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| | number = ML060600080 | | | number = ML060600080 |
| | issue date = 02/05/2006 | | | issue date = 02/05/2006 |
| | title = 2006/02/05-Comment (52) of Linda and Robert Hecker Opposing the Proposed 20% Energy Uprate at Vermont Yankee and to Request an Independent Safety Assessment | | | title = Comment (52) of Linda and Robert Hecker Opposing the Proposed 20% Energy Uprate at Vermont Yankee and to Request an Independent Safety Assessment |
| | author name = Hecker L, Hecker R | | | author name = Hecker L, Hecker R |
| | author affiliation = - No Known Affiliation | | | author affiliation = - No Known Affiliation |
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| {{#Wiki_filter:////j;1 4 'M7// 1'RULES [L.); DSi iECTiVES 2450 Packer Corners Road 0) .Guilford, VT 05301-Fr~'71\!D February 5, 2006 Chief, Rules and Directives Branch Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Re: Federal Register notice: page 1774 Vol. 71, No. 7 / Wednesday, January 11, 2006 | | {{#Wiki_filter:RULES DSi iECTiVES |
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| | ////j;1 4 ' |
| | M7// 1' 2450 Packer Corners Road |
| | : 0) .Guilford, VT 05301 February 5, 2006 Chief, Rules and Directives Branch Division of Administrative Services Office of Administration -Fr~'71\!D U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Re: Federal Register notice: page 1774 Vol. 71, No. 7 / Wednesday, January 11, 2006 |
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| ==Dear Chief,== | | ==Dear Chief,== |
| NRC I am writing as a U.S. Citizen who lives within the Evacuation Zone of the Entergy Nuclear/Vermont Yankee (ENVY) in Vernon, Vermont to express my extreme concerns about the proposed 20% energy uprate and to request an Independent Safety Assessment.. | | NRC I am writing as a U.S. Citizen who lives within the Evacuation Zone of the Entergy Nuclear/Vermont Yankee (ENVY) in Vernon, Vermont to express my extreme concerns about the proposed 20% energy uprate and to request an Independent Safety Assessment.. |
| My concerns include the following: | | My concerns include the following: |
| * The risk assessments in the draft Safety Evaluation released by the NRC are based on the fallacious assumption that the reactor is brand new. The plant is NOT brand new, so the design basis safety margins NO LONGER APPLY. The vast number of reduced safety margins on every page of the St add up to a SIGNIFICANT REDUCTION IN SAFETY MARGINS* the defeat of containment overpressure by valves that might be in the wrong position (as recently revealed to be the case by the VT state nuclear eng:ineer in testimony to the Advisory Committee on Reactor Safeguards) means that allowing credit for containment overpressure, even for 15 minutes, represents a significant reduction of a safety margin and of "defense in depth." An ISA is needed to ensure containment integrity. | | * The risk assessments in the draft Safety Evaluation released by the NRC are based on the fallacious assumption that the reactor is brand new. The plant is NOT brand new, so the design basis safety margins NO LONGER APPLY. The vast number of reduced safety margins on every page of the St add up to a SIGNIFICANT REDUCTION IN SAFETY MARGINS |
| .repeated events involving inoperability of the high pressure coolant injection system (HPCI system) call into question defense in depth. An ISA is needed to understand why this is happening and what else might go wrong in other back-up cooling systems.The fatal flaw and limitation of probabilistic risk assessment is that it does not consider consequences and is based on theoretical design standards and not real experience. | | * the defeat of containment overpressure by valves that might be in the wrong position (as recently revealed to be the case by the VT state nuclear eng:ineer in testimony to the Advisory Committee on Reactor Safeguards) means that allowing credit for containment overpressure, even for 15 minutes, represents a significant reduction of a safety margin and of "defense in depth." An ISA is needed to ensure containment integrity. |
| In the ACRS hearings NRR staff admitted there were better methods to evaluate system integrity under uprate conditions, but NRC is not using them. In order to protect the health, safety, and well being of my family and my community, I strongly urge you to conduct an Independent Safety Assessment. | | . repeated events involving inoperability of the high pressure coolant injection system (HPCI system) call into question defense in depth. An ISA is needed to understand why this is happening and what else might go wrong in other back-up cooling systems. |
| Not to do so exposes all of us to an unacceptable level of risk.Sincerely Linda and Robert Hecker z.6e-" s,''II S;7 h:>- e cZ1 ::.?}} | | The fatal flaw and limitation of probabilistic risk assessment is that it does not consider consequences and is based on theoretical design standards and not real experience. In the ACRS hearings NRR staff admitted there were better methods to evaluate system integrity under uprate conditions, but NRC is not using them. In order to protect the health, safety, and well being of my family and my community, I strongly urge you to conduct an Independent Safety Assessment. Not to do so exposes all of us to an unacceptable level of risk. |
| | Sincerely Linda and Robert Hecker S;7 h:>- e cZ1 ::.? |
| | ''II z.6e-" s,}} |
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Category:General FR Notice Comment Letter
MONTHYEARML17179A2462017-06-22022 June 2017
Comment (4) of Schuyler Gould Regarding Vermont Yankee Nuclear Power Station; Entergy Nuclear Operations, Inc.; Consideration of Approval of Transfer of License and Conforming Amendment
ML17179A2452017-06-21021 June 2017
Comment (3) of Anonymous Regarding Vermont Yankee Nuclear Power Station; Entergy Nuclear Operations, Inc.; Consideration of Approval of Transfer of License and Conforming Amendment
ML17163A0882017-06-0303 June 2017
Comment (2) of Robert Oeser on Vermont Yankee Power Station; Energy Nuclear Operations, Inc.; Consideration of Approval of Transfer of License and Conforming Amendment
ML17163A0872017-05-29029 May 2017
Comment (1) of Richard Holschuh on Behalf of Elnu Abenaki Tribe on Vermont Yankee Power Station; Energy Nuclear Operations, Inc.; Consideration of Approval of Transfer of License and Conforming Amendment
ML15159A1832015-06-0101 June 2015
Comment (2) of Kyle Landis-Marinello on Behalf of State of VT on Entergy Nuclear Operations, Inc.; Vermont Yankee Nuclear Power Station; Draft Environmental Assessment and Finding of No Significant Impact; Request for Comment
ML15159A1842015-06-0101 June 2015
Comment (3) of Sandra and Charles Kosterman Opposing Entergy Nuclear Operations, Inc.; Vermont Yankee Nuclear Power Station; Draft Environmental Assessment and Finding of No Significant Impact; Request for Comment
ML15138A0942015-05-0101 May 2015
Comment (1) of Clay Turnbull on Entergy Nuclear Operations, Inc.; Vermont Yankee Nuclear Power Station; Draft Environmental Assessment and Finding of No Significant Impact; Request for Comment
ML15096A4582015-03-23023 March 2015
Comment (36) by Louise Amyot on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4422015-03-23023 March 2015
Comment (31) by Wendy Lapointe on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4522015-03-23023 March 2015
Comment (35) by Carol Levin on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4472015-03-23023 March 2015
Comment (34) by Virginia Hastings on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4452015-03-23023 March 2015
Comment (33) by John Cevasco on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4432015-03-23023 March 2015
Comment (32) by Charles Kosterman on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4402015-03-23023 March 2015
Comment (30) by Thomas Gajewski on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4392015-03-23023 March 2015
Comment (29) of Maggie Gunderson on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4382015-03-23023 March 2015
Comment (28) by Beth Watrous on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4372015-03-23023 March 2015
Comment (27) by John Tuthill on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4362015-03-23023 March 2015
Comment (26) by Nancy Hazard on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4352015-03-23023 March 2015
Comment (25) by Anonymous Individual on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4342015-03-23023 March 2015
Comment (24) by Erik Hoffner on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4332015-03-23023 March 2015
Comment (23) by Constance Harvard on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4322015-03-23023 March 2015
Comment (22) by David Jacke on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4602015-03-23023 March 2015
Comment (38) by Suzanne Carlson on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4612015-03-23023 March 2015
Comment (39) by Michael Rice on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4622015-03-23023 March 2015
Comment (40) by Susan Pelis on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4632015-03-23023 March 2015
Comment (41) by Elyssa Serrilli on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4592015-03-23023 March 2015
Comment (37) by Loren Kramer on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4652015-03-23023 March 2015
Comment (43) by Tim Murphy on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4292015-03-22022 March 2015
Comment (19) by Leslie Sachs on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4302015-03-22022 March 2015
Comment (20) by Jon King on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4642015-03-22022 March 2015
Comment (42) by Nancy Meagher on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4672015-03-20020 March 2015
Comment (17) by Anonymous Individual on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4692015-03-20020 March 2015
Comment (16) by Ulrike Von Molrke on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0502015-03-20020 March 2015
Comment (4) of Anonymous Individual on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15084A2242015-03-20020 March 2015
Comment (13) of Clay Turnbull Request for Extension of Time to File Public Comments
ML15096A4662015-03-20020 March 2015
Comment (44) by Christopher Williams on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4272015-03-20020 March 2015
Comment (18) by Nancy First on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15097A0792015-03-19019 March 2015
Comment (2) by State of Vermont on NRC-2015-0029, Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations
ML15091A2552015-03-19019 March 2015
Comment (14) of Peter B. Elwell on Behalf of Town of Brattleboro on Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15096A4682015-03-18018 March 2015
Comment (15) by an Anonymous Individual on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0662015-03-18018 March 2015
Comment (12) of Susan Lantz on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0652015-03-17017 March 2015
Comment (11) of Bob Dickerman on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0632015-03-15015 March 2015
Comment (10) of Anne Stevens on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0622015-03-15015 March 2015
Comment (9) of Sue Prent on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0612015-03-13013 March 2015
Comment (8) of D. Brigham on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0602015-03-12012 March 2015
Comment (7) of Robert Oeser Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A2342015-03-0606 March 2015
Comment (6) by William Irwin, on Behalf of State of Vermont Department of Health, Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0592015-02-27027 February 2015
Comment (5) of Valerie Stuart on Entergy Nuclear Operations, Inc., Venriont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15082A0492015-02-19019 February 2015
Comment (3) of Norton Garber on Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report
ML15049A0332015-02-0909 February 2015
Comment (24) of Shauna Lynn Opposing Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station; License Amendment Aplication; Reopening of Public Comment Period
2017-06-03
[Table view] |
Text
RULES DSi iECTiVES
[L.);
////j;1 4 '
M7// 1' 2450 Packer Corners Road
- 0) .Guilford, VT 05301 February 5, 2006 Chief, Rules and Directives Branch Division of Administrative Services Office of Administration -Fr~'71\!D U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001 Re: Federal Register notice: page 1774 Vol. 71, No. 7 / Wednesday, January 11, 2006
Dear Chief,
NRC I am writing as a U.S. Citizen who lives within the Evacuation Zone of the Entergy Nuclear/Vermont Yankee (ENVY) in Vernon, Vermont to express my extreme concerns about the proposed 20% energy uprate and to request an Independent Safety Assessment..
My concerns include the following:
- The risk assessments in the draft Safety Evaluation released by the NRC are based on the fallacious assumption that the reactor is brand new. The plant is NOT brand new, so the design basis safety margins NO LONGER APPLY. The vast number of reduced safety margins on every page of the St add up to a SIGNIFICANT REDUCTION IN SAFETY MARGINS
- the defeat of containment overpressure by valves that might be in the wrong position (as recently revealed to be the case by the VT state nuclear eng:ineer in testimony to the Advisory Committee on Reactor Safeguards) means that allowing credit for containment overpressure, even for 15 minutes, represents a significant reduction of a safety margin and of "defense in depth." An ISA is needed to ensure containment integrity.
. repeated events involving inoperability of the high pressure coolant injection system (HPCI system) call into question defense in depth. An ISA is needed to understand why this is happening and what else might go wrong in other back-up cooling systems.
The fatal flaw and limitation of probabilistic risk assessment is that it does not consider consequences and is based on theoretical design standards and not real experience. In the ACRS hearings NRR staff admitted there were better methods to evaluate system integrity under uprate conditions, but NRC is not using them. In order to protect the health, safety, and well being of my family and my community, I strongly urge you to conduct an Independent Safety Assessment. Not to do so exposes all of us to an unacceptable level of risk.
Sincerely Linda and Robert Hecker S;7 h:>- e cZ1 ::.?
II z.6e-" s,
