ML031010479
| ML031010479 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/04/2003 |
| From: | Tosch K State of NJ, Dept of Environmental Protection, Bureau of Nuclear Engineering |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML031010479 (2) | |
Text
,$ftd of >viu &ersv James E. McGreevey Department of Environmental Protection Bradley M Campbell Governor Commissioner Division of Environmental Safety, Health and Analytical Programs Radiation Protection Programs Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625-0415 Tel (609) 984-7700 Fax (609) 984-7513 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 April 4, 2003
Subject:
PSEG Nuclear LLC License Change Request H02-01: Relaxation of Secondary Containment Operability Requirements and Elimination of Filtration, Recirculation, Ventilation System Charcoal Filters.
Dear Sir:
The New Jersey Bureau of Nuclear Engineering has completed its review of PSEG Nuclear LLC License Change Request H02-01 dated June 28, 2002. The request seeks to revise the definition of core alteration, relax the secondary containment operability requirements, and revise the LOCA dose calculation in light of the Alternate Source Term (AST). This change, as stated by PSEG Nuclear LLC, reduces refueling outage time. AST provides the means for the change, according to PSEG Nuclear LLC.
According to our review, the central issue involves the trade-off between saving time during outages and potentially releasing more iodine than would have been released if the FRVS charcoal filters were operating. Assuming that the new alternate source term properly describes the latest accident behavior in reactor accidents, we still question eliminating a part of a system that removed 99.9% of the iodine generated post accident and replacing it with one that releases 4.85% of the iodine.
The other significant change is the opening of the secondary containment so refueling outage time is reduced. Allowing the equipment hatch to remain open will certainly reduce outage time; however, the trade-off is a direct release pathway that bypasses containment if a fuel-handling accident occurs.
The loss of secondary containment and the potential reduction of filtration would reduce the mitigation of the spent fuel pool Design Basis Accident. This change increases the New Jersey is an Equal Opporruniry Employer Recycled Paper
risk of an unmonitored, unfiltered release to the environment. Certainly the safety margin has been reduced. It seems imprudent to have an open pathway with reduced filtration and based on AST. If there were a fueling handling accident under this analysis, could PSEG physically secure containment and protect the health and safety of the public?
In light of the terrorists attacks of September 11, 2001, it would be best to wait until the NRC analysis on containment operability is released before approving this request.
Therefore, the NJ Department of Environmental Protection requests that the FRVS charcoal filters remain operational when required and that PSEG conduct a full risk analysis for securing the equipment hatch during a fuel-handling accident. If you wish to discuss this further, please contact Dennis Zannoni or me at (609) 984-7700.
Sincerely, Kent Tosch, Manager NJ DEP Bureau of Nuclear Engineering C:
George Wunder, NRC Gabe Salamon, PSEG Nuclear LLC Robert Bores, NRC Jill Lipoti, NJDEP Dennis Zannoni, NJDEP