ML20211K694
| ML20211K694 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/25/1986 |
| From: | Derrickson W PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SBN-1142, NUDOCS 8606300221 | |
| Download: ML20211K694 (7) | |
Text
i WiUiam B. Derricksen June 25, 1986 Seni r Vice President Nuclear i:nergy SBN-1142 T.F.
B7.1.7 g.ggg New Hampshire Yankee Division United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) PSNH Letter dated March 30, 1973, W. C. Tallman to AEC, Director, Directorate of Licensing Subj ect :
Full 40 Year Term Operating License
Dear Sir:
As you are aware, we soon expect to receive an operating license on or about June 30, 1986.
In preparation of issuance of the license, members of your Staff requested further information/ clarification of our original operating license request for the subject license term of 40 years, which was filed with the NRC's predecessor agency via Reference (b).
Enclosed, we have provided further supportive arguments for author-izing Seabrook Station an operating license for a full 40 year term, commencing on the date of license issuance. We firmly believe, that based on the NRC's already established precedent of issuing full 40 year term licenses, and that Seabrook Station's design, construction and licensing was based on an operating license term of 40 years, the NRC is obligated to issue Seabrook Station the full 40 year term operating license.
It is believed that not only will this request maintain consistency with NRC's practices, but that it will also be in the best interest of the public, by allowing the maximum economic benefits of operating the Station. Therefore, we request that the Seabrook Station be granted its operating license for the full 40 year term, commencing on the date of its issuance.
Very truly yours, William B. Derrickson Enclosure cc: Atomic Safety and Licensing Board Service List 8606300221 860625
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PDR ADOCK 05000443 i
3 A
PDR P.O. Box 300
- Seabrook,NHO3874 Telephone (603)474-9521
United States Nuclear Regulatory Commission Attention:
Mr. Harold R. Denton Page 2 STATE OF NEW HAMPSHIRE Rockingham, ss.
June 25, 1986 Then personally appeared before me, the above-named William B.
Derrickson who, being duly sworn, did state that he is Senior Vice President of Public Service Company of New Hampshire, that he is duly authorized to execute and file the foregoing information in the name and on the behalf of Public Service Company of New Hampshire, and that the statements therein are true to the best of his knowledge and belief.
3 9.o( b b Neoni 4
Beverly E. Sit $oway, Notary P blic.,
My Commission Expires: March 671990 a
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Dicna Currsn, E: quire Pater J. Mathaws, Mayor H2rson & Weico City Hall 2001 S. Street, N.W.
Newburyport, MA 01950 Suite 430 Washington, D.C.
20009 Judith H. Mizner Silvergate, Gertner, Baker, Sherwin E. Turk, Esq.
Fine, Good & Mizner Office of the Executive Legal Director 88 Broad Street U.S. Nuclear Regulatory Commission Boston, MA 02110 Tenth Floor Washington, DC 20555 Calvin A. Canney City Manager Robert A. Backus, Esquire City Hall 116 Lowell Street 126 Daniel Street P.O. Box 516 Portsmouth, NH 03801 Manchester, NH 03105 Stephen E. Merrill, Esquire Philip Ahrens, Esquire Attorney General Assistant Attorney General George Dana Bisbee, Esquire Department of The Attorney General Assistant Attorney General l
Statehouse Station #6 Office of the Attorney General Augusta, ME 04333 25 Capitol Street Concord, NH 03301-6397 Mrs. Sandra Gavutis Chairman, Board of Selectmen Mr. J. P. Nadeau RFD 1 - Box 1154 Selectmen's Office i
Kennsington, NH 03827 10 Central Road Rye, NH 03870 Carol S. Sneider, Esquire Assistant Attorney General Mr. Angie Machiros Department of the Attorney General Chairman of the Board of Selectmen One Ashburton Place, 19th Floor Town of Newbury i
Boston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Mr. William S. Lord U.S. Senate Board of Selectmen i
Washington, DC 20510 Town Hall - Friend Street (ATTN: Tom Burack)
Amesbury, MA 01913 Richard A. Hampe, Esq.
Senator Gordon J. Humphrey l
Hampe and McNicholas 1 Pillsbury Street 1
35 Pleasant Street Concord, NH 03301 Concord, NH 03301 (ATTN: Herb Boynton)
J Thomas F. Powers, III H. Joseph Flynn, Esquire l
Town Manager Office of General Counsel Town of Exeter Federal Emergency Management Agency l
10 Front Street 500 C Street, SW Exeter, NH 03833 Washington, DC 20472 Brentwood Board of Selectmen Paul McEachern, Esquire RFD Dalton Road Matthew T. Brock, Esquire Brentwood, NH 03833 Shaines & McEachern 25 Maplewood Avenue Gary W. Holmes, Esq.
P.O. Box 360 Holmes & Elis Portsmouth, NH 03801
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47 Winnacunnet Road Hampton, NH 03842 Robert Carrigg i
Town Office l
Mr. Ed Thomas Atlantic Avenue l
FEMA Region I North Hampton, NH 03862 442 John W. McCormack PO & Courthouse l
Boston, MA 02109 i
Administrative Judge Helen Hoyt, Chairperson Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Consission Washington, D.C. 20555 Administrative Judge Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel l
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Eameth A. Luebke Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 j
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ENCLOSURE TO SBN-1142 I.
STATUTORY AND REGULATORY CONSIDERATIONS Section 103(c) of the Atomic Energy Act of 1954 authorizes the Nuclear Regulatory Commission to issue commercial reactor operating licenses for a "specified period...but not exceeding 40 years".
It is presumed that Congress intended to provide 40 year operating licenses so that public utility companies would not be discouraged f rom undertaking the costly construction of nuclear power plants.
The fact that new plants are more complex and expensive, and take longer to build and license than was envisioned in 1954, underscores the need for allowing a utility and the public it serves the full economic benefit of a 40 year license term originally intended by Congress.
The NRC regulations (10CFR50.51) which implement Section 103(c) carry forth the intent of the statute by prescribing procedures which ensure a full term of 40 years to an applicant who meets the necessary safety and environmental requirements of the Commission.
In particular, 10CFR50.51 entitled " Duration of License", provides:
"Each license will be issued for a fixed period of time to be specified in the license but in no case to exceed 40 years from the date of issuance. Where the operation of a facility is involved the Commission will issue the license for the term requested by the applicant or for the estimated useful life of the facility if the Commission determines that the estimated useful life is less than the term requested...".
The regulation clearly requires the NRC to grant PSNH et al's req ue s t for 40 year operating license, unless the useful life of Seabrook Station is determined to be something less.
In addition, Section 50.51 states that tha 40 year license term should commence "from the date of issuance", not from a date prior to the issuance.
The statute and the regulation do provide allowance for a full 40 year operating license term, to which the licensee is entitled.
II.
SAFETY CONSIDERATIONS The Seabrook Station and the associated structures, f acilities, utilities, and transportation services were designed to meet, with margin, the objective of having an operating license for a 40 year t e rm.
Our decision to construct Seabrook Station was made under that assumption.
ENCLOSURE TO SBN-1142
( Continued)
All aspects of the design of Seabrook Station have been chosen to be compatible with a 40 year operating lifetime objective.
For example, the corrosion allowance on piping, tanks, valves, and pump bodies, was conservatively established for 40 years of operating service and was measured in the Preservice Inspection Program to verify that the l
minimum thickness met ASME code requirements.
Additionally, the allowable stress levels in the power generation and safety equipment have been established on the basis of service conditions more severe than those expected in 40 years of routine power and transient opera-tion.
As it will be part of an operating license condition, an Inservice Inspection Program will verify the continuing adequacy of piping and components.
The reinforced concrete primary containment structure is designed to withstand all credible loadings, including severe environmental and abnormal loads throughout the full 40, year operating service life.
Internal shielding and equipment access were designed on the ALARA principle for a full 40 year operating service life.
The radwaste equipment was designed to accommodate conditions throughout the full 40 year operating life. Plant i
structures have been designed to accommodate thermal, hydrodynamic, seismic, and other cyclic loads for 40 years of operation,' plus margin. The reactor vessels and internal structures which will be subjected to high neutron influence have all been designed' to accom- ~~
r modate the ef fects of 40 years of exposure.
Our programs for seismic and environmental qualification of electrical I,
4 and mechanical equipment have used a 40 year operating life as a goal.
Test conditions and qualification envelopes are evaluated against thi s' objective.
Appraisals of life-limited equipment have resulted in sur-veillance and maintenance requirements to maintain the qualification objective throughout plant lifetime. To verify the continued opera,
bility of engineered safeguards equipment, the performance of plant systems will be routinely tested as described in the Technical SpecipI fications which will be an Appendix to an operating license for a 40' year term.
Safety margins are all established with acknowledgment of limitations imposed by a 40 year operating license term.
The combination of conservative design and extensive operations sur-veillance submits confidence that the Seabrook units can be safely operated during a 40 year operating term..
III.
ENVIRONMENTAL CONSIDERATIONS No significant adverse environmental impact associated with the operating authorization for a 40 year term exists.
The continued impact of plant operation upon ground-water surf ace water and aquatic biota is minute.
The adverse ef fects are also minute in terms of terrestial resources, visual intrusion, noise, traffic, demand on public and private facilities and services, accident risk, human health ef fects, and in the balance of the fuel cycle.
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ENCLOSURE TO SBN-1142
_(Continued)
The magnitude of these effects is not expected to vary signifi-cantly over the 40 year operating life.
In addition, non-radio-logical, environmental Technical Specifications included as an Appendix B to the license will be in effect throughout the 40 year license term.
IV.
ECONOMIC CONSIDERATIONS Continued operating and fuel costs are more than balanced by the income from the continuing production of electricity, annual employme nt, local tax payments and the secondary benefits asso-ciated with the use of electricity from the station and the money paid as wages and taxes.
Operation of Seabrook Station provides continued diversity of supply on the New England area electrical grid and provides additional reductions in generating costs over j
alternative forms of generation. The 40 year operating life also defers capital costs and environmental impacts of replacement generating capacity.
V.
SUMMARY
As identified above, there are no safety, environmental, or economic concerns which would prevent issuance of 40 year operating license to Seabrook Station.
By law, the NRC is obligated by regulation to issue 40 year licenses, and the precedent for issuance of 40 year licenses has already been firmly established. Upon consideration of the ex-tensive effort and detail which has gone into the design, construction, and licensing of the Seabrook Station, it is apparent that issuance of 40 year operating license serves the best interest of the public, the NRC and the applicant.
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