ML051390231
| ML051390231 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/25/2005 |
| From: | Tosch K State of NJ, Dept of Environmental Protection |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML051390231 (3) | |
Text
Richard J. Codey Acting Governor
,$tate of Ariu JTrsrg Department of Environmental Protection Division of Environmental Safety and Health Radiation Protection and Release Prevention Element Bureau of Nuclear Engineering PO Box 415 Trenton, New Jersey 08625-0415 Phone: (609) 984-7700 Fax: (609) 984-7513 Bradley M. Campbell Commissioner April 25,2005 U.S. Nuclear Reguiatory Commission Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:
Subject:
Hope Creek Generating Station Docket No. 50-354
.,...License Change Request H-04-06,,.
PSWENi' Nuclear LC. (1
- 9) submitted the subject Change reque§st tothe Nucler Regulatory.
Commission (NRC) on October 1,2004.' The propsed changes would eliminatecertai..
Technical Specifications' and associated Surveillance Requirements pertaining to the Primary' Containment Hydrogen Recombiners and the Primary Containment.Hydrogen/Oxygen Concentration Analyzers and Monitor Channels..'
The New Jersey Department of Environmental Protection's Bureau of Nuclear Engineering (BNE) reviewed the request in accordance with the requiremnrits of 10 CFR'50.91(b). We have
-the-following conmments.
As part of the request to delete the applicable Technical Specificationis, PSEG Nuclear, LLC (PSEG) has made regulatory commitments to maintain both'a Primary Containment Hydrogen Monitoring System capable of diagnosing beyond design basis accidents and an Oxygen Monitoring System capable of verifying s
f the inert Primary.Containment...
These commitnients are in accordance with the~following sections of thq! Notice of Ayailability ofTMhdhi Applieaiin Co;;cerningTchhidcl. Specification Improvemnfit To.Eliminate, Hydrogen Reco;ibindr Requiieffidn, and Relia the Hydrogen and Oxygen Monitor ReqJuirements for Light Water Reactors Using the Consolidated Line Item Improvement Process" as described in the September 25, 2003 Federal Registe.r.(6,8FR..5$4l6):,1) Applicability; 2) Model Safety f" -
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-7 Evaluation (SE), Section 3.2, Hydrogen Monitoring Equipment; and 3) Model Safety Evaluation (SE), Section 3.3, Oxygen Monitoring Equipment PSEG has made no commitment to retain any requirements pertaining to the Primary Containment Hydrogen Recombiners although Model SE Section 3.1, Hydrogen Recombiners states that "requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TS and may be relocated to other licensee-controlled documents for all plants."
The BNE recommends that the NRC require PSEG to make a commitment to relocate the TS requirements for maintaining the Primary Containment Hydrogen Recombiners to other licensee-controlled documents as PSEG has done for the Primary Containment Hydrogen and Oxygen Monitoring Equipment. By making such a commitment, PSEG would then be in compliance with the NRC staffs Model SE position. In addition, this commitment would satisfy Section 9 (Fr-ceadei-f LCR7-HO4-06w h
ei-ha"PSEG -is-nostpr6pbing variations or deviationss~
from the TS changes described in Revision 1 to TSTF-447 or the NRC staffs model SE published on September 25,2003 (68 FR 55416)."
Although the above referenced Applicability section states the licensee need not provide details about the designs or procedures.when making the regulatory commitments, the BNE considers the program details that will be utilized by P$EG to ensure the operability and functionality of the Oxygen/Hydrogen Monitoring Equipment and the Hydrogen Recombiners to be essential in providing the confidence that this equipment will be available to analyze and mitigate the consequences of an accident in order to protect the health and safety of the public. Therefore, the BNE requests that these details be provided by PSEG for review prior to the NRC approving the proposed TS changes.
If you have any questions, please contact Jerry Humphreys at (609) 984-7469.
Sincerely Kent Tosch Manager Distribution:
J. Lipoti, Ph. D.
R. Bores, Ph. D.
NRC Region I State Liaison Officer D. Collins NRC Project Manager C. Perino PSEG
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