ML20214P955

Forwards Comments on Draft Low Power License,Per 860820 Request.Page 3,Item 2.B(4),re Limiting Fuel Movement to Only Two Assemblies,Should Be Deleted as Licensing Condition for OL

ML20214P955
Person / Time
Site:	Seabrook
Issue date:	09/19/1986
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Novak T Office of Nuclear Reactor Regulation
References
SBN-1200, NUDOCS 8609240114
Download: ML20214P955 (7)

Text

,

SEABROOK STATION 4.

Engineering Offica

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'J September 19, 1986 g

gg NEW HAMPSHIRE YANKEE DIVISION SBN-1200 T.F.

B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Mr. Thomas M. Novak, Acting Director Division of PWR Licensing-A

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated August 20,1986, "Draf t License for Seabrook Station, Unit 1", T. M. Novak to R. J. Harrison Subj ect :

Comments to Draf t License for Seabrook Station, Unit 1

Dear Sir:

In Reference (b), you transmitted a revised Draft Low Power License, No.

NPF-56, for Seabrook Station, Unit I and requested written comments to that enclosure. Therefore, enclosed please find our comments to the Draft Low Power License.

Very truly o /s, ohn DeVincentis Director of Engineering Enclosures cc:

Atomic Safety and Licensing Board Service List 8609240114 860919 DR ADOCK 05000443 QCP{

PDR J )

Seabrook Station Construction Field Office. P.O. Box 700. Seabrook, NH 03874

-Otane Curran, Esquire Peter J. Mitnews, Mayor Hargon 6 U21oa City Hall 2001 S. Street, N.W.

Navburyport, MA 01950 Suite 430 Wa shington, 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. Herrill, Esquire Philip Ahrens, Esquire Attorney General Assistant Attorney General George Dana Bisbee, Esquire Department of The Attorney General Assistant Attorney General 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 Kenosington, 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 Boston, MA 02108 Newbury, MA 01950 Senator Gordon J. Humphrey Mr. William S. Lord U.S. Senate Board of Selectmen Washington, DC 20510 Town Hall - Friend Street (ATTN:

Tom Burack)

Amesbury, MA 01913 Richard A. Hampe, Eng.

Senator Gordon J. Humphrey I

Hampe and McNicholas 1 Pillsbury Street 35 Pleasant Street Concord, NH 03301 Concord, NH 03301 (ATTN: Herb Boynton)

I Thomas F. Powers, III H. Joseph Flynn, Esauire Town Manager Office of General Counsel l

Town of Exeter Federal Emergency Management Agency 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 & Ells Portsmouth, NH 03801 47 Winnacunnet Ro'ad Hampton, NH 03842 Robert Carrigg Town Office Mr. Ed Thomas Atlantic Avenue FEMA Region I North Hampton, NH 03362 442 John W. McCormack PO & Courthouse Boston, MA 02109

e Administrative Judge Helen Hoyt, Chairperson Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 a

Administrative Judge Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Emmeth 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 i

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o ENCLOSURE TO SBN-1200 COMMENTS TO REVISED DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 2

2.B.(1)

Should read, "The Licensees acting through Public Service Company of New Hampshire (PSNH) pursuant to..."

3 2.B.(3)

Should read, "The Licensees acting through PSNH, pursuant to..."

3 2.B.(4)

As discussed below, we believe that this para-raph should be deleted as a licensing condition for the operating license.

This licensing condition is apparently an incorporation of a Seabrook Station SNM licensing condition with some slight modifi-ation.

Limiting the movement of f uel to only two assemblies in the case of the SNM license did not cause any burden regarding movement of fuel from the shipping containers to the storage location.

However, in the case of the operating license a similar licensing condition would be burdensome to the initial fuel loading and subsequent loads of the reactor.

Limiting the number of assemblies out of approved shipping, approved storage racks, and the reactor vessel to a specified quantity, will restrict the fuel handling operations as described in FSAR Section 9.1 in particular 9.1.4.

This restriction would result in longer outages and the attendant increase in exposure to station 4

personnel. Given that there is no criticality concerns associated with these fuel handling operations (see generally FSAR Section 9.1.4) we do not believe that limiting the number of assemblies "out of approved storage locations" should be conditioned in the license.

4 3

2.B.(6)

Revise to read "No loaded shipping container shall be outside for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from j

time of receipt onsite or before shipment 1

offsite".

l l

ENCLOSURE TO SBN-1200 (Continued)

COMMENTS TO REVISED DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 3

2.B.(7)a The 3.55 w% U.235 enrichment requirement is specified in FS AR Section 9.1.2.3; therefore, specifying the maximum U-235 enrichment is redundant.

Accordingly, since any change to the 3.55 w% U-235 enrichment would trigger a 50.59 review, we believe this paragraph should be deleted.

3 2.B.(7)b The numbering of fuel assemblies is desig-nated in the FSAR Section 9.1.1.1 which is referred to in paragraph 2.B.(3); therefore, specifying number of assemblies is redundant.

Also this is similar to p'aragraph in SNH license except there the number of assen-blies allowed was less than 90 assemblies.

i Since the number assemblies to be stored is already provided in the FSAR and since any changes to maximum quantity stored would trigger a 50.59 review, we believe this paragraph should be deleted.

3 2.B.(7)c This paragraph was specifically pro-vided in the SNM license to assure spacing i

between the storage of 12 assemblies in the new fuel storage racks.

Since we are qualified to use the maximum capacity of the racks (90 assemblies), this provision j

has no application to the operating license.

3 2.B.(7)d This was committed to by the Applicant under the SNM license to provide additional assurance of the checkerboard storage of fuel assemblies.

Given the context this commitment was made, we do not believe it necessary to similarily condition the operating license.

3 2.B.(8)

This paragraph should be included in Section 2.D.

As provided in Section 1.D all exemp-tions from compliance are to be provided in Section 2.D.

Should be revised to read "The Licensees are exempted from..."

Paragraph also should be revised to clarify that exemption does not pertain to fuel in the reactor.

) 1

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~ -

w ENCLOSURE TO SBN-1200 (Continued)

COMMENTS TO REVISED DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 3

2.B.(9)

Should read, "The Licensees acting through PSNH, pursuant to..."

4 2.B.(10)

Should read, "The Licensees acting through PSNH, purs uant to..."

4 2.B.(11)

Should read, "The Licensees acting through PSNH, pursuant to..."

4 2.C.(1)

Should read, "The Licensees acting through Public Service Company of New Hampshire are authorized to..."

4 2.C.(2)

Second sentence should read, "The Licensees acting through PSNH shall operate..."

4 2.C.(3)

Should read, "The Licensees acting through PSNH shall..."

5 2.C.(9)

The second paragraph regarding qualified isolation devices should be deleted. The qualification of the existing isolation devices was provided in SBN-1185.

6 2.D Should read, "The Licensees are exempted f rom..."

Add the following to the end of the second paragraph..." Based on the foregoing the Licensees are exempted f rom those portions of General Design Criteria 4 of Appendix A to 10CFR50 as described above".

6 2.E Should read, "The Licensees shall f ully imple-ment and maintain..."

7 2.F Fi rs t paragraph should be revised to read "The Licensees shall implement and maintain..."

i Second paragraph should be revised to read "The Licensees may make changes..."

o.

ENCLOSURE TO SBN-1200

( Continued)

COMMENTS TO REVISED DRAFT LICENSE NO. NPF-56 PAGE ITEM COMMENT 7

2.G Should read, "Except as otherwise provided in the Technical Specifications or Environmental Protection Plan, the Licensees shall..."

6 2.I The license should have an indication as to the ef fective date and expiration date.

If in the event the NRC does, pursuant to the Applicant's Motion of August 22,1986, i ssue a 0% power license, we request that the license expiration be revised to read as follows:

l

"...and shall expire 40 years af ter the issu-ance of a license allowing the reactor to become critical".

Appendix B W'e do not believe it necessary to notify the Section 3.2 NRC individually of each proposed change to the NPDES permit since all approved changes to the NPDES shall be reported to the NRC and because the NRC will rely on the U.S.

E.P. A. and the NPDES permit for regula-tion of matters involving water quality and aquatic biota.

Accordingly the first sentence of the second paragraph (The licensee shall notif y...) should be deleted.

If the NRC will not accede to this request then we would request that this paragraph be rewritten to read as follows:

The licensee shall provide the NRC with a copy (e.g., cc of the transmitting letter) of the following at the same time it is being submitted to the permitting agency.

o proposed changes to the effective NPDES Pe rmi t.

o the application for renewel of the NPDES Pe rmi t. _

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