View source for NRC-2015-0088, Comment (3) of Unknown Individual Opposing Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations

{{Adams
| number = ML15139A023
| issue date = 05/14/2015
| title = Comment (3) of Unknown Individual Opposing Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations
| author name = 
| author affiliation = - No Known Affiliation
| addressee name = 
| addressee affiliation = NRC/ADM/DAS/RADB
| docket = 05000368
| license number = 
| contact person = 
| case reference number = 80FR20020 00003, NRC-2015-0088
| document type = General FR Notice Comment Letter type:NRC
| page count = 2
}}

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HULLS         CTIVES As of: 5/15/15 10:57 AM Received: May 14, 2015 PUBLIC PUBL           SUBM S BMIS  C ISSION     IONTracking7t &#xa2;15 i" 1: 3L4          Status: PendingPost No. ljz-Siuj-i75y Comments Due: May 14, 2015 Submission Type: Web D ock et: N R C -20 15-0088                                  .. .. ..
Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Comment On: NRC-2015-0088-0001 Biweekly Notice; Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Document: NRC-2015-0088-DRAFT-0003 Comment on FR Doc # 2015-08579 Submitter Information Name: Anonymous Anonymous                                                                                  -
General Comment ID: NRC-2015-0088-0001 ENTERGY OPERATIONS, INC., DOCKET NO. 50-368, ARKANSAS NUCLEAR ONE, UNIT NO. 2 (ANO-2), POPE COUNTY, ARKANSAS While pretending that you are increasing safety oversight at Arkansas One, you are actually decreasing safety with this. Leaving the reactor in hot shutdown mode increases risk, decreases safety, at every level. It means that it will be slower and harder to get any incident-accident under control. Leaving it hotter increases the risk of pressurized thermal shock (PTS), too. The PTS risk increases with age, as does all embrittlement, and the Arkansas One reactors are old.
Perhaps most important for safety is that the pressure is also reduced going from hot to cold shutdown. At the cooler shutdown it is less likely to undergo pressurized thermal shock and catastrophic failure of the reactor pressure vessel. At the hot shutdown it is more likely to undergo pressurized thermal shock and catastrophic failure of the reactor pressure vessel (RPV). Hot Shutdown is 200-300 F and Cold Shutdown is 200 degrees F or less.
You need to read: Development of Standardized Probabilistic Risk Assessment Models for Shutdown Operations Integrated in SPAR Level 1 Model" S. Khericha, Ph. D. a* , J. Mitman b a Idaho National Laboratory, Idaho Falls, ID, USA b U.S. Nuclear Regulatory Commission, Washington DC, USA They state that risks for PWRs arise for ALL shutdown modes. Thus, it is best to put it into the overall safer 6)g *,&,.                                                                                   ,'.-! 6e2i-bS.=-
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https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectld=0900006481                ael 3a9&for... 05/15/2015

Page 2 of 2 mode, which is lower pressure Cold Shutdown.
    "most of the risk from shutdown operations arises from Mode 4 (hot shutdown), Mode 5 (cold shutdown), and Mode 6 (refueling) for PWRs The risk is dominated by the operators understanding of the event and the ability to respond appropriately. In the example PWR, more than 98% of the core damage frequency was dominated by operator action...
the risk to fuel damage (per hour) during shutdown operations is comparable to at-power operations".
You pretend that you are increasing safety at Arkansas One, all while decreasing risk! One death at Arkansas One wasn't enough for you?
https://www. fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=090000648 1ae 13 a9&for...          05/15/2015}}