NRC-2010-0299, 2011/01/05-Errata Request for a Public Hearing and Petition for Leave to Intervene in the Matter of Firstenergys Application to Relicense the Davis-Besse Nuclear Power Plant
| ML110050528 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/05/2011 |
| From: | Kamps K Beyond Nuclear, Citizens Environmental Alliance of Southwestern Ontario, Don't Waste Michigan, Green Party of Ohio |
| To: | Annette Vietti-Cook NRC/SECY |
| SECY RAS | |
| References | |
| License Renewal 2, RAS 19389, 50-346-LR, NRC-2010-0299 | |
| Download: ML110050528 (6) | |
Text
Beyond Nuclear Citizens Environment Alliance of Southwestern Ontario Dont Waste Michigan Green Party of Ohio January 5, 2011 Annette Viette-Cook, Secretary Office of the Secretary United States Nuclear Regulatory Commission Washington, DC 20555-0001
[Electronically filed by NRC Digital Certificate]
Errata re: Request for a Public Hearing and Petition for Leave to Intervene in the Matter of FirstEnergys Application to Relicense the Davis-Besse Nuclear Power Plant (Facility Operating License No-NFP-003, Docket No. 50-346, NRC-2010-0299) for 20 Additional Years of Extended Operation, as filed Dec. 27, 2010 Ms. Viette-Cook:
As noticed by Federal Register of October 25, 2010 [Vol. 75, No. 205, Pages 65528 to 65531],
Notice of Acceptance for Docketing of the Application, Notice of Opportunity for Hearing for Facility Operating License No. NPF-003 for an Additional 20-Year Period; Firstenergy Nuclear Operating Company, Davis-Besse Nuclear Power Station, Unit 1, on December 27, 2010 we provided your agency with the a Request for Public Hearing and Petition for Leave to Intervene, filed by Beyond Nuclear, Citizens Environment Alliance of Southwestern Ontario, Dont Waste Michigan, and the Green Party of Ohio, in the matter of FirstEnergys license renewal application for the Davis-Besse nuclear power plant located near Oak Harbor, Ohio.
As a follow up to that, we now file an Errata to correct errors contained in that Request for Public Hearing and Petition for Leave to Intervene.
Sincerely,
/Signed by Kevin Kamps/
Kevin Kamps, Radioactive Waste Watchdog Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 Tel. (301) 270-2209 extension 1 kevin@beyondnuclear.org
January 5, 2011 UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY
__________________________________________
In the Matter of )
)
FIRSTENERGY NUCLEAR OPERATING COMPANY )
) DOCKET NO. 50-346 LRA DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 ) NRC-2010-0298
)
Regarding the Renewal of Facility Operating License )
NPF-003 for a 20-Year Period )
__________________________________________ )
ERRATA Page 1: Citizens Environmental Alliance should be corrected to Citizens Environment Alliance. The same is true at Paragraph 12, on Page 10.
Errors containted in CONTENTION ONE: WIND POWER Paragraph 51, Page 27: The phrase as described in points 14 and 15 above should be written as described in Petitioners Paragraphs 40 and 41 above.
Paragraph 61, Page 35: The phrase the 40-year life span should be written the 26-year life span, that is, Davis-Besses remaining 6 years of its current operating license (2011-2017), plus a 20-year license extension (2017-2037).
Paragraph 66, Page 38: The reference to Paragraph 53 should instead be to Paragraph 52.
Paragraph 82, Page 47: The phrase for years wind, in fact, is the fastest-growing electrical generating source in North America, although in the past year or two, in terms of percentage growth, solar has the fastest growing, should be written for years wind, in fact, has been the fastest-growing electrical generating source in North America, although in the past year or two, in terms of percentage growth, solar has been the fastest growing.
Paragraph 88, Page 50: The passage EWEA reported in September 2009 that There are currently 830 wind turbines now installed and grid connected, totaling 2,063 MW in 39 wind farms in nine European countries. should specify that this refers to offshore wind power.
Error contained in Contention Two: Solar Power Paragraph 126, Page 72: The reference to Petitioners Exhibit #23 should instead refer to Petitioners Exhibit #53, Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Main Report (NUREG-1437, Volume 1)).
Error contained in CONTENTION 3: SOLAR AND WIND IN COMBINATION Paragraph 160, Page 94: What reads Similarly, FENOC is not free to favor legitimate technical information over bad should have been written Similarly, FENOC is not free to favor illegitimate technical information over good.
Errors contained in CONTENTION FOUR: SEVERE ACCIDENT COST UNDERESTIMATED Paragraph 182, Page105: Entergy should be written as FENOC; also, Seabrook should be written as Davis-Besse; also, Probabilistic Safety Analysis should be written as Probabilistic Risk Assessment; finally, the phrase [Using this method, the application states that Risk is defined as the product of consequence and frequency of accidental release.
Application ER E.4.20.] should be deleted.
Paragraph 185, Page 108: an end parenthesis mark is needed on the citation (September, 2004 --
Available on the internet at:
http://www.ucsusa.org/nuclear_power/nuclear_power_risk/sabotage_and_attacks
_on_reactors/impacts-ofa-terrorist-attack.html.)
Paragraph 186, Page 108: NextEra should be written as FENOC.
Paragraph 196, Page 114: Next Era should be written as FENOC.
Paragraph 218, Page 128: Seabrook should be written as Davis-Besse.
Paragraph 219, Page 129: The statement page references used here refer to the portion attached should be disregarded.
Page 135: Beginning on Page 135, and continuing to Page 152, a repeated error in paragraph numbering occurred. The last correctly numbered paragraph is Paragraph 229 on Page 134. After that, paragraphs should be numbered 48 higher than they are. Following are, first, the incorrect paragraph number within brackets, followed by the correct paragraph number in bold:
[Incorrect] Correct
[Paragraph 182] Paragraph 230
[Paragraph 183] Paragraph 231
[Paragraph 184] Paragraph 232
[Paragraph 185] Paragraph 233
[Paragraph 186] Paragraph 234
[Paragraph 187] Paragraph 235
[Paragraph 188] Paragraph 236
[Paragraph 189] Paragraph 237
[Paragraph 190] Paragraph 238
[Paragraph 191] Paragraph 239
[Paragraph 192] Paragraph 240
[Paragraph 193] Paragraph 241
[Paragraph 194] Paragraph 242
[Paragraph 195] Paragraph 243
[Paragraph 196] Paragraph 244
[Paragraph 197] Paragraph 245
[Paragraph 198] Paragraph 246
[Paragraph 199] Paragraph 247
[Paragraph 200] Paragraph 248
[Paragraph 201] Paragraph 249
[Paragraph 202] Paragraph 250
[Paragraph 203] Paragraph 251
[Paragraph 204] Paragraph 252
[Paragraph 205] Paragraph 253
[Paragraph 206] Paragraph 254
[Paragraph 207] Paragraph 255
[Paragraph 208] Paragraph 256
[Paragraph 209] Paragraph 257
[Paragraph 210] Paragraph 258
[Paragraph 211] Paragraph 259
[Paragraph 212] Paragraph 260
[Paragraph 213] Paragraph 261
[Paragraph 214] Paragraph 262
[Paragraph 215] Paragraph 263
[Paragraph 216] Paragraph 264
[Paragraph 217] Paragraph 265
[Paragraph 218] Paragraph 266
[Paragraph 219] Paragraph 267
[Paragraph 220] Paragraph 268
[Paragraph 221] Paragraph 269
[Paragraph 222] Paragraph 270
[Paragraph 223] Paragraph 271
[Paragraph 224] Paragraph 272
[Paragraph 225] Paragraph 273
[Paragraph 226] Paragraph 274
[Paragraph 227] Paragraph 275
[Incorrectly Numbered Paragraph 216], Corrected to Paragraph 264, Page 147: Seabrook should be written as Davis-Besse.
Error contained in CONCLUSION: CONTENTIONS ONE TO FOUR
[Incorrectly Numbered Paragraph 227], Corrected to Paragraph 275, Page 152:
Although it was stated in [Incorrectly Numbered Paragraph 226], Corrected to Paragraph 274, on Page 151 that To reiterate verbatim the concluding arguments already given at the conclusion of Contention One: Wind Power, above, but this time to apply them to all four contentions above, it should also have been specified at the end of Corrected Paragraph Number 275, at the very end of this CONCLUSION: CONTENTIONS ONE TO FOUR, that this conclusion relates to all four contentions. Thus, where it reads The Petitioners' recitation in support of its contention is not brief; the evidence of FENOCs poor consideration of wind power as a serious alternative to the continuation of Davis-Besses operation from 2017 to 2037 is overwhelming. The Environmental Report fails the standards of NEPA, and as well, NRC regulations and case law interpretations. Petitioners seek admission as intervenors in this relicensing to set the record straight, and to prove that the licensee must take a hard look at far more than it has revealed so far in its perfunctory ER. The presumption that an operating Davis-Besse atomic reactor is the best that can be done respecting the environment is therefore less supportable than ever.
it should instead have been written The Petitioners' recitation in support of its contentions is not brief; the evidence of FENOCs poor consideration of wind power (Contention One), solar power (Contention Two), and a combination of wind and solar power (Contention Three), as
serious alternatives to the continuation of Davis-Besses operation from 2017 to 2037 is overwhelming. Likewise, the evidence of FENOCs poor consideration of the true costs of severe accidents requires a much more careful and comprehensive Severe Accident Mitigation Alternatives Analysis (Contention Four). The Environmental Report fails the standards of NEPA, and as well, NRC regulations and case law interpretations. Petitioners seek admission as intervenors in this relicensing to set the record straight, and to prove that the licensee must take a hard look at far more than it has revealed so far in its perfunctory ER. The presumption that an operating Davis-Besse atomic reactor is the best that can be done respecting the environment is therefore less supportable than ever.
/Signed by Kevin Kamps & submitted by Digital Certificate Pro Se on behalf of Petitioners/
Kevin Kamps Radioactive Waste Watchdog Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 Tel. 301.270.2209 ext. 1 Email: kevin@beyondnuclear.org Website: www.beyondnuclear.org January 5, 2011