ML20031G753
| ML20031G753 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/08/1981 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8110230611 | |
| Download: ML20031G753 (1) | |
Text
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Docket Nos. 50-325 OCT 8 - 1981 and 50-324 3
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j Mr. J. A. Jones 4
h [l@ikjif Senior Executive Vice President 0
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2f Carolina Power and Light Company 336 Fayetteville Street
,U 001'13 S81Q, Raleigh, North Carolina 27602
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Dear Mr. Jones:
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SUBJECT:
FIRE PROTECTION RULE EXEMPTION P500EST i'
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RE: BRUNSWICK STEAM ELECTRIC PLANT, UNITS HOS. 1 AND 2
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Your letter dated March 6,1981 petitioned for exemption from certain of l
the requirements of 10 CFR 50.48 and Appendix R to 10 CFR Part 50. That petition requested, in part, specific extensions in the submittal and implementation schedule of 10 CFR 50.48. By subsequent letter dated 1
September 14, 1981, you have requested additional extensions to January j
15, 1982 for each of the schedular items set forth in your original petition.
f Our review of your nemption request is continuing. We will consider, 1
during the remainder of our review, the additional infonnation provided in, and the extended schedule requested by, your September 14, 1981 submittal.
Sincerely, ORIGINAL SIGNED BY
!r/r 0{W Thomas M. Novak, Assistant Director for Operating Reactors Division of Licensing cc: See next page Distribution:
Docket File M. Bridgers, ED0 E. Case R. Mattson NRC PDR Pro. Spt. Stf, NRR H. Denton T. Murley Local PDR E. Hughes W. Dircks D. Vollmer EDO Reading M. Stine K. Cornell B. Snyder-TMIP0 I
D. Eisenhut S. Norris T. Rehm P. Fine-TCSB R. Purple J. Van Vliet V. Stello S. Cavanaugh hl-U 'I J. Heltemes, AE0D T. Ippolito PPAS W. Houston OELD T. Novak S. Hanauer E. Markee R. Abbey ORB #2 Reading T. Wambach d.k
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/O Cys sllo c@%y Op Carolina Power & Light Company September 14, 1981 File: NG-3514(B)
Serial No.: NO-81-1501 Honorable Nunzio J. Palladino Chairman United States Nuclear Regulatory Commission Washington, D.C.
20555 BRUNSWICrt STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 EXTENSION REQUEST FOR PETTTION OF CAROLINA POWER & LIGHT COMPANY bOR EXEMPTIONS FROM CERTAIN REQUIREMENTS OF 10CFR50.48 AND APPENDIX R TO 10CFR PART 50
Dear Mr. Palladino:
By letter dated March 6, 1981, Carolina Power & Light Company (CP&L) submitted to the Nuclear Regulatory Commission (NRC or the Commission)
CP&L's petition for exemption from certain of the requirements of 10CFR S 50.48 and Appendix R to 10CFR Part 50 (sometimes referred to collectively herein as the fire protection rule) with respect to the Brunswick Steam Electric Plant, Units Nos. 1 and 2 (BSEP).
Aniong other things, CP&L requested exemptions from 5 50.48 in the following respects:
(1)
CP&L requested the following extensions of schedule:
(a) Extend from March 19, 1981 to September 1, 1981 the date for:
(1)
Submittal of plans and schedules for any modifications necessary to achieve compliance with Section III.G.2 of Appendix R; (ii) Filing requests for additional exemptions from Section III.G pursuant to 5 5 50.12(a) and 50.48(c)(6).
(b) Extend from March 19, 1981 to December 1, 1981 the date for submittal of design descriptions of alternative or dedicated shutdown systems to comply with Section III.G.3, if such are necessary.
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(c) Extend from February 17, 1981 to December 1, 1981 the date from which the installation schedules established in 5 50.48(c)(2) and (3) are calculated, with leave to request an additional extension of time on or before September 1, 1981, if such additional extension is found to be necessary.
(2)
CP&L requested an exemption from the last paragraph of Section Ill.G.3 of Appendix R to the extent that it requires the installation of fire suppression systems in the control room and cable spread rooms.
By letter dated May 7, 1981, the Commission advised CP&L that CP&L had provided a sound technical basis for its exemption request described in numbered paragraph (2) above warrsnting further Staff review; and that, therefore, the schedule requirements for that item were suspended pending final Commission action. As to the remaining requests for exemptions, the Commission informed CP&L that those requests were "still under consideration and would be the subject of future correspondence." As of the date of this letter, CP&L has received no further correspondence from NRC indicating that there has been any further Commission action on any of CP&L's exemption requests for BSEP.
CP&L hereby requests that the schedules for each of the items set forth in numbered paragraph (1) be extended until January 15, 1982.
These modifications of schedule are necessary to enable CP&L to complete the tasks it must perform in order to comply with the fire protection rule.
In its March 6, 1981 petition, CP&L stated that it had initiated studies to determine to what extent its previously completed and approved fire protec-tion modifications meet the requirements of Section III.G; to develop technical justifications to support requests for such exemptions from Section III.G as CP&L believes to be warranted upon the conclusion of its analyses; to determine whether any modifications will be necessary to achieve compliance with Section III.G; to develop all plans and schedules for any modifications necessary to satisfy Section III.G.2; and to prepare and submit design des-criptions for an alternative or dedicated shutdown system to satisfy Section III.G.3, if such a system is necessary.
While CP&L and its architect-engineer have made every reasonable effort to meet the schedules proposed by CP&L in its petition, it has not been possible to complete nr. necessary studies as of September 1, 1981. Thus far, approximately 9,000 man-hours have been expended conducting these analyses.
CP&L estimates that an additional 3,000 man-hours will be required to complete the studies.
CP&L believes, therefore, that it will be able to conclude the studies, develop necessary plans, schedules and design descriptions and any additional exemption requests which may be appropriate for submittal to NRC by January 15, 1982.
In light of these necessary schedular adjustments, January 15, 1982 would be the appropriate date from which to calculate the installation schedules established in 9 50.48(c)(2) and (3).
In its petition, CP&L pointed out that CP&L has satisfied all of the requirements of Appendix A to BTP 9.5-1 at BSEP and has received a staf f
t Safety Evaluation r.eport approving each such item.
The fire protection features currently install;d at BSEP, therefore, are entirely adequate to protect the health and safe *.y of the public.
It is clear that the NRC Staff believes that requests for extension of time can be granted without adverse impact to the public health and saf ety.
Mr. Edson G. Case filed an Affidavit on June 15, 1981 in the United States Court of Appeals for the District of Columbia Circuit as part of Respondent's Opposition to Motion for Stay in the case of the Connecticut Light and Power Company, et al v. Nuclear Reg-ulatory Commission.
In his Affidavit, Mr. Case stated that licensees for 43 out of the 70 operating plants af fected by the rtile have filed requests for cuensions of the schedule.
Mr. Case revealed that these requests were under review and would be responded to within the next two months.
In fact, an noted above, there has been no Commission action upin CP6L's requests for extension of schedule as of yet.
If the NRC considered that these extensions jeopardized the health and safety of the public, it is evident that the ruling on these requests would have been made long before now.
Clearly then, the granting of QP&L's request for this additional extension of the schedule established in 5 50.48(c) will in no way adversely affect the health and safety of the public.
CP&L, therefore, respectfully requests that the Commission grant the requests for extension set forth herein.
Yours very truly,
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E. E. Utley Executive Vice President Power Supply and Engineering & Construction JAM /1r (4358)
Sworn to and subscribed before me this 14th day of September,1981.
&Y siddCL,b"U!!k Notary Publ ff
". Tr.E My commission expires: Oct. 4, 1981 3
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