ML20196C933
| ML20196C933 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/22/1988 |
| From: | Moody J AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR16435, RULE-PR-50 53FR16435-00917, 53FR16435-917, NUDOCS 8807010269 | |
| Download: ML20196C933 (2) | |
Text
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DOCKET NUMBER y)
PROPOSED RULE uLSO hBFOW3gf
- cu irr, um June 22,1988 +88 M 23 P1 :53 Secretary of the Commission OFFICE e g,
Attention:
Docketing and Service Branch 00CXE im.i >,.r m:.;
0 United States Nuclear Regulatory Commission Washington, DC 20555 Proposed Rule 53FR16435 re:
Emergency Planning and Preparedness Requirements for Nuclear Power Plant Fuel Loading and Initial Low Power Operations Gentlemen:
This communication is in support of your proposed rule that would eliminate the requirement for proept notification of the surrounding populace as a condition for fuel load or initial low power operations at commercial nuclear generating stations.
Further, the proposed rule would make it clear that, for fuel load or initial low power operations, it is not necessary for a plant to have the same full-scale public notification system in place that is required for full power operation because:
o The NRC has determined that the risk to public health and safety from low power operation at any nuclear power plant is significantly lower than at f ul l-powe r.
o The time avai-for taking any emergency action would be much longer (at le, 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) than if the plant was in full-power operation.
Safety systems in nuclear plants are designed to handle 100% power o
emergenclea. During low power testing, the plant never exceeds 5% power and testing takes only a matter of days.
At Seabrook Station, the risk is even lower than for other sites.
New Hampshire Yankee (NHY) studies show that:
In the unlikely event that all safety systems fail, it would take o
longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to cause serious damage to the plant.
o The strength of Seabrook's containment structure is so great that, l
even without any saf ety systems, the containment would not f ail during any event at or following lowpower operation.
269 000622 g701 png 50 53FR16435 Osa
.-o Unit d Sectes Nuclear Rsgu1& tory Commission Paga 2 Attention: Docketing and Service Branch In addition to these points, there are several others that can be made about Seabrook:
1) hHY has a fully operational siren notification system in place in New Hampshire, and has submitted to the NRC a detailed explanation of how they will compensate for the deliberate dismantlement of an operabli siren system in Massachusetts.
2)
The Emergency Broadcast System (EBS), used to provide information to both New Hampshire and Massachusetts communities, is in place and provides 24-hour-a-day coverage, backed by emergency power.
3)
The proposed rule would not lessen the ef fectiveness of emergency preparedness around Seabrook, or any other nuclear power plant.
It merely clarifies the NRC's original intention regarding public notification requirements that must be met prior to low power testing.
The proposed rule will clear up any confusion over the public notification system requirements for low power testing.
I support any effort to reduce misunderstanding. New England needs the power Seabrook will provide.
Seabrook is complete, fueled and safe.
It's tinae to say "yes" to the proposed rule, and "yes" to the opening of Seabrook.
Sincerely,
/
W J. H. Moody
/
897 Washington Road Rye, NH 03870 05-/0