ML20040D888
| ML20040D888 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/18/1982 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NO-82-104, NUDOCS 8202020353 | |
| Download: ML20040D888 (3) | |
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RECEWGD C rolina Power & Light Company FEB1 1ggg ![3
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<v File: NG-3514(B)
Serial No.:
NO 'lIdd Honorable Nunzio J. Palladino Chairman United States Nuclear Regulatory Commission Washington, D.C.
20555 BRUNSWICK 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 PETITION OF CAROLINA POWER & LIGHT COMPAh"I FOR 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 require-ments of 10CFR 550.48 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, Unit Nos. 1 and 2 (BSEP).
By letter dated September 14, 1981, CP&L amended its March 6,1981 petition with respect to certain schedules for submitting information.
In our September 14, 1981 letter, CP&L requested exemptions from 550.48 in the following respects:
(1)
CP&L requested the following extensions of schedule:
(a) Extend from September 1, 1981 to January 15, 1982 the date for:
(i)
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 5550.12(a) and 50.48(c)(6).
fp (b) Extend from December 1, 1981 to January 15, 1982 the date j
for submittal of design descriptions of alternative or dedicated shutdown systems to comply with Section III.G.3,
}g if such are necessary, 8202020353 820118
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PDR ADOCK 05000324 Box 1551
- Raleigh, N. C, 27602 F
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_(c) Extend from December 1, 1981 to January 15, 1982 the date from which the installation schedules established in 550.48(c)(2) and (3) are calculated.
CP&L hereby requests that -the schedules for each of the items set forth in numbered paragraph (1) be extended until June 30, 1982.
These modifications of schedule are necessary to enable CP&L to complete the tasks we must perform in order to comply with the fire protection rule. In our March 6,1981 petition, CP&L stated that it had.
initiated studies to determine to what extent our previously completed and approved fire' protection 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 modifi-cations will be necessary to achieve < spliance with Section III.G; to develop all plans and schedules for any nodifications necessary to satisfy Section III.G.2; and to prepare and submit design descriptions for an alternative or dedicated shutdown system to satisfy Section III.G.3 if such a system is necessary.
While CP&L and our architect-engineer have made every reasonable effort to meet the schedules proposed by CP&L in our petition and sub-sequent letter of September 14, 1981, these extensive studies have produced a significant amount of results and recommendations that must now be evaluated for their safety significance. Approximately 12,000 s
man-hours were expended conducting the fire protection analyses. The results were received from our architect-engineer last week for one Brunswick unit, and should be received for the second unit by January 22, i
1982. Prior to implementing design changes, the scudy results must be evaluated to determine if there-are unreviewed safety issues involved or other safety concerns.
Because of the extensive scope of the study, a substantial evaluation will be required by CP&L engineering and plant-personnel.
CP&L believes that it will be able to conclude the studies; develop necessary plans, schedules, and design descriptions; and complete any additional exemption requests which may be appropriate for submittal to NRC prior to June 30, 1982.
In light of these necessary schedular adjust-ments, June 30, 1982 would be the appropriate date from which to calculate the installation schedules established in 550.48(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 Staff Safety Evaluation Report approving each such item.
The fire protection features currently installed at BSEP, therefore, are entirely adequate to protect the health and safety of the public.
As discussed in our March 6 and September 14, 1981 letters, 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 safety, and that the granting of CP&L's request for this additional extension of
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the schedule established in 550.48(c) vill 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.
Yoars v(ry truly,
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E E. Utley Executive Vice President' Power Supply and
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Engineering & Construction i s DLB/1r (1405)
Sworn to and subscribed before me this 18th day of January,1982.~
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0 Notary Public My commission expires: Oct. 4, 1986
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