ML20207E632
| ML20207E632 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/18/1986 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-055, CON-#386-55 OL, NUDOCS 8607220388 | |
| Download: ML20207E632 (6) | |
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FILED: July 18, 1986 US UNITED STATES OF AMERICA N
NUCLEAR REGULATORY COMMISSION gI PI:iy BEFORE THE ATOMIC SAFETY AND LICENSING BOARkhC[g,Sgeg 7ARY G
E BRA % rtytcj in the matter of:
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL DOCKET NOS. 50-444 OL ~ ~ ~
50-443 OL (Seabrook Station, Unit 1)
ON-SITE ISSUES SEACOAST ANTI-POLLUTION LEAGUE'S FIFTH SUPPLEMENTAL PErlFION FOR LEAVE TO INTERVENE The Seacoast Anti-Pollution League hereby submits the fdtowing contention regarding Draft License No. NPF-56 for Seabrook Station, Unit 1 pursuant to 0 2.714(a)(3).
The Draft License is attached to the letter of June 20, 1986 to Mr. Robert J. Harrison of Public Service Company of New Hampshire from Thomas M. Novak, Acting Director, Division of PWR Licensing-A, Office of Nuclear Reactor Regulation.
SAPL addresses below the five-part test at 10 CFR I 2.714(a)(1):
A.
Good cause, if any, for failure to file on time t
SAPL was not in possession of, and could not have anticipated the contents of the Draft License referenced above nor the Technical Specifications (which are Appendix A to the Draft License). SAPL received both of these documents in the 4th week of June,1986. SAPL is filing its contentions on these documents in a timely manner.
B.
Availability of other means to protect petitioner's interest SAPL has no other means to protect its interests other than to litigate the deficiencies in the Draft License. The applicants are intending to begin operation of the plant at low power and SAPL does not believe the Draft License and its Appendix A support the conclusion that that proposed action will not be inimical to the health and safety of the public as required at 10 CFR 650.40. SAPL has not yet been served j
8607220388 860718 PDR ADOCK 05000443 O
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a copy of Appendix B, the Environmental Protection Plan, and reserves its right to protect its interests further by litigating the contents of that document when obtained.
C.
Extent to which petitioner can contribute to development of a sound record SAPL is making an effort to find an expert witness on the subject matter of the contention below.
D.
The extent to which other parties will repcesent petitioner's interest No other party to this proceeding has filed a contention on the Draft License and SAPL therefore has no reason to assume that any other party will represent its interests in this matter.
E.
Broadening and delay of proceeding SAPL notes that a hearing on the issue of an operating license has been requested by Hampton, Massachusetts Attorney General, NECNP, and SAPL and was anticipated by this Board's Order of November 4,1985. Litigation of the attached contention may somewhat increase the length of the hearing, but should not do so unduly. Length of the hearing will be directly affected by the extent to which the Technical Specification omissions are remedied.
I SAPL Contention No. 32 l
The Draft License for Seabrook Station, Unit No.1, No. NPF-56 fails to meet the standards for licenses at 10 CFR 0 50.40 and 10 CFR Q 50.36(c)(1), (c)(2), (c)(3) and (c)(4) because the Technical Specifications, which are Appendix A to the Draft License, are incomplete.
Basis:
The Commission's regulations require that the Technical Specifications for nuclear reactors include safety limits, limiting safety system settings, limiting conditions fer operation, surveillance requirements and design features. l o
Safety limits "are limits upon important process variables which are found to be necessary to reasonably protect the integrity of certain of the physical barriers which guard against the uncontrolled release of radioactivity" 10 CFR I 50.36(c)(1Xi)(A).
Limiting safety system settings "are settings for automatic protective devices related to those variables having significant safety functions." 10 CFR I 50.36(c)(1Xii)(A).
Limiting conditions for operation "are the lowest. functional capability or performance levels of equipment required for safe operation of the facility." 10 CFR 6 50.36(c)(2).
Surveillance requirements "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and comonents is maintained, that facility operation will be within the safety limits, and that the limiting conditions of operation will be met."
10 CFR I 50.36(c)(3).
Design features "are those features of the facility... which, if altered or modified, would have a significant effect on safety..." 10 CFR I 50.36(c)(4)
The Seabrook Station Unit 1 Technical Specifications are incomplete because the following portions have not been provided in violation of the requirements set forth above.
i Technical Specifications Incompletions Figure 2.1-1 Reactor Core Safey Limit - Four Loops in Operation Figure 3.1-1 Road Bank Insertion Limits Versus Thermal Power Four-Loop Operation Figure 3.2-1 Axial Flux Difference Limits As A Function of Rated Thermal Power l
Figure 3.2-2 K(z) - Normalized FQ(z) As A Function of Core Height Figure 3.4-1 Dose Equivalent I-131 Reactor Coolant Specific Activity Limit Versus Percent of Rated Thermal Power With the Reactor Coolant Specific Activity > 1 u, Ci/ gram Dose Equivalent I-131 Figure 3.4-2 Reactor Coolant System Heatup Limitations - Applicable Up To 16 EFPY l
Figure 3.4-3 Reactor Coolant System Cooldown Limitations - Applicable Up To 16 EFPY l 1
Figure 3.4-4 RCS Cold Overpressure Protection Setpoints Figure B 3/4. 4-1 Fast Neutron Fluence (F>1 Mev) as A Function of Full Power Service Life Figure B 3/4 4.4-2 Effect of Fluence and Copper Content On Shift of RT for Reactor Vessels Exposed to 550' F.
Figure 5.1-1 Exclusion Area Figure 5.1-2 Low Population Zone Figure 5.1-3 Site Boundary for Liquid and Gaseous Effluents Figure 6.2-1 Offsite Organization Figure 6.2-2 Station Organization Other sections of the Technical Specifications are, in certain instances, rendered meaningless due to the absence of the above-cited material.
For example at 2.1-1 under Safety Limits Reactor Core, the following appears:
The combination of THERMAL POWER, pressurizer pressure, and the highest operating loop coolant temperature (Tavg) shall not exceed the limits shown in Figure 2.1-1 for four-loop operation.
Since there is no Figure 2.1-1, there is no indication of what this safety limit really means.
As another example, under Reactivity Control Systems Movable Control Assemblies Control Rod Insertion Limits, the Limiting Condition For Operation states at 3.1.3.6, i
"The control banks shall be limited in physical insertion as shown in Figure 3.1-1."
Since there is no Figure 3.1-1, this statement is also meaningless.
SAPL believes that the incompleteness of the Technical Specifications makes impossible a finding that the health and safety of the public will not be endangered, 4
a common standard the Commission must be guided by in determining that a license will e
se e
i
be issued to an applicant.10 CFR 6 50.40.
Therefore, SAPL holds that the draft license ought not issue.
Respectfully submitted, SEACOAST ANTI-POLLUTION LEAGUE By its Attorney Rotfert A. Backuse ~4A-
/
BACKUS, MEYER & SOLOMON 116 Lowell Street P. O. Box 516 Manchester, NH 03105 (603) 668-7272 I hereby certify that copies of the foregoing have been sent to all persons on the attached service list, by first class postage prepaid mail.
Rob K A'.4FIFek C ~
.-._.. - -- _. -,,._=.
CERTIFICATE OF SERVICE AND SERVICE LIST Joseph Flynn, Asst.Gn.Cnsl.
Sheldon J. Wolfe, Chrm.
Thomas Dignan, Esq.
Fed. Emerg. Mgmt. Agcy.
Admn. Judge Ropes & Gray 500 C.St. So. West Atomic Safety & Lic Brd.
225 Franklin St.
Washington, DC 20472 USNRC Boston, MA 02110 Washington, DC 20555 Office of Selectmen Dr. Jerry Harbour ~
Docketing & Serv. Sec.
Town of Hampton Falls Admin. Judge Office of the Secretary Hampton Falls, NH 03844 Atomic Safety & Lic Brd.
USNRC USNRC Washington, DC 20555 Washington, DC 20555 9'
Dr. Emmeth A. Luebke Jane Doughty Office of Exec. Legl. Dr.
Admin Judge SAPL USNRC Atomic Safety & Lic. Brd.
5 Market Street Wahsington, DC 205..
USNRC Portsmouth, NH 03801 Washington, DC 20555 Phillip Ahrens, Esq.
Paul McEachern, Esq.
George Dana Bisbee, Esq.
Asst. Atty. General Matthew Brock, Esq.
Attorney General's OFF.
State House, Sta. #6 25 Maplewood Ave.
State of New Hampshire Augusta, ME 04333 P.O. Box 360 Concord, NH 03301 Portsnouth, MI 03801 Carol Sneider, Esq., Asst.AG Diane Curran, Esq.
William S. Lord One Ashburton Place, Harmon, Weiss Board of Selectmen 19th Floor 20001 S Street NW Suite 430 Town Hall-Friend St.
Boston, MA 02108 Washington, DC 20009
/mesbury, MA 01913 Richard A. Hampe, Esq.
Maynard Young, Chairman Sandra Gauvutis New Hampshire Civil Defense Board of Selectmen Town of Kingston Agency 10 Central Road Box 1154 Hanpe & McNicholas Rye, MI 03870 East Kensington, MI 03827 35 Pleasant St.
Concord, MI 03301 Edward Thomas Mr. Robert Harrison HNA Pres, & Chief Exec. Officer 442 J.W. McComack (POGI)
PSCO Boston, MA 02109 P.O. Box 330 Manchester, NI 03105
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Roberta Pevear State Rep.-Town of Haupt Falls Drinkwater Road Hanpton Falls, MI 03844 l
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