ML15084A314

Attachment 1 - VT Errata to Errata to Reply to NRC Staff and Entergy Answers to Petition for Leave to Intervene and Hearing Request

ML15084A314
Person / Time
Site:	Vermont Yankee
Issue date:	03/25/2015
From:	State of VT, Dept of Public Service
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-271-LA-2, RAS 27414, TBD
Download: ML15084A314 (2)

Text

ATTACHMENT 1 LAR, both when viewed alongside the directly related exemption request and alone, that pose a risk to public health and safety. As explained above, the contentions focus on problems posed by the exemption request constitutes an admissible contention on the exemption in the event that the NRC grants a hearing on the request now under reconsideration. The contention also presents a basis for a hearing on the LAR alone.

The States Petition and companion expert-supported declarations outline a number of credible threat scenarios that have not been analyzed by Entergy in the LAR. Public health and safety, in turn, would be adversely impacted in the event of any of these scenarios if the LAR is granted. The State has identified credible beyond design-basis-scenarios, including hostile action, the use of fire accelerants compromising spent fuel pool safety, spent nuclear fuel pool loss of cooling that results in a zirconium fire, and spent fuel transfer accidents. In the case of threats from accelerants in the fuel pool, Entergy performed an emergency response exercise at VY in March 2015 that included the use on an accelerant dropped into the fuel pool. In each of these scenarios, the LARs proposed expansion of notification of an emergency to the State from 15 to 60 minutes, coupled with the reduction of the Emergency Planning Zone to the plant footprint, as contemplated by the LAR, adds significant and unnecessary risk to the public by way of delayed and reduced emergency response action.

The reduction in emergency response capabilities violates the requirements of 10 CFR § 50.54(q)(4), even in the event that Entergy is exempted from portions 10 CFR § 50.47 and Part 50, Appendix E. The lack of adequate safety analysis regarding credible accident scenarios applies independently to the LAR in addition to applying to the directly related exemption request.

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