ML20137W789

Submits Addl Info Re 850709 Request for Extension for Full Compliance W/Environ Qualification of Electrical Equipment to 860330 for Unit 2.Extension Would Allow Unit 1 Outage Info to Be Incorporated Into Unit 2 Outage Activities

ML20137W789
Person / Time
Site:	Brunswick
Issue date:	09/10/1985
From:	Shawn Smith CAROLINA POWER & LIGHT CO.
To:	Asselstine J, Bernthal F, Palladino N, Roberts T, Zech L NRC COMMISSION (OCM)
References
GL-85-15, NLS-85-310, NUDOCS 8510040391
Download: ML20137W789 (2)

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Carolina Power & Ught Company P. o. Box 1551

• Raleigh. N. C. 27602 SERIAL: NLS-85-310 (919) 836-6382 SEP 101985 SHERWOOD H. SMITH, JR.

Chairman / President Mr. N. J. Palladino, Chairman Mr. J. K. Asselstine Mr. F. M. Bernthat Mr. T. M. Roberts Mr. L. W. Zech United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. l AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT -

SCHEDULE EXTENSION REQUEST Gentlemen:

Carolina Power & Light Company (CP&L) submitted a request on July 9,1985 to extend the Brunswick Unit 2 date for full compliance with 10 CFR 50.49 (the EQ Rule) to March 30,1986. We presented exceptional circumstances which we believe justify the additional 120-day extension to allow remaining modifications to a limited number of electrical devices to be completed during the refueling outage that would normally occur beginning March 30,1986.

Subsequent to our July 9 extension request, the NRC issued Generic Letter 85-'l5 to inform licensees of the Commission's intentions regarding enforcement of the EQ Rule after November 30,1985.

Carolina Power & Light Company has reviewed Generic Letter 85-15 and interprets the section discussing extension requests beyond November 30,1985 to be consistent with our request for Brunswick Unit 2. Our July 9 request, and previous correspondence directed to your staff, identified elements beyond CP&L control justifying an extension. On April 25,1984 we requested an extension beyond the second refualing outage af ter March 31,1982. This submittal detailed those things, largely beyond our control, which prohibited us from completing the EQ work on Unit 2 within the schedule set forth by the rule. Our letters of July 6,1984 and August 30, 1984 provided follow-up justification for extension. Your staf f concurred with those arguments and on September 28,1984 the extension request was granted. That same reasoning remains valid.

The Company reiterates its position that we are prepared to shut down Brunswick Unit 2 by November 30,1985 in order to complete the remaining equipment qualification work, but that the requested deferral qualifies as an exceptional case deserving of an extension. We do not intend to operate beyond the November 30 deadline without your approval and be subject to a civil penalty per Generic Letter 85-15, unless an unforeseen system emergency should arise.

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r NRC Commissioners NL5-85-310/Page 2 Sound reasons justifying continued operation until March 30,1986 were discussed in detail in our July 9 submittal. The following information is provided in further support of our request, based on developments since July 9,1985.

As noted in our July 9 letter, CP&L has a unique opportunity to benefit from the back-to-back nature and substantially duplicate content of the Unit I and planned Unit 2 extended outages. We are more than halfway toward completion of outage work on Unit I similar to the work to be performed during the upcoming Unit 2 outage. Much of the work scheduled for the current Unit 1 outage has progressed as planned. However, actual conditions encountered in the field, especially during repairs to recirculation piping and the reactor instrumentation penetration (RIP) valve EQ modifications have required more human resources than originally projected. In addition, the complexity and congestion associated with RIP valve work have resulted in critical path delays. This has resulted in radiation doses for a number of tasks in excess of original estimates yielding an outage total exceeding the originally projected doses. Although the current outage schedule is set by the EQ requirements, a 120-day extension could result in ALARA improvements relating to all Unit 2 ef forts. The requested extension would allow lessons learned during the Unit 1 outage to be more fully incorporated into all the scheduled Unit 2 outage activities. By including applicable field revisions on Unit I activities into the Unit 2 design and procedures, a radiation dose savings in the planned Unit 2 work could be realized. An extensive ALARA review is expected to result in over a 100 manrem savings for the Unit 2 outage.

During the period of August 12-16, 1985 the NRC conducted an in-depth audit of the Brunswick Environmental Qualfication Program. Although the inspection report will not be available for some time, remarks made by the NRC staf f at the exit critique indicated to us that, despite a few individual discrepancies, the audit verified that a comprehensive, workable program is in place which meets the NRC requirements.

On June 28,1985, Carolina Power & Light Company submitted an updated set of Justifications for Continued Operation (JCOs). Following review and discussion during the audit, a clarified set of JCOs has been submitted to the staf f.

This additional information.made available since our July 9 request, verifies our original conclusion that our request for continued operation until March 30,1986 should be granted as being in the overall public interest.

As stated in our extension request of July 9,1985, we need a timely decision in order to effectively plan for the upcoming Unit 2 outage and make appropriate fuel management decisions. Your decision by mid-September,1985 would be appreciated to allow our timely action.

Yours very truly, Q Sherwood H. Smith, Jr.

/ r SHSjr/crs (1870RWS) cc: Mr. H. R. Denton Dr. J. N. Grace Mr. W. J. Dircks Mr. V. Stello Mr. D. G. Eisenhut Mr. H. L. Thompson

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