ML13297A047
| ML13297A047 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/23/2013 |
| From: | Taylor W Sierra Club |
| To: | Joseph Sebrosky Plant Licensing Branch IV |
| References | |
| MF2869 | |
| Download: ML13297A047 (2) | |
Text
1 NRR-PMDAPEm Resource From:
wtaylorlaw@aol.com Sent:
Wednesday, October 23, 2013 10:36 AM To:
Sebrosky, Joseph
Subject:
Ft. Calhoun license amendment
Dear Mr. Sebrosky:
I know that the deadline for comments on the above license amendment request was October 15, 2013. I did submit comments on that date. Now, however, I find that the NRC requested additional information from OPPD regarding that license amendment request. I am therefore submitting additional comments for the Sierra Club Nuclear Free Campaign based on OPPDs response to the request for additional information. I request that you consider these comments along with my previous comments.
Regarding information request No. 3, the NRC must ensure that OPPD, as set forth in its response, is properly including loadings in Level B, and that those loadings should not be in Level A.
Regarding information request No. 4, OPPD is proposing to use a definition for terminal end that is different than the definition in MEB 3-1. This should not be allowed. MEB 3-1 is the controlling guidance document. It appears that OPPD is arguing that some other definition of terminal end was being followed when Fort Calhoun was initially licensed. But that does not mean that the current definition should not be used. OPPD has not provided any reason why it cannot comply with MEB 3-1. MEB 3-1 would be consistent with Fort Calhouns current licensing basis. And OPPD, in its license amendment request, said that the amendment was being submitted to revise its current licensing basis. The current licensing basis and the current guidance should therefore be followed. No variance should be allowed.
Regarding information request No. 5, OPPD reiterates its intention to use the definition of terminal end as discussed with respect to information request 4. For the same reasons set out above, this request by OPPD should not be allowed.
Regarding information request No. 6, it appears that OPPD is making an oblique assertion that it need not comply with the intent of MEB 3-1 because OPPD is attempting to rely on its original licensing basis. The NRC must examine closely the language and intent of the modified footnote 4 proposed by OPPD to ensure that it complies with MEB 3-1.
Regarding information request No. 7, it appears that OPPD is trying to maneuver a way to avoid comprehensively protecting the piping from crack failures. OPPD should not be allowed to avoid the requirements of MEB 3-1.
Regarding information request No. 9, OPPD is reverting to its responses to information requests 3, 4, and 5. For the reasons already stated, this should not be allowed.
Regarding information request No. 10, OPPD is blatantly and arrogantly refusing to comply with MEB 3-1. Again, OPPD is claiming it only has to comply with guidance that was in effect when the original license was issued. But, as previously noted, OPPD, in its license amendment request, is proposing to update its current licensing basis. The NRC should find OPPDs arrogant attitude offensive and require OPPD to comply with MEB 3-1.
Regarding information request No. 11, OPPD is again refusing to comply with MEB 3-1. OPPD gives no justifiable reason why it cannot or should not be required to abide by MEB 3-1. As stated previously in these comments, MEB 3-1 is the controlling guidance document. The NRC should require OPPD to comply with MEB 3-1.
High energy line breaks are a significant issue. In fact, a recent event report at Fort Calhoun on October 18 describes a high energy line break that may adversely impact the upstream piping and the outboard containment isolation valve.
OPPD should not be allowed to dictate what it will do regarding high energy line breaks. It is the NRCs duty to tell OPPD what it must do to ensure safe operation of Fort Calhoun. This entire issue requires a formal license amendment proceeding.
Wallace L. Taylor Attorney at Law 118 3rd Ave. S.E., Suite 326 Cedar Rapids, Iowa 52401 319-366-2428;(Fax)319-366-3886 e-mail: wtaylorlaw@aol.com
Hearing Identifier:
NRR_PMDA Email Number:
880 Mail Envelope Properties (8D09E1444A6C555-2020-3768)
Subject:
Ft. Calhoun license amendment Sent Date:
10/23/2013 10:35:34 AM Received Date:
10/23/2013 10:37:48 AM From:
wtaylorlaw@aol.com Created By:
wtaylorlaw@aol.com Recipients:
"Sebrosky, Joseph" <Joseph.Sebrosky@nrc.gov>
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