ML091110322

Submittal of License Amendment Request

ML091110322
Person / Time
Site:	Hope Creek
Issue date:	04/14/2009
From:	Mulligan P State of NJ, Dept of Environmental Protection, Bureau of Nuclear Engineering
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
H08-06
Download: ML091110322 (2)

Text

State of Nefv jrrer DEPARTMENT OF ENVIRONMENTAL PROTECTION JON S. CORZINE MARK.N. MAURIELLO Governor Division of Environmental Safety and Health. Acting Commissioner 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 April 14, 2009 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Gentlemen:.

Subject:

Hope Creek Generating Station (HCGS), Docket No. 50-354 License Amendment Request.(LAR) H08,06, PSEG Nuclear LLC (PSEG) -submitted the subject amendment request to the Nuclear Regulatory Commission(NRC) on. January 5, 20091 The proposed amendment would delete the Technical Specification (TS) requirements for operational condition change limitations in TS 3.0.4 and 4.0.4, using the NRC's Consolidated Line. Itemnimprovement Process (CLIIP). The proposed changes would allow entry in an operating condition or other specified condition that has a specific required action and completion time after performance of an assessment that focuses on managing plant risk.

The New Jersey Department of Environmental Protection's Bureau of Nuclear Engineering (NJ BNE) reviewed the request in accordance with the requirements of 10 CFR. 50.91(b). We have the following comment.

The proposed changes to the Bases pages (Attachment 4) state on the third page that "The LCO 3.0.4.b risk assessments do not have to be documented." The position of the NJ BNE is that documentation of these risk assessments is necessary in order to provide a method for verifying that these risk assessments address all risk concerns, are performed and reviewed correctly, are approved by the proper level of plant management, and.will become a permanent record. Without documentation,. any future inquiries. as.to .a specific operational,,ondiiion,.

change that required. a risk. assessment would be severely hamlered. Therefore, we suggest that the above quoted sentence be deleted from the proposed Bases pages. . "

If you have any questions, please contact Jerry Humphreys at (609) 984-7469.

New Jersey is an Equal Opportunity Emplover , Printedon Recycled Paper and Recyclable

Sincerely, Patrick Mulligan Manager Bureau of Nuclear Engineering c: P. Bauldauf, New Jersey DEP, Assistant Director N. McNamara, NRC Region I State Liaison Officer R. Ennis, NRC Hope Creek Project Manager B. Welling, NRC Senior Resident Inspector, Hope Creek M. Gaffney, PSEG Hope Creek Regulatory Assurance C. Neely, PSEG Director - Regulatory Assurance