ML20041F265

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Discusses Final Rule, Interim Requirements Re Hydrogen Control, Effect on Commitments to Satisfy NUREG-0737 Item II.E.4.1 Re Dedicated Hydrogen Penetration.Installation of Penetration Deferred Until Requirements Analyzed
ML20041F265
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 03/11/1982
From: Utley E
CAROLINA POWER & LIGHT CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.4.1, TASK-TM NUDOCS 8203160346
Download: ML20041F265 (2)


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Ss Carolina Power & Light Company E!ECEivgo 9

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MAR v5;gg Q mE$p Mr. Darrell G.

Eisenhut, Director Division of Licensing f

United States Nuclear Regulatory Commission Washington, D.C.

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BRUNSWICK STEAM EL8CTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 NUREG-0737 ITEM II.E.4.1 -

DEDICATED HYDROGEN PENETRATION

Dear Mr. Eisenhut:

SUMMARY

The adoption of the final rule on " Interim Requirements Related to Hydrogen Control", as published in the December 2, 1981 Federal Register, has affected previous commitments provided to satisfy NUREG-0737, Item II.E.4.1, concerning dedicated hydrogen penetrations.

In order to ensure that our hydrogen penetrations planned for Item II.E.4.1 are also compatible with the requirements of the December 2, 1981 final rule, we have re-scheduled thq design, procurement, and installation of the hydrogen penetrations to occur after the analysis of full H 2 recombiner capability is complete.

DISCUSSION By a letter dated October 31, 1980, the NRC provided to all licensees the requirements of NUREG-0737, Clarification of TMI Action Plan Requirements.

NUREG-0737 Item II.E.4.1, i

Dedicated Hydrogen Penetrations, requires a plant using either external recombiners or a purge /repressurization system for post-accident containment hydrogen control to provide a dedicated containment penetration sized to satisfy the flow requirements of either an external recombiner or a purge /repressurization system, as appropriate.

Based on the'NUREG-0737 II.E.4.1 requirements, i

CP&L performed engineering analyses and scheduled equipment delivery necessary to install a dedicated hydrogen penetration at Brunswick as part of the existing purge /repressurization system.

On December 2, 1981, the final rule on " Interim Requirements Related to Hydrogen Control" was published in the Federal Register, 46 FR 58484.

This rule requires the Brunswick Plant to have the capability to install an external hydrogen recombiner following the start of an accident.

The requirements of the final rule represent a significant change in technical

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content from the requirements of the proposed rule as published October 2, 1980 in the Federal Register, 45 FR 65466, and the requirements of NUREG-0737, Item II.E.4.1.

Consequently, CP&L is reviewing, both individually and with the BWR Owners' Group, the hydrogen recombiner requirements and technical bases therefor, the technical bases for hydrogen control, and the schedules required for any necessary modifications at Brunswick.

In the interim, CP&L is deferring the installation of a dedicated hydrogen penetration until the new requirements of the December 2, 1981 final rule can be analyzed adequately.

If we determine that a hydrogen recombiner capability is appropriate, CP&L will size the dedicated H penetration to be compatible with 2

the selected H recombiner design.

At such time, CP&L will adopt 2

a schedule for the installation of the dedicated H 2 penetration which is consistent with the schedule which is ultimately established for installation of the hydrogen recombiner capa-bility.

As CP&L has discussed previously with the Staff, it may be necessary for CP&L to seek an exemption from the schedule established in the December 2, 1981 final rule.

However, if we determine that a hydrogen recombiner capability is not appropriate, we intend to seek an exemption from the relevant portion of the December 2, 1981 final rule and to continue with plans to install a dedicated hydrogen penetration during the next available refueling outage following such a determination.

Yours very truly, Utley}

E.

E.

Executive Vice President Power Supply and Engineering & Construction l

l WRM/lr (nrcl) cc:

Mr.

J.

P.

O'Reilly (NRC-RII)

Mr.

J. Van Vliet (NRC-NRR) l t.