ML090330388

Response to January 13, 2008, Comments Regarding the Scoping of Aging Management for Susquehanna Steam Electric Station License Renewal Application

ML090330388
Person / Time
Site:	Susquehanna
Issue date:	02/05/2009
From:	Brian Holian Division of License Renewal
To:	Epstein E Three Mile Island Alert
Stuyvenberg, A L, NRR/DLR/ 415-4006
References
Download: ML090330388 (6)

Text

February 5, 2009 Mr. Eric Epstein, Chairman Three Mile Island Alert, Inc.

4100 Hillsdale Road Harrisburg, PA 17112

SUBJECT:

RESPONSE TO JANUARY 13, 2009, COMMENTS REGARDING THE SCOPING OF AGING MANAGEMENT FOR SUSQUEHANNA STEAM ELECTRIC STATION LICENSE RENEWAL APPLICATION

Dear Mr. Epstein:

Thank you for the scoping comments submitted January 13, 2009 on behalf of Three Mile Island Alert (TMI Alert) regarding the license renewal application for the Susquehanna Steam Electric Station (SSES). The comments appear to be presented in the form of petition with a formal caption that references the Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (Board) proceeding number (07-851-01-LR). In summary, these comments are about your general concerns associated with the PPL Susquehanna LLCs labor outsource practices, and socioeconomic matters regarding the aging population, potential utility rate increases, and tax issues.

The timely opportunity to raise safety and environmental concerns regarding the SSES license renewal application has previously been afforded to TMI Alert and the public. Moreover, in response to a January 2007 TMI Alert petition, these issues were formally addressed in a decision that was published by the Board. As a matter of clarification and in response to your recent comments the following is provided.

By letter dated September 13, 2006, the PPL Susquehanna LLC submitted a license renewal application to extend the operation of the Susquehanna Steam Electric Station. On November 2, 2006, the NRC issued a federal register notice that docketed the application for review and provided notice of an opportunity for a hearing. Subsequently, the NRC published a correction to the notice, and extended the comment period for scoping of the Environmental Impact Statement to January 2, 2007. On January 2, 2007, you timely filed a petition to intervene and requested a hearing with contentions that were almost identical in language to the concerns contained in your recent January 13, 2009, comments (See, e.g. Contentions 3 and 4 in January 2007 petition).

On March 23, 2007 the Board served you with its decision (ADAMS Accession No.

ML070820022). While, the Board found that you had made a sufficient showing to establish standing for yourself (but not your organization - TMI Alert), the Board did not grant your petition. Under the applicable Commission procedures, the contentions that were presented in your petition were not admissible. Moreover, the Board found that while your petition discussed in general the aging population, outsourcing, utility rates and tax issues, it did not address any issues involving the aging of any relevant plant systems, structures, or components, or any aging-management issues which is the scope of review of a license renewal application. Nor did that petition adequately demonstrate how any of the issues raised were within scope of any of the Commission

E. Epstein regulations site specific Generic Environmental Impact Statement (GEIS) Category 2 issues or provide new and significant information that challenged the GEIS findings for Category 1 issues.

On May 2, 2008, a federal register notice announced an opportunity to provide comments on the Draft Supplemental Generic Environmental Impact Statement (DSEIS). Additionally, a public meeting regarding the DSEIS was held on May 28, 2008, which you attended and at which time you offered comments in both spoken and written form (the NRC staff is currently in the process of responding to these comments in preparation for issuing the Final SEIS, scheduled for March 11, 2009). Many of the issues you raised in your spoken comments are similar to the issues you raised in your comments from January 13, 2009. Further, the federal register notice established July 21, 2008 as the date ending the public comment period on the DSEIS. Your recent January 13, 2009, comments were provided well beyond the date set for receipt of comments to the DSEIS.

As discussed in the prior Boards decision and in the NRC staffs response to your 2007 petition, the concerns that you repeatedly assert either fall outside the scope of the License Renewal Application review process or outside the NRCs regulatory authority. Moreover, you have not provided any new and significant information in your January 13th comments that has not previously been presented for consideration.

Sincerely,

/RA/

Brian E. Holian, Director Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 cc: See next page

ML090330388 OFFICE PM:DLR:RPB2 LA BC:DLR:RPB1 OGC NRR/DLR NAME DStuyvenberg YEdmonds DPelton LSubin BHolian w/comments w/changes w/comments DATE 2/2/09 2/4/09 2/3/09 2/4/09 2/5/09

Letter to E. Epstein from B. Holian dated February 5, 2009 DISTRIBUTION:

SUBJECT:

RESPONSE TO JANUARY 13, 2008, COMMENTS REGARDING THE SCOPING OF AGING MANAGEMENT FOR SUSQUEHANNA STEAM ELECTRIC STATION LICENSE RENEWAL APPLICATION HARD COPY:

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EGettys AStuyvenberg BVaidya SBurnell, OPA LSubin, OGC SUttal, OGC DScrenci, RI OPA RConte, RI PKrohn, RI FJaxheimer, RI PFinney, RI

Susquehanna Steam Electric Station, Units 1 and 2 cc:

Cornelius J. Gannon Bryan A. Snapp, Esq.

Vice President - Nuclear Operations Associate General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSB3 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Robert M. Paley Document Control Services General Manager - Plant Support PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSB2 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Michael H. Crowthers Allegheny Electric Cooperative, Inc.

Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Ronald E. Smith Pennsylvania Department of General Manager - Site Preparedness Environmental Protection and Services Rachel Carson State Office Building PPL Susquehanna, LLC P.O. Box 8469 769 Salem Blvd., NUCSA4 Harrisburg, PA 17105-8469 Berwick, PA 18603-0467 Senior Resident Inspector Manager - Quality Assurance U.S. Nuclear Regulatory Commission PPL Susquehanna, LLC P.O. Box 35, NUCSA4 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0035 Berwick, PA 18603-0467 Regional Administrator, Region 1 Joseph J. Scopelliti U.S. Nuclear Regulatory Commission Community Relations Manager, 475 Allendale Road Susquehanna King of Prussia, PA 19406 PPL Susquehanna, LLC 634 Salem Blvd., SSO Dr. Judith Johnsrud Berwick, PA 18603-0467 National Energy Committee Sierra Club Board of Supervisors 443 Orlando Avenue Salem Township State College, PA 16803 P.O. Box 405 Berwick, PA 18603-0035