ML20147H191

Forwards Response to Request for Addl Info Re 871001 Application for Schedular Exemption from 10CFR50.54(w) Concerning Level of Onsite Property Insurance Coverage.Util Believes That Response Meets NRC Request & Supports Request

ML20147H191
Person / Time
Site:	Seabrook
Issue date:	02/29/1988
From:	George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NYN-88026, NUDOCS 8803080412
Download: ML20147H191 (2)

Text

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u George S. Thomas vice hesk$ent Nuch hoduction -

NYN-88026 PW2c Service of New Hampshire

' N:w Hampshire Yankee Division United States Nuclear Regulatory Commission Washington DC 20555 .

. Attention: Document Control Desk References (a) Facility Operating License No. NPF-56, Docket No. 50-443 (b) PSNH Letter (NYN-87117) dated October'1, 1987, ' Application for Schedular Exemption from 10 CFR 50.54(w)," G. S. Thomas to NRC

Subject:

Request for Additional Information Gentlemen In Reference (b), New Hampshire Yankee (NHY) transmitted its request and justification for a Schedular Exemption with regards to the level of onsite ,

pro'perty insurance coverage. 'As a result of their review, the NRC Staff requested additional information with regards to considerations delineated in .

I 10 CFR 50.12. -The specific additional information requested by the Staff is provided in the Enclosure'.

Accordingly, NHY believes that the enclosed meets the Staff's request and further supports the Schedular Exemption request. Should you have any questions regarding this matter, please contact our Bethesda Licensing Office (Mr. R. E. Sweeney) at (301) 656-6100.

Very truly yours, eor d

S. Thomas ,

Enclosure cci Mr. Victor Nerses, Project Manager Mr. Antone C. Cerne Project Directorate I-3 NRC Senior Resident Inspector .

Division of Reactir Projects Seabrook Station

-U.S. Nuclear Regulatory Commission Seabrook, NH 03874 Washington, DC 20555 Mr. William T. Russell Regional Administrator

, U.S. Nuclear Regulatory Commission

Region I 425 Allendale Road King of Prussia, PA 19406 8803080412 880229

R ADOCK 05000443 g f PDR P.O Box 300. Seabrook, NH 03874 . Telephone (603) 474 9574 lj)t

_,_ _ ~._. _ _ _ _ . _ _ , _ _ , . , _ .

ENCLOSURE TO NYN-88026 Section 50.12(a)(1) of Title 10 to the Code of Federal Regulations (CFR) authorizes the Commission to grant exemptions which are authorized by law, will not present undue risk to the public health and safety, and are consistent with the common defense and security. Furthermore, the Commission can only issue an exemption if special circumstances are present.

NHY believes that the response provided in Reference (b) provides sufficient justification to the special circumstances present; however, NHY provides the following with regards to Section 50.12:

(1) The Commission should grant the Schedular Exemption from the requirements of 10 CFR 50.54(w) as presented in Reference (b);

(2) Pursuant to 50.12(a)(1), the Commission is authorized by law because the Schedular Exemption does not present an undue risk to the public health and safety as noted in Keference (b); and (3) The subject Schedular Exemption represents special circumstances as identified in Reference (b); and special circumstances are present pursuant to 50.12(a)(2)(v) because the Schedular Exemption would provide only temporary relief from the applicable regulation (10 CFR 50.54(w)). NHY has made good faith efforts to comply with the regulations; and full compliance with the regulation will be assured prior to initial criticality, thus ensuring that the circum-stances of the Schedular Exemption do not present an undue risk to the public health and safety.

Furthermore, the Schedular Exemption request has been evaluated for other considerations; and NHY believes the proposed Schedular Exemption does not (1) involve a significant increase in the probability or consequences of an accident because the Schedular Exemption request is administra-tive in nature and has no bearing on the consequence of an accident because no undue risk exists; (2) create the possibility of a new or different kind of accident because a significant accident is, for all practical purposes, highly improbable since the reactor has not gone critical or allowed to operate at any power level as noted in the conditions of the Facility Operating License NPF-56; or (3) involve a significant reduction in the margin of safety, because this Schedular Exemption does not affect changes in the plant design or operation which could have an affect on safety margins.

( NHY submits that justification exists for granting the Schedular Exemption based on the information provided above and in Reference (b).

Furthermore, granting the Schedular Exemption would eliminate the need to incur costs associated with obtaining increased onsite property damage l insurance until such time as a low power license allowing criticality is issued, thus eliminating the undue financial burden placed on the Seabrook

! owners and their respective ratepayers.

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