ML15139A030

Comment (7) of Kevin Kamps on Behalf of Beyond Nuclear Opposing Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule

ML15139A030
Person / Time
Site:	Palisades
Issue date:	05/12/2015
From:	Kamps K Beyond Nuclear
To:	Division of Administrative Services
References
80FR13449 00007, NRC-2014-0137
Download: ML15139A030 (7)

Text

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J -X 12.41 Docket: NRC-2014-0137 F- \, /7-Technical Basis for Regulatory Guidance on the Alternate PTS Ru le-Comment On: NRC-2014-0137-0001 Draft Guidance Regarding the Alternate Pressurized Thermal Shock Rule Document:

NRC-2014-0137-DRAFT-0008 Comrumnent on FR Doc # 2015-05754 As of: 5/13/15 11:02 AM Received:

May 12, 2015 Status: PendingPost Tracking No. ljz-8ita-fehc Comments Due: May 12, 2015 Submission Type: Web Submitter Information Name: Kevin Kamps Address: Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD, 20912 Email: kevin@beyondnuclear.org General Comment

Dear NRC,

Please see the attached file, DECLARATION OF PIERMAN, KAMPS AND KEEGAN CONCERNING COUPON AVAILABILITY FOR PTS TESTING, dated December 1, 2014. It was submitted as a part of the Beyond Nuclear-Don't Waste MI-MSEF Shoreline Chapter-NEIS intervention against Entergy Nuclear Palisades' LAR for 1 OCFR50.61 a regulatory relief. Please accept this document as public comment in this proceeding.

We object to 1OCFR50.61 a's dismissing and ignoring existing, readily available hard physical data, and relying largely to exclusively instead on probabilistic risk assessment.

Palisades, for example, has four capsules remaining, which could be pulled and tested. But instead of accessing this readily available physical data, a scheduled 2007 capsule pull and test was simply canceled.

A full 16 years between capsule pulls and tests (2003 to 2019) will have passed, with no reality check in between. Apparently, Entergy has no plans to access three capsules at all, during the 2019 to 2031 (extended license expiration in 203 1) time period. This is unacceptable.

NRC's rationale, as documented in the attached affidavit, that physical capsules can't be pulled and tested, because then there would be no physical capsules left to pull and test, is absurd and unacceptable from a v--- -https://www.fdms.gov/fdms-web-agency/compoinent/contentstreamer?objectld=0900006481 adceae&for...

05/13/2015 Page 2 of 2 perspective of protecting public health, safety, and the environment from a scientific, physical reality-based regulatory approach.

Over- to exclusive-reliance on PRA is unacceptable, and such aspects of 1 OCFR50.6 1 a, as embodied in DG- 1299 and NUREG-2163, cannot be allowed to stand in NRC regulations, regulatory guides, and their technical bases documents.

Sincerely, Kevin Kamps, Beyond Nuclear (and Don't Waste MI board member, representing the Kalamazoo chapter)Attachments 12 1 14 Coupon Decl COMPLET-1 https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=090000648 1 adceae&for...

05/13/2015 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-255 Entergy Nuclear Operations, Inc.(Palisades Nuclear Plant)December 1, 2014 Operating License Amendment Request DECLARATION OF PIERMAN, KAMPS AND KEEGAN CONCERNING COUPON AVAILABILITY FOR PTS TESTING 1. Bette Pierman, Kevin Kamps and Michael Keegan make the following statements under penalty of perjury.2. On June 5, 2014, we attended a meeting in Benton Harbor, Michigan, between about a dozen concerned local residents and environmental group representatives and the Chairman of the U.S. Nuclear Regulatory Commission, Dr. Allison Macfarlane, regarding Entergy Nuclear's Palisades atomic reactor.3. Michael Keegan, a board member of Don't Waste Michigan, addressed the coalition's concerns regarding the embrittlement of the Palisades reactor pressure vessel. He asked Chairman Macfarlane why remaining metal coupons within Palisades' reactor pressure vessel had not been pulled and tested in so many years, in order to determine the extent of neutron-bombardment embrittlement of the reactor pressure vessel.4. NRC Chairman Macfarlane asked one of her staff members to respond to the question.

Alex Garmoe, Senior Resident Inspector at Palisades, responded that coupons had not been pulled and tested in so long because so few were left. To do so would mean there would be no more to pull and test during the 2014 to 2031 extended operating license period which the NRC had granted Palisades in 2007.5. As neither Dr. Macfarlane nor any other NRC staff member present at the meeting, including the Region III Administrator Cynthia Pederson, spoke up to contradict Mr. Garmoe's statement, we took the statement to be the official position of the NRC. In fact, Dr. Macfarlane's written correspondence to us to follow up the in-person meeting did not mention, let alone contradict, her staff member's response.[The remainder of this page is deliberately left blank.]

I hereby declare under penalty of perjury that the foregoing facts are true and correct and that any expressions of opinion are based on my judgment.[date]Bette Pierman I hereby declare under penalty of perjury that the forcgoing facts are true and correct and that any expressions of opinion are based on my judgment.Kevin Ka'mps I hereby declare under penalty of perjury that the foregoing facts arc true and correct and that any expressions of opinion are based on myvjudgpnent.

f~iatef Michael Keegan 6-5-