ML20209D194
| ML20209D194 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/20/1987 |
| From: | Corbin McNeil, Mittenburger C Public Service Enterprise Group |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20209D151 | List: |
| References | |
| NLR-N87067, NUDOCS 8704290202 | |
| Download: ML20209D194 (6) | |
Text
o09 935 0668 20 '87 08812 HRC OFFICE HOPE CREEK P02 PUDhc berv Cu (tectric and Gas Cur"p ar y Corbin A. McNeilt, Jr.
PLbhc Seruce tiectric Ja9d Gas Company P Q Bo. 236 Hancocks bru)1e NJ 0B038 009 330-4800 Senu V te P'ehle1f -
Nwbr.sr April 20, 1987 NLR-N87067 U.S. Nuclear Regulatory Commission Region I 631 Park Avenuo King of Prunsia, PA 19406 Attention: Regional Adminintrator Gentlemen:
REQllEST FOR DISCRETIONARY ENFORCCMENT TECI!NICAL SPECIFICATION 3.3.7.5 FACILITY OPERATING LICENSC NPP-b7 flOPE CREEA GENERATING STATION DOCKET NO. 50-354 Public Service Electric and Gan Company (PSEGG) hereby requestn diserotionary enforcement of Action Statement 80(a) for Technical Specification Table 3.3.7.5-1, Instrument No. 8 l
( Primary Cont.alnment Hydrogen / Oxygen Concentration Analyzor And l
Monitor) for the flopo Creek Generating Station (IICGS).
As i
discussed in Attachment 1,
plant operation nubsequent to the granting ot thin request would not. croato a significant hazard t.o public health and safety and in justified on technical and economic bases. The requestod relief would provide an additional seven day period beyond the expiration of the current action ntatement. allowance in which to rentore the affected channel to an oporable condition.
This roquest has become neconsary due t.o delayn in replacement pump acquisition, compounded by t.esting and calibration problems, that have arisen during our repair offorts following the discovery of det.eriorated performance of one of the two redundant ifydrogen/0xygen Analyzor and Monitor nample pumps during routine survoillance calibration activitios.
Within 14 days of our compliance with the requirements of the subject specitication, PSE&G will submit a special report, pursuant to Technical Specification 6.9.2, identifying all corrective actions taken.
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4/20/07 Regional Administrator via a verbal approval of Your timely assistance is requested, 1987, in order to by 9:30 A.M.,
Monday, Apell 20, shutdown as detailed heroin.
If this request avert an unnecessary plantyou have any questiona, we will be plea with you.
Sincerely, hu h//
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Attidavit Attachment.
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Mr. G. W. Rivonbark
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USNRC Licensing Project Manager
~I M r. 14.
W. Borchardt USHRC Senior Resident Inspector D. M. Scott, Director i
Mr.
Hureau of Nuclear Engincoring l
Department of Environmental Protection i
380 Scotch Road l
Trenton, NJ 00628
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0 '87 08:15 HRC OFFICE HOPE CREEK PO4
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_ i, Rett REQUEST POR DISCRETIONARY ENFORCEMENT - HCGS STATE OF NEW JERSEY
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COUNTY OF SALEM
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Miltenbergne, Jr., being duly sworn according to law Steven E.
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deposos and says:
l am Vice President - Nuclear Operations of Public Service
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I Electric and Gan Company, and as such, I find the matters not j
forth in our letter dated April 20, 1987, concerning Pacility is operating Licenso NPF-57 for Hope Creek Conorating Station, l'
true to the best of my knowledge, information and belief.
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r Subscribed and Sworn to beforo me this; dom _ day of jAn'/
1987 1
a Onom$D.M 288
.s blic of NeW Jersey A Notary Putts afitse Jenny Not.ary idy Censhalen Eschenthset KlNS My Commission oxpires on
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20 '87 08:16 NRC OFFICE HOPE CREEK P05
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..If ATTACHMENT,I j
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Technical specitication 3.3.7.5
.j Technical Specification 3.3.7.5 identifies the operability requirements for accident monitoring instrumentation.
Table i
3.3.7.5-1 lists those instruments necessary for accident L
monitoring which includon, as Inntrument No.
8, the Primary containment Hydrogon/0xyqun concentration Analyzor and Monitor.
The basis for this specification la found in both Roqulatory Guido 1.97 and NUREG 0737 which require that sufficient information be availabic for selected plant l,
parametern to monitor and asuona important variables i
following an accident.
Hope Crook Generatino Station (HCGS) i complies with the recommendations of the referenced bases as described in Final Safety Analysis Report (PSAR) Sections i
1.8.1.97, 1.10.II.P.1, 6.2.5 and Table 7.5-1.
t Summary of current _ situation
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lj At 9: 37 A.M.
on April 13, 1987, the
'B' channel of the l
j Primary Containmont 112/02 Analyzer / Monitor was taken out of i
servico and declared inoperable to replace the tost gas cylinder and to perform quarterly surveillanco calibration on the instrumentation.
1.ator in the day, during the t
calibration, technicians found comple flown to be lower than l
would have boon expected, sinco the analyzer / monitor vendor i
reprosontative was on sito, he assisted in the ensuing troubleshooting to determine the cause of the roduced d
tlown. Investination ultimately lod to the discovery that wear on the internal components of the analyzer / monitor i
cample pump was the causo for low flows being experienced.
No apare parta wore available on-sito, although an entire pump /notor assembly had been on order for months.
An vmorgency requent for a replacement pump was made to the vondor.
Installation of a vendor-supplied roolacement pump f or the !!2/02 Analyzer / Monitor has boon completed.
Additional replacement parts from the Sunquohanna Station are r.till arrivinar honett, it is anticipated that final ausenbly, testing and cal.ibration will take longer than the romaining amount of inopor'able timo permitted by Technical Specification Action Statoment No. 80(a).
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ATTACIIMENT I (Cont'd) 1,te, ques t for Disc _retionary Enforcement HCGS plant management in concerned t h a t. repair and calibration efforts on the analyzer / monitor will extend beyond the current deadline of 9:37 A.M. Monday, April 20, 1907, requiring a plant shutdown from approximately 90% of rated power.
PUM&G, thorofore, requests that NltC Itegion I grant. discretionary enforcement of Action Statomont 80(a) for Instrument. No.
8, on Table 3.3.7.5-1 of the Hopo Creek Generating Station Technical Specificationn for a period that would permit an additional 7 dayn, beyond the presently allowed 7 days, to comple t.e t.he rost. oration of the Primary Containment Hydroqen/ Oxygen Concentration Analyzer and Monitor to OPEl<Antx ctat us.
Operat. ion under the requested discrotionary enforcement will not. place the plant in an unnafe condit. ion.
PSC&G belloves that t.h e r e is ample technical justificntion for the requented tellaf, i n t h a t. :
Tho (rodundant)
'A' Channel of tho analyzer / monitor is fully operable.
This channot had its tent qan cylinder replaced and was calibrated during the first week of April, 1987.
The Post. Accident Sample Syutem (PASS) in operable and capablo of providing primary containment hydrogen and oxycon concentrations an a backup to the
'A' Channel Analyzer and Monitor.
Although the PASS doou not, as required of Category 1 Instruments in Regulatory Guide 1.97, provido a continuous display of the paramet.ern of concern, primary containment samplos can be drawn and analyzed uninq the PASS in a timely manner and at a sufficiently frequant rato so an to supply the control room with adequato information during accident conditions in the ovent of a failure of the
'A' Channel Analyzer and Monitor.
1 Pormitting continued plant operation while the allowad repair time for the analyzor/ monitor is extended for seven (7) dayn will avoid the stresnes produced by the t.hormal and hydraulle transients attendant to cycling the plant systems throuqh a shutdown from, and a ret. urn to, full power.
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ATTACl! MENT I (Cont'd)
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i Additionally, the economic impact of onforced compliance with the requirements of Action Statement No. 80(a) would be only in the immediato lost revenue and replacement folt, not power costs that a plant shutdown would entail, but also in I
the penalty imposed on our ability to recover replacement energy costa based on the capacity factor of our nuclear generating stations.
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