ML20087J688
| ML20087J688 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/15/1995 |
| From: | Hicks G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9508220070 | |
| Download: ML20087J688 (5) | |
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CP&L Carolina Power & Light Company P.O. Box 10429
'i Southport, NC 28461-0429 I
AUG151995 SERIAL: BSEP 95-0367 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk 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 i
SUPPLEMENT TO ASME CODE RELIEF REQUEST RHR AND FUEL POOL COOLING MANUAL VALVES Gentlemen:
By letter dated June 7,1995 (Serial: BSEP 95-0162), Carolina Power & Light Company (CP&L) i submitted a request for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI. The relief request pertains to the ASME Code, i
Section XI, Article IWV-3400 requirement that Category B valves in the Residual Heat Removal System and Fuel Pool Cooling System which are used to provide supplemental cooling to the spent fuel pool be exercised at least once every three months.
During telephone discussions with the NRR Project Manager on June 23,1995, CP&L was requested to clarify the following items in our June 7,1995 submittal:
Whether the relief request is based on hardship or impracticality.
The plant operating conditions for which the dose rates described in the relief request would occur.
Plans for testing the supplemental spent fuel pool cooling system prior to placing the system in service.
i The Company hereby resubmits the ASME Code,Section XI relief request in accordance with j
10 CFR 50.55a(a)(3)(ii) based on the hardship described herein. The revised relief request is
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provided in Enclosure 1 with the changes marked by revision bars in the right-hand margin.
Please refer any questions regarding this submittal to Mr. George Honma at (910) 457-2741.
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- Sincerely, I'j f<fy--
. D. Hicks Manager-Regulatory Affairs i
Brunswick Nuclear Plant 9508220070 950815 PDR ADOCK 05000324-P PDR.
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NRC Document Control Desk BSEP 95-0367 / Page 2 WRM!ap
Enclosure:
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Revised Relief Request 2.
Summary of Commitments cc:
Mr. S. D. Ebneter, Regional Administrator, Region ll Mr. D. C. Trimble, NRR Project Manager - Brunswick Units 1 and 2 Mr. C. A. Patterson, NRC Senior Resident inspector-Brunswick Units 1 and 2 The Honorable H. Wells, Chairman - North Carolina Utilities Commission Mr. Billy Walker, Assistant Director - Boiler & Pressure Vessel Division
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ENCLOSURE 1 a
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO RELIEF REQUEST ASME BOILER AND PRESSURE VESSEL CODE, SECTloN XI RHR AND FUEL POOL COOLING MANUAL VALVES SYSTEM:
Residual Heat Removal (E11) and Fuel Pool Cooling (G41)
COMPONENTS:
E11-V40 G41-F004 G41-F016 FUNCTION:
These manual valves are ASME Code,Section XI, Category B valves that have an active safety function (required to change position) to provi-supplemental cooling to the spent fuel pool.
CATEGORY:
B CLASS 2 and 3 TEST REQUIREMENT: ASME Boiler and Pressure Vessel Code,Section XI, Article IWV-3400 requires that Category A and B valves be exercised at least once every three months.
BASIS FOR REllEF:
As required by ASME Code,Section XI, Article IWV-3400, Carolina har & Light Company (CP&L) performs a full-stroke exercising of
,, above identified valves on a quarterly frequency. These 8-inch
,nanual valves are located in an area with a significant background radiation level (approximately 300 millirem per hour while the unit is in operation). Approximately 40 millirem of personnel exposure is received during the performance of this surveillance test for each unit during each calendar quarter. The total site personnel exposure received while performing this surveillance is approximately 320 millirem per year. Therefore, exercising of these valves creates a hardship to CP&L in the area of site personnel exposure.
The alternate testing of these valves is acceptable since the safety function for these valves would only be required when the unit is in Operational Condition 4 (Cold Shutdown) or 5 (Refueling). In accordance with the Brunswick Plant's Updated Final Safety Analysis Report (UFSAR) and Operating Procedures (OP), the supplemental fuel pool cooling safety function of the Residual Heat Removal System can only be employed in Operational Conditions 4 (Cold Shutdown) or 5 (Refueling). As such, operational readiness of these valves need only be verified when the plant is in such operating conditions.
The above referenced valves are not associated with the safety i
function to use Residual Heat Removal System as the seismic makeup j
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to the Fuel Pool Cooling System. Those valves associated with this safety function are unaffected by this re!ief request.
ALTERNATE TESTING: Perform full-stroke exercising of the manual valves prior to placing the system into service. in addition, full-stroke exercising of these manual valves will be performed on a cold shutdown frequency as defined in NUREG-1482, Section 3.1.1.1.
REFERENCES:
UFSAR 5.4.7.2.1.5, 9.1.2 -
1/2-OP-17, RHR System Valve and Electrical Lineup, Sections 8.9 and 8.10 OAOP-38.0, Loss of Fuel Pool Cooling E1-2
ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENT TO RELIEF REQUEST ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI RHR AND FUEL POOL COOLING MANUAL VALVES LIST OF REGULATORY COMMITMENTS The following table identifies those actions cominitted to by Carolina Power & Light Company in this document. Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments.
Committed Commitment date or outage 1.
Perform full-stroke exercising of manual valves E11-V40, G41-F004, N/A and G41-F016 prior to placing the system into service.
(Upon approval of requested relief) 2.
Perform full-stroke exercising of manual valves E11-V40, G41-F004, N/A and G41-F016 on a cold shutdown frequency as defined in (Upon NUREG-1482, Section 3.1.1.1.
approval of requested relief)
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