ML20248C586

Comment Opposing Several Requests for License Changes That Appeared in Fr on 980422,pp 19972-74

ML20248C586
Person / Time
Site:	Seabrook
Issue date:	05/22/1998
From:	Haberman S SEACOAST ANTI-POLLUTION LEAGUE
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR19964 63FR19964-00001, 63FR19964-1, NUDOCS 9806020193
Download: ML20248C586 (2)

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93 H I O H S T R E E T / P. O. B O X 1136 RULES & DlR. BRANCH PORTSMOUTH, NH 03802 US NRC 603-431 5089 May 22,1998 Secretary John Hoyle Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Re: North Atlantic Energy Services Corp., Docket No. 50-443, Seabrook' Station, Unit l 1, Rockingham County, New Hampshire i

Dear Secretary Hoyle,

Please accept this letter as notice of the. Seacoast Anti-Pollution League's formal opposition to several requests for license changes that appeared in the Federal Register of Wednesday, April 22,1998, Pages 19972-74.

l SAPL is particularly concerned about the April 3 amendment request asking the NRC to approve a 24-month refueling cycle for Seabrook Station, and the removal of the "during shutdown" restriction from the performance requirements of certain surveillance requirements.

Seabrook Station Unit 1 operators, North Atlantic Energy Services Corp., have recently been cited for multiple violations of NRC regulations. Most of those violations have to do with the plant management's inability or unwillingness to address degraded safety equipment issues in a timely manner. In fact, the plant's rating in the area of maintenance was downgraded in its most recent Systematic Assessment of Licensee Performance (SALP) report, and fines were considered against North Atlantic for failure to address safety systems-related problems the company was aware of as much as four years ago.

'Most recently, degraded steam generator tubes have been discovered at the Seabrock plant. As you are aware, those tubes cannot be checked except during outages, and recent studies have shown that if as few as 15 tubes fall simultaneously the loss of fluid could overwhelm the plant's safety systems.

By extending the refueling cycle a full year beyond what was determined to be appropriate when the plant first went on-line just eight years ago, operators lose the ,

ability to review the status of those tubes on a more current basis.

This also feeds into the objection SAPL has already raised concerning the dangers of performing maintenance while the plant is on-line. Plant operators will have no choice but to do more on-line maintenance if the time normally set aside for this \

maintenance, refueling outages, is extended.

All this, we feel, creates a new risk at the plant, contrary to the view of the NRC staff i

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'i as expressed in the Federal Register notice.

We are also concerned with the amendment request dated March 5,1998, calling for relocating the plant's Radiological Effluent Technical Specifications currently in the administrative controls section of the technical specifications to the Offsite Dose Calculation Manual. We believe this constitutes an "end-run" around 10CFR50.91, and the ability that regulation gives the public to intervene in decisions concerning the release of radioactive effluents, both solid and liquid, from the Seabrook Station plant.

In addition, we feel the ramifications and technical basis for the license amendment request from North Atlantic dated March 2,1998, has not been adequately investigated by NRC staff.

It is our understanding that the Westinghouse technical specifications for the testing of the Emergency Diesel Generators were not reviewed prior to the staff finding no significant impact would result from the license change being requested.

As you are aware, the diesel generators are the backbone of Seabrook's reactor safety systems in the event of a full plant blackout, an incident that has already occurred in this plant's short history. To lower the testing standards for these most important pieces of safety equipment certainly increases the risk to on- and off-site personnel in the event of an accident at the nuclear plant. ]

SAPL sees all these proposed amendments as cost-beneficial licensing actions aimed at lowering the cost of operating the Seabrook Station nuclear power plant in the face of the financial troubles currently being experienced by its primary owner, Northeast Utilities, and the New Hampshire and national moves toward electric utility deregulatiori.

However, we feel these requested license changes create new risks for the public and should be rejected as simply not feasible at a plant that is, per its management's own admission, experiencing some internal control problems.

Thank you for your consideration, and we look forward to a response to our concerns.

Sincerely, ,7 n

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< -u w teve Haberman Field Director 1

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