ML20099B462
| ML20099B462 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/21/1992 |
| From: | Tosch K NEW JERSEY, STATE OF |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207310170 | |
| Download: ML20099B462 (4) | |
Text
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h Ni" 5 tate of New lersey Department of Environmental Protec.tlon anct Energy CN 415 Tr enton. N] 08625-0402 scott A weiner ccmmisssoner July 21, 1992 U.S.
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Summary of Changes to Systems and Procedure.3 for 1991 c
The New Jersey Department of Environmental Protection and Energy's Bureau of Nuclear Engineering (BNE) has reviewed GPU Nuclear Corporation letter C321-92-2164, dated June 22, 1992. This letter provided a description and safety evaluation summary for certain changes to procedures and modifications to the plant during 1991 as required by 10 CFR 50.59. We have an overall concern and a specific comment as delineated below.
Safety evaluations, required by 10 CFR 50.59, are the bases for licensees to modify plant hardware and procedures without obtaining prior NRC approval. For this reason, the BNE believes each safety evaluation must include a rationale and basis for concluding that a change to plant hardware and procedures is not an unreviewed safety question. Some of the safety evaluation suma ries in the GPUN letter include this; however, many do not. These instead recite the words rrom 10 CFR 50.59 and state only that an unreviewed safety question isn't created by the change. It is our-recommendation that the NRC ensure through the appropriate means (e.g. information reqaest or inspection) that a sound basis exists for-the procedure and plant changes made at Oyster Creek. is a list of the modifications for which the safety evaluation summary was lacking.
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e Page 2 In addition, the BNE has a concern with the safety evaluation performed for the procedure change related to augmented offgas system operation. This procedure change re:hices the holdup times for xenon and krypton. The safety evaluation summary states that "since there has been no increase seen in activity in the stack gas monitors and no increase seen in AOG radiation monitors, this safety evaluation is good for 60 dayc." It appears that the safety evaluation was written af ter the procedure change was implemented.
It is our recommendation that this procedt.re change be re-evaluated and that the safety evaluation procer.s for procedura changes be assessed for adequacy.
If you have any questions, please contact Rich Pinney at (609) 987-2086.
Sincerely, 9
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Kent W.
Tosch, Manager Bureau of Nuclear Engineering Attachment c:
Jill Lipoti Assistant Director, Radiation Protection Programs N.J.
DEPE D.
Vito Senior Resident Inspector A.
Dromerick Project Manager U.S.
NRC J.J.
Barton Vice President and Director Oyster Creek l
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l ATTACHMENT 1 (Page 1 of 2)
S AFETY EVALUATlpN SUMMARIES LACKING BASIS Procedure Changes:
Augmented Offgas System Operation Alternare Water Supply to AOG Heat Exchanger Modifications:
RPV Heat Vent Valve Addition (SE 402953-010)
Appendix J Replacement Options (SE 402946-001)
Total FeedWater Flow Element Addition (SE 402945-001)
Temporary Demineralizer System (SE 312100-003) 125V DC System Knife Switch Modification (SE 323560-008)
RWCU Drywell Penetration Pipe Replacement (SE 402938-001) i Note: This safety evaluation references a section 3 that j
is not provided in the GPUN-letter.
4 Drywell Chiller Unit' Piping Modification (SE 402939-001) l-Torus Oxygen Sample Line Isolation Valves Modification (SE 402872-001)
Core Spray / ADS Logic Modification -(SE _328279-001) f Reactor 11anual Control System _ Modification (SE 328298-001)
I Containment Airborne Particulate and Gaseous Radiation Monitor System - Phase II (SE 402815-002)
ESW Flow Indication (SE 402859-001)
Heater Bay Roof. Trailers, Fire Protection (SE 402860-003)
Circulating Water Pump Pit Conduit Replacement (SE 402869-001) l Sewer Water Radiation Monitor Upgrade (SE 328293-004) l Main Feedwater Line Block Valve Addition (SE 402901-002)
Temporali Torus Fans and Filter (SE 000820-002)
Monitor Sump for conduit Pit in Feedwater Pump Room (SE 408843-001)
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ATTACHMENT 1 (Page 2 of 2)
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SAFETY EVALUATION SUMMARIES - LACKING BASIS j
Remove Core Spray Min. Flow Check Valves (SE 000212-018) l Reactor Building Construction Power Upgrade (SE 402949-001) a f
Drywell Power Improvement (SE 402939-004)
Chlorination System Upgrade (SE 402792-001) l_
installation of Test Modules in the SDIV Level Circuit (SE 402953-002) i Chemical-Decontamination Support Modifications (SE 328265-004) 4 j
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