
Why and who or what persons made the decision to not include the 10 CFR Part 21 in the IN Notices from the 1989 Generic Letter 89-02 to the language replaced from that time to what is used in the 2008 and current notices now being sent out to NRC licensees?  I suspect very strongly Victor Stello had strong influence to incorporate this new language to accommodate the Nuclear Industry wishes.

I request once again, the name or names of who was made in charge of keeping track of when and what companies were supplying Counterfeit Substandard Parts to U.S. Nuclear Plants during Victor Stello was Executive Director of the NRC?

NRC Reponses: “We have reviewed the materials you provided, but noted that most of your concerns in this area seem to date to the 1987-1990 time period, or shortly thereafter. “

Stephen B. Comley’s Response:
This is not correct from March 15 – April 26, 2011 I was invited and testified before five of the Florida House and Senate Energy Committees regarding my concerns of substandard parts being built in all of Florida’s Nuclear Plants which were listed in the GAO including Seabrook Nuclear Plant owned currently by Florida Power and Light.  I request the NRC subpoena my testimony I gave in Florida for the record.  I also was invited and appeared 3 times on NPR in Tallahassee and Jacksonville during which I debated the President of the Nuclear Institute in WashingtonI hope you also request those tape recordings where the representative from the Institute in a bold impudence way stated, “Nuclear Power Plants are not located in America’s neighborhoods without the approval of the people lining in the area of a plant.”

Page 8 Stephen Comley Sr. Replies to NRC letter to him of 2/12/14.

NRC Responses Page 2 Beginning of 3rd paragraph: “Regarding your request for a list of counterfeit and/or substandard pars replaced or not replaced at Seabrook station, the NRC does not retain such a list.   NextERA has a corrective action system to address the identification and correction of any such equipment.  The NRC has unfettered access to this system for inspection and enforcement purposes, but does not develop lists of the type you describe.” 

Stephen B. Comley’s response: NRC does not retain such a list.”  Question: Why not?  We are not talking about a donut shop here!
 
NRC Statement: The NRC has unfettered access to this system for inspection and enforcement purposes.”  I point to Satin industries and NRC Information (Enclosure I) Notice No.89-45, Supplement 2: Metal clad, Low-voltage Power circuit Breakers Refurbished with Substandard Parts.   

Note again (Enclosure I) here Page 2 of 7 Paragraph 2, It is expected that recipients will review this information for applicability to their facilities and consider actions, if appropriate, to avoid similar problems.  However, suggestions contained in this notice do not constitute NRC requirements; therefore, no specific action or written response is required.”   
Here again is just another example of the NRC penciling away safety concerns.

Note specifically Page 4 of 7 second paragraph
, “The SA facility in Shelton, Connecticut, suffered major damage in a fire in July 1989.  The resultant destruction of records may make it difficult or impossible for SA’s customers to audit the company and obtain the information necessary to assure that previously purchased equipment was in full compliance with the applicable specifications and purchase order requirements.”
 
Question: How did NextERA handle this in the case of Satin Industries when in this statement above destruction of records may make it difficult or impossible for SA’s customers to audit the company?  Should be noted U.S. Marshalls were scheduled to seize all of Satin’s records but the company building burned to the ground the night before the U.S. Marshalls were scheduled to arrive. 

Question: Was there an investigation into whether Satin was tipped off ahead of time of the pending U.S. Marshalls seizure of Satin American Companies records? 

Also Note in May of 1993, the President and Vice President/manager of Satin American Corporation were sentenced (E
nclosure I) in U.S. District Court (Conn)   
on criminal charges: specifically, Section 371 of Title 18 of the U.S. code (18 U.S.C. 371), “Conspiracy to Traffic in Goods Bearing Counterfeit Marks.”  They had pled guilty to participating in a conspiracy from 1985 to 1987 in which circuit breakers and related
Page 9 Stephen Comley Sr. replies  to NRC letter sent to him 2/12/14.

 
Comley Sr. responses concerning Satin American Corporation continued:
Equipment was refurbished at their Shelton, Connecticut, facility.  This equipment was sold to various NRC licensees and others bearing counterfeit nameplates made to look like those from the original manufacturers.  The Satin American President was sentenced to 4 years of imprisonment, which was suspended, and 3 years’ probationThe conditions of probation were restitution, a $250,000 fine, 400 hours of community service each year of probation, and barring of the President, Satin American Corporation, and any related or successor companies controlled by him from engaging in nuclear safety-related business for 5 years.  The Satin American Vice president/manager was sentenced to 3 years of imprisonment, also suspended with 3 years’ probation, 200 hours of community service each year of p-probation, a $5,000 fine and barred from nuclear safety-related business for 3 years.    

The above so called punishment will hardly be a deterrent to prevent these same individuals from trying it again.  Satin recently was found in the possession of (Enclosure I) Substandard parts.


3) NRC responses (Emergency PlanningPotassium Iodide)  “you asserted that laws governing the distribution of potassium iodide (II) tablets to citizens living up to 20 miles from nuclear power plant are not being implemented.”

The Law to which you are referring is Section 127(f) of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the Act), which was signed into law by President Bush on June 12, 2002.  However, as detailed in the enclosed January 22, 2008, memorandum form the Office of Science and Technology Policy *OSTP) -Executive Office of the President, this provision of the Act was waived.  This document provides the technical basis for this decision, and why there exists more effective preventive measures than KI for the population between 10-20 miles from a nuclear station.  Since this waiver of the Act is permitted by law, and was promulgated by and individual delegated this authority by the President, the NRC is actin in accordance with the law as it currently stands. 

If you have questions or comments on this decision, we suggest you direct your concern to OSTP at:  Office of Science and Technology Policy – Executive Office of the President , Eisenhower Executive Office Building, 1650 Pennsylvania Avenue, Washington, DC 20504,  Phone: 202-456-4444   

Stephen B. Comley’s Response:

Yes you are correct.  The laws specifically I believe President Obama, Governor Deval Patrick, Governor Maggie Hassan, the NRC and Seabrook owner, Florida Power and Light are in violation of all of the following which include the Potassium Iodide KI issue outlined in the next pages..

 

Page 10 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr continued response to violations of U.S. Laws:

Discrimination: Federal Law prohibits discrimination against disabled persons. According to 29 U.S.C. 794, no person, solely by reason of their handicap, may be subjected to discrimination by any program or activity which receives federal funds. Since most of the entities involved in evacuating a population receive federal funds, it would be a contravention of federal law MA and NH to effectuate a plan that wholly ignores persons solely by reason of their handicapped status. 

According to the emergency evacuation plan created by the owners of the Seabrook nuclear power plant in NH, the young, the old, and the physically and mentally disabled are left to fend for themselves in some bizarre Darwinian version of Survival of the fittest.  People who are frail, ill, helpless, and people with special needs will be a larger part of any group which ends up being sheltered indefinitely rather than evacuated with the general population. 

I raised this issue in 8/15/1986 during my interview with to James K. Asselstine, NRC Commissioner and to Lando Zech, NRC’s Chair and the other 3 when (Enclosure E) I asked question # 2, “Do you feel that some means should be provided for people who cannot be moved, other than merely being sheltered?”  

On August 19, 1986, Mr.Asselstine replied, “I do not believe the commission has faced the situation in which evacuation is impossible for some individuals within the EPZ and the only alternative is sheltering within unprotected facilities.” 

Victor Stello, former Executive Director for operations, replying to the same question to me due to the fact Chairman Zech and the other 3 refused to reply individually to me. .  Mr. Stello wrote on October 1, 1986, “For the few individual patients where in the judgment of medical experts prompt evacuation is not advisable, we believe that shelter is an appropriate protective measure until they can be safely relocated.  In some cases it may be appropriate to administer potassium iodide (KI).” 

This statement revealed to me very early on these high officials at the NRC as well as other people including Presidents I have written were then and are now willing to make a certain segment of the American Population expendable which began my 27 year journey of investigating the NRC and the Nuclear Civilian and Weapons Industries.

In considering the KI option, the NRC must examine the issue of discrimination.  Many people not immediately evacuated will be left behind because they are ill,
frail and senior citizens or people with special needs.  Using KI could endanger some of them.  They deserve to have more protection against a radioactive plume than KI and their bedclothes.



Page 11 Stephen B. Comley Sr. replies to NRC letter sent to him 2/12/14.

Comley Sr. responses to Violation of U.S. Discrimination Law continued:
The Nuclear Industry is licensed by the Federal Government to generate electricity (and profits) with this potentially lethal technology.  To prevent a situation which discriminates against those left behind, the federal government should make a criteria for licensing that the licensee provide comparable protection for those left behind.  One possible means of preventing discrimination should be to build shelters similar to the bomb shelters built during the early years of the Cold War to protect against nuclear bomb attacks.   

We The (WTP) People is bringing our awareness to these concerns and others by circulating our National “Petition To President Obama, Vice President Biden, Speaker Boehner and Members of Congress to create an Independent Commission to investigate the U.S. Nuclear Regulatory Commission (Enclosure J), (part of content is) “WHERE AS current emergency plans propose that senior citizens and other special needs persons who cannot immediately evacuate be left behind in the event of a nuclear accident be given potassium iodide which only protects the thyroid against radioactive iodine, leaving them susceptible to contamination by other dangerous radioactive products released during an accident or act of sabotage; and such plans assume these valuable members of our communities are expendable, a discriminatory policy which violates their civil rights.”

WTP hope is State Senator Tarr, Rep. Hill, Governor Patrick, U. S Senator Edward Markey and others elected officials  will follow the lead of former FL.Rep. Julio Robaina who was the first elected leader to sign WTP’s National Petition.   Citizens and I will be circulated the petition throughout the Town of Rowley MA when I return from South Korea and Japan where I have been invited to speak about my experiences with the NRC and the Nuclear Civilian and Weapons Plants. 
 
3).Comley Sr. responses to NRC’s Emergency Plannning –Potassium Iodide
)
Law Violation of Potassium (KI) Iodide: Partially taken from News and issues US Government Info: The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 expanded the Potassium (KI) Iodide distribution radius to 20 miles from 10 miles.  President George W. bush signed the measure into law following the terrorist attacks of September 11, 2001, amid concerns that enemies were planning attacks on American nuclear facilities.  Neither former President George W. Bush nor his successor, President Obama, actually implemented the law mandating broader distribution of the so-call “emergency Pills” containing potassium iodide, which reduce the risk of thyroid cancer in people at risk for inhalation or ingestion of radioiodines.”

Even when this law and in some cases this unacceptable drug KI is put into effect the area where KI is made an option must be more extensive than the 20-mile evacuation zone delineated by law as the area for which licensees must provide a detailed plan.  A radioactive plume form a damaged nuclear power plant can extend a great distance,


Page 12 Stephen B. Comley sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. responses to of law concerning KI continued: as was learned during the Chernobyl and Fukushima disasters when radiation fell heavily within those countries, and elevated radiation levels were even measured in the U.S. from both accidents including affecting the air in MA and Cows’ milk in VT... 

The use of KI can have serious side effects, a matter to address when making KI an emergency option.  Some manufacturers and pharmacies state KI should not be administered without a physician’s prescription.  A manufacturer’s caution about Potassium Iodide solution include: giving the preparation with a full glass of water to assure against gastrointestinal injury: to notify a physician if skin rash, fever, swelling of throat or signs of iodism (brassy taste, burning of mouth and throat, chronic sore gums and teeth, symptoms of head cold) occur; and the note that KI is contraindicated in cases of Addison’s disease, acute or chronic renal disease, dehydration, tuberculosis, and in patients with sensitivity to iodides.  The manufacturer cites several reports on nonspecific bowel lesions where surgery was required and deaths occurred, and says KI should be discontinued immediately if abdominal pain, distention, nausea, vomiting, or gastrointestinal bleeding occurs.  In cases of over dosage, lethal levels can be reached in a few hours.  

All emergency personnel including volunteers who are willing to stay behind in the event of a nuclear explosion to administer KI, including hospital and nursing home employees, police and fire departments must receive in-depth training in administering KI, its side effects, and antidotal measures. From many of the individuals I have spoken associated with the departments above have informed me they are not familiar or have been trained in this matter. 
.
When stockpiling, it is necessary the stockpile not exceed its shelf life.  For example, some of the liquid solutions have only a shelf life of six months.  The tablet form may be longer lived, but some special needs people are unable to consume tablets and would have to have the liquid form available.  It is difficult to believe during a nuclear disaster that anyone will have enough time to discern who should receive the correct tablet or the liquid KI. 

A great deal of preparation and ongoing attention is involved in making KI one of the options in protecting the public, but none of these cautions should exclude KI as an option.

The entire population at risk of exposure to a radioactive plume should be educated about the benefits and side effects of KI so they are informed of their options.  The Nuclear Management and resources Council (NUMARC), and organization of nuclear utility owners, recommend the NRC discourage use or stockpiling of KI because “Stockpiling or predistribution and the associated public education

Page 13 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. Reponses to KI Law continued:
would result in a potentially significant negative public perception.”  In CNN’s year and half investigation of WTP’s work which aired on EARTH MATTERS entitled, INSIDE THE NRC: INTIMIDATION OR REGULATION (Enclosure K copy of  DVD 2  segmentts: one of CNN investigation of WTP work and 2nd is more actiies of WTP)  touched on the NUMARC stated above.  WTP recommended the NRC disregard the NUMARC position which I have been told has influenced the NRC’s stand on KI for the last several years. 

NUMARC’s short term “potentially significant negative” image problems pale in the face of the public’s right to be protected against life-threatening radiation in the event of a nuclear power plant accident. 

Negative publicity does not last long; thyroid cancer has a much deeper, long-lasting, and more devastating consequence. This is again another example of the NRC bowing to the wishes of the Industry and penciling away once again safety concerns in favor of protecting the profits of the Nuclear Industry who’s Lobbyists routinely fill many politicians’ war chests.  

Just before the NRC hearing I found out in NH and MA the availability of KI is very limited or nonexistent.  In evidence I presented at the NRC hearing 12/18/13 I included statements (Enclosure L) attested to by managers of two CVS Pharmacies in Salisbury MA and Seabrook NH directly in front of the Seabrook Nuclear plant who stated, “We do not carry potassium Iodide for the past year or so. We cannot get it or normally carry potassium iodide.”   

I recall the U.S. government sending all of our KI was sent to Japan when the Fukushima explosion occurred which left us who live near the Seabrook Plant and other parts of the U.S. plum out of luck if Seabrook Station blew up. 

3. Violation of Law and standards of NRC licensing U.S. Nuclear Plants. 
As I stated in my oral and written (Enclosure M testimony)
“This NRC panel should not even be having this hearing.  It is a waste of tax payer’s hard earned money because the NRC never should have licensed the Seabrook Nuclear Plant in the first place.  Anyone familiar with the Beach areas in MA and NN surrounding this plant knows you cannot possibly evacuate citizens safely in the event of a Seabrook Nuclear disaster. 

Proof of this is when I attended the Ted Nugent concert August 11, 2013 this past summer at the Hampton Beach Casino when I noticed during the time before the concert I was having trouble crossing the street because of all the people at the Hampton Beach in NH that day.  Due to this congestion I decided to individually ask 15 NH State troopers this question, “If the Seabrook Nuclear Power Plant blew up right now what would you do?”


Page 14 Stephen B. Comley Sr. Replies to the NRC letter sent to him 2/12/14.

Comley Sr. Reponses to Violations Law and Standards of NRC licensing of U.S. Nuclear Plants continued: Time and time again I received this answer, “There is noting we can do, we would all be a goner because we cannot safely evacuate these people.”  Since August 11, 2013 I have talked with other State Troopers in NH and MA as well as other State Police officers and Chiefs and police in authority in the surrounding towns within the 10 miles radius of Seabrook Station and got the same replies.  

Due to these troubling concerns I revealed at this hearing I requested the NRC Panel,,“To arrange an investigative hearing before the State Troopers of MA, NH and the Police officers of the surrounding towns of within the 10 mile radius of the Seabrook Nuclear Plant whether it is in their opinion who have knowledge of how much traffic congestion is present on holidays and high beach days in MA and NH if people can be evacuated safely in the event of nuclear disaster at the Seabrook Nuclear Plant.”

If in fact these traffic experts testify they are not able to safely evacuate citizens in MA and NH safely and I believe they will.it is obvious to me the NRC, President Obama, FEMA, both Governors of NH and MA are currently in violation of US Laws.  Under these circumstances, Seabrook Station’s license to operate must be revoked and the Plant must be shut down immediately because it was built in the wrong location and has been violation of U.S. Law since the NRC licensed it....

Since requesting this Investigative Committee Hearing during my oral testimony at the NRC hearing December 18, 2014 your reply to me in your letter was for me to contact FEMA.
 In all due respect to you Mr. Dentel,  I believe this is your responsibly to contact FEMA just like if I gave your office additional information concerning falsification of welds at Seabrook Station which brave Informants from Seabrook brought to WTP in the past, you would have to act on them. Unfortunately information I gave to the NRC IG concerning weld deceptions at Seabrook Nuclear Plant was never fully investigated. 

Please let me know when the NRC and FEMA will arrange and assembly this Investigative Hearing. 

NRC reposnse
: “U.S. Nuclear Power Plants must conform to safe evacuation procedures when approving the location of a Nuclear Plant.”    

Stephen B. Comley Sr. response to NRC’s: It is pretty obvious to me and many others I know the NRC and FEMA in the event of a Nuclear disaster at Seabrook Nuclear Plant never ever really held legitimate tests on Routes 1 or US Federal Highway 95 in MA and NH established whether citizens can be evacuated safety during crowed beach days or   

Page 15 Stephen B. Comley Se. Replies to the NRC letter sent to him 2/12/14.

Comley Sr. Responses to Violation of Law and Standards of NRC Licensing of U.S. Nuclear Plants continued:  people traveling to Maine or Canada from MA and NH.

I have obtained a DVD (Enclosure N) which shows Traffic patterns during high traffic days in MA and NH on 95 as well as other roads in the proximity of Seabrook Nuclear Plant.

Those of us who watched the licensing of Seabrook knows what a mockery of our democratic process was made by former Governor Sununu, Victor Stello and NRC Administrative Licensing Law Judge, Ivan Smith in making sure evacuation plans would indeed be passed and established in the unlikely event of a nuclear accident at Seabrook instead of the likely occurrence of one happening. This was done with the establishment of one step licensing which I explained more fully on page 3 with Enclosure D and contained in Media articles in enclosure N.

 I have always wondered how Former NH Governor John Sununu then and now can ride around in his car with the NH license plate saying “Live Free or Die.”   

4) NRC remarks (Emergency Planning): “You questioned the ability of local authorities to implement the emergency preparedness program in the 10-mile emergency planning zone (EPZ), as well as the ability to protect the special needs population both inside and outside the 10-mile EPZ.  You also asked that the NRC hold a meeting with the State Police in Massachusetts and New Hampshire to gain their insights on the ability of local officials to implement the emergency plan in the event of a radiological release at Seabrook station.  You further asked why the NRC has not required emergency planning beyond 10 miles.

NRC Response
Each reactor site in the US has onsite and offsite emergency plans to assure that adequate protective measures can be taken to protect the public in the event of a radiological emergency.  Federal oversight of emergency preparedness for nuclear power plants in the US is shared by the NRC and Federal Emergency Management Agency (FEMA).  This sharing is facilitated through a Memorandum of Understanding (MOU) that is responsive to the President’s decision of December 7, 1979, that FEMA take the lead in overseeing offsite planning and response, and that NRC assist FEMA in carrying out this role.  The NRC has statutory responsibility for the radiological health and safety of the public by overseeing onsite preparedness and has overall authority for bout onsite and offsite emergency preparedness.   

The NRC must have reasonable assurance that adequate protective measures can and will
be taken in the event of a radiological emergency.  The NRC’s decision of reasonable assurance is based on licensees complying with NRC regulations and guidance.  In addition, licensees and area response organizations must demonstrate
they can effectively implement emergency plans and procedures during periodic

Page 16 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/112/14.

4) NRC responses continued for Emergency Planning: evaluated exercises.  These plans include provisions for dealing with school children, as well as special needs populations, such as nursing home patients, imprisoned individuals, and other persons incapable of evacuating an area on their own.  The options include providing assistance to relocate them or sheltering the, in place.  Each plant owner is required to exercise its emergency plan with the NRC, FEMA, and offsite authorities at implementing their emergency plans.  Licensees also self-test their emergency plans regularly by conducting drills.  Each plant’s performance in drills and exercises can be accessed through the NRC Web site; http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html

FEMA takes the lead in initially reviewing and assessing the offsite planning and response, and in assisting State and local governments, while the NRC reviews and assesses the onsite planning and response.  FEMA findings and determinations as to the adequacy and capability of implementing offsite plans are communicated to the NRC.  The NRC reviews the FEMA finding and determinations as well as the onsite findings.  The NRC then makes a determination on the overall state of emergency preparedness.
 
As for emergency planning activities beyond the 10 mile EPZ, FEMA does require that licensees have plans in-place out to 50 miles from a facility to address the possible ingestion of radioactive materials.  The primary risk from a radiological release beyond 10 miles is not from the direct exposure of individuals to radiation from a release plume, but rather long-term exposure from residual contamination in surface water, on the ground, on food supplies or ingested by livestock.  Protective actions for the 50-mile ingestion Pathway Zone include stopping the distribution of contaminated food and water, relocating livestock, and controlling access to the area.

The Seabrook Station offsite emergency preparedness plans meet current NRC and FEMA requirements were demonstrated during the last exercise conducted in late 2012, and will be evaluated again in an exercise in late 2014.  In those exercises, the performance of the State Police in New Hampshire and Massachusetts, as well as the numerous local communities in both states, is evaluated by a team of FEMA employees and contractors.  Since FEMA has offsite EP responsibility, we suggest you contact the FEMA Region I office that is responsible for Seabrook station’s emergency plan to discuss your concerns.   FEMA Region I, Attn:  Steve Coirman, Regional Assistance Chair, 98 High St., Boston, MA 02110, 1-877-336-2734 (or 617-832-4731 for Steve’s direct number) . .

Stephen Comley Sr. responses to the NRC’s to Emergency Planning.
The Seabrook Nuclear Plant does NOT have onsite and offsite emergency plans to assure adequate protective measures can be taken to protect the public in the event of a radiological emergency.  You state Federal oversight of emergency preparedness for nuclear power plants in the US is shared by the NRC and Federal Emergency Management Agency (FEMA). This sharing is facilitated through a Memorandum of

Page 17 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. continued Reponses to NRC’s to Emergency Planning:


Understanding (MOU) (That certainly rings another bell in one of WTP’s investigations of cover-ups within the NRC (see enclosure O, I will discuss further on page 19) that is responsive to the President’s Carter decision of December 7, 1979, that FEMA take the lead in overseeing offsite planning and response and that NRC assist FEMA in carrying out this role.  This all sounds good on paper but the fact remains neither the NRC, FEMA or the Seabrook owners have fulfilled their Statutory responsibility for the radiological health and safety of the public because their plans for onsite and offsite emergency preparedness have never been really tested in the likely event of an explosion at Seabrook Station but only from the standpoint of the unlikely result of a nuclear accident at Seabrook. . 

There are several reasons and facts that prove why I make this determination which I outlined in my previous responses to 3) (Emergency Planning) which included current violations of U.S. Laws as they relate to Potassium Iodide,  Discrimination and the Law and standards of NRC licensing U.S. Nuclear Plants.  

In addition the NRC does not have reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.  You state, “Each plant owner is required to exercise its emergency plan with the NRC, FEMA, and offsite authorities at implementing their emergency plans.  Licensees also self-test their emergency plans regularly by conducting drills.  You also state Seabrook Station offsite emergency preparedness plans meet current NRC and FEMA requirements and were demonstrated during the last exercise conducted in late 2012, and will  be evaluated again in an exercise in late 2014.  In all due respect who is the agency and persons that determined December would be the best time of year in this area to test offsite emergency preparedness plans for Seabrook Station? 

Was this an the old idea that came from former Governor Sununu and Victor Stello, former Executive Director of the NRC: The only way to conduct a viable and true test of Seabrook Nuclear Plant’s Emergency Preparedness Plans is to test them during summer and fall holidays when droves of citizens of MA, NH and Me are relaxing at the Hampton and Salisbury beaches not when it is snowing and no one is around.     

NRC states, “As for emergency planning activities beyond the 10 mile EPZ, FEMA does require that licensees have plans in-place out to 50 miles from a facility to address the possible ingestion of radioactive materials.  I have had citizens in Amesbury, Newburyport and Salisbury within the 10 mile radius of Seabrook Station state after they have read in the newspaper Seabrook Station had conducted a drill no sirens were heard by these individuals in their area.


Page 18 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. continued responses to the NRC;s to Emergency Planning:
Considering these circumstances and facts I have now reported to the NRC, will the NRC and FEMA instruct Seabrook Plant owners, Florida Power and Light to install for more sirens and other equipment needed for special needs people within the 20 mile radius of Seabrook Station?   


I also believe where Former President Bush felt Potassium Iodide should be stockpiled within 20 miles it seems reasonable he would be infavor of installing more sirens within 20 miles instead of just 10 miles, so citizens within that radius will hear when to take the controversial drug KI.  Please comment. 

Hopefully President Obama will elect to change his present position not requiring Potassium Iodide to be stockpiled within 20 mile radius of U.S. Nuclear Plants. Can once again be signed into law and implemented. .    

NRC (Decommissioning Funding) you asked how much money is set aside for decommissioning Seabrook Station.

NRC Response:   “As of the end of 2012, approximately $450 million has been set aside in decommissioning funds for Seabrook Station.  Per 10CFR 50.75(f) (1), licensees are required to provide that information to the NRC.  The information as of March 2013 is available to the public in the NRC; s document management system under Accession Number Ml, 13093A156: a copy of that report is attached.

Stephen B. Comley Response to the NRC’s: who determines the adequacy of decommissioning funds and how it this determined?  Does it include the dimensioned value of the U.S. dollar in figuring possible new determine increased costs to decommission Seabrook? 

If indeed the amount is not currently enough to decommission Seabrook where and when would the NRC require Florida Power and Light to raise the necessary funds?   

6) NRC (CNN DVD) You provided a DVD copy of a CNN report and urged it to be placed in the NRC library.

NRC Response: As this video is not an NRC production, was not required to be submitted to the NRC, and would require the copyright clearance of CNN, we cannot load such a video on the NRC website.  However, CNN has loaded many such videos to YouTube.  We suggest you contact CNN to determine if this video is public by ccessible.

Comley Sr.’s response concerning CNN video:
WTP has the copyright clearance for the NRC to store CNN’s video on their Website. 

Page 19 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. response continued to NRC’s regarding CNN Video:
WTP has had no problem getting copyright clearance for CNN’s video.  I can’t imagine why CNN would not offer the NRC the same privilege.  If there some reason why you believe your agency would not ask for the right?

Due to a NRC MEMO of UNDERSTANDING  (MOU) which gives the NRC authority to reveal identities to their employers of Nuclear Industry Plant workers who report safety violations to the NRC. Enclosure O contains several Media articles of NRC IG investigation brought about by WTP informants including the MOU see AP and Christion Science Monitor articles).  Also in O include other article. Including one  initled, “ US removes a gag from Seabrooki critic.”  WTP’s lawyer, Ernest Hadley was successful by getting former Dept. of Labor Secretary Robert B. Reich to rule, “This provision was contrary to public policy and unenforceable.”  This lead to hearings involving Joseph D. Wampler who was fired for raising safety concerns at the Seabrook Nuclear Plant Wampler and contended that 20 % of the 2,669 safety-related welds at Seabrook were either defective or improperly documented - X-rays used for backup were flawed and the safety of the welds could not be determined.    This was the second case of falsification of welds at Seabrook which WTP brought to light.  I was never asked to testify about what additional information I knew about these two separate cases.  Former Seabrook workers and supervisors should have been be subpoenaed and put under oath which means they faced with having to tell the truth why weld records were falsified at Seabrook Station or go to jail. 

It should be noted,
when the NRC IG office was created they only were given authority to subpoena records not people, I know why,  Due to this circumstances and others I believe it would be more appropriate and helpful to potential whistleblowers within the NRC and the Nuclear Industry to at least be made aware of our organization by the NRC agreeing to load the CNN video entitled, INSIDE THE NUCLEAR REGULATORY COMMISION: REGULATION OR INTIMIDATION on NRC’s Website.  I certainly do not object to your suggestion to place CNN investigation of WTP’s work in exposing Cover-ups within the NRC and unsafe conditions at most U.S. Nuclear Plants to have to recommend CNN’s video be placed on You Tube for the general public to view. 

7) (NRC  Seabrook Concrete) you asked which company supplied the concrete during the construction of Seabrook Units 1 and 2.
NRC’s Response
Concrete is a composite of cement, aggregate (e.g., crushed rock & sand), water and, in some cases, small amounts of admixtures. The component of concern in the Alkali silica Reaction is the aggregate, which contains the reactive silica.  As stated at the public meeting, the aggregate that was supplied to the constructor, United Engineers constructors, originated form four quarries in southern Maine (denoted in NextEra’s slide presentation at the meeting & now available on the NRC website).While that aggregate was originally tested by a short duration test & found to be acceptable, the test performed was not adequate to identify that ASR would develop over a much longer time frame.

Page 20 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

8) (Seabrook Concrete)
Can Seabrook’s Unit 2 ever go on-line or would a second unit have to be constructed from scratch?  If that is indeed the case why isn’t the testing of the degradation of the cement being done on the Seabrook Nuclear plant on the old Unit 2?

NRC Response the NRC construction permit for Seabrook Unit 2 was cancelled in 1988.  Moreover, since that time, a number of key plant components, namely the steam generators, were sold to other utilities for use, while the upper portions of the containment liner were torn down following the sale of the site to NextEra.

During the meeting on December 18, 2013, NextEra staff discussed with the NRC staff their large-specimen testing program underway at the University of Texas’ Ferguson Structural Engineering Laboratory.  The NRC has neither recommended not ordered NextEra to take this approach nor have we approved it.  Neither has the NRC required the licensee to use concrete from the cancelled Seabrook Unit 2 structures.  Should NextEra elect to use the results of this test program to resolve the ASR non-conforming condition, the testing methodology and results will be subject to NRC review  pursuant to the applicable regulatory processes described in 10 CFR 50.59 and /or 50.90.  Should NextEra decide to use another approach, the NRC will likewise implement these regulatory review processes.

Stephen B. Comley response to NRC’s

Thank you for this information.  Please keep me informed if NextEra decides to use another approach and if and when the NRC approves and will implement any new regulatory review processes.

9)  NRC remarks: (Public Meeting Transcription) You requested a copy of the video made during the public meeting on December 18, 2013, and asked why the agency changed its position regarding transcribing this meeting?

NRC Response

NRC management decided before the meeting to have our sound contractor video record the meeting due to the high level of public interest in the issue.  Management even pursued webcasting the meeting to the public, but ran into technical challenges at tat conference facility venue.  The intention is to place it on the NRC website with the other Seabrook ASR information.  We did not change our position regarding transcribing the meeting – it was not transcribed.  As a rule, the NRC does not transcribe the roughly one thousand public meetings it conducts annually.

Members of the public are free to record such meeting if they so desire.  On December 18, the meeting was recorded by three groups – the NRC sound contractor, a local cable access station, and by a friend of yours.  The NRC video is scheduled to be posted on our
Page 21` Stephen B.Comley sr. Replies to NRC letter sent to him 2/12/14.

9) NRC remarks continued (Public Meeting Transcription:: own website in mid-February.  The video will be unedited, with the exception of a remark that will be deleted.  Specifically, someone at the microphone mentioned their name and home address, so for personal privacy and identity protection reasons, the NRC is obligated to withhold that information.

Stephen B. Comley Sr. responses to NRC

First of all this meeting was inappropriately scheduled one week before Christmas one of busiest times of the year for most people.  Why wasn’t more consideration given by the NRC to hold this meeting so the citizens from MA and NH who live within the 10 mile radius of the Seabrook Nuclear Plant would have had a more convenient time to voice their concerns and objections to extending Seabrook Station license  from 2030 to 2050?.

The NRC does not usually videotape meetings either do they?  Why did the NRC decide to video tape this meeting?  How many people would have to usually attend before the NRC would spend the money to video tape a meeting?

Mr. Dentel I believe some of the reasons why the NRC requested that a video be taken was because of the 3 consecutive phone calls I got from Richard Barkley as a result of letters I wrote published in several newspapers (Enclosure P) in NH and MA stating I would testify at the Hearing.  I found out the questions he was asking me were really coming from the NRC General Council.  She made allegations about me possible bringing signs with sticks attached and that I may injure people attending the Seabrook NRC hearing December 18, 2003.  I was insulted by her remarks and requested an apology letter from her which I have not received to date.  Please Reply.    

10) (NRC Staff Notes)
You requested the notes of Diane Screnci, Sr, Public Affairs Officer taken during conversations you had with her, information which she later summarized and passed on to the NRC’s Office of the Inspector General.

NRC Response     
As Ms. Screnci mentioned to you, the personal notes of NRC staff member are not releasable under the FOIA process.  However, the subject matter you discussed with Ms. Screnci was captured by the many documents you submitted to the NRC, which
as stated earlier are publicly available on the NRC’s document management system ADAMS at ML. 14023A685.  A copy of this letter is being provided to the NRC Office of Inspector General for information. 

The same applies to Richard Barkley, whom you have spoken with and emailed on a number of occasions since early December 2013.

Page 22 Stephen B. Comley Sr. Replies to NRC letter to him 2/12/14.

Stephen B. Comley Sr. Responses to 10)  NRC. Staff Notes:

:
I am sure Mr. Dental that you and many others in the NRC, the NRC IG and most elected officials in Washington know by now that I do not trust the NRC, NRC IG, FBI,  DOJ,    or Congress to thoroughly investigate cover-ups within the NRC or the unsafe conditions at the U.S. Nuclear Civilian and Weapons Plants. I have been left with only one other choice but to ask our Commander and Chief, President Barak Obama, to fully investigate these cover-ups by the NRC and the highest Officials in the U.S. Government which have been ignored now for many years.  

I will be sending a letter soon to Leon Panetta who as you know has tried to help in the past to get the concerns fully investigated by the DOJ.  I believe Mr. Panetta will honor my request for President Obama to meet with me once reads my letter and examines the statements and documents I have included with my letter and mailed to him at his foundation “Institute for Public Policy in California.

Ironically due to the many cover-ups WTP informants have brought to light which WTP reveals to Main Stream American could indeed cause the very demise of the Civilian Nuclear Industry and possibly put a dent in getting President Obama in taking the lead
into disarming the U.S. Nuclear Industrial Amory so other countries will follow suit..

The notes taken by both Diane Screnci and Richard Barkley of my conversations with them were I believe to be of a very serious nature.  Due to the fact I have never received a phone call from the NRC IG Mr. Bell certainly confirms to me once again the NRC, the FBI or the Department of Justice is obviously intimidated from investigating the call of former NRC IG David Williams and former White House Chief of Staff, Leon Panetta directive to investigate wrongdoing by Former Presidents Ronald Reagan, George Bush and others I know who had involvement in the cover-up of the Counterfeit Substandard Nuclear Parts Scandal. 

Mr. Dental would please request Diane Screnci and Richard Barkley to reply back to me whether the notes they took from the conversations I had with them which you say they sent to NRC IG office should at least warranted some sort of reply or contact from the NRC IG office to me concerning what I believe to be a very serious matter the American people should have answers to?.  I have also been made aware by the NRC OI who also stated to me sent information to NRC IG from notes taken from conversation I had with NRC OI but again like the notes sent by Diane Screnci and Richard Barkley I was never contacted by NRC IG, Mr. Bell or anyone form that office.. Obviously if in fact Diane Screnci, Richard Barkley and NRC OI notes were accurate of my conversations with them why I hasn’t the NRC IG’s office contacted me?  Since I have no problem of making these notes public, just maybe a congressional investigative committee down the road will find it necessary to subpoena these so called private notes. Please respond.

Page 23 Stephen B. Comley Sr. replies to NRC letter sent to him 2/12/14.

11) (Commission/EDO Response to Your Concerns} You stated at the meeting and in a subsequent email that you feel the public has a right to hear from each of the NRC Commissioners, the NRC Executive Director of Operations (EDO) and the five NRC panel members who attended the NRC public meeting given the significance of the NRC deciding whether to extended the Seabrook Nuclear Plant’s operating license from 2030 to 2050.  You believe it is important to note the NRC should also being taking in account the age of the material and parts from when the construction of the Seabrook Nuclear Plant first started, not form the time it was licensed.

NRC Response:

The purpose of the public meeting of December 18, 2013, was to inform the public of the actions being taken by NextEra and the NRC to address the ASR issue, and for the NRC to answer question from the public.  It was not a formal legal hearing.  As the individuals most directly responsible for the oversight of the NRC inspection program for Seabrook station, my staff and I are the most appropriate to address you
concerns and questions.  Should you feel the need to express your question and concerns to the five members of the Commission of the EDO, you are always free to do so directly via phone, email, or in writing.

Regarding the monitoring of the condition of the material and parts at Seabrook Station during the period of extended operation, the NRC has imposed a large number of testing and surveillance requirement on the facility during the current license period.  Those requirements will continue during the period of extended operation, and be supplemented by aging management programs implemented to monitor the condition of select material and components at Seabrook Station independent of their age.  As with any industrial facility, many parts of the station will be replaced in the future, or have already been replaced, due to equipment obsolescence, corrosion, or in the case of components in continuous use (e.g., gaskets, select valves and valve packing, etc.) because the components have reached the end of their service life.  This process will continue independent of the length of service of the facility.
 
Comley Sr. Responses: to NRC responses.

Thank you for your suggestion and I will exercise my right to contact all of the NRC Commissioners, the NRC Executive Director of Operations (EDC) and the five panel
members who attended the NRC Public meeting given the significance of the NRC deciding whether to extend that Seabrook Nuclear Plant’s operating license from 2030 to 2050.  This will include several matters which I have had and still have extreme passion about especially since I have gotten these replies. 




Page 24 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

The NRC and some of our top elected officials in our government continue to establish a double standard for safety for the Nuclear Civilian and Weapon Industries. 

My family certainly knows our Son’s family owned and run Health Care
extended Community Center would have his license to operate revoked immediately by the if he had inadequate evacuations plans or installed Counterfeit Substandard Fire Doors in his facility. I know if the MA Dept. of Safety and the Federal Life Safety Code found a Bogus fire door in my Son’s Health Care Home they would not be in favor of lowering the standards so he could save money and time instead of replacing substandard door with a Fire door that is properly tested and labeled..

Your statement on page 6 in your last response to me state, “As the individuals most directly responsible for the oversight of the NRC inspection program for Seabrook Station, my staff and I are the most appropriate to address your concerns and questions.”  In all due respect to you and everyone else in the NRC who want me to believe the NRC is protecting the safety of the American people is like expecting me to recommend that the mafia be placed on the police force to enforce our laws.

In over the 27 years of WTP’s informants and myself investigating and revealing the
NRC’s penciling away of inadequate evacuation plans and covering up unsafe conditions at US Nuclear Plants including the Counterfeit Substandard Scandal which the NRC IG office only did a  Generic investigation of the NRC’s cover –up of these bogus .parts - instead of a doing a specific investigation of the NRC which  also included the involvement which I can prove of  President Reagan, President Bush, Rudolph Giuliani, Senator John Glenn and his Legal Counsel Stephen Ryan,  60 minutes, Former Chairman of the Senate Arms Committee, Senator Sam Nunn, who conducted hearings during President Bush’s Nomination of Victor Stello to become assistant Secretary of Energy, Former Senator Peter Kostmayer and his Legal counsel, John O’Donnell,  Former Attorney General Thornburg and others.

The NRC’s and other officials in our Government continues with their philosophy of allowing the Nuclear Civilian and Weapons Industries to play Russian Roulette in America’s neighborhoods still continues to exist this day...
|
You mentioned in your letter to me on the bottom of page 1 and onto 2, “given your protracted and costly legal involvement with the agency and the department of Justice in this matter.”  Yes, it has been costly during the 6 years I spent in MA Fed Court with the charge of “Conspiring to Topple the NRC” and other experiences like the threats on my family and me. I believe it has been one of the best investments I will ever make.  I found in this life there are some things we cannot ignore or walk away from. This ordeal has only strengthened my faith but brought me closer to Jesus.  I carry many Bible passages in my head there of which have had a profound effect on me. They are Hebrews 11:1, “Being sure of what you hope for and being certain of what you cannot see.”, Luke 18: 1-8, “The Parable of the persistent widow who kept going to a Judge who did not respect  
Page 25 Stephen B. Comley Sr. Replies to NRC letter sent to him 2/12/14.

Comley Sr. response continued. “ man or God but because of her persistence the Judge finally said, give her justice because she is driving me crazy.” and Genesis 50:20, “You intended to harm me, but God intended it for good to accomplish what is now being done, the saving of many lives.”

I have no intention of allowing the NRC or anyone else in Washington to risk my family’s safety.”   I fully intend to continue to take the advice of Albert Einstein after he spilt the atom when he stated, “To the village squire we must take the facts of Atomic Energy from there must come America’s voice.”

I will be traveling soon to South Korea and Japan where I have been invited to speak about my experiences with the NRC and the dangers associated with the Nuclear Civilian and Weapons Industries. Upon returning to my home town of Rowley I will be circulating along with others a National Petition to President Obama like Rowley citizens who believe STRONGLY IN DEMOCRACY will again rise up again like we did in 1986 when 80% of our Town of Rowley MA signed a petition to then President Reagan which he ignored. Hopefully President Obama will accept our invitation to visit our small Town of Rowley like he did others towns in America during his Presidential campaigns and address our concerns and not ignore us like others past Presidents have done.  .

In closing I know there are good and dedicated people within the NRC and at Nuclear Civilian and Weapons Plants who also have families that want to protect against a nuclear disaster from occurring in the American again.  I also believe both you and Mr. Barkley and others I know who are present or and former employees of the NRC are pulling for WTP to continue to reveal truth to the American People when we discover wrongdoing at the NRC and unsafe conditions at U.S. Nuclear facilities. .

If anyone in the NRC needs further clarification or comment please do not hesitate to contact me. I would like to reinstate my offer I made at the December 18, 2013 NRC hearing to be willing to work with any responsible NRC individuals who would like to meet with me privately in revealing any wrongdoing at the NRC.  These individuals can contact me without revealing their identities or can meet with me privately in person. 

I can be reached by my Cell # 904-206-314 or by e-mail scomleysr@yaho.com .  . 

Sincerely,
  Signed
Stephen B. Comley Sr.
Founder of We the People a National Whistleblower Non-Profit Organization