ML072900427
| ML072900427 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/12/2007 |
| From: | Shaw S - No Known Affiliation |
| To: | Marcia Carpentier, Valloch K NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 50-271-LR, RAS 14452 | |
| Download: ML072900427 (3) | |
Text
HearingDocket - Additional comment'tto ASLB on ENVY kRelicensing contentionsP
...Page 1 1A 5 /
1/95 0 2 From:
"Sally Shaw" <acer8sac@comcast.net>
To:
"NRC Hearing docket" <hearingdocket@nrc.gov>, <secy@nrc.gov>, <mxc7@nrc.gov>,
<ksv@nrc.gov>
Date:
Fri, Oct 12, 2007 12:01 PM
Subject:
Additional comment to ASLB on ENVY Relicensing contentions Additional Comment from Sally Shaw to ASLB on Vermont Yankee Relicensing. Judge Karlin: Please incorporate the following into your deliberations.
RE: NEC Contention 2: aging management of anticipated metal fatigue, pursuant to 10 CFR Section 54.21 (a) and 10 CFR Section 54.21(c).
Entergy's aging managment program for the reactor vessel (beltline) is inadequate. The surveillance capsules originally incorporated into VY's reactor vessel expressly for the purpose of plant-specific monitoring of embrittlement are being ignored. From the Uprate SE,
- p. 15 "The surveillance data from Susquehanna Unit 1 will be utilized to monitor the impact of neutron radiation on the VYNPS beltline materials" while VY's "untested capsules, originally part of the licensee's plant-specific surveillance program, having received significant amounts of neutron bombardment, will remain in place."
This is like using data from the Iraq Occupation to determine how we're doing in Afghanistan. Or using the Prairie Island cooling tower collapse to predict and prevent a similar event at VT Yankee. IT ONLY WORKS IF YOU STUDY AND THEN HEED THE DATA. Obviously, even if the Susquehanna capsule indicated dangerous embrittlement, Entergy would argue that it wasn't plant specific so they could ignore it. (The Prairie Island warning is a case in point. The lax safety culture at VT-Yankee is further evidenced in the following hypocrisy: Despite engineer David McElwee claiming that "a hands on inspection where you could get your hands on actual members would be far better" Entergy is proposing to look at ANOTHER REACTOR'S SURVEILLANCE CAPSULES rather than their own, to determine the condition of the reactor vessel. They won't check their own capsules because that WOULD be plant specific data which they would be forced to heed. Another example: Entergy's record of using flawed projections, remote calculations and fuzzy math rather than actual installed instrument readings to determine fenceline radiation exposure, resulting in repeated violations of VT State Health standards.
We request the ASLB to require that Entergy pull out at least one capsule from the VY reactor vessel, determine the reactor's actual degree of embrittlement, and compare it to the neutron bombardment levels of a similarly located Susquehanna capsule to document their assumption that the capsules are interchangeable.
NRC should not allow data shared between reactors or probabilistic calculations to substitute for actual surveillance, testing, and monitoring of plant-specific conditions. This does not provide the public with "reasonable assurance" of anything.
Sally Shaw, Gill Massachusetts October 12, 2007 "Our lives begin to end the day we become silent about things that really matter." -MLK DOCKETED USNRC October 12, 2007 (12:01pm)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Docket No. 50-271-LR
'Fe/It CK-O3S14' A 0
ýýOW)0,0,001.TMP
-Page11e c :..........
T M P.
.....P a ge..
........ 1...
Mail Envelope Properties (470F9A31.B60 : 22 :31584)
Subject:
Creation Date From:
Created By:
Additional comment to ASLB on ENVY Relicensing contentions Fri, Oct 12, 2007 11:49 AM "Sally Shaw" <acer8sac(icomcast.net>
acer8 sac(-comcast.net Recipients nrc.gov OWGWPO02.HQGWDOO1 HearingDocket (NRC Hearing HearingDocket) nrc.gov TWGWPO02.HQGWDOO1 SECY (SECY) nrc.gov OWGWPOOI.HQGWDOO1 MXC7 (Marcia Carpentier) nrc.gov TWGWPO04.HQGWDOO1 KSV (Karen Valloch)
Post Office OWGWPOO2.HQGWDOOI TWGWPO02.HQGWDOO1 OWGWPOO1.HQGWDOO1 TWGWPO04.HQGWDO01 Route nrc.gov nrc.gov nrc.gov nrc.gov Files MESSAGE TEXT.htm Mime.822 Options Expiration Date:
Priority:
ReplyRequested:
Return Notification:
Concealed
Subject:
Security:
Size 2787 3467 8227 Date & Time Friday, October 12, 2007 11:49 AM None Standard No None No Standard
- \\tem GW}o 1.TMP Junk Mail Handling Evaluation Results Message is eligible for Junk Mail handling This message was not classified as Junk Mail Junk Mail settings when this message was delivered Junk Mail handling disabled by User Junk Mail handling disabled by Administrator Junk List is not enabled Junk Mail using personal address books is not enabled Block List is not enabled