ML20084F087
| ML20084F087 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/25/1984 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| IEB-79-01B, IEB-79-1B, NLS-84-126, NUDOCS 8405030116 | |
| Download: ML20084F087 (8) | |
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Carolina Power & Light Company SERIAL: NLS-84-126 P. O. Box 1551 e Raleigh, N. C. 27602 APR 2 51984 E.E.UTLEY Executt* e Vice President Power Supply and Engineering & Construction Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-324/ LICENSE NO. DPR-62 ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT - EXTENSION REQUEST PER 10 CFR 50.49(g)
Dear Mr. Denton:
INTRODUCTION During a February 2, 1984 meeting held with your staff, Carolina Power & Light Company (CP&L) notified the NRC per 10 CFR 50.49(h) that an extension to the schedular requirements described in 10 CFR 50.49(g) would be required for the Brunswick Steam Electric Plant (BSEP) Unit No. 2.
This letter requests an extension until November 30, 1985 to complete the environmental qualification of certain equipment pertaining to BSEP Unit No. 2.
Carolina Power & Light Company has followed and will continue to follow a deliberate, but continuous path in pursuit of final qualification as required by 10 CFR 50.49.
Due to the complexities of the procurement and modifications required to properly integrate the 10 CFR 50.49 related work with already scheduled regulatory and maintenance work and the resulting magnitude of the change in plant design, CP&L has determined that it is prudent to request a schedular extension for Unit No. 2 to ensure proper management control of affected outages. We believe that this course of action affords the best protection for the interest of the public health and safety.
It is anticipated that BSEP Unit No. I will meet the schedular requirements established in the environmental qualification rule.
Carolina Power & Light Company is also considering a plan to replace recirculation piping on both Brunswick Units in 1985 and 1986. Adoption of this plan would require CP&L to further modify the scope and schedule of the presently planned outages. Carolina Power & Light Company expects to finalize its plans and notify you of the need for any required extension requests by December 31, 1984.
8405030116 840425 PDR ADOCK 05000324 0
P PDR IlI
i Harold R. Denton DISCUSSION When CP&L set out to respond to IEB 79-013, we determined to do so in a deliberate manner. Accordingly, we commissioned our A/E, United Engineers &
Constructors, to compile a list of safety-related equipment (Master List).
This list was assembled by referencing the design documents for BSEP and contained approximately 1500 items per unit. Since the initial list was made using the original design documents, we considered it necessary to verify it by field inspection. Concurrently with the field verification, we contacted equipment vendors in an attempt to develop qualification information on the installed equipment, or failing that, to procure qualified replacements.
As stated in our May 20, 1983 submittal, CP&L intended to achieve full compliance with the environmental qualification rule by the summer of 1984 for BSEP Unit No. I and by winter 1984/1985 for BSEP Unit No. 2.
However, due to significant conflicting scheduling problems discussed in detail in, CP&L was forced to reschedule the refueling outages for both units. The changes in the operational plan af fected the capability of meeting the schedular requirements of paragraph (g) of 10 CFR 50.49 for Unit No. 2.
The above mentioned changes in the operating plan moved the starts of the second refueling outages af ter March 31, 1982 from July 1984 up to March 1985 for Unit No. 1, and from December 1984 to March 1984 for Unit No. 2.
The juxtaposition of the respective unit outages, and the consequent loss of nine months of preparation time for Unit No. 2 modifications, compounded by the magnitude of other work that must be accomplished, has effectively prevented CP&L from being able to complete the environmental qualification effort for BSEP Unit No. 2 electrical equipment as originally intended. A list of the remaining equipment for which replacement will be required per rection (g) of the environmental qualification rule is provided for your information in.
The environmental severity reduction modifications will also require an extension due to material delivery schedule.
The extension of BSEP Unit No. 2 past March 31, 1985 to November 1985 is necessitated by the work schedule for BSEP Unit No. 1.
As noted above, the second refueling outage for BSEP Unit No. I will commence in March 1985, and it is expected that compliance with the environmental qualification rule will be achieved during that outage. Management of construction and engineering j
resources and application of project management expertise to BSEP Unit No. I will preclude any degree of effort being simultaneously applied to BSEP Unit No. 2.
Since meaningful work could not be accomplished with both units down, the extension is being requested to November 30, 1985 to allow the return to service of BSEP Unit No. 1.
l CONCLUSION Carolina Power & Light Company believes it has made a good faith effort to complete work required by 10 CFR 50.49 within the schedule provided in paragraph (g) of the rule. To date, CP&L has spent approximately eight million dollars towards the engineering and installation of EQ-related modification packages. Of approximately 500 components requiring
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4 Harold R. Denton i j
replacement / installation addressed in our program, nearly 100 will have been j
completed before the end of the present outage and approximately 75 of the remaining items cannot be completed due to non-availability of qualified
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replacements. Therefore, as provided in 10 CFR 50.49(g), CP&L is seeking a schedular extension to November 30, 1985 for all items in Attachment 2.
In support of our request for deferral, a reference to previously submitted l,
justifications for continued operation (for each piece of equipment), is also included in Attachment 2.
Since nothing in this extension request serves to change the plant conditions or parameters f rom those previously justified, CP&L reaffirms the previously submitted bases for continued operation.
i Should you have any questions regarding this request, please contact a member of our Licensing Staff.
I Yours very truly, 4
i hay 1)
E. E. Utley 4
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j cc:
Mr. D. O. Myers (NRC-BSEP)
Mr. J. P. O'Reilly (NRC-RII)
Mr. M. Grotenhuis (NRC) l I
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ATTACHMENT I OUTAGE SECHEDULE CHANGES IMPACTING ENVIRONMENTAL QUALIFICATION The following events have severely affected the fuel cycle and outage sequence for both Brunswick Units and have resulted in major changes to the scheduling of the units' refueling outages:
1.
The Unit No. I outage of December 1982, which was originally scheduled for 25 weeks, was extended to 36 weeks and was completed in mid-August 1983.
2.
In July 1983, the NRC issued an order for Intergranular Stress Corrosion Cracking (IGSCC) inspections on Unit No. 2.
A shutdown date of November 1983 was designated to prevent outage overlap with Unit No. 1.
This November shutdown was an unscheduled outage which, due to problems with the unit battery, increased to eight weeks duration.
3.
The original nuclear operating plan for 1983 and 1984 had two j
outages to complete EQ for Unit No. 2 and one outage for Unit No. 1, all of which were within the schedular requirement of-10 CFR 50.49.
Specifically for Unit No. 2, the plan showed a maintenar.ce outage in the fall of 1983 followed by refueling outage in the winter of 1984.
For Unit No. 1, the plan showed a refueling outage in the summer of 1984.
The extended Unit No.1 outage and the shutdown order for Unit No. 2 pushed the start of a planned maintenance Unit No. 2 outage from September 1983 to the next refueling window in the spring of 1984. Therefore, the originally planned " September 1983 maintenance outage" was rescheduled to start in March 1984, and became the "second refueling outage af ter March 31, 1982" which is referenced in paragraph (g) of 10 CFR 50.49.
As a result of these changes, Brunswick U' it No. 2 effectively lost one outage n
in which to complete portions of the EQ work and 9 months of preparation time. This meant that the entire EQ work scope, which had already been scheduled to be completed by the end of the originally planned December 1984 outage, was pushed into the rescheduled March 1984 outage.
Specifically, the outage started on March 12, 1984 and has a planned duration of 30 weeks. During that time, 78 major modifications and projects will be made to the plant including 49 regulatory mandated items. These items include off-gas recombiner and A0G system work, seismic supports, Mark I containment long-term torus modifications, IGSCC inspections, 10-year inservice inspections, analog instrumentation replacements, and modifications related to environmental qualification (10 CFR 50.49). The remaining major projects consist principally of the service water system upgrade, condenser retubing, RWCU system upgrade, replacement of the extraction steam line, refueling (and associated work) and routine surveillance testing including ILRT. At its peak, the outage will involve some 160 procedure changes. An outage of this size already approaches the limits of work scope that responsible management permits to occur in a single outage.
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ATTACHMENT 2 UNIT 2 1 of 1 REPLACEMENT ITEMS TO BE DEFERRED - QUALIFIED REPLACEMENTS NOT AVAILABLE JC0 5/20/83 INDEX ITEM PLANT ID #
SCEWS #
REMARKS NUMBER Pressure Switch B32-PS-N018A,A-1 2057 Barksdale 74 Pressure Switch B32-PS-U018B 2058 Barksdale 81 i
Pressure Switch E11-PS-N016A-D 2059 Barksdale 71 Pressure Switch Ell-PS-N020A-D 2060 Barksdale 73 Pressure Switch E41-PSH-N012A-D 2061 Barksdale 79,80 Pressure Switch E41-PSH-N017A,B 2062 Barksdale 73 Pressure Switch E41-PSH-N027 2063 Barksdale 73 Pressure Switch E51-PS-N019A-D 2064 Barksdale 75 Pressure Switch E51-PS-N020 2065 Barksdale 72 Pressure Switch E51-PSH-N009A,B 2066 Barksdale 76 Pressure Switch E51-PSH-N012A-D 2067 Barksdale 76 Pressure Switch IA-PSL-3594,5 2068 Barksdale Note 1 Pressure Switch SW-PS-1175.6 2071 Barksdale Note 1 Temperature Switch SW-TS-Il09-12 2072 Barksdale 99 l
Pressure Switch CAC-PDS-4222,3 2073 Barton 57 Flow Switch Ell-PDIS-N021A,B 2074 Barton 96 Flow Switch E21-FS-N006A,B 2075 Barton 98 Flow Switch E41-FSL-N006 2076 Barton 97 Flow Switch E51-FS-N002 2078 Barton 97 Pressure Suitch E41-PS-N001A-D 2077 Barton 59 Limit Switch B21-F003,4; 2143 Honeywell 124 B32-F019 124 Connector NS2 2238 Pyle National 169 Level Switch E41-LSH-N015A,B 2243 Robertshaw 82 Control Switch B32-CS-F019,20 2261,2 Sentry Note 2 Pressure Switch Ell-PS-N010-A-D 2265 Static-0-Ring.
60 Pressure Switch C72-PS-N002A-D 2264 Static-0-Ring 61 Pressure Switch Ell-PS-N011A-D 2266 Static-0-Ring 61 Pressure Switch Ell-PS-N019A-D 2267 Static-0-Ring 61 Pressure Switch E21-PS-N008A,B 2268 Static-0-Ring 63 Pressure Switch E21-PS-N009A,B 2268 S tatic-0-Ring 63 Pressure Switch E41-PS-N010 2269 Static-0-Ring 62 NOTES:
1.
JC0 index number 77 is applicable to these items as they are the same model number (D2TM150SS)
- 2. JC0 supplied as page VII-14 of CP&L's 5/20/83 submittal.
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4 ATTACHMENT 2 UNIT 2 1 of 3 REPLACEMENT ITEMS TO BE DEFERRED DUE TO SCHEDULE RESTRAINTS i
1 JC0 5/20/83 INDEX ITEM PLANT ID #
SCEWS #
REMARKS NUMBER Time Delay Relay DBO-74-17 2123 Agastat 143 Solenoid Valve B32-F020 2012 ASCO 45 Solenoid Valve CAC-PV-1260-1,2 2013 ASCO 35 Solenoid Valve CAC-PV-3439,40 2014 ASCO (Note 1)
Solenoid Valve CAC-SV-4222,3 2015 ASCO 24 Solenoid Valve CAC-V4,5,8 2016,17 ASCO 25,26,53 Solenoid Valve CAC-V6 2018,9 ASCO 36,38 Solenoid Valve CAC-V7 2020 ASCO 52 Solenoid Valve CAC-V9 2021 ASCO 49 Solenoid Valve CAC-V10 2022 ASCO 37 Solenoid Valve CAC-VIS 2023 ASCO 36 Solenoid Valve CAC-V47,55,56 2024,5 ASCO 29,30 Solenoid Valve CAC-V48 2026,7 ASCO 45,50 Solenoid Valve CAC-V49,50 2028 ASCO 44 j
Solenoid Valve C12-F110A,B 2030 ASCO 44 Solenoid Valve Ell-F053A,B 2032 ASCO 30 i
Solenoid Valve G16-F003,04,19,30 2033 ASCO 45 Solenoid Valve TD-SV-3598,3601 2051 ASCO (Note 1)
Solenoid Valve 2(A-D)-BFIV-RB 2052 ASCO 39
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Pressure Transmitter CAC-PT-1257-2 2055 Bailey 67 Flow Transmitter VA-FT-2577 2056 Bailey 93 ls i
Terminal Blocks Penetration Boxes 2097 Curtis 182 J
Inside Containment Motor NP6,7-MOT-M1 2098 Doerr (Note 2) l Motor NP6,7-MOT-M2 2099 Doerr (Note 2)
Temperature Switch B21-TS-N010A-D 2101 Fenwall 109 i
Temperature Switch E41-TS-3314 2102 Fenwall 110 j
Temperature Switch E41-TS-3315-8,3354 2103 Fenwall 112 i
Temperature Switch E41-TS-3488,9 2104 Fenwall 107 Temperature Switch E51-TS-3319-23,3355 2105,6 Fenwall 108,111 i
Temperature Switch E51-TS-3487 2107 Fenwall 108 J
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f ATTACHMENT 2 I
UNIT 2 2 of 3 i
l REPLACEMENT ITEMS TO BE DEFERRED DUE TO SCHEDULE RESTRAINTS I
JC0 i
5/20/83 INDEX ITEM PLANT ID #
SCEWS #
REMARKS NUMBER Pressure Transmitter C32-PT-N005A,B 2110 GE 68 Radiation Detector D12-RE-N010A,B 2111 GE 148 Pressure Transmitter Ell-PDT-N002A,B 2114 GE 69
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Flow Transmitter E41-FT-N008 2116 GE 95 Terminal Block Penetration Boxes 2119 GE 180 Inside Containment i
j Solenoid Valve VA-SV-936A,B 2157 Johnson Sves.
34 Temperature Switch VA-TS-936A-F 2158 Johnson Sves.
113,114 Position Switch VA-ZS-936A,B 2159 Johnson Sves.
123 Limit Switch C12-F010-L 2164-1 NAMCO (Note 3) j Limit Switch E51-C002-LS4 2166 National ACME 155 Accelerometer B21-FT-4157 to 67 2168 NDT Int'l.
(Note 4)
I Motorized Viv Actuator B21-F016 2184 Limitorque 20 Motorized Viv Actuator Ell-F022 2184 Limitorque 20 l
Motorized Viv Actuator CAC-V22 2188 Limitorque 1
Motorized Viv Actuator E51-F007 2222 Limitorque 20
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Motorized Viv Actuator E51-F019 2225 Limitorque 17 RTD CAC-TE-1258-1 to 2235 PYC0 100 13 & 22,23,24 RTD CAC-TE-1258-14,21 2236 PYC0 100 RTD CAC-TE-1258-17, 2237 PYC0 100 i
18,19,20 i
Float Switch E51-C002-H 2263 Square D (Note 5)
Pressure Switch E51-PSL-N006 2270 Static-0-Ring 62 i
l Level Transmitter B21-LITS-N026A,B 2279 Yarway 85 (9714PPCa/pgp)
ATTACHMENT 2 UNIT 2 3 of 3 REPLACEMENT ITEMS TO BE DEFERRED DUE TO SCHEDULE RESTRAINTS JC0 5/20/83 INDEX ITEM PLANT ID #
SCEWS #
REMARKS NUMBER Reactor Instrument 27 Soleniods 2035-7 Manufactured by:
27,28,35 Penetration System 25 Press. SW 2041-3 ASCO, Barksdale, 41,42,47, Components Consisting 62 Pos. SW 2046,7 Cherry Electric 48,ASC0; of; Solenoid Vivs.
42 Flow SW 2069,70 and Magnetrol 77,78, Pressure Switches, 2094,5 Barksdale; Position Switches and 2160,1 94,122 Flow Switches Cherry Electric; 91 Magnetrol Standby Gas Treatment 4 Switches 2084 Manufactured by:
- 116, System Components 8 Indicator 2090 Bettis, Bradley, Bettis; Consisting of; Lights 156 Swtiches, Indicator 8 MCC 2100 Farr and NAMCO
- Farr, Lights, Various MCC Components Bradley; components, Limit 4 Limit 2165 115, NAMCO Swtiches Switches Notes 1.
As noted in previous submittals, the same justification is applicable to all existing installed ASCO solenoid valves.
2.
JC0 supplied as page VII-17 of CP&L's 5/20/83 submittal.
3.
JC0 supplied as page VII-ll of CP&L's 5/20/83 submittal.
4.
JC0 supplied as page VII-12 of CP&L's 5/20/83 submittal.
5.
JC0 supplied as page VII-18 of CP&L's 5/20/83 submittal.
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