ML14192A335
| ML14192A335 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/16/1982 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14192A336 | List: |
| References | |
| GL-81-12, NUDOCS 8203190251 | |
| Download: ML14192A335 (4) | |
Text
REGULATORY *ORMATION DISTRIBUTION SY M (RIDS)
ACCESSION NBR:8203190251 DOC.DATE: 82/03/16 NOTARIZED: NO DOCKET #
FACIL:,-50-261 H. B. Robinson Plant, Unit 2, Carolina Power and Ligh 05000261 AUTH,NAME AUTHOR AFFILIATION UTLEYE,E, Carolina Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION DENTONH.R.
Office of Nuclear Reactor Regulation, Director
SUBJECT:
Forwards util rePt "Safe Shutdown Capability Assessment &
Proposed Mods,"
per 10CFR50,App RSection III G & Generic Ltr 81-12.
DISTRIBUTION CODE: A006S COPIES RECEIVED:LTR L -ENCL 1-SIZE:_-.
TITLE: Fire Protection Information (After Issuance of OP. Lic,)
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL ORB #1 BC 01 7
7 INTERNAL: ELD 1
0 GC 1
1 IE 06 1
1 NRR FIORAVANTO7 2
2 NRR WAMFBACH 10 1
1 NRR/DE/CEB 08 3
3 NRR/OL DIR 1
1 REG 04 1
1 RGN2 1
1 EXTERNAL:
ACRS 09 10 10 LPDR 03 1
1 NRC PDR 02 1
1 NSIC 05 1
1 NTIS
,1 1
TOTAL NUMBER OF COPIES REQUIRED: LTTR 33 ENCL atvr
CP&L Carolina Power & Light Company MA~R I6 wo8 Office of Nuclear Reactor Regulation ATTN:
Mr. Harold R. Denton, Director United States Nuclear Regulatory Commission Washington, D.C. 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 CONFORMANCE TO THE REQUIREMENTS OF 10CFR50, APPENDIX R, SECTION III.G AND RESPONSE TO GENERIC LETTER 81-12
Dear Mr. Denton:
Attached is Carolina Power & Light Company's (CP&L) evaluation of Unit No. 2 of the H. B. Robinson Steam Electric Plant ("Robinson") to the specific requirements of 10CFR50 Appendix R, Section III.G. In response to the guidance of the "Supplementary Information" section of the final fire protection rule published by the commission on November 19, 1980 CP&L has, for Robinson, reviewed those previously approved configurations of fire protection that do not meet the specific requirements of Section III.G of Appendix R.
The result of this detailed re-examination is contained within Attachment 1 to this letter. That attachment includes a listing in tabular format of the fire zones of Robinson. Fire zones which specifically meet the requirements of Section III.G.2 are identified. Fire zones in the plant which will conform to Section III.G.2 after modifications have been made are also noted along with the date upon which CP&L estimates that the modifications will be completed.
Fire zones for which the provisions of Section III.G.3 are to be implemented are also indicated. Attachment 1 to this letter contains the description of a conceptual design for an alternative/dedicated shutdown system which CP&L will install in order to meet the requirements of Section III.G.3.
Generic Letter 81-12, dated February 20, 1981 from Mr. D. G.
Eisenhut contained information requests associated with modifications to implement an alternative or dedicated shutdown system. Our enclosed report specifically responds on a point-by-point basis to the February 20, 1981 request for those areas where modifications will be made pursuant to Appendix R to provide an alternative or dedicated shutdown system (ASS/DSS).
It is CP&L's interpretation of the February 20 letter that the information requested did not-relate to previously installed plant modifications to Robinson to provide an alternative or dedicated shutdown system. Therefore, descriptions with regard to previously installed ASS/DSS modifications have not been described in this report. Similarly, modifications to bring the unit into conformance with the specific provisions of III.G.2 are not described in detail in the enclosed report. Rather, those modifications are anticipated to be the subject of a future I&E inspection upon completion of the modifications.
411 Fayetteville Street
- P. 0. Box 1551 e Raleigh, N. C. 27602 8203190251 820316 I
PDR ADOCK.05000261
The schedules for completing the modifications are summarized in, and are in accordance with 10CFR 50.48(c)(2) and (3),
as modified by CP&L's exemption request of March 11, 1981 as supplemented by its requests of June 30 and October 15, 1981.
Thus, CP&L expects to complete presently identified modifications which require neither NRC approval nor an outage by December 1, 1982.
CP&L expects to complete those presently identified modifications which do not require NRC approval, but which do require an outage, at the next refueling outage, which is presently scheduled for late 1983. Finally, CP&L expects to complete those modifications for the dedicated shutdown system (all of which require NRC approval) in the refueling/maintenance outage which is presently scheduled to begin in late 1984 or the first half of 1985.
Should it become neccessary for CP&L to reschedule that refueling/maintenance outage, the completion date of the modifications for the dedicated shutdown system will be revised accordingly.
To the extent that such refueling/maintenance outage extends beyond the 30 months subsequent to NRC approval of the modifications established in 10CFR50.48(c)(4), CP&L hereby requests an exemption from that schedule provision to permit CP&L to complete the modifications during the refueling/maintenance outage.
The submittal of this information at this time is in accordance with the provisions of CP&L's Petition for Exemptions from Certain Requirements of 10CFR Section 50.48 and Appendix R to 10CFR Part 50 for Robinson dated March 11, 1981 as supplemented on June 30, 1981, October 15, 1981, and March 1, 1981.
In accordance with 10CFR Section 50.48(c)(6), CP&L also hereby requests exemption from the provisions of Section III.G(2) of 10CFR Appendix R for Robinson for four (4) specific fire areas described in Attachment 2 to this letter. CP&L requests an extension of time until April 27, 1982 for submitting the detailed technical justifications for such exemption requests. The bases for these exemption requests are (1) that the existing plant configurations in conjunction with additional modifications which CP&L will make to certain of these fire areas provide equivalent protection to the public health and safety to that which would be provided by the specific requirements of Section III.G(2) of Appendix R in those areas; and (2) that, therefore, the plant modifications necessary to comply with the specific requirements of Section III.G(2) would not enhance overall facility fire protection safety. CP&L believes that the existing configurations given the light fire loadings of the areas, the degree of protection already inherent in the current design, and the additional modifications planned provide protection equivalent to that which would be achieved by conformance to the literal requirements of Section III.G(2).
The submittal which CP&L will make on April 27, 1982 will address on a point-by-point basis the NRC Staff Criteria for granting Section III.G exemptions which were contained in Enclosure 2 of SECY 82-13, dated January 11, 1982.
If the exemptions requested are granted by the Commission, CP&L believes that a complete and sufficient demonstration of the conformance of the design of Robinson to the level of safety articulated in Appendix R,Section III.G will have been achieved.
CP&L hereby renews its requests for exemptions from Sections III.L.3, III.M.2 and III.0 for Robinson as set forth in CP&L's March 11, 1981 Petition, as supplemented, for the reasons and upon the technical bases previously furnished to the Commission by CP&L in that Petition and on other occasions.
There exists the possibility that, during the detailed design phase of the modification program described in this submittal, CP&L may discover facts which are not currently ascertainable and which may dictate a course of action different from that proposed in this submittal. CP&L, therefore, must reserve the right to seek further exemptions from the technical requirements of Sections III.G and III.L of Appendix R should later discovered facts and circumstances warrant such exemptions.
In submitting the enclosed information and proposals, CP&L is not abandoning or waiving any of its claims or rights asserted in or arising out of the action pending in the Court of Appeals for the District of Columbia Circuit in Connecticut Light & Power Company, et al v. NRC, No. 81-1050. Any commitments made by CP&L in this submittal are made conditionally, subject to a determination by the Court as to the validity of the provisions of the fire protection rule which are being challenged in that litigation.
Our staff is available to discuss the enclosed reports, should you have any questions concerning the Robinson fire protection.program.
Yours very truly, E. E. Utley Executive Vice President Power Supply and Engineering & Construction MRO/DLB/lr (nrc2)
Attachments cc:
Mr. J. P. O'Reilly (NRC-RII)