ML20196F153

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Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations
ML20196F153
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 06/22/1988
From: Tefft J
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-01316, 53FR16435-1316, NUDOCS 8807050075
Download: ML20196F153 (1)


Text

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June 22, 1988 16 Folsom St.

Exeter, NH 03833 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

Subject:

Comments on Proposed Rule, "Emirgency Planning and Preparedness Requirements for Nuclear Power Plant Fuel Loading and Initial Low-Power Operations".

(53FR16435)

Dear Sir,

I fully support the promulgation of the proposed subject rule.

The fission product inventory resulting from low power operation for a relatively short duration is very small compared to the fission product inventory in a core that has run at full power for three fuel cycles for which plants are designed.

The small source term and low decay heat potential when compared to the water inventory, system and component full power design capability result in the conclusion that a prompt, significant off-site release of radioactivity is virtually impossible.

If it is physically possible at all it would take many hours or days for a significant off-site release to develop.

Therefore, there is no technical justification to require a prompt notification system to be in place for low power operation.

Sincerely, s#

John G. Tefft 880705007G 080622 PDR PR 50 53FR16435 PDR O S-/o

.