ML060410065

2006/01/11-Comment (10) of Joanna and Charles Hamlin Opposing the VT Yankee Proposed Uprate and the Risk Assessments in the Draft Safety Evaluation Released by the NRC Based on Fallacious Assumption That the Reactor Is Brand New

ML060410065
Person / Time
Site:	Vermont Yankee
Issue date:	01/11/2006
From:	Hamlin C, Hamlin J - No Known Affiliation
To:	NRC/ADM/DAS/RDB
References
%dam200606, 71FR1774 00010
Download: ML060410065 (2)

Text

• ~RULFS so1 ries From: Joanna and Charles Hamlin P0 Box 86 I O-7 j Shutesbury, MA 01072 A1Y 9 20 To: Chief, Rules and Directives Branch r- rn Division of Administrative Services l ')

Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555 0001 To Whom It May Concern:

Re: The following Federal Register notice:

page 1774 Federal Register / Vol. 71, No. 7 / Wednesday, January 11, 2006 I am a member of the Pioneer Valley community, living in the shadow of VT Yankee. I want it on record that I am against the proposed EPA Test.

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 SE add up to a SIGNIFICANT REDUCTION IN SAFETY MARGINS. It is not known what safety margins should apply to an aged, embrittled, cracked plant, because of your refusal to do an ISA to actually inspect the degree to which components are leaking, degraded, cracked or left in the wrong position. This is irresponsible.

A few examples:

You (NRC) say: "significant uncertainty exists regarding the licensee's method for calculating stress on the -(cracked) steam dryer" so it plans an EXPERIMENTAL POWER ASCENSION TEST. Experimenting with stressing out plant systems while the reactor is on-line is by definition a reduced safety margin. John Olver calls it "IRRESPONSIBLE" and "RISKING THE LIVES OF ALL WHO LIVE IN THE VICINTY."

He is a scientist, a PhD in Chemistry, a cautious man, and does not say such things lightly.

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 engineer 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 5 - } j t/)5 v>35

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s-4_>; - 'i 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.

All of the above argue that the NRC is wrong in its ruling, and should revisit its decision after performing an Independent Safety Assessment and a real risk and consequence assessment.

Sincerely, Joanna and Charles Hamlin