ML20093A701

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Provides Schedule for Installation of Mods to Instrument Air Sys Necessary to Satisfy Generic Ltr 84-09.Exemption from Schedule Requirements of 10CFR50.44(c)(3)(ii) Until Next Refueling Outage Requested
ML20093A701
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 06/27/1984
From: Howe P
CAROLINA POWER & LIGHT CO.
To: Vassallo D
Office of Nuclear Reactor Regulation
References
GL-84-09, GL-84-9, NLS-84-299, NUDOCS 8407110155
Download: ML20093A701 (2)


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L CD&L Carolina Power & Light Company S: 'I l.:

NLS-84-299 4

F Director of Nuclear Reactor Regulation Attention:

Mr. D. B. Vassallo, Chief f

Operating Reactors Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, DC 20555 t

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 l

DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 ADDITIONAL INFORMATION CONCERNING REQUEST FOR SCHEDULAR EXEMPTION TO 10 CFR 50.44(c)(3)(ii) i

Dear Mr. Vassallo:

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.In our letter of June 8, 1984, Carolina Power & Light Company (CP&L) committed l

to provide a description and schedule for installation of modifications to the 1

instrument air system needed for Brunswick Steam Electric Plant Unit Nos. I and 2'to meet the intent of the criteria of Generic Letter 84-09.

The purpose of this letter is to provide the schedule for installation of these modifications. The description of the modifications will be provided separately.

As discussed with members of your staff, CP&L is scheduling completion of these modifications for the next refueling outage for each unit. These outages are presently scheduled to begin in March 1985 for Unit 1_(Reload 4) and April 1986 for Unit 2 (Reload 6), and are the next scheduled outages which i

are of sufficient duration to complete these modifications. This schedule is required in order to allow sufficient time to complete detailed design of the modifications.and permit procurement of necessary equipment. These modifications will involve installation of new, and modification of existing,

. safety class piping and control systems including all the required seismic support and QA of design and installation inherent with such work.

F In addition to the measures previously cited in the schedule exemptions 3

granted on June 21, 1983 and December 29, 1983, CP&L has identified two

' additional measures which may be developed to control accumulation of oxygen inside the containment in the highly unlikely event of a loss-of coolant accident (LOCA). Following such an accident, once the unit has been brought to a cold shutdown condition, the instrument air system inside containment is

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no longer required. Further, the capability also exists to supply the entire instrument air system with nitrogen from outside the reactor building. This

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8407110155 840627 PDR ADOCK 05000324 P

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  • P. O. Box 1551
  • Raleigh. N C, 27602 l

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1 Mr. D. B. Vassallo ;

I nitrogen would be brought in by tanker truck from off site and could be made available within two to three days following the accident. Carolina Power &

I Light Company believes these actions would preclude further introduction of

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oxygen to the containment well before concentrations could build to i

combustible levels.

Carolina Power & Light Company believes that these capabilities, combined with our existing containment atmosphere control systems, provide very conservative assurance that concentrations of combustible gases can be maintained well below combustible levels without venting of the containment following a LOCA.

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In a letter dated October 11, 1982, CP&L petitioned the Nuclear Regulatory Commission for exemption from the technical requirements of-

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10 CFR 50.44(c)(3)(ii). Since that time, CP&L has requested, and been I

granted, exemptions from the schedule requirements of the rule pending Commission approval of its technical exemption request. These extensions have

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been based in part on the Company's commitment to modify the instrument air

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system if the Commission ruled favorably on CP&L's technical exemption i

request. Design, procurement, and installation of these types of modifications are very intensive in terms of resources.

It would not have been prudent to proceed with detailed design and installation of such modifications until it had been positively determined that such modifications would be found acceptable to the Commission to meet the requirements of the rule. Carolina Power & Light Company therefore respectfully requests that its f

request for exemption to the schedule requirements of 10 CFR 50.44(c)(3)(ii) be granted until the next refueling outage, or scheduled outage of sufficient duration after design and procurement is complete, for each of the Brunswick units.

Should you have any further questions regarding this request, please contact Mr. S. R..Zimmerman at (919) 836-6242.

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l Yours very tru i

P. W. Howe I

Vice President Brunswick Nuclear Project

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cc:

Mr. D. 0.-Mycrs (NRC-BSEP)

Mr. J. P. O'Reilly ~(NRC-Ril) l Mr. M. Grotenhuis (NRC) i

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