ML13018A244

G20110171 - Letter to Licensees on Proposed Director'S Decision Regarding 2.206 Petition Dated: March 12, 2011

ML13018A244
Person / Time
Site:	Beaver Valley, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Oconee, Mcguire, Palisades, Perry, Indian Point, Fermi, Catawba, Wolf Creek, Point Beach, Oyster Creek, Watts Bar, Cooper, Sequoyah, Pilgrim, Three Mile Island, Summer, Seabrook, Brunswick, North Anna, Callaway, Vogtle, Cook, FitzPatrick, McGuire, LaSalle, BWX Technologies, 07003098
Issue date:	04/08/2015
From:	Lund A L Division of Operating Reactor Licensing
To:	B & W Nuclear Operations Group, Calvert Cliffs, Chicago Bridge & Iron Co, DTE Electric Company, Duke Energy Carolinas, Duke Energy Progress, Entergy Nuclear Operations, Exelon Generation Co, Exelon Nuclear, FirstEnergy Nuclear Operating Co, Indiana Michigan Power Co, Nebraska Public Power District (NPPD), Point Beach, NextEra Energy Seabrook, Northern States Power Co, Nuclear Fuel Services, Progress Energy Carolinas, South Carolina Electric & Gas Co, Southern Nuclear Operating Co, Tennessee Valley Authority, Union Electric Co, Virginia Electric & Power Co (VEPCO), Wolf Creek
Chawla M L
Shared Package
ML13018A145	List: ML13018A239 ML13018A244
References
TAC ME5840, TAC MF5853
Download: ML13018A244 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AllPowerReaciorLicenseesand Holders of Construction Permits in Active or Deferred Status

Dear Sir or Madam:

Apri 1 8, 2015 By letter dated March 12, 2011, as supplemented on April 14, 2011, April 16, 2011, and May 25, 2011, Mr. Thomas Saporito submitted a petition pursuant to Section 2.206 of Title 10 of the Code of Federal Regulations of the U.S. Nuclear Regulatory Commission's (NRC's) regulations with respect to all nuclear power reactors in the U.S. located on or near an earthquake fault line. The petition has been reviewed by the NRC staff and the staff's proposed director's decision on the petition is enclosed.

I request that you provide comments to me on any portions of the decision that you believe involve errors or any issues in the petition that you believe have not been fully addressed.

The staff is making a similar request of the petitioner.

The NRC staff will then review any comments provided by you and the petitioner and consider them in the final version of the director's decision with no further opportunity to comment. Please provide your comments within two weeks from the date of this letter. The petition manager, Mahesh Chawla, can be reached at 301-415-8371 or at Mahesh.Chawla@nrc.gov.

Docket Nos. See Enclosure 2

Enclosures:

1. Proposed Director's Decision Sincerely, A. Louise Lund, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

2. List of Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status cc: Listserv ENCLOSURE 1 Proposed Director's Decision ADAMS Accession No. ML 1301BA159 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION William M. Dean, Director [7590-01-P]

DD-15-XX In the Matter of ) ) ) ) Docket Nos.: See Enclosure 2 All Operating Reactor Licensees License Nos.: See Enclosure 2 PROPOSED DIRECTOR'S DECISION UNDER 10 CFR 2.206 I. Introduction By letter dated March 12, 2011, Thomas Saporito, representing Saprodani Associates, filed a petition pursuant to Title 10 of the Code of Federal Regulations ( 10 CFR) 2. 206 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 110740026).

The petitioner requested that the U.S. Nuclear Regulatory Commission (NRC or the Commission) take escalated enforcement action against the above-captioned licensees and suspend or revoke the NRC licenses granted to the licensees for operation of nuclear power reactors.

In particular, the petitioner requested that the "NRC ORDER the immediate shut-down of all nuclear power reactors in the USA which are known to be located on or near an earthquake fault-line." The petitioner cited the Fukushima Dai-ichi accident in Japan as the rationale for and basis of the petition.

On March 21, 2011, the NRC acknowledged receipt of the petition (ADAMS Accession No. ML 110840274).

On April 4, 2011, the Petition Review Board (PRB) met internally to discuss petitioner's request for immediate action. The PRB determined that the request for immediate action is a general assertion without supporting facts. Thus, the PRB did not identify a significant safety concern from the information provided which would warrant the NRC to order an immediate shutdown of nuclear power reactors located on or close to earthquake fault lines. On April 4, 2011, the petitioner was informed of the PRB's decision to deny his request for an immediate action (ADAMS Accession No. ML 110940603).

On April 14, 2011, the petitioner addressed the PRB during a teleconference.

A copy of the teleconference transcript is available at ADAMS Accession No. ML 11109A014.

During the teleconference, the petitioner stated that the petition falls into four requests as follows: 1. Order the immediate shutdown of all nuclear power reactors located on or near an earthquake fault line in the United States. 2. Order the immediate shutdown of all power reactors employing GE Mark I containment design in the United States, characterizing such design as flawed from the nuclear safety standpoint.

3. Advise other countries employing the GE Mark I nuclear power reactors about the serious nuclear safety design flaws associated with that design, which is likely to result in a serious nuclear accident comparable to the Japanese nuclear disaster.

4. Immediately revoke all 20-year license extensions issued to NRC licensees, because the NRC "has improperly and illegally granted 20-year license extensions to the 40-year license that was initially granted by the agency for the 104 nuclear reactors throughout the United States." During the teleconference, the petitioner supplemented the second request by specifically naming NRG-licensed plants that employ the GE Mark I containment design and characterizing them as "flawed nuclear reactors" which pose an "unwarranted risk to the national security and common defense of the United States of America." He stated that "for these reasons standing alone, petitioners urge the NRC to order the immediate shutdown of all GE Mark I nuclear power reactors in the United States." Subsequently, on April 14 and 16, 2011, he provided additional documents in support of his claim (ADAMS Accession Nos. ML 1111 OA026, ML 1111 OA027, ML 1111 OA028, and ML 11119A024, respectively).

The PRB met internally on April 28, 2011, to discuss the petition, as supplemented.

In accordance with the criteria for review and rejection described in Management Directive (MD) 8.11, the PRB made its initial recommendation to accept the petition in part, insofar as the petitioner requested additional regulatory action in response to the events at Fukushima.

The supplemental information provided by the petitioner was not sufficient to warrant further inquiry regarding the petitioner's assertions that the original licensing bases of U.S. nuclear reactors were faulty and that immediate shutdown was warranted.

On May 12, 2011, the Petition Manager informed the petitioner of the PRB's initial recommendation to accept this petition in part (ADAMS Accession No. ML 111320018).

At that time, the petitioner requested another opportunity to address the PRB to provide comments on its initial recommendation and additional information in support of the petition.

On May 25, 2011, the petitioner addressed the PRB by teleconference to present supplemental information on the petition.

Also, on May 25, 2011, he e-mailed additional information to the NRC (ADAMS Accession No. ML 111450897), which the PRB considered.

A copy of the transcript for the May 25, 2011, teleconference is available under ADAMS Accession No. ML 11146A010.

The PRB considered the additional information provided during the teleconference on May 25, 2011, by the petitioner and determined that it did not contain any new or relevant information that would change the PRB's initial recommendation.

Consistent with its initial recommendation, the PRB declared its final recommendation to partially accept the petition for review, as modified and supplemented.

Requests 1 and 2 were partially accepted to the extent that the petitioner sought regulatory action in light of the events at Fukushima.

However, Requests 1 and 2 were partially rejected on the basis that the petitioner did not provide sufficient facts to justify shutting down all nuclear power reactors located on or near fault lines, or those with the GE Mark I containment design. Request 3 was rejected on the basis that the petitioner requested an action that the NRC was already implementing, and Request 4 was rejected on the basis that the petitioner's claim was general and insufficient to warrant further inquiry, and that the issue had already been the subject of NRC staff review and evaluation.

This decision was communicated to the petitioner via letter dated June 28, 2011 (ADAMS Accession No. ML 11137A213).

The transcripts of the teleconferences were treated as supplements to the petition and are available for inspection at the NRC's Public Document Room (PDR), located at 01 F21, 11555 Rockville Pike (first floor), Rockville, Maryland 20852. Publicly-available documents created or received at the NRC are accessible electronically through ADAMS in the NRC Library at http://www.nrc.gov/reading-rm/adams.html.

Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC's PDR reference staff by telephone at 1-800-397-4209, or 301-415-4737, or by e-mail to pdr.resource@nrc.gov.

11. Discussion Based on the NRC's timeline related to its Fukushima lessons-learned review, and because the items accepted for review pertained to the Fukushima review, the NRC's review of this petition took longer than the standard of 120 days for reaching a decision on the petition.

This section includes both the petitioner's requests for orders to be issued and the NRC's actions and decisions. Additional information regarding the implementation of Japan Lessons-Learned Activities, including plant-specific implementation status, is available on the NRC's Japan Lessons-Learned public website at http://www.nrc.gov/reactors/operating/ops-experience/

japan-dashboard.

html. Request 1: Order the immediate shutdown of all nuclear power reactors located on or near an earthquake fault line in the United States. NRC decision:

The NRC has determined that U.S. plants located at or near earthquake fault lines continue to operate safely and do not pose an immediate safety concern to the members of the public. Nuclear power plants in the U.S. have been designed, built, and operated to safely withstand earthquakes likely to occur in their region. As part of the NRC post-Fukushima lessons-learned activities, the NRC established the Near-Term Task Force (NTTF). The NTTF was tasked with conducting a systematic and methodical review of NRC processes and regulations and determining if the agency should make additional improvements to its regulatory system. Ultimately, a comprehensive set of recommendations was developed in a report to the Commission dated July 12, 2011, SECY-11-0093 (ADAMS Accession No. ML 111861807).

In the report, the NTTF determined that the current regulatory approach, and the resultant plant capabilities, gave the NTTF and the NRC the confidence to conclude that an accident with consequences similar to the Fukushima accident is unlikely to occur in the U.S. On March 12, 2012, the NRG issued a request for information pursuant to Title 10 CFR 50.54(f) regarding recommendations 2.1, 2.3, and 9.3 of the NTTF review (ADAMS Accession No. ML 12056A046).

The purpose of the 10 CFR 50.54(f) letter is to gather information with respect to the NTTF Recommendations for seismic hazards. The letter instructs all licensees to reevaluate seismic hazards at their sites using updated seismic hazard information, present-day guidance and methodologies, and a risk evaluation.

The NRC staff is currently reviewing the licensees' submitted seismic hazard reports. In cases where a licensee's reevaluated hazard exceeds the design basis, more detailed site-specific evaluations and actions will be required, such as a seismic probabilistic risk assessment.

NRC will review each step in the analysis process and take action to require plant changes as necessary.

In addition to the 10 CFR 50.54(f) letter, the Commission issued Order EA-12-049 on March 12, 2012, which requires mitigation strategies to protect against external events, including postulated seismic events (ADAMS Accession No. ML 12054A735).

Licensees must comply with the order no later than two refueling cycles after submittal of the overall integrated plan (OIP), or December 31, 2016, whichever comes first. To date, all licensees have submitted OIPs to describe how they will comply with the Order, and the OIPs have been evaluated by the NRC staff. In addition, the NRC staff has performed on-site audits to ensure that full implementation will occur within the required time period. The NRC has concluded that continued operation of nuclear plants on or near earthquake fault lines does not pose an imminent risk to public health and safety. The NRC is addressing the petitioner's seismic hazard concerns through Orders and requests for information, as described above. No further action will be taken regarding this request. Request 2: Order the immediate shutdown of all power reactors employing GE Mark I containment design in the United States. NRC decision:

The NRC has determined that GE Boiling Water Reactors (BWRs) with Mark I containments continue to operate safely and do not pose an immediate safety concern to the members of the public. The concern with GE Mark I containment design was previously addressed by the NRC in NUREG-0661, "Safety Evaluation Report Mark I Containment Long-Term Program - Resolution of Generic Technical Activity A-7," dated July 1980 (ADAMS Accession No. ML072710452).

In the report, NRC staff concluded that "the proposed structural acceptance criteria are consistent with the requirements of the applicable codes and standards and, in conjunction with the structural analysis techniques, will provide an adequate basis for establishing the margins of safety in the containment design." All GE Mark I BWRs were evaluated for suppression pool hydrodynamic loads, and appropriate modifications were made to maintain the containment structural integrity.

The NRC issued Order EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," on March 12, 2012 (ADAMS Accession No. ML 12054A694).

This order was superseded by a modified Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable for Operation Under Severe Accident Conditions," on June 6, 2013 (ADAMS Accession No. ML 13143A334).

The order requires all BWR licensees with Mark I and Mark II containments to design and install a venting system that provides venting capability during severe accident conditions.

This order further enhances the reliability of the containment vent system, thereby protecting the containment during severe accidents.

To date, all affected licensees have submitted OIPs for upgrading containment venting capabilities from the pressure suppression wetwell to assist in preventing core damage, and the OIPs are currently being reviewed by the NRC staff. OIPs for reliable ventilation from the drywell, or reliable venting strategies that eliminate the need for drywell venting, will be submitted by licensees within the next year. The NRC has concluded that continued operation of power reactors employing GE Mark I containment design does not pose an imminent risk to public health and safety. The NRC is addressing the petitioner's containment concerns through Orders, as described above. No further action will be taken regarding this request. Request 3: Advise other countries employing the GE Mark I nuclear power reactors about the serious nuclear safety design flaws associated with that design, which is likely to result in a serious nuclear accident comparable to the Japanese nuclear disaster.

NRC decision:

This is a general request for the NRC to ensure that policies exist to support the sharing of information related to the events involving Fukushima.

The NRC's current policies and practices support its openness goals with external, including international, stakeholders.

Specifically, since the earthquake and tsunami in Japan, the NRC has participated in meetings at the International Atomic Energy Agency, Nuclear Energy Agency, G8 Nuclear Safety and Security Group, and at numerous other bilateral and multilateral meetings to share information on this event with NRC's international counterparts.

Therefore, since the petitioner requested an action that the NRC is currently implementing, the PRB determined that this request did not meet the criteria for review on the basis that the request does not set forth sufficient facts to warrant further actions beyond the actions that the NRC has already undertaken to ensure openness on this issue with all external stakeholders.

Request 4: Immediately revoke all 20-year license extensions issued to NRC licensees, because the NRC "has improperly and illegally granted 20-year license extensions to the 40-year license that was initially granted by the agency for the 104 nuclear reactors throughout the United States." NRC decision:

In accordance with MD 8.11, the PRB will review a petition under 10 CFR 2.206 only where the petitioner specifies the bases for taking the requested action. Although the petitioner asserted that the NRC lacked the legal authority to grant license extensions for numerous plants, he failed to set forth the basis for his assertion.

He claimed that the NRC "improperly interpreted the amendment to section 104b under 42 USC 2134 and under the Atomic Energy Act of 1954, as amended," and thus, "improperly and illegally granted 20-year license extensions to the 40-year license that was initially granted by the agency." This is a general claim, insufficient to warrant further inquiry. The petitioner also claimed that "the NRC has recklessly endangered public health and safety in these circumstances because in so extending these licenses by 20 years, the agency has significantly increased the likelihood of a loss-of coolant accident" due to neutron embrittlement of the reactor vessel over time. All license renewals have been subjected to the NRC's license renewal review process, per 10 CFR 51 and 54, with several opportunities for public participation, including a hearing. A reactor vessel neutron embrittlement analysis is included in each license renewal application, and is evaluated in the resulting NRC staff safety evaluation report in accordance with NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Section 4.2. Request 4 was rejected based on the criteria that the petitioner raised issues that have already been the subject of NRC staff review and evaluation for which a resolution has been achieved, the issues have been resolved, and the resolution is applicable to the facility in question.

111. Conclusion As discussed above, the supporting facts provided in the petition, as supplemented by the teleconferences and petitioner's additional submittals, were found to be insufficient to warrant that the NRC accept the petitioner's Requests 1 and 2 to immediately shutdown U.S. nuclear power plants at or near earthquake faults or those employing the Mark I reactors.

The NRC partially accepted Requests 1 and 2 of the petition to the extent that the petitioner sought some type of regulatory action in light of the events at Fukushima.

The above discussion demonstrates that the NRC has addressed the petitioner's concerns related to the events at Fukushima through the issuance of Orders and through a request for information pursuant to 10 CFR 50.54(f).

Such actions significantly enhance the margins of safety to the effects of extreme natural phenomena at commercial operating reactors in the United States. Request 3 was rejected on the basis that the petitioner requested an action that the NRC was already implementing, and Request 4 was rejected on the basis that the petitioner's claim was general and insufficient to warrant further inquiry, and that the issue had already been the subject of NRC staff review and evaluation.

Based on the staff responses to the petitioner's four concerns, the NRC does not plan to take any additional enforcement actions as specified in the petitioner's requests.

Therefore, the NRC is closing this petition.

As provided in 1 O CFR 2.206(c), a copy of this director's decision will be filed with the Secretary of the Commission for the Commission to review. As provided for by this regulation, the decision will constitute the final action of the Commission 25 days after the date of the decision unless the Commission, on its own motion, institutes a review of the decision within that time. Dated at Rockville, Maryland, this day of FOR THE U.S. NUCLEAR REGULATORY COMMISSION William M. Dean, Director Office of Nuclear Reactor Regulation LIST OF POWER REACTOR LICENSEES AND HOLDERS OF CONSTRUCTION PERMITS IN ACTIVE OR DEFERRED STATUS Beaver Valley Power Station First Energy Nuclear Operating Co. Docket Nos. 50-334 and 50-412 License Nos. DPR-66 and NPF-73 Mr. Eric A. Larson Site Vice President Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Bellefonte Nuclear Plant Tennessee Valley Authority Docket Nos. 50-438 and 50-439 Construction Permit Nos. CPPR No. 122 and CPPR No. 123 Mr. Michael D. Skaggs Senior Vice President, Nuclear Construction Tennessee Valley Authority Lookout Place 6A 1101 Market Street Chattanooga, TN 37402-2801 Braidwood Station Exelon Generation Co., LLC Docket Nos. 50-456 and 50-457 License Nos. NPF-72 and NPF-77 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Browns Ferry Nuclear Plant Tennessee Valley Authority Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, DPR-52 and DPR-68 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37 402-2801 Byron Station Exelon Generation Co., LLC Docket Nos. STN 50-454 and STN 50-455 License Nos. NPF-37 and NPF-66 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Callaway Plant Union Electric Company Docket No. 50-483 License No. NPF-30 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Plant P.O. Box 620 Fulton, MO 65251 Calvert Cliffs Nuclear Power Plant Calvert Cliffs Nuclear Power Plant, LLC Docket Nos. 50-317 and 50-318 License Nos. DPR-53 and DPR-69 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC. Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Enclosure 2

Catawba Nuclear Station Duke Energy Carolinas, LLC Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 Mr. Kelvin Henderson Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 297 45 Columbia Generating Station Energy Northwest Docket No. 50-397 License No. NPF-21 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest MD 1023 North Power Plant Loop P.O. Box 968 Richland, WA 99352 Cooper Nuclear Station Nebraska Public Power District Docket No. 50-298 License No. DPR-46 Mr. Oscar A Limpias Vice President Nuclear and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 Davis-Besse Nuclear Power Station First Energy Nuclear Operating Co. Docket No. 50-346 License No. NPF-3 Mr. Raymond A Lieb Site Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760 Diablo Canvon Power Plant Pacific Gas and Electric Co. Docket Nos. 50-275 and 50-323 License Nos. DPR-80 and DPR-82 Mr. Edward D. Halpin Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424 Donald C. Cook Nuclear Plant Indiana Michigan Power Company Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106 Dresden Nuclear Power Station Exelon Generation Company, LLC Docket Nos. 50-237 and 50-249 License Nos. DPR-19 and DPR-25 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Co. Docket Nos. 50-321 and 50-366 License Nos. DPR-57 and NPF-5 Mr. C.R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc. P.O. Box 1295/BIN B038 Birmingham, AL 35201-1295 Fermi DTE Electric Company Docket No. 50-341 License No. NPF-43 Mr. Joseph H. Plana Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 210 NOC 6400 North Dixie Highway Newport, Ml 48166 H. B. Robinson Steam Electric Plant Duke Energy Progress, Inc. Docket No. 50-261 License No. DPR-23 Mr. William R. Gideon, Vice President H.B. Robinson Steam Electric Plant 3581 West Entrance Road Hartsville, SC 29550 Indian Point Nuclear Generating Entergy Nuclear Operations, Inc. Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Vice President, Operations Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 LaSalle County Station Exelon Generation Company, LLC Docket Nos. 50-373 and 50-374 License Nos. NPF-11 and NPF-18 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Monticello Nuclear Generating Plant Northern States Power Company -Minnesota Docket No. 50-263 License No. DPR-22 Karen D. Feli Site Vice President Northern States Power Company -Minnesota Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362-9637 North Anna Power Station Virginia Electric and Power Co. Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Co. Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Oconee Nuclear Station Duke Energy Carolinas, LLC Docket Nos. 50-269, 50-270 and 50-287 License Nos. DPR-38, DPR-47 and DPR-55 Mr. Scott Batson Vice President, Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672 Oyster Creek Nuclear Generating Station Exelon Generation Co., LLC Docket No. 50-219 License No. DPR-16 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Palisades Nuclear Plant Entergy Nuclear Operations, Inc. Docket No. 50-255 License No. DPR-20 Vice President, Operations Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 Palo Verde Nuclear Generating Station Arizona Public Service Company Docket Nos. STN 50-528, STN 50-529 and STN 50-530 License Nos. NPF-41, NPF-51 and NPF-74 Mr. Randall K. Edington Executive Vice President Nuclear and Chief Nuclear Officer Arizona Public Service Co. P.O. Box 52034, MS 7602 Phoenix, AZ 85072-2034 Peach Bottom Atomic Power Station Exelon Generation Co, LLC Docket Nos. 50-277 and 50-278 License Nos. DPR-44 and DPR-56 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Perry Nuclear Power Plant FirstEnergy Nuclear Operating Co. Docket No. 50-440 License No. NPF-58 Mr. Ernest J. Harkness Site Vice President-Nuclear-Perry FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant PO Box 97, A290 Perry, OH 44081 Pilgrim Nuclear Power Station Unit No. 1 Entergy Nuclear Generation Co. Docket No. 50-293 License No. DPR-35 Mr. John Dent, Jr. Vice President and Site Vice President Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Point Beach Nuclear Plant NextEra Energy Point Beach, LLC Docket Nos. 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Mr. Eric McCartney Site Vice President NextEra Energy Point Beach, LLC 6610 Nuclear Road Two Rivers, WI 54241-9516 Seabrook Nuclear Plant NextEra Energy Seabrook, LLC Docket No 50-443 License No. NFP-86 Mr. Dean Curtland Vice President Seabrook Nuclear Plant ' c/o Mr. Michael Ossing NextEra Energy Seabrook, LLC P.O. Box300 Seabrook, NH 03874 Sequoyah Nuclear Plant Tennessee Valley Authority Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and DPR-79 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street LP 3D-C Chattanooga, TN 37402 Three Mile Island Nuclear Station Exelon Generation Company, LLC. Docket No. 50-289 License No. DPR-50 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Virgil C. Summer Nuclear Station South Carolina Electric and Gas Company Docket No. 50-395 License No. NPF-12 Mr. Thomas D. Gatlin, Vice President Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065 Vogtle Electric Generating Plant Southern Nuclear Operating Company, Inc. Docket Nos. 50-424 and 50-425 License Nos. NPF-68 and NPF-81 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P. 0. Box 1295 I Bin 038 Birmingham, AL 35201-1295 Watts Bar Nuclear Plant Tennessee Valley Authority Docket Nos. 50-390 and 50-391 License Nos. NPF-90 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801 William B. McGuire Nuclear Station Duke Energy Carolinas, LLC Docket Nos. 50-369 and 50-370 License Nos. NPF-9 and NPF-17 Steven D. Capps Duke Energy Carolinas, LLC McGuire Nuclear Station 12700 Hagers Ferry Road Huntersville, NC 28078-8985 Wolf Creek Generating Station Wolf Creek Nuclear Operating Corporation Docket No. 50-482 License No. NPF-42 Mr. Adam C. Heflin President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 DISTRIBUTION:

G20110171/EDATS:

OED0-2011-0192 (Letter to Licensee Dated April 8, 2015) PUBLIC LPL2-1 r/f LPL3-2 r/f RidsEdoMailCenter Resource RidRgn2MailCenter Resource RidsNrrOd Resource RidsNrrLAMHenderson Resource RidsNrrDorlLpl1-1 Resource RidsNrrDorlLpl2-2 Resource RidsNrrDorlLpl4 Resource MMiller, Region 2 ABurritt, Region1 TFarnholtz, Region 4 RidsNrrPMBeaverValley Resource RidsNrrPMBrownsFerry Resource RidsNrrPMCallaway Resource RidsNrrPMClinton Resource RidsNrrPMCooper Resource RidsNrrPMDCCook Resource RidsNrrPMDuaneArnold Resource RidsNrrPMFitzPatrick Resource RidsNrrPMHatch Resource RidsNrrPMKewaunee Resource RidsNrrPMMcGuire Resource RidsNrrPMNineMilePoint Resource RidsNrrPMOysterCreek Resource RidsNrrPMPeachBottom Resource RidsNrrPMPointBeach Resource RidsNrrPMREGinna Resource RidsNrrPMSalem Resource RidsNrrPMSequoyah Resource RidsNrrPMStLucie Resource RidsNrrPMSusquehanna Resource RidsNroDseaRgs2 Resource LPL 1-1 r/f LPL2-2 r/f LPL4 r/f RidsOgcRp Resource RidRgn3MailCenter Resource Rids AcrsAcnw&MailCenter RidsOpaMailCenter Resource RidsNrrDorlLpl1-2 Resource RidsNrrDorlLpl3-1 Resource RidsNrrDpr Resource RidsNrrPMBellefonte1 and2 Resource RidsNrrPMBrunswick Resource RidsNrrPMCalvertCliffs Resource RidsNrrPMColumbia Resource RidsNrrPMCrystalRiver Resource RidsNrrPMDiabloCanyon Resource RidsNrrPMFarley Resource RidsNrrPMFortCalhoun Resource RidsNrrPMHopeCreek Resource RidsNrrPMLaSalle Resource RidsNrrPMMillstone Resource RidsNrrPMNorthAnna Resource RidsNrrPMPalisades Resource RidsNrrPMPerry Resource RidsNrrPMPrairielsland Resource RidsNrrPMRiverBend Resource RidsNrrPMSanOnofre Resource RidsNrrPMShearonHarris Resource RidsNrrPMSummer Resource RidsNrrPMThreeMilelsland Resource RidsNrrPMVogtle Resource RidsNrrPMWattsBar2 Resource RidsNroDnrlLb4 Resource RidsNrrPMWattsBar1 Resource LPL 1-2 r/f LPL3-1 r/f RidsNrrMailCenter Resource RidRgn1 MailCenter Resource RidRgn4MailCenter Resource RidsNrrDorl Resource RidsOcaMailCenter Resource RidsNrrDorlLpl2-1 Resource RidsNrrDorlLpl3-2 Resource DHills, Region 3 RidsNrrPMANO Resource RidsNrrPMBraidwood Resource RidsNrrPMByron Resource RidsNrrPMCatawba Resource RidsNrrPMComanchePeak Resource RidsNrrPMDavisBesse Resource RidsNrrPMDresden Resource RidsNrrPMFermi2 Resource RidsNrrPMGrandGulf Resource RidsNrrPMlndianPoint Resource RidsNrrPMLimerick Resource RidsNrrPMMonticello Resource RidsNrrPMOconee Resource RidsNrrPMPaloVerde Resource RidsNrrPMPilgrim Resource RidsNrrPMQuadCities Resource RidsNrrPMRobinson Resource RidsNrrPMSeabrook Resource RidsNrrPMSouthTexas Resource RidsNrrPMSurry Resource RidsNrrPMTurkeyPoint Resource RidsNrrPMWaterford Resource RidsNrrPMWolfCreek Resource RidsNroDseaRgs1 Resource All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status

Dear Sir or Madam:

April 8, 2015 By letter dated March 12, 2011, as supplemented on April 14, 2011, April 16, 2011, and May 25, 2011, Mr. Thomas Saporito submitted a petition pursuant to Section 2.206 of Title 1 O of the Code of Federal Regulations of the U.S. Nuclear Regulatory Commission's (NRC's) regulations with respect to all nuclear power reactors in the U.S. located on or near an earthquake fault line. The petition has been reviewed by the NRC staff and the staff's proposed director's decision on the petition is enclosed.

I request that you provide comments to me on any portions of the decision that you believe involve errors or any issues in the petition that you believe have not been fully addressed.

The staff is making a similar request of the petitioner.

The staff will then review any comments provided by you and the petitioner and consider them in the final version of the director's decision with no further opportunity to comment. Please provide your comments within two weeks from the date of this letter. The petition manager, Mahesh Chawla, can be reached at 301-415-8371 or at Mahesh.Chawla@nrc.gov.

Docket Nos. See Enclosure 2

Enclosures:

1. Proposed Director's Decision Sincerely, IRA! A. Louise Lund, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

2. List of Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status cc: Listserv DISTRIBUTION:

820110171 (See Next Page) ADAMS Accession Nos.: Package: ML13018A145 Incoming:

ML110740026 (Petition dated March 12, 2011) ML 1111 OA026 (Supplement dated April 14, 2011) ML 1111 OA027 (Supplement dated April 14, 2011) ML 1111 OA028 (Supplement dated April 14, 2011) ML 11119A024 (Supplement dated April 16, 2011) Proposed Director's Decision:

ML 1301BA159 Letter to Petitioner:

ML 13018A239 Letter to Licensees:

ML 13018A244

• via email OFFICE LPL3-1/PMiT LPL3-1/PM LPL3-1/LA DPR/PGCB*

JLD NAME A Dietrich MChawla MHenderson MBanic KWitt DATE 01/16/2015 02/09/2015 02/19/2015 01/21/2015 01/16/2015 OFFICE LPL3-1/BC Region 1* Region 2* Region 3* Region 4* NAME DPelton A Burritt MMiller DH ills TFarnholtz DATE 3/17/2015 01/20/2015 02/09/2015 01/21/2015 02/09/2015 OFFICE OGC* PRB Chair DO RUD NRR/D DORUD(A) !NAME I MClark I Jlubinski I MEvans I WDean (JU hie for) I Llund I 1 IDATE 10112212015 13/18/2015

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[ 4106/2015 14/08/2015 I OFFICIAL RECORD