ML20086H566

Comments on License Amend Request 199 to License DPR-16,dtd 911004,to Extend Duration of full-power License from 041215 to 090409.Change Should Be Approved Contingent on Resolution of Listed Issues

ML20086H566
Person / Time
Site:	Oyster Creek
Issue date:	11/27/1991
From:	Tosch K NEW JERSEY, STATE OF
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9112090221
Download: ML20086H566 (3)

Text

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e r 3 State of New Jersey Department of imironmental Protection And inergy CN 402 h enton. NJ OPC40402 Scott A. Welnet Commlutoner November 27, 1991 U.S. 11uclear Regulatory Commission Attention: Document Control Desk ..

Wachington, DC 20555 Gentlement Subject Oyster Crook liuclear Gonorating Station Docket 110. 50-219 Facility Operating Licenso Amendment Request 11o.199 On October 4, 1991, GPU Nuclear Corporation, licenseo of the Oyster Crook Nuclear Gone"iting Station (OCNGS), submitted Facility Operating License AmenC, c Rsquest No.199 to extend the duration of the OCNGS Operuting License DPR-16 to forty (40) years from the dato of the full power licenso. The curront licensed term is 40 years commencing with issuance of the construction permit on December 15, 1964. Thus, the Facility Operating Licenso for OCNGS wil) expire on Docomber 15, 2004. Since the full power licenso was issued on April 9, 1969, GPUN is now requesting that the Facility Operating License be extended from December 15, 2004 to April 9, 2009 to teficct forty (40) years from the date of issuance of the full power licenso.

The New Jersey Department of Environmental Protection and Energy's Bureau of Nuclear Engineering (BNE) has reviewed the ebove amendment, published in the Federal Register dated November 1, 1991. As a result of this review, the BNE recommends that the change request be approved contingent on resolution of the following issues.

The regulation 10 CFR 50.51 and the August 16, 1982 NRC policy lotter from William J. Dirckr, Executive Dinoctor for Operations, essentially permit the Commission to issue an operating licenso for a fixed period of timo requested by the licensee but not to exceed 40 years from the date of issuance of the operating license for the facilit'/. However, they also state that if the Commission datormines the estimated useful life ic less than the term requested, the operating licence rill be issued for the estimated useful life only. BNE believes that since many significtnt safety 1 issues, specific to OCNGS, are sti.'1 open, the useful life determination requires more specific analysic and evaluation.

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6 One of the major concerns is the drywell thinning due to corrosion, which is an ongoing safety assessment activity for OCNGS. Based on the current corrosion rat < for the sandbod region, a critical region. the vessel would atta.n its minimum required thickness by 1995. Although, GPUN is planning to remove the sand from this region, there is no assurance that the corrosion vill be oliminated. In other regions, such as the upper spherical region, one current thinnest reading is approaching the minimum required thickness. Since the drywell structural integrity is based on a design pressure of 62 psig, GPUN has recently submitted a r.

amondment request, revising the peak design pressure from 62 psig to 44 psig. This design criteria revision, if approved by the NRC, will be unique to the nuclear industry. Since the drywell, and its integrity, is essential to the tafo operation of the plant, the drywell corrosion mitigation program must be a licenso requirement.

Another significant safety issue for OCNGS is the hydrogen mitigation requirements of 10 CFR 50.44. This issue, open sinco the early 1980's, arono from the accident at the Three Milo Island Unit

2. The Commission on December 24, 1980, in a special report to the Congress, identified "Ilydrogon control Measures and Effects of j

!!ydrogen Burns on Safety Equipment" as an Unresolved Safety Issue (USI A-48). Recently, the resolution of USI A-48 was published in I the Fodoral Register dated February 15, 1990. It stated that

" Ignition of hydrogen after the production of additional combustible gases from radiolysis is to be mitiqated by recombiners, purge repressurization system or combination."

HowoVer, GPUN is still treating this issue as plant specific. DNE believes that since NRC's resolution was published in the Federal Register, no exception should be allowed for any plant.

OCNGS is one of the oldest operating nuclear plants in the United States. Although it moots the minimum dmergency Core Cooling System (ECCS) dLoign criteria specified in 10 CFR 50.46, it does not have modern design features such as High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems.

Its Core Spray System sparger, an ECCS system, has a crack in the piping and operates with a clamp installed on the sparger. In 1988, BNL expressed its concerns on this issue and recommended that the structural integrity of this sparger, under severe accident conditions, should be analyzed.

Lastly, in the Full Term Operating License (FTOL) Gafety Evaluation Report (SER), issued in January,1991 by the NRC, it was stated that there is sufficient truck traffic on U.S. Route 9 to require an assessment of the frequency of hazardous-material shipping, and potentially, the level of risk associated with the shipment. By letter dated May 23, 1990, the NRC staff requested that the GPUN address within one year of tne issuance of the SER l the transportation issue in order to verify that the risk duo to nearby truck transportation along Route 9 ib acceptably low. By letter dated August 9, 1990, GPUN committed to perform an assessment of transportation in the vicinity of Oyster Crook and ww-.- w- w -r- w *,gw- y ,g-(e 4 y 7 g-i---,Ny- - - - - - , -c------,y-f- , ,, m-w+ w> m-er---- e---r--

0 submit it as requested. To dato this issue has not boon resolved.

For the above reasons, Facility Operating Licent40 Request lio.

199 should be approved contingent upon resolution of the issues.

BliE strongly suggests that 11RC staff initiato a plant specific analysis and evaluation for OCl4GS to determine its useful life before approving an operating licenso extension from December 15, 2004 to April 9, 2009.

If you have any questions, please contact suren Singh of my staff at (609) 987-2039.

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Kent Tosch, Chief Dureau of 11uclear Engineering c: J. Knuble GPU liuclear Corporation

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