ML13190A006

Comment (134) of Robert L. Fishman on Behalf of Self Opposing Entergy'S Request for Exemption from Fire-safety Federal Regulation Standards for Indian Point Unit 3

ML13190A006
Person / Time
Site:	Indian Point
Issue date:	06/03/2013
From:	Fishman R L - No Known Affiliation
To:	Bladey C K Rules, Announcements, and Directives Branch
References
78FR26662 00134, NRC-2013-0063
Download: ML13190A006 (2)

Text

4J/7 PO Box 4 Plymouth, VT 05056 ýW9 June 3, 2013 Cindy Bladey Chief, Rules, Announcements, and Directives Branch (RADB)Office of Administration TWB-05-BOl U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 r 11ýý13 U RE: Docket ID NRC-2013-0063 Entergy Nuclear Operations Inc., Indian Point Nuclear Generating Unit 3 I II (D)co Os Cn

Dear Ms Bladey:

The fire safety exemption should not be granted.-NRC violates the Appendix R Defense in Depth by considering this fire safety exemption-NRC produced unlawful Environmental Assessment (EA)and Finding Of No Significant Impact (FONSI) analysis-NRC must comply with NEPA requirements regarding foreseeable terrorist acts The Environmental Assessment and Finding Of No Significant Impact are completely silent about the ways in which the exemption makes a terrorist attack more likely and make the consequences of a terrorist attack much worse. THE EXEMPTION'S RELIANCE ON MANUAL FIRE SUPPRESSION AND ADMINISTRATIVE CONTROLS WILL MAKE A TERRORIST ATTACK MORE LIKELY AND MORE DESTRUCTIVE.

When it originally approved the exemption in 2007 the NRC considered only 11 documents in its possession that analyze its E 0' V*u i .*4 0 F5Ci a if Z E-w safety and health impacts. There are dozens and dozens of other such documents that show how dangerous and unnecessary the exemption is. THE NRC MUST CONSIDER ALL THE EVIDENCE AND DOCUMENTS IT HAS THAT RAISE QUESTIONS ABOUT OR SHOW THE EXEMPTION IS DANGEROUS.

Sincerely, Robert L. Fishman