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| {{#Wiki_filter:ATTACHMENT 1 7 LAR, both when viewed alongside the directly related exemption request and alone, that pose a by the exemption request constitutes an admissible contention on the exemption in the event that the NRC grants a hearing on the request now under reconsideration. The contention also presents a basis for a hearing on the LAR alone. -supported declarations outline a number of credible threat scenarios that have not been analyzed by Entergy in the LAR. Public health and safety, in turn, would be adversely impacted in the event of any of these scenarios if the LAR is granted. The State has identified credible beyond design-basis-scenarios, including hostile action, the use of fire accelerants compromising spent fuel pool safety, spent nuclear fuel pool loss of cooling that results in a zirconium fire, and spent fuel transfer accidents. In the case of threats from accelerants in the fuel pool, Entergy performed an emergency response exercise at VY in March 2015 that included the use on an accelerant dropped into the fuel pool. In each of 15 to 60 minutes, coupled with the reduction of the Emergency Planning Zone to the plant footprint, as contemplated by the LAR, adds significant and unnecessary risk to the public by way of delayed and reduced emergency response action. The reduction in emergency response capabilities violates the requirements of 10 CFR § 50.54(q)(4), even in the event that Entergy is exempted from portions 10 CFR § 50.47 and Part 50, Appendix E. The lack of adequate safety analysis regarding credible accident scenarios applies independently to the LAR in addition to applying to the directly related exemption request.}} | | {{#Wiki_filter:ATTACHMENT 1 LAR, both when viewed alongside the directly related exemption request and alone, that pose a risk to public health and safety. As explained above, the contentions focus on problems posed by the exemption request constitutes an admissible contention on the exemption in the event that the NRC grants a hearing on the request now under reconsideration. The contention also presents a basis for a hearing on the LAR alone. |
| | The States Petition and companion expert-supported declarations outline a number of credible threat scenarios that have not been analyzed by Entergy in the LAR. Public health and safety, in turn, would be adversely impacted in the event of any of these scenarios if the LAR is granted. The State has identified credible beyond design-basis-scenarios, including hostile action, the use of fire accelerants compromising spent fuel pool safety, spent nuclear fuel pool loss of cooling that results in a zirconium fire, and spent fuel transfer accidents. In the case of threats from accelerants in the fuel pool, Entergy performed an emergency response exercise at VY in March 2015 that included the use on an accelerant dropped into the fuel pool. In each of these scenarios, the LARs proposed expansion of notification of an emergency to the State from 15 to 60 minutes, coupled with the reduction of the Emergency Planning Zone to the plant footprint, as contemplated by the LAR, adds significant and unnecessary risk to the public by way of delayed and reduced emergency response action. |
| | The reduction in emergency response capabilities violates the requirements of 10 CFR § 50.54(q)(4), even in the event that Entergy is exempted from portions 10 CFR § 50.47 and Part 50, Appendix E. The lack of adequate safety analysis regarding credible accident scenarios applies independently to the LAR in addition to applying to the directly related exemption request. |
| | 7}} |
Latest revision as of 13:58, 31 October 2019
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Category:Legal-Correspondence/Miscellaneous
MONTHYEARML18102B1922018-04-12012 April 2018
Substitution of Counsel for State of Vermont
ML18066A0432018-03-0707 March 2018
State of Vermont Notice of Anticipated Withdrawal of the State Petition for Leave to Intervene and Hearing Request
ML18066A0442018-03-0202 March 2018
March 2, 2018 Vermont Yankee Settlement Agreement
ML17164A2672017-06-13013 June 2017
Transmittal of New England Coalition'S Request for Leave to Reply and Reply to the Applicant'S Response to Request for Extension of Time of June 9, 2017
ML17163A3442017-06-12012 June 2017
Notice of Appearance of Kyle H. Landis-Marinello
ML17160A4472017-06-0909 June 2017
Request for Extension of Time to File Request for Hearing and Petition for Leave to Intervene
ML16123A3822016-05-0202 May 2016
NRC Staff Updated Notices of Appearance for Beth Mizuno, Mitzi Young, Anita Ghosh, Jeremy Wachutka and Matthew Ring
ML16099A2992016-04-0808 April 2016
Kuyler Notice of Withdrawal of Raphael Kuyler
ML15357A2482015-12-21021 December 2015
State of Vt'S Respondents' Reply to Opposition to Motion to Dismiss
ML15355A5232015-12-21021 December 2015
Attachment 1 - Petitioners Opposition to Motion to Dismiss
ML15355A5222015-12-21021 December 2015
Notice to the Commission of Information Relevant to the November 4, 2015 Petition Filed by the State of Vermont, Vermont Yankee Nuclear Power Corporation, and Green Mountain Power Corporation
ML15341A2972015-12-0707 December 2015
Notices of Appearance for Raimo Bessette and Burdick (VY 11-4-2015 Petition)
ML15309A7582015-11-0505 November 2015
State of Vermont'S Notice to Board of Petition Filed with Commissioners
ML15183A3742015-07-0202 July 2015
State of Vermont'S Notice of Supplemental Authority
ML15183A3752015-07-0202 July 2015
State of Vermont'S Notice of Supplemental Authority Exhibit 1
ML15169A2482015-06-18018 June 2015
Notification of Issuance of Exemptions
ML15160A7242015-06-0909 June 2015
Notice of Appearance of Kyle Landis-Marinello
ML15142A9052015-05-22022 May 2015
Notice of Appearance of Aaron Kisicki on Behalf of the State of Vermont
ML15135A4972015-05-15015 May 2015
Notices of Appearances for Susan H. Raimo, Paul M. Bessette and Stephen J. Burdick
ML15132A4082015-05-12012 May 2015
Jeremy L. Wachutka Notice of Appearance
ML15124A8472015-05-0404 May 2015
Attachment 1 Draft EA and Fonsi
ML15124A8452015-05-0404 May 2015
State of Vermont'S Notice of Supplemental Authority
ML15098A0302015-04-0808 April 2015
Notice of Appearance Jeremy L. Wachutka
ML15084A3142015-03-25025 March 2015
Attachment 1 - VT Errata to Errata to Reply to NRC Staff and Entergy Answers to Petition for Leave to Intervene and Hearing Request
ML15084A3152015-03-25025 March 2015
VT Errata to Errata to Reply to NRC Staff and Entergy Answers to Petition for Leave to Intervene and Hearing Request
ML15070A5922015-03-11011 March 2015
Notice of Appearance of Aaron Kisicki
ML15055A5182015-02-24024 February 2015
Notices of Appearance of Susan H. Raimo, Paul M. Bessette, and Raphael P. Kuyler
ML15036A5622015-02-0505 February 2015
Staff Notification of Issuance of License Amendment No. 261
ML15030A4932015-01-30030 January 2015
Notice to Board and Parties Re Nshcd and License Amendment
ML14342A3362014-12-0808 December 2014
NRC Staff Answer to Atomic Safety and Licensing Board Question Asked During December 1, 2014 Contention Admissibility Oral Argument
ML14300A2142014-10-27027 October 2014
State of Vermont'S Unopposed Motion for Extension of Time to File a Reply to NRC Staff and Entergy Answers to the State of Vermont'S Notice of Intention to Participate, Petition to Intervene, and Hearing Request, and Request for Reschedulin
ML11172A3822011-06-20020 June 2011
State of VT, Petitioners V. USNRC, Respondents; No. 11-1168 - Certificate of Service
ML1109505442011-04-0505 April 2011
Letter from Annette L. Vietti-Cook, Secretary to Messrs. Michael Mulligan, Raymond Shadis, and Thomas Saporito Director'S Decision DD-11-03
ML0725601622007-08-28028 August 2007
Commonwealth of Massachusetts V. USNRC, Nos. 07-1482 and 078-1483; Joint Stipulation to Supplement the Record
ML0714402182007-05-14014 May 2007
5/14/2007 - Letter from Karen Tyler to Richard Donovan Regarding the Filing of New England Coalition, Inc.'S Reply to Entergy'S Response; No. 07-1482
ML16267A2722002-05-0202 May 2002
May 2, 2002 Vermont Yankee Citizen Mail Responses
2018-04-12
[Table view] |
Text
ATTACHMENT 1 LAR, both when viewed alongside the directly related exemption request and alone, that pose a risk to public health and safety. As explained above, the contentions focus on problems posed by the exemption request constitutes an admissible contention on the exemption in the event that the NRC grants a hearing on the request now under reconsideration. The contention also presents a basis for a hearing on the LAR alone.
The States Petition and companion expert-supported declarations outline a number of credible threat scenarios that have not been analyzed by Entergy in the LAR. Public health and safety, in turn, would be adversely impacted in the event of any of these scenarios if the LAR is granted. The State has identified credible beyond design-basis-scenarios, including hostile action, the use of fire accelerants compromising spent fuel pool safety, spent nuclear fuel pool loss of cooling that results in a zirconium fire, and spent fuel transfer accidents. In the case of threats from accelerants in the fuel pool, Entergy performed an emergency response exercise at VY in March 2015 that included the use on an accelerant dropped into the fuel pool. In each of these scenarios, the LARs proposed expansion of notification of an emergency to the State from 15 to 60 minutes, coupled with the reduction of the Emergency Planning Zone to the plant footprint, as contemplated by the LAR, adds significant and unnecessary risk to the public by way of delayed and reduced emergency response action.
The reduction in emergency response capabilities violates the requirements of 10 CFR § 50.54(q)(4), even in the event that Entergy is exempted from portions 10 CFR § 50.47 and Part 50, Appendix E. The lack of adequate safety analysis regarding credible accident scenarios applies independently to the LAR in addition to applying to the directly related exemption request.
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