ML032591148

Technical Specification Change Request 314

ML032591148
Person / Time
Site:	Oyster Creek
Issue date:	09/02/2003
From:	Lipoti J State of NJ, Dept of Environmental Protection
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032591148 (2)

Text

Atate of JWeht ~Ytrsiei James E. McGreevey Department of Environmental Protection Bradley M. Campbell Governor Division of Environmental Safety and Health Commissioner Radiation Protection and Release Prevention Element Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625-0415 Tel (609) 984-7700 September 2, 2003 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Ladies and Gentlemen:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Technical Specification Change Request 314 AmerGen Energy Company submitted the subject change request to the Nuclear Regulatory Commission (NRC) on June 2, 2003. The proposed change will revise the allowed outage duration for the Oyster Creek startup transformers and diesel generators.

The current Technical Specifications specify that the reactor may remain in operation for a period not to exceed 7 days in any 30-day period if a startup transformer is out of service. A similar requirement is in place for a diesel generator out of service. AmerGen proposes to delete the "in any 30 day period" statement and keep a 7 day allowed outage time for a startup transformer and a diesel generator. AmerGen concedes this is will be a less restrictive requirement if approved. In addition, the NRC Standard Technical Specification for BWR 4 plants, NJREG 1433, Revision 2, has a more restrictive 3-day allowed outage time.

The New Jersey Department of Environmental Protection's Bureau of Nuclear Engineering reviewed the request in accordance with the requirements of 10 CFR 50.91(b) and has the following comments.

Clearly, the operability of startup transformers and diesel generators has taken on an increased importance with the numerous offsite power issues and power supply events that occurred in 2003, e.g. the cable failure at Oyster Creek in May, the ground fault at Salem in July, the August 3 electrical fault at Indian Point Unit 2, and the August 14 blackout.'A relaxation of allowed outage times for diesel generators and startup transformers is ill-advised.' It would be more appropriate for the NRC to utilize its probabilistic risk assessment (PRA) techniques to re-examine loss of offsite power and to establish allowed outage times for diesel generators and New Jersey is an Equal Opportunity Employer Recycled Paper

startup transformers based on industry experience and existing infrastructure issues. The nuclear industry and the NRC are quick to delete or reduce requirements based on PRA, this is one time that safety requirements may need to be strengthened based on PRA.

A U.S. and Canadian Joint Power System Outage Task Force Nuclear Working Group has been assembled and will be preparing two reports. Phase I will provide detailed information about the cause of the August 14 outage. Phase II will make recommendations about how nuclear power plants should be configured to contribute to grid stability. It would not be prudent to proceed with any change to onsite or offsite electrical power technical specifications for Oyster Creek until this effort is completed.

In addition, prior to approving any relaxation of a technical specification requirement, the basis for the change should be fully explained and added to the bases section of the technical specification.

If you have any questions, please contact Rich Pinney at (609) 984-7558.

Sincerely, Jill Lipoti, Ph. D.

Assistant Director Distribution:

Kent Tosch N.J. DEP Dennis Zannoni N.J. DEP R. Bores, Ph. D.

NRC Region I State Liaison Officer P. Tam NRC Project Manager J. Hufnagel AmerGen