ML042960154
| ML042960154 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/11/2004 |
| From: | Shadis R New England Coalition on Nuclear Pollution |
| To: | Atomic Safety and Licensing Board Panel |
| Byrdsong A T | |
| References | |
| 50-271-OLA, ASLBP 04-832-02-OLA, RAS 8653 | |
| Download: ML042960154 (4) | |
Text
1RA S 96,653 October I I. 004 LTNTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED Before the Atomic Safetv and Licessize Board USNRC In the Matter of ) October 19, 2004 (11:32AM)
Docket No. 50-.71 ENTERG' NUCLEAR VERMONT OFFICE OF SECRETARY YANKEE. LLC and ENTERGY ) ASLB No. 04-832-02-OLA RULEMAKINGS AND NUCLEAR OPERATIONS. INC ADJUDICATIONS STAFF (Vernont Yankee Nuclear Po'%er Station)
Rulemaking and Adjudications Staff Office of the Secretarn U.S. Nuclear Regulatory Commission Washinmton. D.C. '0-0001 Dear Rulemaking and Adjudications Staff.
Enclosed. Please find for filing in the above captioned matter an original and two copies of DECLARATION OF PAUL M. BLANCH SUPPORTING NEW ENGLAND COALTION'S REPLY TO APPLICANT AND1NRC STAFF ANSWERS TO NEW ENGLAND COALITION'S REOUEST FOR HEARING, DEMONSTRATION OF STANDING, DISCUSSION OF SCOPE OF PROCEEDING AND CONTENTIONS..
-'This Declaration. with original signature. is being mailed by the declarant separately from the above captioned REPLY in order to facilitate timely delivery. Copies of the REPLY and the supporting DECLARATION are being served electronically and by First Class US Mail to all parties. 'We sincerely hope that this does not cause any confusion or inconvenience.
Thank vou for your kind attention.
Sincerelv.
Ravmbnd Shadis New England Coalition Post Ofice Box.98.
Edgecorb. Maine 04556
'07-882-7801 shadis - prexar.com FempIate -sec- EC 0/ CY-C°0 -
October 11. 2004 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-271 ENTERGY NUCLEAR VERMONT YANKEE L.L.C. and ENTERGY ASLBP 04-832-02-OLA NUCLEAR OPERATIONS. INC.
(Verrmont Yankee Nuclear Power Station)
DECLARATION OF PAUL M. BLANCH SUPPORTING NEW ENGLAND COALTION'S REPLY
- 1. Paul M. Blanch. declare as follows:.
- 1. Mv name is Paul Blanch. I am an electrical engineer with more than 35 years of experience in the nuclear industry. I am an independent energy consultant. A copy of m! curriculum vitae was attached as Exhibit E-A to my Declaration submitted in support of New England Coalition's Contentions in this case and it remains true and correct. As I stated in my Declaration and supporting Exhibit. I am. and remain. a qualified expert on matters relating to the safety of operation of nuclear power plants who is familiar with the license amendment application for an Extended Power Uprate that has been submitted by Entergy Nuclear Vermont Yankee. L.L.C. and Entergy Nuclear Operations. Inc.
(hereinafter collectively referred to as CEntersva) for the Vermont Yankee Nuclear Power Station. (-Vermont Yankee-).
- 2. 1 hereby reallege the statements in my previous declaration in this matter and set forth comments supporting the New England Coalition's Reply to the NRC Staff Answers. In particular. my comments below address those portions of the NRC Staff Answer criticizing aspects and bases of the contentions that I supported with my expertise and expert opinion on issues I believe are relevant to the matter before this Atomic Safetv and Licensings Board Panel. These comments are intended to be a part of New England Coalition's Reply.
S. On or about page ']. NRC Staffs Answer to New England Coalition's Contentions. it is stated that:
NEW ENGLAND COALITION'S REPLY EXHIBIT '4A
Blanch Declaration October 1.2004 Page 2 This portion of the contention is inadmissible for failure to dispute the Application. In Supplement 8 to the Application. in response to RAI SPSB-C-1 O.
Entergy performed a sensitivity case. assuming a single failure of a residual heat removal ("RHR") heat exchanger. NEC has not challenged this assessment in anv wav, nor does it provide any basis for an argument that an assessment involving its stated single failures would be more conservative than the analysis done by the applicant. Because NEC does not dispute the pertinent portion of the application addressing the single failure issue. this basis is insufficient to support admission of the contention.
Id. It is my professional opinion that this statement is incorrect. As NRC Staff-and its counsel--should be aware. The General Design Criteria [CDG] are very clear in that all single failures must be considered. In their Answer. Staff (or its counsel) concluded that because Enterge analyzed one single failure. that is sufficient.
- 4. The GDC are quite precise and clear on this matter:
Criterion 34-Residual heat removal. A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.
Suitable redundancy in components and features. and suitable interconnections.
leak} detection. and isolation capabilities shall be provided to assure that for onsite electric power system operation (assurning offsite power is not available) and for-offsite electric power system operation (assuming onsite power is not available) the sy stem safety function can be accomplishedc assUeift a sinde failure.
Criterion35--Emergency core cooling. A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-uater reaction is limited to negligible amounts.
Suitable redundancy in components and features. and suitable interconnections.
leak; detection. isolation. and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safetv function can be accomplished, assuminE a sindle failure.
Id. at 1O C.F.R. Part 50. Appendix AW.Criterion 34 and 35 (emphasis added).
The requirements of the GDC are part of the NRC regulations with which Entergy must comply both in the operation of Vermont Yankee Nuclear Power Station and in the material representations made to the NRC in the license amendment application at issue in this case. In my professional opinion. the intent of the rules are plain. Taken in conjunction with the General Design Criteria cited above. in my professional opinion.
Blanch Declaration October 11. 2004 Paoe 3 Entergy must provide more than a single calculation. not only to be certain that the requirements of the NRC's rules and regulations have been met on a pro forma basis. but also to comply with any -conservative engineering practice.
Finally. examining the UFSAR for the Vermont Yankee Nuclear Power Station. one finds the followine statement concerning Entergy s compliance regarding compliance with design criteria:
Information regarding application of the General Design Criteria can be found elsewhere in the UFSAR and in other design and licensing basis documents.
Id. at Appendix F. My review of the UFSAR and all other design and licensing- basis documents failed to uncover the referenced information.
- 6. In my professional opinion this absence of the information referenced in the UFSAR indicates that the documents supporting the application at issue in this case and. perhaps the UFSAR itself. contain inaccurate statements and are. at a minimum. a possible violation of the requirements in 'RC regulations at 10 CFR 50.9. -Completeness and accuracy of information" and 10 CFR 50.71 et seq.
- 7. Havini! completely reviewed the NRC Staff Answer to New England Coalition's Contentions in this case. it is mv considered professional opinion that the declaration I provided in support of the Contentions remains correct and the above provided information should be of common and working knowledge to anyone connected with the application.
use. and enforcement of NRC rules and regulations. Information. my opinion is a-safetv tool. It must be accurate. complete. and available. If it is not. occupational and public health and safety cannot be assured.
I declare under penalty of perury that the foregoing is true and correct. Executed on October 1P1. al004. Bl Paul M. Blanch