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Category:E-Mail
MONTHYEARML24024A1372024-01-24024 January 2024 NRR E-mail Capture - Final Snsb RAI Regarding FitzPatrick Amendment to Modify Safety Relief Valves Setpoint Lower Tolerance ML24017A1112024-01-17017 January 2024 NRR E-mail Capture - Acceptance of Requested Licensing Action Amendment Request to Adopt TSTF-529, Clarifyuse and Applicaion Rules, Revision 4 ML23264A7992023-09-21021 September 2023 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1 ML23261C3982023-09-0808 September 2023 Acceptance Review of Amendment to Update the Fuel Handling Accident Analysis ML23244A2662023-09-0101 September 2023 Acceptance of Requested Licensing Action Amendment Request to Modify Surveillance Requirement 3.4.3.1, Safety Relief Valves Setpoint Lower Tolerance ML23237B3972023-08-24024 August 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Alternative Request to Use Updated BWRVIP Guidelines ML23194A1822023-08-0303 August 2023 Acceptance Review for LAR Re SRM 3.3.1.2 ML23163A2292023-06-12012 June 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of License Amendment Request to Adopt TSTF-580, Revision 1 ML22354A2622022-12-20020 December 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Request to Use Certain Provisions of the 2019 Edition of the ASME BPV Code, Section XI NRC-2100-2022, EN 55999 Valcor Coil Shell Assemblies Final Notification (004)2022-09-12012 September 2022 EN 55999 Valcor Coil Shell Assemblies Final Notification (004) NRC 2110-2022, EN 55999 - Valcor Engineering Corporation (009)2022-07-18018 July 2022 EN 55999 - Valcor Engineering Corporation (009) ML22124A2672022-05-0404 May 2022 Request for Additional Information for James A. FitzPatrick Nuclear Power Plant TSTF-505 ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML22063A4742021-11-29029 November 2021 Acceptance of Requested Licensing Action License Amendment Request to Eliminate Selected Response Time Testing ML21301A0672021-10-28028 October 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-541 ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21252A0482021-09-0707 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21246A2112021-09-0303 September 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt TSTF-505 ML21246A2072021-09-0303 September 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt 10 CFR 50.69 ML21215A3502021-08-0303 August 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-554 ML21187A0522021-07-0606 July 2021 Fitz RAI Regarding FitzPatrick Amendment Request to Modify SR 3.5.1.6 ML21246A2142021-06-23023 June 2021 Acceptance of Requested Licensing Action Regarding License Amendment Request to Adopt TSTF-264 ML21154A0112021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0142021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0132021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21144A1072021-05-17017 May 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt TSTF-582 ML21117A0442021-04-26026 April 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21084A2532021-03-24024 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Transfer Application ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML21033A8552021-02-0202 February 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request to Expand the Use ASME Codes Cases N-878 and N-880 ML21014A5112021-01-12012 January 2021 Acceptance of Requested Licensing Action License Amendment Request to Adopt TSTF-545 Revision 3 ML20352A2752020-12-17017 December 2020 Request for Additional Information Regarding FitzPatrick Primary Containment Isolation Valve Amendment Request ML20350B5582020-12-14014 December 2020 NRR E-mail Capture - Exelon Generation Company, LLC -Alternative Request for Documentation of Replacement of Pressure Retaining Bolting ML20294A0372020-10-19019 October 2020 Request for Additional Information Primary Containment Isolation Valve License Amendment Request ML20266G3032020-09-22022 September 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Request to Use Paragraph IWA-5120 of the 2017 Edition of the ASME B&PV Code, Section XI ML20217L3882020-08-0404 August 2020 Acceptance of Requested Licensing Action License Amendment Request to Modify Primary Containment Isolation Valve TS (EPID L-2020-LLA-0145) (E-Mail) ML20204A9692020-07-22022 July 2020 Acceptance of Requested Licensing Action License Amendment Request to Adopt-TSTF-478 Revision 2 ML20122A2302020-05-0101 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of Fleet License Amendment Request to Adopt TSTF-566 ML20066L3682020-03-0505 March 2020 Request for Additional Information: License Amendment Request for Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment ML20056E7992020-02-25025 February 2020 Request for Additional Information for LAR on Primary Containment Hydrodynamic Loads ML20035D5762020-02-0303 February 2020 Request for Additional Information: License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequence ML20027A0672020-01-24024 January 2020 Accepted for Review - Fitzpatrick License Amendment Request to Adopt TSTF-568, Revision 2, Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2 ML20027A0112020-01-23023 January 2020 Request for Additional Information: License Amendment Request for Change to the Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation ML19353A9452019-12-19019 December 2019 Request for Additional Information: License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences ML19319C3582019-11-15015 November 2019 NRR E-mail Capture - Accepted for Review - FitzPatrick License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation ML19322A0062019-11-15015 November 2019 NRR E-mail Capture - Fermi 2: Request for Additional Information- Relief Request VRR-006, Proposed Alternative for Preservice Testing of Butterfly Valves ML19316A0162019-11-0404 November 2019 NRR E-mail Capture - Revised Staff Hours Estimate - FitzPatrick License Amendment Request on Proposed Changes to the Technical Specifications Related to Primary Containment Hydrodynamic Loads 2024-01-24
[Table view] Category:Meeting Summary
MONTHYEARML23320A2472023-11-17017 November 2023 Constellation - Summary of November 14, 2023, Public Pre-Application Meeting with Constellation Energy Generation, LLC on Adoption of TSTF-591 ML23271A2682023-10-0505 October 2023 September 25, 2023, Summary of with Constellation Energy Generation, LLC on Proposed Changes to Emergency Plans ML23263B1062023-09-22022 September 2023 R. E. Ginna Nuclear Power Plant - Constellation - Pre-Application Amse 9/18/2023 Meeting Summary ML23179A0012023-06-28028 June 2023 6/7/2023 - Annual Assessment Meeting for Pa/Md/Ny/Nj Nuclear Power Plants - Meeting Summary ML23055A0352023-03-24024 March 2023 Summary of February 23, 2023, with Constellation Energy Generation, LLC on Proposed Changes to Emergency Plans to Revise Emergency Action Levels ML22187A1462022-07-0606 July 2022 Joint Annual Assessment Meeting for Pa/Md/Nj/Ny Nuclear Power Plants - Meeting Summary ML21333A1532021-11-30030 November 2021 Summary of November 16, 2021, Meeting with Exelon Generation Company, LLC Regarding a Planned Request for an Alternative to Extend the Inservice Inspection Interval ML21237A0412021-08-30030 August 2021 Summary of the July 27, 2021, Meeting with Exelon Generation Company, LLC Regarding a Planned Request to Use Case OMN-28, ML21176A0822021-07-0606 July 2021 June 15, 2021, Summary of Meeting with Exelon Generation Company, LLC Vessel Nozzle Repair Related to a Planned Request for an Alternative Related to Reactor Pressure ML21139A1852021-06-22022 June 2021 Summary of Meeting with Exelon Generation Company, LLC Regarding Its Requested Alternative to Eliminate Certain Documentation Requirements for the Replacement of Pressure Retaining Bolting ML21011A2822021-01-21021 January 2021 Summary of January 6, 2021, Presubmittal Meeting Between the NRC and Exelon Generation Company, LLC Regarding Licensing Activities to Support the Planned Early Closures of Byron, Unit Nos. 1 and 2 and Dresden, Units 2 and 3 ML20351A2832020-12-18018 December 2020 Summary of Meeting with Exelon Generation Company, LLC Regarding a Planned Request for an Exemption to Reduce the Frequency of Updates to Its Inservice Testing and Inspection Programs ML20342A3522020-12-10010 December 2020 Summary of November 13, 2020, Meeting with Exelon Generation Company, LLC Regarding a Planned Request for an Alterantive to Certain Documentation Requirements for the Replacement of Pressure Retaining Bolting (EPID-L-2020-LRM-0102) ML20323A0332020-12-0101 December 2020 Summary of November 4, 2020, Meeting with Exelon Generation Company, LLC Regarding a Planned Request for an Alternative to Reduce the Frequency of Updates to Its Inservice Testing and Inspection Programs ML20205L3712020-07-23023 July 2020 and R.E. Ginna Nuclear Power Plant Summary of Meeting ML20163A1722020-06-12012 June 2020 Summary of June 9, 2020, Pre-Submittal Meeting with Exelon Generation Company, LLC, Regarding Planned License Amendment Request to Modify Surveillance Requirement 3.6.1.3 ML19326C3582019-12-0303 December 2019 Summary of November 20, 2019, Meeting with Exelon Generation Company, LLC Regarding a Planned Request to Revise the Quality Assurance Program ML19326A3152019-12-0303 December 2019 Summary of November 18, 2019, Meeting with Exelon Generation Company, LLC Regarding a Planned Request for an Alternative to Supplemental Valve Position Indication Testing Requirements ML19302F8772019-11-0404 November 2019 Summary of the October 28, 2019, Meeting with Exelon Generation Company, LLC, Regarding a Planned Supplement to a License Amendment Request Regarding Revising the Allowable Value for Reactor Water Cleanup System Isolation ML19291A0022019-11-0101 November 2019 10/03-10/08/2019 Summary of Meetings with Exelon Generation Company, LLC, on Emergency Amendment Request Regarding One-Time Extension to Technical Specifications 3.8.1 Action A.3 Completion Time for Inoperable Offsite Source (EPID L-2019-LL ML19302D3152019-10-28028 October 2019 Annual Assessment Meeting for James A. Fitzpatrick Nuclear Power Plant and Nine Mile Point Nuclear Generating Station - Meeting Summary ML19176A0042019-07-15015 July 2019 Summary of Meeting with Exelon Generation Company, LLC, on a Planned License Amendment Request Regarding the Relaxation of Containment Differential Pressure Requirements ML19183A1282019-07-15015 July 2019 Summary of June 20, 2019, Meeting with Exelon Generation Company, LLC, on a Planned License Amendment Request Regarding Main Steam Isolation Valve Leak Rate Increase Utilizing ML19162A0272019-06-21021 June 2019 Summary of June 4, 2019, Meeting with Exelon Generation Company, LLC Regarding a Planned Request to Extend the Test Interval for Safety Relief Valves ML19036A8832019-02-0707 February 2019 Summary of Meeting with Exelon Generation Company, LLC Regarding a Planned Request to Use ASME Code Case N-879 ML18354B1712019-01-0202 January 2019 Summary of December 19, 2018, Meeting with Exelon Generation Company, LLC Regarding the Use of Boiling Water Reactor Vessel and Internals Project Guidelines ML18347B4932019-01-0202 January 2019 Summary of Pre-Application Meeting with Exelon Generation Co., LLC (Exelon) Forthcoming License Amendment Requests to Revise Technical Specification Requirements for Main Steam Isolation Valve Leak Rate Tests ML18325A1712018-11-28028 November 2018 Summary of Meeting with Exelon Generation Company, LLC Regarding Planned Fleet License Amendment Request to Revise Technical Specifications for High Radiation Areas ML18304A1662018-11-0606 November 2018 Summary of October 23, 2018, Teleconference with Exelon Generation Co., LLC to Discuss Potential License Amendment Request Ultimate Heat Sink Bar Rack Bar Heaters ML18297A1722018-10-26026 October 2018 Summary of Meeting with Exelon Generation Company, LLC Regarding Planned License Amendment Request to Adopt TSTF-427 ML18262A3662018-09-18018 September 2018 August 21, 2018, James A. Fitzpatrick Nuclear Power Plant (Fitzpatrick) and Nine Mile Point Nuclear Generating Station (Nine Mile Point) Summary of Public Meeting ML18163A2682018-06-19019 June 2018 Summary of June 5, 2018, Teleconference with Exelon Generation Company, LLC to Discuss Emergency Plan Changes at James A. Fitzpatrick Nuclear Power Plant and Nine Mile Point Nuclear Station ML18120A1772018-05-0101 May 2018 Summary of Meeting with Exelon Generation Company, LLC Regarding Draft Guidance for Emergency Response Organization Staffing ML18107A4972018-04-27027 April 2018 April 10, 2017, Summary of Public Meeting with Entergy Nuclear Operations, Inc. Regarding Upcoming License Amendment Request to Add Setpoint Verification Requirement to Technical Specification Surveillance Requirements ML17256A7482017-09-28028 September 2017 Summary of September 5, 2017, Meeting with Exelon Generation Co., LLC to Discuss Potential License Amendment Request Technical Specifications Task Force Traveler TSTF-542, Revision 2, for James A. Fitzpatrick Nuclear Power Plant ML17216A1732017-09-0707 September 2017 Notice of Meeting with Florida Power & Light Company and NextEra Energy to Discuss Closing Out Generic Safety Issue-191 and Generic Letter 2004-02 ML17144A2852017-06-0202 June 2017 Summary Teleconference with Exelon Generation Company, LLC, on Planned Submittals of License Amendment Requests to Change Emergency Action Levels Associated with Lake Ontario Water Level ML17143A3582017-05-23023 May 2017 Summary of Public Meeting for James A. Fitzpatrick and Nine Mile Point ML17143A1902017-05-23023 May 2017 Public Meeting Handouts and Sign in Sheet ML17031A2802017-02-0808 February 2017 Summary of Teleconference with Entergy Nuclear Operations, Inc. Regarding Verbal Authorization for Relief Request RR-21 for the James A. Fitzpatrick Nuclear Power Plant ML16229A4542016-08-16016 August 2016 Summary of Annual Assessment Meeting for James A. Fitzpatrick Nuclear Power Plant ML15197A3332015-07-24024 July 2015 June 29, 2015 Summary of Meeting with Beyond Nuclear, Et. Al., Regarding Its 10 CFR 2.206 Petition Requesting Enforcement Action Against the James A. FitzPatrick Nuclear Power Plant ML15120A0212015-04-28028 April 2015 April 23, 2015, Summary of Annual Assessment Meeting for James A. FitzPatrick Nuclear Power Plant on 4/23/2015 ML14197A5832014-09-18018 September 2014 Summary of the June 19, 2014, Category 1 Public Meeting with Entergy to Discuss Seismic Hazard Reevaluations Associated with Implementation of Japan Lessons-Learned Near-Tear Task Force Recommendation 2.1 ML14086A1532014-03-26026 March 2014 Summary of Annual Assessment Meeting for Nine Mile Point Nuclear Station and James A. FitzPatrick Nuclear Power Plant on 3/18/2014 ML13100A1172013-04-10010 April 2013 Summary of Public Meeting Regarding Nine Mile Point Nuclear Station and James A. Fitzpatrick Nuclear Power Plant ML13162A5812012-07-19019 July 2012 PRB Closed Meeting Notes - 07/19/12 Gunter Et Al. 2.206 Requesting Enforcement Action Against James A. Fitzpatrick Plant ML13162A5802012-05-29029 May 2012 PRB Closed Meeting Notes - 05/29/12 Gunter Et Al. 2.206 Requesting Enforcement Action Against James A. Fitzpatrick Plant ML12102A1752012-04-11011 April 2012 and James A. FitzPatrick Nuclear Power Plant - Summary of Public Meeting on March 22, 2012 ML13162A6282012-03-20020 March 2012 by Larry Doerflein: PRB Notes Attached-Dial-In Provided 2023-09-22
[Table view] |
Text
r Ocerfimin, Lawrence From: Russell, Andrea
- Sent: Friday, March 16, 2012 1:29 PM Lee, Samson; Ulses, Anthony; Dennig, Robert; Fretz, Robert; Monninger, John; MorganButler, Kimyata; Bickett, Brice; Jennerich, Matthew; Doerflein, Lawrence; Eul, Ryan; Safford, Carrie
Subject:
Action: Request for Review of G20120172 (Fitzpatrick 2.206): PRB Internal Meeting Notes on the Request For Immediate Action Only (TAC ME 8189)
Attachments: G20120172 Fitzpatrick Immediation Action MTG Notes 3 14 12 FlNAL.docx Good afternoon, On behalf of Bhalchandra, I am providing you with PRB internal meeting notes on the request for immediate action, for your review. Please provide your comments to myself and Bhalchandra by noon Monday March 1 9th.
Thank you for your time, Andrea 2.206 Coordinator Andrea Russell Project Manager Nuclear Regulatory Commission NRR/DPR/PGCB Ph: 301-415-8553
I P
10 CFR 2.206 PRB Closed Meeting Notes on Immediate Action- 03/20/12
SUBJECT:
GUNTER ET AL. 2.206 REQUESTING ENFORCEMENT ACTION AGAINST JAMES A. FITZPATRICK PLANT (G20120172) (TAC ME8189)
PETITIONER: Paul Gunter, et al DATE: March 9, 2012 PRB MEMBERS & ADVISORS Samson Lee (PRB Chair - Deputy Director, NRR, Division of Risk Assessment)
Bhalchandra Vaidya (Petition Manager - NRR, Division of Operating Reactor Licensing)
Anthony Ulses (Branch Chief - NRR, Division of Safety Systems, Reactor Systems Branch)
Robert Dennig (Branch Chief - NRR, Division of Safety Systems, Containment and Ventilation Branch)
(Senior Project Manager- NRR, Japan Lessons Learned Project Robert Fretz Directorate, Projects Management Branch)
John Monninger (Associate Director - NRR, Japan Lessons Learned Project Directorate)
Andrea Russell (Agency 2.206 Coordinator - NRR, Division of Policy and Rulemaking)
Kim MorganButler (Branch Chief(A) - NRR, Division of Policy and Rulemaking, Generic Communications Branch)
Brice Bickett (Senior Project Manager - Region 1, Branch 2, Division of Reactor Projects)
Mathew Jennerich (Project Engineer - Region 1, Branch 2, Division of Reactor Projects)
Lawrence Doerflein (Branch Chief - Region 1, Branch 2, Division of Reactor Safety)
Carrie Safford (Deputy Assistant General Counsel Materials Litigation and Enforcement - Office of General Counsel)
Ryan Eul (Enforcement Specialist - Office of Enforcement)
SUMMARY
OF REQUEST FOR IMMEDIATE ACTIONS:
The joint petitioners request that the FitzPatrick operating license be immediately suspended as the result of the undue risk to the public health and safety presented by the operator's reliance on non-conservative and wrong assumptions that went into the analysis of the capability of FitzPatrick's pre-existing ductwork containment vent system. The joint petitioners state that the risks and uncertainty presented by FitzPatrick's assumptions and decisions, in regard to NRC
plant Generic Letter 89-16, as associated with the day-to-day operations of this nuclear power now constitute an undue risk to public health and safety. The joint petitioners request that the suspension of the operating license be in effect pending final resolution of a public challenge to the adequacy of the pre-existing vent line in light of the Fukushima Daiichi nuclear accident.
The joint petitioners do not seek or request that FitzPatrick operators now install the Direct Torus Vent System (DTVS) as it is demonstrated to have experienced multiple failures to mitigate the severe nuclear accidents at Fukushima Daiichi.
The joint petitioners are requesting that the NRC take action to suspend the FitzPatrick operating license immediately until the following emergency enforcement actions are enacted, completed, reviewed and approved by the NRC and informed by independent scientific analysis:
- 1) Entergy Nuclear Operations' FitzPatrick nuclear power plant shall be subject to public hearings with full hearing rights on the continued operation of the Mark I BWR and the adequacy and capability of a pre-existing containment vent which is not a fully hardened vent line as recommended by NRC Generic Letter 89-16. As such, the FitzPatrick operator uniquely did not make containment modifications and did not install the DTVS, otherwise known as "the hardened vent," as requested by NRC Generic Letter 89-16 and as installed on every other GE Mark I in the US;
- 2) Entergy Nuclear Operations shall publicly document for independent review its post-Fukushima re-analyses for the reliability and capability of the FitzPatrick pre-existing containment vent system as previously identified as "an acceptable deviation" from NRC Generic Letter 89-16 which recommended the installation of the Direct Torus Vent System and as outlined in the NRC Safety Evaluation Report dated September 28, 1992. The publicly documented post-Fukushima analysis shall include the reassessment of all assumptions regarding the capability and reliability of the pre-existing containment venting and specifically address non-conservative assumptions regarding:
a) the FitzPatrick cost-benefit analysis used to justify not installing a fully hardened vent system and; b) "unlikely ignition points" as claimed in the FitzPatrick pre-existing vent line system that would otherwise present increased risks and consequences associated with the detonation of hydrogen gas generated during a severe accident.
BASIS FOR THE REQUEST As a basis for the request, the joint petitioners state that in light of the multiple failures of the GE Mark I containment and hardened vent systems at the Fukushima Daiichi nuclear power station in the days following the March 11, 2011, station black out event, the joint petitions seek the prompt and immediate suspension of the FitzPatrick operations because:
" The GE Mark I BWR pressure suppression containment system is identified as inherently unreliable and likely to fail during a severe accident.
" The capability of FitzPatrick's pre-existing containment vent as approved for severe accident mitigation is not a fully "hardened vent" system.
" The capability of FitzPatrick's pre-existing containment vent as approved relies upon non-conservative and faulty assumptions.
- The capability of FitzPatrick's pre-existing containment vent system uniquely allows for a severe nuclear accident to be released at ground level.
" The Fukushima Daiichi nuclear catastrophe dramatically and exponentially changes the FitzPatrick cost-benefit analyses.
. V The continued day-to-day reliance upon the significantly flawed pre-existing containment vent system as would be relied upon to mitigate a severe accident at the FitzPatrick Mark I reactor presents an undue risk to the public health and safety.
The identified containment vulnerability, the non-conservative if not false assumption of "no likely ignition sources" in the pre-existing vent line and the unacceptable consequences of failure of the FitzPatrick pre-existing containment vent place both greater uncertainty and undue risk on public health and safety and are not reasonably justified by arbitrarily assigning a low probability of the occurrence of a severe accident.
(b)(5)