ML20215B308

Discusses Review of Application for Amend to License DPR-16, Consisting of Tech Spec Change Request 147 Re Change in High Drywell Pressure Trip Setting & Bypassing High Flow Trip Function of Isolation Condenser.App R Exemption Supported

ML20215B308
Person / Time
Site:	Oyster Creek
Issue date:	12/05/1986
From:	Scott D NEW JERSEY, STATE OF
To:	Zwolinski J Office of Nuclear Reactor Regulation
References
NUDOCS 8612120112
Download: ML20215B308 (2)

Text

E State of Netu 3erseg DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF ENVIRONMENTAL QUALITY BUREAU OF NUCLEAR ENGINEERING CN 411 TRENTON, NEW JERSEY 00625 (809) 530-4022 December 5, 1986 ,

Mr. John A. Zwolinski, Director BWR Project Directorato #1 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Mr. Zwolinski:

Subject:

Oyster Creek Nuclear Gonorating Station Docket No. 50-219 Technical Specification Chango Request (TSCR) No. 147 (a) Change in the High Drywell Pressuro Trip Setting (b) Bypassing the high flow trip function of the Isolation condonsor Upon Initiation

,of the A1tornato Shutdown Panol The purpose of this lotter is to inform you that the Bureau of Nuclear Engineering (BNE) has reviewed Oystor Crook Technical Specification Change No. 147 pursuant to Public Law 97-415 and concurs with the issuance of part (a) of the request, i.e., change in the high drywell pressure trip notting. However, the Bureau does not concur with the issuance of part (b) of the request, i.e., bypassing the high flow trip function of the isolation condenser upon initiation of the alternato shutdown panol.

The Bureau staff realizes that Appendix R does not require the licensoo to postulato a firo together with a Design Basis Accident (DBA). Likewise we realize that Appendix R does not requiro the licensco to provido fire protection to both trains of a redundant system. As such, GPUN's proposal of bypassing the high flow trip function of the isolation condonsor upon initiation of the romoto shutdown panol in ordor to avoid a spurious signal does not appear to violato Appendix R.

8612120112 861205 $

PDR ADOCK 05000219 - 0, P PDR g

- y,

(

However, given Oyster Creek's unique design, the Bureau's position --~ is that. the NRC should require GPUN to take whatever measures are necessary to protect these cables from the' effects of. a fire, and therefore eliminate tho

. possibility of a_ . spurious signal, rather than to by-pass this function. As my staff has discussed with Mr. Donohaw, a leak or ' break in the lines: that -run to and from the isolation condensers outside of containment provides a potential release pathway that could result in unacceptably high radiation doses to the public. In addition, since these lines have cracks due .to Intergrannular stress Corrosion ' Cracking (IGSCC) it is not that improbable that such a leak or break could occur, especially in the light of the fact that these lines and the isolation condensers will probably be used since they are Oyster Creek'n first line of defense in bringing the plant _ to a safe shutdown during a fire.

Finally, we do not consider the dilution through the stack of the Noble Gases that would be released during such an event as the most acceptable alternative to controlling radioactive releases to as low as reasonably achievable with the present technology available. The Bureau is of the position that every effort should be made to minimize the amount of radiation . released from the plant to the environment, and that dilution is the least acceptable method unless no other alternative is available.

Therefore, we would like to suggest that the NRC consider making a site specific exception to Appendix R, and require l GPUN to address this issue. If Mr. Donohue should have any l questions, please contact Mrs. Rebecca Green, of my staff,

! at (609) 530-4022.

l Thank you.

l sincerely, bb hW Day d M. Scott

! Bureau Chief Bureau of Nuclear Engineering cct

< Gerald P. Nicholls, Ph. D.

Jack Donohaw, NRR Rebecca Green Kent Tosch