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Category:CORRESPONDENCE-LETTERS
MONTHYEARBSEP-99-0170, Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6)1999-10-19019 October 1999 Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6) BSEP-99-0161, Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V3511999-10-13013 October 1999 Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351 ML20217G1191999-10-0808 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Brunswick NPP & Did Not Identify Any Areas Where Performance Warranted More than Core Insp Program.Nrc Plan to Conduct Only Core Insps at Facility Over Next Five Months ML20217C6931999-10-0606 October 1999 Forwards Insp Repts 50-324/99-06 & 50-325/99-06 on 990801- 0911 at Brunswick Reactor Facility.No Violations Were Identified BSEP-99-0114, Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl1999-10-0404 October 1999 Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl BSEP-99-0157, Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii)1999-10-0404 October 1999 Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii) BSEP-99-0142, Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-23023 September 1999 Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0158, Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-21021 September 1999 Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0153, Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 19991999-09-14014 September 1999 Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 1999 BSEP-99-0147, Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval1999-09-14014 September 1999 Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval BSEP-99-0151, Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP1999-09-0808 September 1999 Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP BSEP-99-0149, Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld1999-09-0202 September 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld BSEP-99-0150, Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-0202 September 1999 Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0112, Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl1999-09-0101 September 1999 Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl ML20211K9001999-08-27027 August 1999 Forwards Insp Repts 50-324/99-05 & 50-325/99-05 on 990620-0731.Two Violations Occurred & Being Treated as NCVs BSEP-99-0146, Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl1999-08-26026 August 1999 Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl BSEP-99-0148, Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 21999-08-25025 August 1999 Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 2 BSEP-99-0141, Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-08-25025 August 1999 Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0130, Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl1999-08-25025 August 1999 Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl BSEP-99-0132, Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl1999-08-20020 August 1999 Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl BSEP-99-0134, Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl1999-08-13013 August 1999 Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl ML20210S9061999-08-11011 August 1999 Informs That GE Document Entitled, Addl Info Regarding 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12, Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act BSEP-99-0128, Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant1999-08-11011 August 1999 Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant ML20210S9121999-08-11011 August 1999 Informs That Document NEDC-31624P,Suppl 2,Rev 6,entitled, Loss-Of-Coolant Accident Analysis Rept for Brunswick Steam Electric Plant Unit 2,Reload 13,Cycle 14 Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) ML20210P8221999-08-11011 August 1999 Advises That Info Contained in Which Submitted Document,Prepared by Siemens Power Corp,EMF-2168(P) Rev 0, Marked Proprietary,Will Be Withheld from Public Disclosure, Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954 ML20210P9381999-08-10010 August 1999 Forwards SE Accepting Licensee & Suppls & 0517,which Submitted Assessment of Impact on Operation of Unit 1 with Crack Indications of 2.11, 6.36 & 1.74 Inches in Three Separate Jet Pump Risers ML20210P8911999-08-10010 August 1999 Forwards SE Authorizing Relief Requests CIP-01,02,06,07,08, 09,10,11 (with Certain Exceptions) & 12-18,for Second 10-year ISI Interval.Requests CIP-04 & 05 Would Result in Hardship,Relief CIP-03 Not Required & CIP-11 Denied in Part BSEP-99-0110, Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI1999-08-0505 August 1999 Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI BSEP-99-0123, Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 21999-08-0505 August 1999 Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 2 ML20210Q4581999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section to Written Operator Licensing Exam on 991006. Authorized Representative of Facility Must Submit List of Individuals to Take exam,30 Days Before Exam Date ML20210P2031999-08-0505 August 1999 Discusses Staff Response to GL 92-01,Rev 1,Suppl 1, Rv Structural Integrity for Plant,Units 1 & 2 ML20210N2041999-08-0505 August 1999 Forwards SE Accepting Response to GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Unresolved Safety Issues (USI) A-46, & Suppl 1 BSEP-99-0127, Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl1999-08-0505 August 1999 Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl BSEP-99-0124, Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld1999-07-30030 July 1999 Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld ML20210G2941999-07-28028 July 1999 Discusses Public Meeting Conducted on 990720 to Present Results of Periodic Plant Performance Review for Brunswick Facility for Period of May 1997 to January 1999.List of Attendees Encl BSEP-99-0122, Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld1999-07-20020 July 1999 Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld BSEP-99-0121, Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant1999-07-19019 July 1999 Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant BSEP-99-0111, Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR1999-07-19019 July 1999 Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR ML20210E1181999-07-19019 July 1999 Forwards Insp Repts 50-324/99-04 & 50-325/99-04 on 990509- 0619.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20209G1081999-07-13013 July 1999 Forwards Radiological Emergency Response Plan & Revised Epips,Including Rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26 BSEP-99-0106, Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl1999-06-28028 June 1999 Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl BSEP-99-0103, Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 11999-06-24024 June 1999 Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 1 BSEP-99-0100, Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results1999-06-23023 June 1999 Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results BSEP-99-0105, Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl1999-06-23023 June 1999 Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl ML20196H8191999-06-21021 June 1999 Informs That on 980915,Commission Suspended SALP Program for an Interim Period Until NRC Completes Review of Process for Assessing Performance at NPPs ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First BSEP-99-0091, Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-06-14014 June 1999 Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20196A8111999-06-14014 June 1999 Ack Receipt of 990401 Response to NRC Ltr Issued on 990302 Re OI Investigation to Determine Whether Former BSEP Manager Threatened to Fire Employees Who Brought Safety Concerns to Nrc.Concluded That No Violation Occurred ML20195J1971999-06-14014 June 1999 Advises That GE-NE-523-B13-01920-56,Rev 1,submitted with 990202 Affidavit,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) & Section 103(b) of AEA of 1954,as Amended BSEP-99-0090, Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 9905141999-06-0909 June 1999 Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 990514 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARBSEP-99-0170, Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6)1999-10-19019 October 1999 Forwards Proprietery Notification of Change in Operator Status.Individual Name,Docket Number,License Number & Effective Date of Expiration,Encl.Proprietary Info Withheld, Per 10CFR2.790(a)(6) BSEP-99-0161, Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V3511999-10-13013 October 1999 Submits Response to NRC RAI Re Relief Request VRR-03.VRR-03 Requested Relief from full-stroke Open Exercise Requirements for Supply Check Valves to air-operated Valves 1(2)-RNA-V313,1(2)-RNA-V314,1(2)-RNA-V350 & 1(2)-RNA-V351 BSEP-99-0114, Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl1999-10-0404 October 1999 Forwards Supplemental Biological Assessment Submitted by CP&L Providing Updated Data for 1998 & 1999. Pictures of Intake Canal at Diversion Structure During High Tide Conditions Also Encl BSEP-99-0157, Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii)1999-10-0404 October 1999 Submits Annual Rept Summarizing Effect of Changes & Errors in Accepted loss-of-coolant Accident ECCS Evaluation Models Applicable to Bsep,Units 1 & 2 IAW 10CFR50.46(a)(3)(ii) BSEP-99-0142, Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-23023 September 1999 Forwards Proprietary Updated List of Home Addresses for Individuals Licensed to Operate CP&L Bsep,Units 1 & 2. Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0158, Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-21021 September 1999 Provides Proprietary Notification of Change in Operator Status.Individual Name,Docket Number,License & Effective Date of Expiration Provided in Encl to Ltr.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0153, Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 19991999-09-14014 September 1999 Forwards Monthly Operating Repts for Brunswick Steam Electric Plant,Units 1 & 2.CP&L Is Submitting Encl Rept of Operating Statistics & SD Experience for Aug 1999 BSEP-99-0147, Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval1999-09-14014 September 1999 Forwards Response to NRC Telcon RAI Re Relief Requests RR-5, 12,13,14,22,23,24 & 25,per Inservice Insp Program for Third 10-yr Interval BSEP-99-0151, Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP1999-09-0808 September 1999 Notifies NRC That Unit 1 Digtial FW Control Sys Upgrade Was Completed on 990831 During Plant Sd.Action Completes Y2K Remediation Activities for BSEP BSEP-99-0150, Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-09-0202 September 1999 Forwards Proprietary Info Re Positive Drug Test for Operator Licensed on CP&L Bsep,Units 1 & 2,in Response to NRC .Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0149, Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld1999-09-0202 September 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Form 398 & NRC Form 396,for Operators Licensed at Plant.Proprietary Encls Withheld BSEP-99-0112, Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl1999-09-0101 September 1999 Forwards Summary of Exam Results for Feedwater Sparger & Nozzle Exams Performed During RFO13.Evaluation of Exam Results Documented in ESR 98-00333, Unit 2 Feedwater Sparger Evaluation Based on B214R1 IVVI Exam Results, Encl BSEP-99-0146, Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl1999-08-26026 August 1999 Forwards Revised EPIPs for Bsep,Units 1 & 2.List of Revised Procedures & Summary of Changes Are Encl BSEP-99-0141, Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-08-25025 August 1999 Forwards Proprietary Info Re Expiration of Operator Licenses SOP-20812-1,OP-20977-1 & OP-21217,per 10CFR50.74(b) Re Notification of Changes in Operator Status.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0148, Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 21999-08-25025 August 1999 Forwards Rev 0 to NF-908.03, Brunswick Unit 2,Cycle 14 Neutronics Startup Rept, IAW Section 13.4.2.1 of UFSAR for Brunswick Steam Electric Plant,Units 1 & 2 BSEP-99-0130, Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl1999-08-25025 August 1999 Requests Relief from ASME Boiler & Pressure Vessel Code, Section Xi,Iaw 10CFR50.55a(g)(5)(iii) & NRC GL 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1,2 & 3 Piping. Regulatory Commitments,Encl BSEP-99-0132, Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl1999-08-20020 August 1999 Requests Delay in Providing Update on Util Intended Actions Re GL 96-06,until 180 Days After NRC Approval of Generic Technical Basis.List of Regulatory Commitments,Encl BSEP-99-0134, Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl1999-08-13013 August 1999 Forwards Monthly Operating Repts for July 1999 for BSEP, Units 1 & 2.Revised Rept for June 1999 for Unit 2,reflecting Info on 990628 Forced Shutdown of Plant,Encl BSEP-99-0128, Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant1999-08-11011 August 1999 Forwards Revised Relief Request RR-17,applicable to Remainder of Third 10-year ISI Program for Plant BSEP-99-0127, Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl1999-08-0505 August 1999 Forwards Rev 3 to Physical Security & Safeguards Contingency Plan, for Brunswick Steam Electric Plant,Units 1 & 2.Without Encl BSEP-99-0123, Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 21999-08-0505 August 1999 Forwards Rev 54 to Radiological Emergency Response Plan (RERP) & Revised Epips,Including Re 44 to OPEP-02.1,rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26.Summary of Changes Provided in Encl 2 BSEP-99-0110, Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI1999-08-0505 August 1999 Forwards Rev 0 to ESR 99-00279, B214R1 RPV Hydrotest Bolted Connection Corrective Action Evaluation, IAW Subparagraph IWB-3144(b) of 1989 Edition of ASME B&PV Code, Section XI BSEP-99-0124, Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld1999-07-30030 July 1999 Forwards Proprietary Medical Status Rept & NRC Form 396 for Individual Holding License SOP-20811-1. Proprietary Encls Withheld BSEP-99-0122, Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld1999-07-20020 July 1999 Informs That,Effective 990702,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired Because Individual Employment at BSEP Was Terminated.Proprietary Encl Containing Name,Docket & License Number Withheld BSEP-99-0111, Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR1999-07-19019 July 1999 Forwards New Affidavit Supporting Withholding of Proprietay Info Provided by GE Entitled, Addl Info Re 1.09 Cycle Specific SLMCPR for Brunswick Unit 1 Cycle 12 & Included in Util 980223 LAR BSEP-99-0121, Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant1999-07-19019 July 1999 Submits Response to Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates. Estimates That 14 Submittals Will Be Made During Fy 2000 & Nine Will Be Made During Fy 2001 for Plant ML20209G1081999-07-13013 July 1999 Forwards Radiological Emergency Response Plan & Revised Epips,Including Rev 4 to OPEP-02.1.1 & Rev 7 to OPEP-02.6.26 BSEP-99-0106, Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl1999-06-28028 June 1999 Informs That Units 1 & 2 Odcm,Spec 7.3.10, Gaseous Radwaste Treatment Sys Requires Gaseous Radwaste Treatment Sys to Be in Operation Whenever Main Condenser Air Ejector Sys Is in Operation.Special Rept Encl BSEP-99-0103, Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 11999-06-24024 June 1999 Submits follow-up Info Re Interlaboratory Comparison Program for 1998 Radiological Environ Operating Rept,Suppl 1 BSEP-99-0100, Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results1999-06-23023 June 1999 Forwards Rev 0 to Calculation 2B11-0001, Core Shroud B214R1 Structural Evaluation, Which Provides Evaluation of Unit 2 Core Shroud Insp Results BSEP-99-0105, Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl1999-06-23023 June 1999 Forwards Rev 6 to OPEP-02.6, Severe Weather. Summary of Changes Encl BSEP-99-0091, Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-06-14014 June 1999 Notifies That Operator Licensed on Units 1 & 2,has Been Reassigned to non-licensed Activities & Operator License Considered Expired.Proprietary Info Encl.Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0090, Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 9905141999-06-0909 June 1999 Provides Notification That Data Point D23C0315 Has Been Restored to Original Configuration During RFO on 990514 BSEP-99-0092, Informs That,Effective 990513,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired.Proprietary Encl Containing Name of Individual,Docket Number,License Mumber & Date of Expiration Encl.Proprietary Encl Withheld1999-06-0808 June 1999 Informs That,Effective 990513,NRC Operator License for Individual Licensed on BSEP Units 1 & 2,expired.Proprietary Encl Containing Name of Individual,Docket Number,License Mumber & Date of Expiration Encl.Proprietary Encl Withheld BSEP-99-0085, Forwards Proprietary Rev 67 to EPIP OPEP-App a, Emergency Response Resources & non-proprietary Rev 53 to Radiological Emergency Response Plan, Rev 15 to EPIP OPEP- 03.8.2 & Rev 17 to EPIP OPEP-04.2.Proprietary Info Withheld1999-05-27027 May 1999 Forwards Proprietary Rev 67 to EPIP OPEP-App a, Emergency Response Resources & non-proprietary Rev 53 to Radiological Emergency Response Plan, Rev 15 to EPIP OPEP- 03.8.2 & Rev 17 to EPIP OPEP-04.2.Proprietary Info Withheld BSEP-99-0078, Provides Addl Info Re Jet Pump Riser Weld Insp Results,Per 990406 Telcon with NRC Re Effect of worst-case Crack on LPCI Sys Flow & PCT1999-05-17017 May 1999 Provides Addl Info Re Jet Pump Riser Weld Insp Results,Per 990406 Telcon with NRC Re Effect of worst-case Crack on LPCI Sys Flow & PCT BSEP-99-0080, Forwards Revs Made to TS Bases Between 980605 & 990507 Without Prior NRC Approval1999-05-17017 May 1999 Forwards Revs Made to TS Bases Between 980605 & 990507 Without Prior NRC Approval BSEP-99-0083, Forwards Two Proprietary License Renewal Applications Consisting of NRC Forms 398 & 396,for Operators Licensed on CP&L Bsep,Units 1 & 2,IAW 10CFR55.57.Proprietary Info Withheld from Public Disclosure IAW 10CFR2.790(a)(6)1999-05-14014 May 1999 Forwards Two Proprietary License Renewal Applications Consisting of NRC Forms 398 & 396,for Operators Licensed on CP&L Bsep,Units 1 & 2,IAW 10CFR55.57.Proprietary Info Withheld from Public Disclosure IAW 10CFR2.790(a)(6) BSEP-99-0056, Forwards 1998 Radiological Environ Operating Rept for BSEP, Units 1 & 2. Encl 1 Provides List of Regulatory Commitments.Vols II & Iii,Sample Analysis Data for Jan-June 1998 & Jul-Dec 1998,respectively1999-05-13013 May 1999 Forwards 1998 Radiological Environ Operating Rept for BSEP, Units 1 & 2. Encl 1 Provides List of Regulatory Commitments.Vols II & Iii,Sample Analysis Data for Jan-June 1998 & Jul-Dec 1998,respectively BSEP-99-0073, Withdraws Request for Approval of Proposed QAP Change Which Was Submitted by1999-05-12012 May 1999 Withdraws Request for Approval of Proposed QAP Change Which Was Submitted by BSEP-99-0062, Forwards Latest Revs of COLR & Suppl Reload Licensing Rept, for Bsep,Unit 2.Proprietary Rev 6,Suppl 2 to NEDC- 31624P & EMF-2168P,included.Proprietary Encls Withheld, Per 10CFR2.790 & 10CFR9.171999-05-11011 May 1999 Forwards Latest Revs of COLR & Suppl Reload Licensing Rept, for Bsep,Unit 2.Proprietary Rev 6,Suppl 2 to NEDC- 31624P & EMF-2168P,included.Proprietary Encls Withheld, Per 10CFR2.790 & 10CFR9.17 BSEP-99-0079, Forwards Proprietary One License Renewal Application Consisting of NRC Form 398, Personal Qualification Statement - Licensee & NRC Form 396, Certification Of... Proprietary Info Withheld,Per 10CFR2.790(a)(6)1999-05-0707 May 1999 Forwards Proprietary One License Renewal Application Consisting of NRC Form 398, Personal Qualification Statement - Licensee & NRC Form 396, Certification Of... Proprietary Info Withheld,Per 10CFR2.790(a)(6) BSEP-99-0066, Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided1999-05-0404 May 1999 Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided ML20195D6301999-04-30030 April 1999 Forwards Natl Marine Fisheries Svc Biological Opinion Based on Review of Continued Use of Cooling Water Intake Sys at Bsep.Rept Reviews Effects of Activity on Loggerhead,Kemps Ridley,Green,Hawksbill & Leatherback Sea Turtles BSEP-99-0071, Forwards Notice of Expiration of Operator License,Per 10CFR50.75(b).Details Withheld Per 10CFR2.790(a)(6)1999-04-27027 April 1999 Forwards Notice of Expiration of Operator License,Per 10CFR50.75(b).Details Withheld Per 10CFR2.790(a)(6) BSEP-99-0069, Discusses Rev of Relief Request RR-17, Leakage at Bolted Connections, for ISI Program for Third ten-yr Interval.Util & NRC Were Unable to Reach Agreement Re Use of ASME Code Case N-566-1 as Permanent Basis for Relief Request RR-171999-04-26026 April 1999 Discusses Rev of Relief Request RR-17, Leakage at Bolted Connections, for ISI Program for Third ten-yr Interval.Util & NRC Were Unable to Reach Agreement Re Use of ASME Code Case N-566-1 as Permanent Basis for Relief Request RR-17 BSEP-99-0063, Notifies NRC of Plans to Install Mod for Bsep,Units 1 & 2 Erds.Physical Computer Sys Changeout Activities Will Temporarily Affect Availability of ERDS Computer Points Via NRC Data Link1999-04-21021 April 1999 Notifies NRC of Plans to Install Mod for Bsep,Units 1 & 2 Erds.Physical Computer Sys Changeout Activities Will Temporarily Affect Availability of ERDS Computer Points Via NRC Data Link BSEP-99-0050, Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping,1999-04-0606 April 1999 Informs NRC That Certain Category C,D & E Piping Welds in Units 1 & 2 Have Not Been Inspected in Accordance with Frequencies Provided by NRC GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, BSEP-99-0051, Forwards Response to Ofc of Investigations Rept 2-1998-014 to Support Final Resolution of Allegations.Response in Encl 1 Withheld.Public Version of Response in Encl 21999-04-0101 April 1999 Forwards Response to Ofc of Investigations Rept 2-1998-014 to Support Final Resolution of Allegations.Response in Encl 1 Withheld.Public Version of Response in Encl 2 BSEP-99-0015, Forwards Response to NRC 981221 RAI Re Cp&Ls Response to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves1999-03-31031 March 1999 Forwards Response to NRC 981221 RAI Re Cp&Ls Response to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves 1999-09-08
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CP&L i
Corolina Power & Light Company Roy A. Ancierson PO Box 10429 Vice President Southport NC 28461 Brunswick Nuclear Plant 910 457-2496 SERIAL: BSEP 95-0378 10 CFR 50.12 AUG 311995 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk >
Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 !
DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR EXEMPTION TO 10 CFR 50, APPENDIX R ,
FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES Gentlemen: ;
in accordance with the Code of Federal Regulations, Title 10, Parts 50.12, Carolina Power & Light Company (CP&L) hereby requests an exemption from the requirements of i 10 CFR Part 50, Appendix R, Section Ill.L.2.b for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The exemption pertains to the extent that reactor coolant must remain above the top of the core during the use of the alternative shutdown system. This exemption would allow an additional method of reactor pressure and level control through the use of Low Pressure Coolant injection and safety / relief valves as the redundant safe shutdown system. A revision to an existing exemption for Section Ill.G.2 separation is ;
also requested to allow this additional method of reactor pressure and level control. !
In addition, CP&L requests a revision to an existing exemption for Section Ill.G.2 separation to allow the use of fire stops as an additional option for establishing separation :
zones in Unit 1 and 2 Reactor Buildings. !
Approval of these exemptions is needed to support CP&L's Thermo-Lag Resolution Actions identified in our letter dated March 23,1995. CP&L has identified circuit modifications which, when implemented, will reduce the amount of Thermo-Lag required in the plant.
Implementation of these rnodifications is currently scheduled for the 1996 refueling i outages. If these exemptions are not acceptable to the NRC Staff, additional circuit ,
modifications may be required in outages following the 1996 refueling outages due to guidance specified in NRC Information Notice 95-27 dated May 31,1995. CP&L requests ;
your response by December 15,1995 in order to support, planning activities for the ;
upcoming Unit 2 refueling outage, which is currently scheduled to begin on February 2, l 1996. CP&L considers this request to be a cost;beneficiallicensing action for the ;
Brunswick Plant, with anticipated savings in excess of $400,000 for the plant. Therefore, l CP&L requests that the proposed exemption be given appropriate review priority.
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Document Control Desk BSEP 95-0378 / Page 2 Please refer any questions regarding this submittal to Mr. George Honma at (910) 457-2741.
Sincerely, l4'sYA /
William R. Campbell GMT/gmt
Enclosure:
- 1. Basis for Exemption Request
- 2. List of Regulatory 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, Brunswick NRC Senior Resident inspector The Honorable H. Wells, Chairman - North Carolina Utilities Commission i
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, , i ENCLOSURE 1
! BRUNSWICK STEAU ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCNET NOS 50-325 AND 50-324 '
OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR EXEMPTION TO 10 CFR 50, APPENDIX R FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES ,
i BASIS FOR EXEMPTION REQUEST INTRODUCTION Based on our analysis and in accordance with the provisions of 10 CFR 50.12.a.1, Carolina Power & Light Company (CP&L) hereby requests exemption from the requirements of Section Ill.L.2.b of Appendix R to 10 CFR 50 to the extent that reactor coolant must remain above the top of the core during the use of the alternate shutdown system to achieve safe shutdown. This exernption would allow an additional method of l
reactor pressure and level control through the use of Low Pressure Coolant injection and safety / relief valves as a redundant safe shutdown system. Based on this additional method, CP&L is also requesting a revision to the existing exemption of Section Ill.G.2 in the Reactor Building RB1-6 and RB2-6 fire areas associated with separation of safe shutdown components.
In addition, CP&L requests a revision to an exemption of Section Ill.G.2 in the Reactor Building RB1 and RB2 fire areas to allow the use of fire stops to establish the separation zone on the 50 foot elevation in lieu of the existing one hour fire barriers that are currently installed utilizing Thermo-Lag material.
i These exemptions will not present an undue risk to the public health and safety, and are consistent with the common defense. Additionally, application of the regulation is not necessary to achieve the underlying purpose of the rule. -
i lil,L Exemotion: l Section Ill.L.2.b of 10 CFR 50, Appendix R requires that the reactor coolant level be maintained above the top of the core for boiling water reactors during a post fire shutdown using alternate shutdown systems. l The safe shutdown methodology credited in the Alternate Shutdown Capability :
Assessment and discussed in Section 2.1.1 of the NRC Safety Evaluation Report (SER) ;
and revision of the SER was as follows:
" Systems required for safe shutdown in the event of a fire concurrent with a loss of-offsite power, reactor shutdown is initiated from the control room by a manual scram of the control rods, if an automatic scram has not occurred. Reactor coolant inventory and pressure control can be maintained by the use of safety relief valves I and Reactor Core Isolation Cooling (RCIC) or High Pressure Coolant injection (HPCI)
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systems during hot shutdown and by the use of the Residual Heat Removal (RHR) system Low Pressure Coolant injection (LPCI) mode during cold shutdown."
1 CP&L's Alternative Safe Shutdown (ASSD) procedures presently utilize Reactor Core Isolation Cooling (RCIC) System (Train B Shutdown) or High Pressure Coolant injection (HPCI) System (Train A shutdown) to provide reactor pressure and level control. CP&L proposes an additional method of reactor pressure and level control through the use of Low Pressure Coolant injection and safety / relief valves as a redundant alternate shutdown system.
Basis for Ill.L Exemption CP&L proposes to use the Low Pressure Coolant injection and safety / relief valves option for a Train B Alternate Shutdown if RCIC becomes unavailable following a fire. The ASSD procedures willidentify RCIC as the primary alternate shutdown system for Train B shutdown and utilize LPCI as a redundant system. This is consistent with the December 3, 1982, NRC memorandum from L. S. Rubenstein to P.. J. Mattson, "Use of the Automatic Depressurization (ADS) and Low Pressure Coolant injection to meet Appendix R, Alternate Shutdown Goals." An analysis (GE Calculation EAS-61-0989) has been performed to ensure that fuel cladding temperatures remain within acceptable limits for the period that the core may be uncovered. The analysis states that after the initial pressurization due to reactor isolation, reactor pressure would be reduced by cycling three safety relief valves (SRVs). At approximately 38 minutes into the event, water levelis at the top of the core and cycling of the SRVs causes water level to swell at each operation until at approximately 40 minutes, with three SRVs open, the LPCI pumps inject coolant into the core returning reactor water to the required level. Adequate core cooling is provided during SRV operation due to coolant flow through the core.
This method of achieving safe shutdown is reflected in the existing BNP Emergency Operating Procedures and the ASSD Procedures for a Control Building and a Unit 2 north Reactor Building fire. The use of this shutdown method was reviewed by the NRC Region 11 during the Appendix R Inspection conducted during May - June 1989 and documented in NRC Inspection Report Nos. 50-325/89-11 and 50-324/89-11 dated July 21,1989. The required components necessary to utilize LPCI for reactor pressure and level control were included in the original Alternate Shutdown Capability Assessment submitted April 24,1984, since the RHR system LPCI mode was required to provide '
makeup water to the reactor from the torus after depressurization. These components and cables will be maintained as part of the Safe Shutdown Analysis and the appropriate procedure changes to reflect this shutdown methodology will be added to the ASSD procedures.
REVISIONS TO EXISTING EXEMPTIONS CP&L submitted the Alternate Shutdown Capability Assessment Report (ASCA) for the Brunswick Steam Electric Plant (BSEP) Unit Nos.1 and 2 on April 24,1984 (Serial No. NLS-84-159). As part of this submittal, CP&L requested eleven (11) exemptions from Section Ill.G.2, Ill.G.3, and Ill.J of 10 CFR 50, Appendix R. These exemptions were El-2
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granted by the NRC in a letter dated December 30,1986, and in clarifications to SER issued December 6,1989.
The safe shutdown rnethodology identified in the Alternate Shutdown Capability !
Assessment and discussed in Section 2.1.1 of the SER was as follows: l "In the event of a fire concurrent with a loss of offsite power, reactor shutdown is initiated from the control room by a manual scram of the control rods, if an automatic scram has not occurred. Reactor coolant inventory and pressure control 3 can be maintained by the use of safety relief valves and Reactor Core isolation Cooling (RCIC) or High Pressure Coolant injection (HPCI) systems during hot ,
shutdown and by the use of the Residual Heat Removal (RHR) system Low Pressure Coolant Injection (LPCl) mode during cold shutdown."
The existing approved exemptions for which CP&L is requesting revision are:
- 1) Unit 1 Reactor Building (Fire Area RB1)
- 2) Unit 2 Reactor Building (Fire Area RB2)
- 3) Unit 1 Emergency Core Cooling System Room (Fire Area RB1-6)
- 4) Unit 2 Emergency Core Cooling System Room (Fire Area RB2-6) :
RB1 and RB2 Exemotions l l
Basis for Existing Exemptions:
For the RB1 (Unit 1) and RB2 (Unit 2) exemptions, the existing exemptions' technical basis [
is as follows:
Exemption from Ill.G.2 provisions for safe shutdown separation features on
-17, 20, and 50 foot elevations in Unit 1 and 2 Reactor Building.
Justification is based upon automatic detection and suppression, separation zone fi considerations, physical separation of redundant trains, water curtain, venting paths l precluding stratification, use of fire stop and 1-hour barriers on exposed cables, and j
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addition of sprinklers.
l As stated in the SER, "The licensee proposes to (1) establish 20 foot wide separation
- zones free of significant quantities of intervening combustibles between the redundant safe !
shutdown trains on the -17, 20 and 50 foot elevations, (2) reroute exposed electrical cables in the separation zones out of the zone, place the cables in conduit, enclose the i cables in non-combustible enclosures, or wrap the cables in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated barriers, and :
l (4) install closely spaced closed sprinklers and draft stops across each separation zone to '
4 serve as water curtains."
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CP&L implemented modifications associated with this approach which were reviewed by the NRC Region 11 during a 1989 Appendix R Compliance Assessment (NRC Inspection Report Nos. 50-325/89-11 and 50-324/89-11 dated July 21,1989).
Basis for Revision:
The Unit 1 and Unit 2 Reactor Building East separation zones on the 50 foot elevation contain a bank of six cable trays which pass through these zones. The cable loading in these six trays varies from 0 to 32 cables with corresponding tray fill from 0 to 5.54 percent. These cables are not required for safe shutdown following a fire. The control of combustibles and ignition sources in the separation zone is controlled by administrative procedures. Fire detection is also provided in the separation zone. CP&L ;
has also installed closely spaced sprinklers in the separation zones to limit the spread of 3 the fire. ,
The cable trays are currently wrapped with Thermo-Lag material. Based on the NRC's !
concern identified in Information Notice 95-27, CP&L proposes to remove the Thermo-Lag material and replace it with fire stops at the north and south ends of the separation zone l similar to the design used in the Southwest corner of the Unit 1 Reactor Building '
Separation Zone. The typical configuration of the proposed fire stop design is shown in Attachment A. The combination of the administrative controls, closely spaced sprinklers
- acting as a water curtain, fire detection system, smoke draft stops and the addition of these cable tray fire stops provides assurance that a single fire will not adversely impact ;
l the ability to achieve and maintain safe shutdown.
This configuration of closely spaced sprinklers acting as a water curtain and cable tray fire stops establishing a separation zone was previously accepted by the NRC for the southwest corner of the Unit 1 Reactor Building (NRC Inspection Report Nos. 50-325/89-11 and 50-324/89-11 dated July 21,1989),
t RB1-6 and RB2-6 Exemotions The existing exemption technical basis for the RB1-6 (Unit 1) and RB2-6 (Unit 2) fire areas (Emergency Core Cooling System (ECCS) Rooms) is described in detailin the Alternative Shutdown Assessment Capability Report, dated April 24,1984, and the NRC Safety
- Evaluation Report dated December 30,1986. A general summary of the technical basis l;
- supporting the existing exemption is the low fire potential; lack of ignition sources;
- electrical cables inside conduit; sufficient propagation retardancy; adequate separation and fire detection; installation of fire wrap, fuses, and a " quick response" sprinkler head; an j inerted primary containment; and features of existing penetration seals.
- ' The existing exemption was requested because the technical requirements of l Section Ill.G.2 could not be met due to redundant shutdown components not separated by 20 feet free of intervening combustibles and because the fire area was not protected by a
fixed automatic fire suppression system.
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Basis for Revision:
The shutdown functions of concern in this area are the reactor pressure level control l (RPLC), shutdown cooling (SDC), and residual heat removal cooling water (RHRCW). The specific redundant hot shutdown components of RPLC include the electrical cables and motor operators for the HPCI and RCIC steam outboard isolation valves (valves E41-F001 and E51-F008). These components are presently separated by a physical distance of approximately 8 feet. Shutdown following a fire in this area will be accomplished from the Control Room using normal shutdown systems.
CP&L proposes the use of Low Pressure Coolant injection and safety / relief valves as a redundant safe shutdown system. The new redundant shutdown equipment components for the reactor pressure level control function for a fire in this area consist of electrical cables and motor-operated valves for the RHR injection inboard isolation Train A and B valves (E11-F015A and E11-F0158). Attachments B and C identify the location of the HPCI, RCIC and RHR isolation valves. The Train A and Train B RHR injection valves and cables are greater than 20 feet apart and are located between 9 to 19 feet from their redundant HPCI or RCIC isolation valve. A partial height concrete wall (approximately 5% feet tall) is also located between these components and a fast response automatic sprinkler head is located adjacent to the RCIC steam outboard isolation valve. This fire area is also provided with a fire detection system.
The original exemption identified cable protection for the RCIC valve (E51-F008) and the RHR Shutdown Cooling valve (E11-F008) to ensure availability of these components in the event of a fire on the north side of the partial height wall. CP&L proposes to use the Low Pressure Coolant Injection System, if fire damage occurs to the RCIC or HPCI components and cables instead of fire wrap protection for these circuits. As stated above the separation between the LPCI valves and cables is greater than 20 feet with low fixed combustible loading in the area, partial height concrete wall, limited accessibility into the area during operation (locked fire door), area fire detection system, and a fast response automatic sprinkler head adjacent to the RCIC valve which provides suppression between the redundant safe shutdown components. Attachments B and C show the arrangement of the equipment located in the ECCS rooms (RB1-6 and RB2-6) and the distances between the components. The RHR Shutdown Cooling valve (E11-F008) is normally closed and is not required post-fire until shutdown cooling is necessary. CP&L will perform a manual operation of this valve if fire damage to the associated cabling results in a loss of the normal valve controls. Emergency lighting will be provided by means of portable lighting since this action is not required for hot shutdown.
As identified in the original exemption request, the fixed fire hazards in the area consist of the combustible jacket of the flexible conduits and approximately 45 pounds of grease distributed among and contained inside the motor-operated valves. This equates to an in-situ fire loading of less than 1 minute. CP&L has calculated the additional combustible loading due to the Thermo-Lag materialin the fire area as part of our Thermo-Lag Resolution Actions and the fire loading increased to approximately 21 minutes. This loading is still considered low for the fire area; however, based on this change in shutdown methodology and to reduce the amount of combustibles in the area, CP&L plans to remove the existing Thermo-Lag in the fire area.
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CP&L believes that adequate separation exists between the components in these fire areas, considering the existing fire protection features and the additional safe shutdown systems. 1 Conclusion Carolina Power & Light Company believes that utilizing the Low Pressure Coolant Injection and safety / relief valves shutdown methodology in addition to the existing shutdown systems provides assurance of the achievement of safe shutdown following a fire and '
reduces the requirements for additional fire protective wrapping materials. Additionally, the use of fire stops to limit the propagation of fire through the separation zones in ,
addition to the existing fire detection and suppression in the zones provides adequate means of assurance that the safe shutdown capability will be available following a fire.
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. CP&L has concluded that there is no significant environmental impacts associated with the requested exemption.
References o Alternative Shutdown Capability Assessment Report (ASCA) for the Brunswick Steam Electric Plant (BSEP) Unit Nos.1 and 2 on April 24,1984 (Serial ,
No. NLS-84-159).
o GE Calculation EAS-61-0989 (Proprietary).
o NRC Inspection Report Nos. 50-325/89-11 and 50-324/89-11 dated July 21,1989.
o NRC by letter dated December 30,1986, and clarifications to Safety Evaluation (SER) issued December 6,1989. ,
o NRC memorandum dated December 3,1982, from L. S. Rubenstein to R. J. l Mattson, "Use of the Automatic Depressurization (ADS) and Low Pressure Coolant Injection (LPCI) to meet Appendix R, Alternate Shutdown Goals."
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b CHASEWAY TO AREA AB0VE HPQ ROOM TOP OF CHASE COVERED WITH SR BRUNSWICK STEAM ELECTRIC PLANT 1/4' STEEL PLATE TO 20' EL UNIT 1 CAROUNA POWER & LIGHT COMPANY APPROXIM ATE. LOCATIONS FIRE AREAS RB1-6 SAFE SHUTDOWN RACEWAYS AND e SMOKE DETECTORS EQUIPMENT (N.T.S.)
ATTACHMENT B
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&xx xxx xx xxxxxxxxxxxxx xxx xxxxxx xxxxxxxxxxxxxxxxxxxxxxxxx2 0 X CHASEWAY TO AREA AB0VE HPCI ROOM TOP 0F CHASE COVERED WITH 21R BRUNSWICK STEAM ELECTRIC PLANT 1/4" STEEL PLATE TO 20' EL UNIT 2 CAROUNA POWER & UGHT COMPANY FIRE AREAS RB2-6 APPROXIMATE LOCATIONS SAFE SHUTDOWN RACEWAYS AND e SM0KE DETECTORS EQUIPMENT (N.T.S.)
ATTACHMENT C
a ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR EXEMPTION TO 10 CFR 50, APPENDIX R FIRE PROTECTION PROGRAM FOR NUCLEAR POWER FACILITIES LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed 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, c
I Committed Commitment date or outage
- 1. Following approval of the revised exemptions, the Thermo-Lag N/A utilized to meet the existing exemptions for the RB1-6 (Unit 1) and the RB2-6 (Unit 2) ECCS Rooms, protecting the RCIC steam isolation valve and RHR suction valve circuits will be removed.
- 2. Following approval of the revised exemptions, the Thermo-Lag N/A utilized to meet the existing exemptions for the bank of six cable trays will be replaced with fire stops.
1 1
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