ML12180A319

Co-petition of Several Individuals with the Alliance for a Green Economy and Beyond Nuclear to Suspend the Operation of James A. FitzPatrick License Until Entergy Nuclear Operations Publicly Documents a Post-Fukushima

ML12180A319
Person / Time
Site:	FitzPatrick
Issue date:	06/12/2012
From:	Rodriquez R, Brady C, Whitney E Alliance for a Green Economy, Beyond Nuclear, - No Known Affiliation
To:	Borchardt R, Bhalchandra Vaidya NRC/EDO, Office of Nuclear Reactor Regulation
References
2.206
Download: ML12180A319 (47)

Text

{{#Wiki_filter:Mr. James Borchardt Executive Director for Operations C_5'EDO U.S. Nuclear Regulatory Commission DEDMRT Washington, DC 20555-0001 DEDR DEDCM AO Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York 12,(

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank vnAI Name (pnnt): . W-1, 7 Date c,b Z . Email: 2 S~lignature 4MVVCILCI Address: Name (print): - V~it i tL_ C* Signature Date 1 2i i. Email: _jFl 1" C-LI*£m.. Q - . Address: Name (print): 6mý '4 Signature Date4/./7 ,mai,: "41 Address: 7279jl6a4

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Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money,, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no fteb," ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): .K i-- 'L- 6(L-*"l(Vetki. Signature ,4 .X Date at 11  ? Email:___ Address: ,0. KdZ,'"/ & k f,-- L,4 Name (print): iiII72l- Signature A-Date - 2/)1/

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Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K.Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scribe, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

 "    The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
 "    The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.

• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (printP4 TQCA M S'Lq Signatu e Date &/7'-// Email:

-Address:

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Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): l W/ J Signature Date __ _ L Email: Address: Name (print): h Signature Date - Email: Address:l 2 co-] V_ Tý ef- /Y r V 1 Name (print): *"-( ** *Sig nature** . Date 6, Email: *$ )($AI cord JA Address: VI/r+ LacV07 Ny . . Name (print): ia P.1Vw_,;,*/U)y Signat-Date L --. *2-../ . Email: Address: 6.ýV c( "-G t* iLIAJ*E R, 'PerýJ/A Y/*AML;D l IY5 27

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during.a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): Sig nature Datee</1 -/ Email: /300 ~ ~ , 6-Zý n Address:2- < 4 ?j,/ 1 fw' Name (print): AkTr- Cc.., yiI Date "-I "L Address: Name (print):. __________, ___,____ Signatur - Date ///z 2.-.- Email: c--ej /,, Address: 'f n FI P og - Name (print): _ ____ p. )V-J7rsJ 4 Signature FLYAA Date *E*V a2, Email:-~ 4 Me~' TQo'Zjhrco-~ Address:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): Skf~~ne~St[A Signature Date G t2"ll z Email: . Atc"es-/- QIt. C 0,U4 Address: *' "[*"' 0 17_ýrOT4 MVY ly4(5n Name (print): , CA_ Signature __- _______, Date Email: Address: Name .dV--C (., d'j --_. ii i.- C ,,I f ,. Jr Name (print):"*- .. L- '* LzL& Signature N% Date (P "1 . -L- Emnail:. F' -, -i eP/t LoA .?ttTV Address: -- k. UJ I Name (print): NOL4w Signature t Date .L.Lz / a Email: Address: qf,-T1/, Yn 4_, - (d"*,,v' -.-

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K.Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.

 "    The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.

• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved oh the assumptions that venting would prevent containment falle, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was conrect during the Fukushima nuclear ctastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen corsiderations" during a severe accident.

Therefore, I request NRC immediately suspj*d the FitzPatrick operating license until Entergy Nuclear - Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print):'A'%_V, il: n Sig,0nature Email: (0ly) , 0*

• Date QL ( IZ..--

I"4 - Address: 4-i*'-2-p (YAi,09'1V' t.J\V Name (print.*C-"V*A*W*- Signature-Date 4 -1.2-1.2, EmaUi: ( rcvt.k cJ, *)O-L Address: C'/.,2 \:.s (!ý!,tIjA (91/& A Name (print): Th7?P. I)'1Ley Signature Date Email: AddreS$:& ) 1/i=) 1312e,~~qt¶JNYfIh~ Name (print): Jr Pi _ _ _ _ Signature /v,*2t

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Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K.Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

 "    The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.

• The plan in the event of a severe accidert - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the'double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venirnfg would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current proce*!res do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): . 1.4 L,/ Signature - Date / I ' 7,

                         ,p,           Email:

Li Address: _ -( . Name (print): ." Signature ___ Date {#  !*Email:-/ Address: '- Name~jrint): W14*' **_, Signature** * '* ., Date "1 2. Email: 1C\VAV,* Q_ v-'e.S4ZD eju Address: <ýs \ .*__V, . .*. , I Wq' .. Name (print): _iQI o V^ý, ) U) .IY7 (,lic Signature (I Date I.//z Email: 7e&-0 ko*if M - 1 Address:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.

    "   In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.
• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

    "   The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

• It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Name (print): a5ý- 6 ,, Signature z, Date Email: /4D--,1C1

                                                                    &qlý7 Irl IC I" /0 Address:                                       4 ~~SsV/~g                                   0

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

    "   The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

    "   The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

• It should also include a reassessment of the assumption of "no likely ignition points", during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you,

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Name (print): ( Signature 6-,- Date V Email: / Address: /// -'

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.

    "    In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.
• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

    "   It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Name (print): Signature Date Email: Address: 413-1 N & 6v

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's, March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident. In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should-be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system. It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, .. Name (print) " Signaturej_

• Date G 14112-EdmAil es s : n, EW1, Address: }g'F**AII* . * *f,~ l'2.*--

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's. March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by'the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident. In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are

'no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system. It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Name (print): ___ Signature Date q0Z Email,: Address:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's. March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident. In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existing containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system. It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay, will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Name (print): _J*/e,- &. , Signature 4______/, __ Date 7,.J,-'e. 2V/2 Email: Address:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.
• The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.
• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, Name (print): j 7& ,QK& 5- 'P, AzJit/ Signatur §) Date (. Ir -. _ Email: Address: Name (print): i "* T' - Signature, Date Email:____ Address: Name (print): Signature Date Email: Address: Name (print): Signature Date ________ __ Email:______________ Address:,

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

We wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing" venting system that is not fully hardened against a severe accident.

 "    The plan in the event of a severe accident - which is to vent dangerous steam, gases and radiation into the Standby Gas Treatment System building which will blow off the double doors to release a radiological accident to the outside environment at ground level - poses severe risk to workers and the public.

• The hydrogen explosions at the Fukushima reactors show the dangers posed by the current FitzPatrick venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current proc6dures do not address hydrogen considerations" during a severe accident.

Therefore, I request NRC immediately suspend the FitzPatrick operating license until Entergy Nuclear Operations publicly documents a post-Fukushima re-analysis for the reliability and capability of the FitzPatrick containment vent plan, and until the public is afforded hearings to address the unacceptable risks to public health and safety posed by FitzPatrick. I wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. Jessica Azulay at the Alliance for a Green Economy is my point of contact for this petition. Thank you, ,*,i A i Name (print): U Signature Date Email: 00 j CO121 Address: 3 r MIN %Omp~oa_ 64 I t/q( Name (print): Signature Date Email: Address: Name (print): _____________________Signature__________________ Date __________ Email:______________________________ Address: Name (print): Signature Date Email: Address:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you,

                                                                     ýýa         2-*2_12 Signature                                                            UDate Name (print):    'L"-/1 Address:LiLLJ.L,7._                44L~X~~

City/State/Zip COzL,ý

                           )

Email:

Mr, James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish toco-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, gature Date Name (print): -

                                  -pK    (1s Address:       _/_____/____   .______  __              _

City/State/ Zip iV-'// 2C(o*" ~7&) Email:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 2055.5-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.

" In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

    " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. h an you, Date Name (print)- .iQ**l .4A4(A/*7*/ Address:

                                                                      /

City/State/ Zip,/f21/4 j//(d4* /'6 Email:

                                                              /

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.
• The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

" The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

" Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   ,   The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Sign Date Name (print): ______! ___ ________,_s_, _ Address: -T. &,-d a/7 (reeL ic ,/l-_L//(a City/State/ Zip Al/h, i IA/V 122.&<' Email: M( 4 W AI &4 A 0

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.

" The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.
• In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

" The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was: approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   "   The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Signature ,, At Date Name (print): Address: C4K rci{ Or"e City/State/Zip Email:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases. and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

" Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
• It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Sign uDate Name(print): -'IA' e 14 Address: / "-) (Zt L. - City/State/Zip F1o LYi(4 302 Email: I~vaIco,V~

                          "Mculfc1

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

" Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   "   The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
   "   It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. SignaDate Name (print): ,t2- k)

                                     . 0 T,'

Address: LCe*--C.& City/State! Zip O ~tfrv Email:.-'-oS,*U.9 1 Acc~p ZP.',

                                          .Cori,_,

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.
• The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

" The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.
• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   " The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Sintur~e) Date Name (print): ij M m* T&*t d/iS. Address: A 8," -e City/State/ Zip 2 i'q Email: J,4 rAd@ &4 -oo,*

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency, enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.

" In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. " Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Signature Date Name (print):. Address: 1 ?75)' 3 City/State/ Zip 9-V' Email:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

• Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   " The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Sigiature Date Name (print): 1. -,*.- *- Address: 12- te*-*,& Te,,'c,- City/State/ Zip A ti / NY I ..* "* Email: -

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.

• The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.
• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.

" In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.

• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

" Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

   "   It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Signature Date Name(print): ___________________ Address: e s _______ City/State/ Zip l cak .1 I >24' Email:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.
• The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.
• The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.

" In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. " Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
• It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you,

     '1(6, Signatiure    LA,,

Date Name (print): <Z bay Address: City/State/ Zi P.

                                               /

Email:

                                      /

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.

• The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion.

" The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident.

• In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk.
• The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe.

" Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident.

Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

      ,  The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.
     "   It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. S i glIature// DAJ Name(print):  ? , o Jý Address:______________- City/State/ Zip * , 4* * *.14* Email:

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 20 i 2 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.

• Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011.

" The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not filly hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. " Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

   "   The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

• It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Signafiure Date Name (print): ___________________ Address: Z/ / /iv4/6* 4//* City/State/ Zip iv*, /*. Email: 7 " CeY-9

Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Bhalchandra K. Vaidya, NRC Petition Manager In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New York

Dear Mr. Borchardt:

I/ We wish to co-petition with Citizens' Environmental Coalition, the Alliance for a Green Economy and Beyond Nuclear in their March 9, 2012 emergency enforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant. " Nuclear Reactors of the GE Mark I design have very small containment structures, and as a result cannot contain radiation in the event of a severe accident. Fukushima Dai-Ichi reactors demonstrated this problem in 2011. " The NRC requested that all Mark I reactors install hardened vents to allow the release of gases and pressure build up, in order to prevent an explosion. " The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct Torus Vent System as requested by the NRC in 1989 and instead, to save money, relies upon a "preexisting" venting system that is not fully hardened against a severe accident. " In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that now place public health and safety at an undue risk. " The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequences posed by the current FitzPatrick severe accident venting plan, since the plan was approved on the assumptions that venting would prevent containment failure, and that there are "no likely" ignition sources along the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe. " Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in that current procedures do not address hydrogen considerations" during a severe accident. Therefore, I/ We request NRC immediately suspend the FitzPatrick operating license until the following emergency enforcement actions are approved by the NRC:

1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plant and the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas Treatment System building, blowing off the double doors to release a radiological accident to the outside environment at ground level. The public must be afforded due process to address the unacceptable risks to public health and safety posed by the FitzPatrick severe accident plan.

2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.

• The analysis should include the reassessment of all assumptions regarding the reliability of the preexisting containment venting and specifically address non-conservative assumptions behind the cost-benefit analysis used to justify not installing a fully hardened vent system.

   " It should also include a reassessment of the assumption of "no likely ignition points" during emergency venting that would otherwise present catastrophic consequences associated with the detonation of hydrogen gas and the release of radioactivity generated during a severe accident.

I/We wish the NRC to process my request using the 2.206 process, and I understand that under this process, the contents of this message and my identity will be made public. The Alliance for a Green Economy (Citizens' Environmental Coalition is a founding member of the Alliance) will keep me informed about the developments of the petition and the opportunity to participate in a public meeting with the NRC Petition Review Board. Thank you, Signaure DaV Name (print):/'C 4/1r Address: _ ___ ___ _ __ __ _ __ _ City/State/ Zip /A/ ', A -A ,/.' 9 ) Email: I-p--

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