ML20210D010

Application for Amend to License NPF-57,revising Tech Spec Sections 3.3.7.9 & 3.3.7.10 Re Radioactive Liquid & Gaseous Effluent Monitoring Instrumentation.Immediate Approval Under 10CFR50.91(a)(5) Requested

ML20210D010
Person / Time
Site:	Hope Creek
Issue date:	09/12/1986
From:	Corbin McNeil Public Service Enterprise Group
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20210D013	List: ML20210D010 ML20210D056
References
NLR-N86126, NUDOCS 8609190040
Download: ML20210D010 (5)

Text

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.g -o Public Service Electric and Gas Company ,

Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge. NJ 08038 609 339-4800

%ce President -

Nuclear September 12, 1986 NLR-N86126 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Attention: Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing

Dear Ms. Adensam:

REQUEST FOR AMENDMENT FACILITY OPERATING LICENSE NFP-57 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 In accordance with the Atomic Energy Act of 1954, as amended and the regulations thereunder, we hereby transmit copies of our request for amendment and our analyses of the changes to Facility Operating License NFP-57 for the Hope Creek Generating Station.

This application meets the intent of 10CFR 50.91(a)(5) for emergency classification since immediate approval is needed to prevent an unnecessary delay in plant startup.

The emergency situation occurred due to failure of a North Plant Vent Radioactive Effluent Flow Monitoring Instrument. The flow

, instrument was declared inoperable at.1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on August 16, i

1986. Technical Specification 3.3.7.10, allows continued discharge via the af fected pathway, as long as flow rate is calculated at-least once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, for only 30 days and then requires that releases via the affected pathway be terminated. This situation occurred due to an unanticipated equipment f ailure which could not be avoided through any actions by PSE&G and which, following initial troubleshooting and repair attempts, was f urther complicated by an initial unavailability of replacement parts. The defective instrument was taken'to the vendor for repair and, concurrently, a replacement unit was located and installed. However, in spite of concerted efforts on the part of station instrument technicians, the new flow \

instrument does not appear to be capable of being satisfactorily hdd calibrated before exceedipa the present 30 day discharge limit. g3 8609190040 860912 T

, PDR ADOCK 05000354

[_ P PDR1

Ms. E. Adensam 9/12/86 Based on the above, releases via the North Plant Vent must be terminated at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on September 15, 1986. This action j would require shutdown if the plant were at power and will~

preclude plant startup until the necessary repairs are completed. Additionally, another instrument af fected by the 30 day termination limit on discharge was declared inoperable on September 3, 1986. It presently appears that this instrument will require an appreciable time to effect complete repairs, such that the change will also provide relief from a potential shutdovn at the end of the 30 day limit for that instrument's affected pathway.

Pursuant to the requirements of 10CFR.91, the State of New Jersey has been notified verbally and, as indicated below, has been sent a copy of this request.

This submittal includes three (3) signed originals and forty (40) copies. A check in the amount of $150.00 will be forwarded shortly in compliance with the fee requirements of 10 CFR170.21.

Sincerely, Enclosure V

C Mr. D. H. Wagner Licensing Project Manager Mr. R. W. Borchardt Senior Resident Inspector Mr. Gerald Nichols, Assistant Director Bureau of Radiation Protection Department of Environmental Protection 380 Scotch Road Trenton, N.J. 08628 Honorable Charles M. Oberly, III Attorney General of the State of Delaware Department of Justice 820 North French Street Wilmi ng to n , DE 19801

Ref: LCR - HC86-05 STATE OF NEW JERSEY )

) SS.

COUNTY OF SALEM )

Corbin A. McNeill, Jr. , being duly sworn according to law deposes and says:

I . am Vice President of Public Service Electric and Gas Company, and as such, I find the matters set forth in our letter dated September 12, 1986 concerning our request for Amendment to Pacility Operating License NPF-57 are true to the best of my knowledge, information and belief.

A R x  %

Subscriby and Sworn oj be ore me this /J day of ,.. , 1986

$ / '

' f/ Notary Pgblic of New Jersey . LARAINE Y. BEARD Notary Public of New Jersey My Commission expires on * " Y C " *'"I'" I" # ** " Y I' #

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PRO'OSED P CHANGE TO: TECHNICAL SPECIFICATIONS HOPE CREEK GENERATING STATION DOCKET NO. 50-354

~ DESCRIPTION OF CHANGE R3 vise Technical Specifications sections 3.3.7.9 and 3.3.7.10 to agree with-the attached changed pages. These changes will reword the ACTION and TABLE NOTATION portions of_the affected specifications to be consistent with the intent of the radiological environmental technical specifications-and to be the same .as the comparable' specifications that _ are in place at other similar plants.

The revisions would require, as they do. presently, an explanation in the Samiannual Radiological Release Report,. subsequent to any effluent monitoring instrument inoperability of more than 30 days,'why the inoperability was not corrected in a timely manner. The changes would also allow continued use of release pathways for which effluent monitoring instruments may not be OPERABLE as long as grab samples and analyses and/or flow 1 rate calculations are made at frequencies specified in the existing ACTION STATEMENTS and TABLE NOTATION. However, present wording in the Hope Creek Technical Specifications must be interpreted, as presently written,.

to require termination of all releases, via a pathway for which an effluent monitor is inoperable, after 30 days...regardless of any sampling, analysis, or calculational capabilities available at that time. This requirement, in most cases, will necessitate a plant shutdown.

REASON FOR CHANGE As stated above, if any effluent monitoring instrument inoperability for a paried of over 30 days requires termination of releases via the affected pathway, this would, in most cases, lead directly to a plant shutdown.

This is particularly true for the gaseous effluent pathway monitoring instruments.

I The following points are. offered as arguments against the continued use of the present wording in the specifications:

Both Technical Specifications sections affected by this request

contain exclusions from the applicability of Specifications 3.0.3 and l 3.0.4 which indicate an intention to not require plant shutdown for l- situations covered in these specifications.

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• Inspection of final draft specifications for a comparable BWR, (Nine Mile Point 2) show effluent monitoring instrument specifications essentially identical to those being proposed for this change.

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REASON FOR CHANGE (Cont'd)

Inspection of in-place specifications for other plants and review of original RETS guidance documents indicate that the 30 day requirement is and was intended as a reporting requirement and that the continued use of any pathway was dependent on specific sampling and analyses actions and was not limited by the 30 day reporting requirement.

Tho ramifications of the present specification wording as compared to what wcc understood to be the original intent were not noticed during review of ,

draft specifications and were, therefore, not identified as requiring revision prior to issuance of the operating license. It was only upon cuf fering an inoperable effluent monitoring instrument that the need for a '

change in the specifications became apparent.

NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION Thio change in ef fluent monitoring instrumentation technical specifications allows the continued use of an effluent pathway while an instrument that '

monitors that pathway may be inoperable. Present wording of the sp cification allows continued use of the affected pathway for up to 30 ,

daya if prescribed sampling and analy'9s are performed and requires a report if the inoperable instrumentation is not restored in that time. "

Allowing continued use of the affected pathway beyond 30 days will not eignificantly increase the probability or consequences of an accident previously evaluated since prescribed sampling and analysis of any discharges via that pathway would be continued while the monitoring instrumentation is inoperable.

The possibility for any previously unanalyzed accident is not created by thic change since there is no physical change to any plant fission product boundary, safeguards equipment, or any procedure.

While there may bo some reduction in the plant's ability to make continous, inctantaneous evaluations of discharge levels with a monitoring instrument ,

inoparable beyond the present 30 day limit, there are sampling and calculational methods available for for making those determinations which provide adequate assurance that no margin of safety is significantly roduced by implementing this change.

Baced on the above, we have determined that operation of the Hope Creek Station with this requested change in place would not involve a significant hazceds consideration.

Additionally, since this change may involve some small reduction in a mergin of safety, but operation of the plant will remain within the i guidalines of section 11.5 of the Standard Review Plan, this request j corresponds to example (vi) of the guidance provided the Commission l ragcrding changes Not Likely To Involve A Significant Hazards ,

Consideration.

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