ML13322A461

James A. FitzPatrick Nuclear Power Plant, ME8189 -G20120172/EDATS: OEDO-2012-0147 - e-mail from Additional Co-Petitioner, Earl Hall

ML13322A461
Person / Time
Site:	Duane Arnold
Issue date:	11/14/2013
From:	Hall E - No Known Affiliation
To:	Borchardt J, Bhalchandra Vaidya NRC/EDO, Plant Licensing Branch 1
References
2.206, EDATS: OEDO-2012-0147, G20120172, TAC ME8189
Download: ML13322A461 (2)

Text

Vaidya, BhalchandraFrom: Earl Hall <earl-hall@att.net>Sent: Thursday, November 14, 2013 12:55 PMTo: Vaidya, BhalchandraSubject: In the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New YorkMr. James BorchardtExecutive Director for OperationsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001VIA email to Bhalchandra K. Vaidya, NRC Petition ManagerIn the Matter of the James A. FitzPatrick Nuclear Plant in Scriba, New YorkDear Mr. Borchardt:I wish to co-petition with the Alliance for a Green Economy and Beyond Nuclear's March 9, 2012 emergencyenforcement petition to suspend the operation of the James A. FitzPatrick Nuclear Plant.* The FitzPatrick plant is the only GE Mark I boiling water reactor in the US that did not install a Direct TorusVent System as requested by the NRC in 1989 and instead, to save money, relies upon a "pre-existing"venting system that is not fully hardened against a severe accident.* In deciding not to install such a vent, the FitzPatrick operator and the NRC relied upon assumptions that nowplace public health and safety at an undue risk.* The hydrogen explosions at the Fukushima reactors show the dangers and unacceptable consequencesposed by the current FitzPatrick severe accident venting plan, since the plan was approved on theassumptions that venting would prevent containment failure, and that there are "no likely" ignition sourcesalong the vent path. Neither of these assumptions was correct during the Fukushima nuclear catastrophe..Subsequent to the Fukushima accident, the NRC inspected FitzPatrick and identified a "vulnerability, in thatcurrent procedures do not address hydrogen considerations" during a severe accident.Therefore, I request NRC immediately suspend the FitzPatrick operating license until the following emergencyenforcement actions are approved by the NRC:1) Public hearings should be held on the continued operation of Entergy Nuclear Operations' Fitzpatrick plantand the adequacy of its plan to vent through a pre-existing path into the adjacent Standby Gas TreatmentSystem building, blowing off the double doors to release a radiological accident to the outside environment atground level. The public must be afforded due process to address the unacceptable risks to public health andsafety posed by the FitzPatrick severe accident plan.2) Entergy Nuclear Operations should publicly document for independent review its post-Fukushima re-analysis for the reliability and capability of the FitzPatrick pre-existing containment vent system.* The analysis should include the reassessment of all assumptions regarding the reliability of the pre-existingcontainment venting and specifically address non-conservative assumptions behind the cost-benefit analysisused to justify not installing a fully hardened vent system.1

• It should also include a reassessment of the assumption of "no likely ignition points" during emergency ventingthat would otherwise present catastrophic consequences associated with the detonation of hydrogen gas andthe release of radioactivity generated during a severe accident.I wish the NRC to process my request using the 2.206 process, and I understand that under this process, thecontents of this message and my identity will be made public.The Alliance for a Green Economy is my point of contact for this petition, and their organizer, Jessica Azulay,will keep me informed about the developments of the petition and the opportunity to participate in a publicmeeting with the NRC Petition Review Board.Thank youEarl Hall546 North Clarendon Streetkalamzoo, MI 4590062