Comment (2) of David Lochbaum on FR Doc # 2013-05491

Environmental Report Section 4.21 addresses Severe Accident Mitigation Alternatives. As stated in Section 4.21.3, a SAMA analysis is required for license renewal unless one has previously been performed for other reasons. The Limerick nuclear plant in Pennsylvania did a SAMA analysis as part of its initial licensing process. When its owner applied for license renewal, it did not submit another SAMA analysis. Page 4-65 explains TVA reviewed 309 SAMA candidates. 262 candidates were screened out as either not being applicable to Sequoyah. 47 SAMA candidates underwent further analysis and TVA identified 9 potentially cost-beneficial SAMAs for Unit 1 and 8 on Unit 2. As explained on page 4-66, because none of these potentially cost-beneficial safety upgrades is related to aging management - the focus of license renewal - none are required in TVA's view. Page 4-67 reports that TVA's analysis of SAMAs 286 and 288 for both units concldued that the "total averted cost risk from the senstivity analyses is greater than the implementation cost...". But Section 4.21.6 concludes that "None of the SAMAs are related to adequately managing the effects of aging during the period of extended operation. Therefore, they do not need to be implemented as part of license renewal pursuant to 10 CFR Part 54." As demonstrated by the Limerick case, SAMA analyses are not required for license renewal unless a SAMA analysis has not yet been done. Thus, the SAMA analysis is not linked solely to aging management during a license renewal period. The SAMA analysis is done for the environmental report. The environmental report considers alternatives to the proposed activity; namely, operating these reactors for 20 more years. The environmental report's evaluation shows that operating these reactors without these safety upgrades for 20 years is the wrong thing to do from a legal and moral perspective. The Sequoyah licenses should not be renewed without these safety upgrades.