ML20133H696

Application for Amend to License DPR-16,consisting of Tech Spec Change Request 142,modifying Reactor Bldg Isolation & Gas Treatment Sys Initiation to Reflect lo-lo Reactor Water Level Not Necessarily Required

ML20133H696
Person / Time
Site:	Oyster Creek
Issue date:	10/11/1985
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20133H699	List: ML20133H696 ML20133H707
References
2457F, NUDOCS 8510180073
Download: ML20133H696 (7)

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GPU Nuclear Corporation NggIg{ Post Ofhce Box 388 Route 9 South Forked River, New Jersey 08731 o388 609 971-4000 Writer's Direct Dial Number:

Director, Nuclear Reactor Regulation '

U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir:

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Subject:

Oyster Creek Nuclear Generating Station i Docket No. 50-219 Technical Specification Change Request No.142 In accordance with the provisions of 10 CFR 50.59,10 CFR 50.90 and 10 CFR 50.91, GPU Nuclear Corporation, operator of the Oyster Creek Nuclear Generating Station, Provisional Operating License No. DPR-16, requests an emergency change to Appendix A of that license. The conditions of this change, if approved, will enable us to complete environmental qualification modifications by the committed November 30, 1985 date and to restart from that outage as scheduled. It is our opinion that a technical basis exists to grant this Technical Specification Change Request. Because of work schedules and operational considerations, power generation will otherwise be limited. The outage involved is scheduled to begin October 18, 1985.

We have determined that table 3.1.1, " Protective Instrumentation Requirements" requires clarification. Item J.4 of that table, " Reactor Building Isolation and Standby Gas Treatment System (SGTS) Initiation" should be modified to reflect that the " low-low" reactor water level feature for SGTS is not required when secondary containment is not required or when certain other I plant conditions are established that eliminate the need for " low-low" automatic initiation of the SGTS. Item B.1 of the table 3.1.1 should be changed to eliminate the need for " low-low" initiation of Reactor Isolation given the same set of plant conditions as described above.

A review of the system lineups necessary to support the required changes has revealed that reactor water level instruments RE02A, B, C, and D will need to i be disabled concurrently for a large portion of the maintenance outage.

! Because both trip systems' instruments share both hydraulic legs, the minimum I

instrument operability requhements for reactor " low-low" level of table 3.1.1 would not be met when eithe r of the sensing lines is valved out for the exchange of instruments. In addition, the return to power, as scheduled, and completion of environmental qualification modifications by November 30, 1985 l can only be accomplished by working on both sets of instruments at one time.

! It is estimated that this work will require 24 days to complete.

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} Beyond not being able to satisfy the instrument operability requirements of i table 3.1.1, the associated circuit logic would cause the SGTS to actuate and the main steam isolation valves to close when either set of mechanically grouped instruments are deenergized. This is based on the g one-out-of-two-twice logic for both functions.

8510180073 851011 PDR ADOCK 05000219 3 40 P PDR UPU Nuclear Lorpulouun is a suDSidiary of the General Pubhc Utihties Corporation

Operation of the SGTS continuously is the alternate action for long-term unavailability of the automatic initiation on " low-low" level function. This is undesireable because reactor building temperature, air quality, and airborne contamination levels will degrade with sustained SGTS operation. In addition to detracting from radiological and worker health conditions, continued operation of the SGTS will reduce the reliability of that system and result in frequent filter changes due to the industrial work atmosphere involved.

It is important to point out that SGTS will be operable with respect to automatic initiation on high radiation levels in the reactor building HVAC exhaust or in the area of the reactor building 119' elevation during the outage work.

The detailed rationale for justifying this change already exists in the Technical Specifications. Criteria of sections 1.1,1.14, and 3.5 should be applied to items B.1 andtJ.4 of table 3.1.1 to assure greater clarity throughout the Technical Specifications with regard to SGTS operability and the Reactor Isolation functions.

Approval of tMs change will enable GPU Nuclear to install and test

' modifications to comply with 10CFR50.49 in a controlled and effective manner.

This will ensure our November 30, 1985 connitment to you will be met and that Oyster Creek's schedule for return to power will be assured. The need for this request first secame apparent within the last few weeks during the process of' planning for the physical work to replace the instruments.

This change request has been reviewed in accordance with section 6.5 of the Technical Specifications.

Pursuant to 10 CFR 50.91(b)(1), a copy of this change request has been sent to the State of New Jersey Department of Environmental Protection. In addition, a check for $150.00 pursuant to 10 CFR 170.12 will be forwarded under separate Cover.

Very truly yours,

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• Vice President and Director Oyster Creek PBF:0GH: dam (2457f)

Attachments cc: Administrator-Region I U.S. Nuclear Regulatory Commission )

631 Park Avenue King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Connission l 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 NRC Resident Inspector Oyster Creek Nuclear Generating Station

l GPU NUCLEAR CORPORATION l 0YSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE N0. DPR-16 l

Technical Specification Change Request No.142 Docket No. 50-219 Applicant submits, by this Technical Specification Change Request No.142 to the Oyster Creek Nuclear Generating Station Technical Specifications, a change to Specification 3.1.

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By: -

P. B. Fiedler Vice President and Director Oyster Creek Sworn and subscribed to before me this // ' day of October,1985 IkttL h. l{dlO Notary PuDlic of NJ

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_ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

GPU NUCLEAR CORPORATION ) DOCKET NO. 50-219 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 142 for the Oyster Creek Nuclear Generating Station Technical Specifications, filed with the United States Nuclear Regulatory Commission on October 11 , 1985, has this 11 day of October,1985 been served on the Mayor" of Lacey Township, Ocean County, New Jersey by deposit in the United States mail, addressed as follows:

The Honorable Thomas R. Waskovich Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 By: J_ _

Peter 5. Fiedler Vice President and Director Oyster Creek PBF:2457f

1 GPU Nuclear Q gf P O. Box 388 Forked River, New Jersey 08731 609-693-6000 Writer's Direct Dial Number:

October 11, 1985 The Honorable Thomas R. Waskovich Mayor of Lacey Township 818 West Lacey Road Forked River, New Jersey 08731

Dear Mayor Waskovich:

Enclosed herewith is one copy of the Technical Specification Change Request No. 142 for the Oyster Creek Nuclear Generating Station Operating License.

This document was filed with the United States Nuclear Regulatory Commission on October 11, 1985.

Very truly yours, P ' dier Vice President and Director Oyster Creek P8F: dam 2457f/001 l Enclosures t

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1 GPU Nuclear is a part of the General Pubhc Utihties System

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4 OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE No. OPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 142 The applicant hereby requests the Commission to change Appendix A to the aoove captioned license. Pursuant to 10 CFR 50.91, an analysis concerning significant hazards consideration is also presented:

1. Sections to be Changed Table 3.1.1

2. Extent of Change A note of clarification will be added to Table 3.1.1 Items B.1 and J.4.

3. Changes Requested The requested changes are indicated in the proposed pages 3.1-8, 3.1-10 and 3.1-14 which are attached. .

4. Discussion It has been determined that the Protective Instrumentation Requirements of Table 3.1.1, Items B.1 and J.4 should be changed (notes added) to indicate the features are not required to be operable when certain conditions are met.

Note (gg) should be added to Item J.4, " low-low" Reactor Water Level, under shutdown mode, to state "These functions are not required to be operable wnen secondary containment is not required to be maintained or when the conditions of 3.5.B.1.a, b, e and d are met, and Reactor water level is monitored. Section J of table 3.1.1 is titled

" Reactor Building Isolation and Standby Gas Treatment System Initiation". Tne " low-low" reactor water level feature is currently required to be operable in the Shutdown, Refuel, Startup, and Run modes. The action statement is to " Isolate Reactor Building and initiate Standby Gas Treatment System, or Manual Surveillance for not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (total for all instruments under J) in any 30-day period."

Having " low-low" reactor water level operable in the shutdown mode insures that if reactor water level reaches the " low-low" trip setting, Reactor Building Isolation and Standoy Gas Treatment System would initiate.

Specification 3.5.B.2 requires Standoy Gas Treatment to be operable when secondary containment is required. The Technical Specification for Secondary Containment in section 3.5.B is stated as follows:

"1. Secondary containment integrity shall be maintained at all times unless all of the following conditions are met:

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l a) The reactor is subcritical and Specification 3.2. A is met.

b) The reactor is in the cold shutdown condition.

c) The reactor vessel head or the drywell head are in place.

d) No work is being performed on the reactor or its connnected systems in the reactor building which could result in inadvertent releases of radioactive material.

e) No operations are being performed in, above, or around the spent fuel storage pool that could cause release of radioactive materials."

When secondary containment is not required, the additional restrictions on operation and maintenance give assurance that the probability of inadvertent releases of radioactive material will be minimized. Maintenance will not be performed on systems which connect to the reactor vessel lower than the top of tne active fuel unless the system is isolated by at least one locked closed isolation valve.

The restrictions of Item 3.5.B.1.e are not applicable for " low-low" reactor water level instrumentation. In the case of an inadvertent release of radioactivity from the fuel pool, Reactor Building Isolation and Standoy Gas Treatment System initiation would be initiated by the following instrumentation: .

Item J.1, High Radiation Reactor Building Operation Floor; and Item J.2, Reactor Building Ventilation Exhaust The additional restriction of monitoring reactor water level when

" low-low" reactor water level is not required to be operaole provides further assurance that inadvertent releases of radioactive material will not occur due to timely operator action.

Note "(gg)" should also be added to Item B.1, " low-low" Reactor Water Level, under the snutdown mode. Section B of table 3.1.1 is titled

" Reactor Isolation. " Low-low" reactor water level is currently required to be operable in the Shutdown, Refuel, Startup, and Run modes. The action statement is to "Close main steam isolation valves and close isolation condenser vent valves, or place in cold shutdown condition."

The action statement is insufficient for the shutdown mode. Note "(gg)"

clarifies when " low-low reactor water level instrumentation is required and provides the additional restriction of monitoring reactor water level.

5. Determination We have determined that the proposed changes in Technical Specification Change Request No.142 involve no significant hazards in tnat operation of the Oyster Creek Nuclear Generating Station in accordance with those changes would not:

A. Involve an increase in the probability or consequences of an accident previously evaluated: or l B. Create the possibility of a new or different kind of accident from any accident previously evaluated, or C. Involve a significant reduction in a margin of safety.

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