ML20003E965
| ML20003E965 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/10/1981 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.13, TASK-2.K.3.22, TASK-TM NO-81-637, NUDOCS 8104170563 | |
| Download: ML20003E965 (2) | |
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- c, April 10, 1981 File: NG-3514(B)
Serial No.:
NO-81-637 Mr. Darrell G. Eisenhut, Director Division of Licensing United States Nuclear Regulatory Commission Washington, D. C.
20555 BRUNSWICK S.EAM ELECTRIC PLANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 POST TMI REQUIREMENTS CONTAINED IN NUREG-0737 ITEM II.K.3.13, " SEPARATION OF HIGH PRESSURE COOLANT INJECTION AND REACTOR CORE ISOLATION COOLING SYSTEM INITIATION LEVELS"
Dear Mr. Eisenhut:
Summary Carolina Power & Light Company (CP&L) has determined that NUREG-0737, Item II.K.3.13, " Separation of High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) System Initiation Levels," is applicable to its Brunswick units and commits to modify the RCIC system to provide automatic reset on low reactor water level during the next scheduled refueling outages. CP&L does not believe, however, that the small additional benefits in safety achieved by these modifica-tions warrants the unscheduled outage which would be required to meet the NRC's schedule for implementation by July 1, 1981.
Background
On December 15, 1980, CP&L submitted a letter containing its commitments for completion of the items in NUREG-0737, " Clarification of TMI Action Plan Requirements" which are applicable to the Brunswick Steam Electric Plant (BSEP). For Item II.K.3.13, CP&L committed to perform the required analyses and make the required modification proposals in accordance with NRC requirements. In addition, CP&L agreed to work with the NRC to schedule any necessary modifications.
In accordance with commitments in the December 15, l'380 letter, CP&L submitted a letter on December 31, 1980 providing the required documentation for several items from NUREG-0737. For Item II.K.3.13, a BWR Owners' Group Report, deemed to be generically applicable to BSEP, was submitted. However, a detailed review against BSEP's plant specific design was not completed at the time of the December 31, 1980 submittal.
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Status 1
The review of the BWR Owners' Group generic report against BSEP's plant specific design has been completed.
CP&L has concluded that the report is applicable to BSEP and that a modification to the RCIC system providing automatic reset to ensure system restart on low reactor water level will contribute a small improvement in the overall safety of BSEP.
Proper installation, checkout, and operational testing'of this modification will require the RCIC system to be out of service for an extended period of time. To meet the NRC implementation date of July 1, 1981, an unscheduled outage would be required. Although this work can be performed during operation, CP&L does not believe that this modifica-tion warrants the reduction in safety margin associated with operating while the RCIC system is out of service. At present, reset of the RCIC system is adequately provided for in current operating procedures and can be performed from the Control Room.
Schedule It is not believed that the small safety improvement to be gained warrants the need for an unscheduled outage at a time when our energy needs are high. Therefore, CP&L proposes to perform this work during the following scheduled refueling outages:
Unit No. 2 - early spring 1982 Unit No. 1 - late spring 1982 We trust you will appreciate our intention to complete this modification in a safe, timely, and orderly manner.
Yours very truly,
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E. Utley Executive Vice President Power Supply and Engineering & Construction ONH/jc (904-401) cc:
Mr. J. N. Hannon (NRC)
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