ML20138Q951
| ML20138Q951 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/10/1985 |
| From: | Shawn Smith CAROLINA POWER & LIGHT CO. |
| To: | Asselstine J, Bernthal F, Palladino N NRC COMMISSION (OCM) |
| References | |
| CON-#485-223 NUDOCS 8512300127 | |
| Download: ML20138Q951 (3) | |
Text
(
4 e
- c.
/
- C Som 1551 e Asiefi. N C 27 02 i m ax.4m
'%)
03C Q q'n L.S M c
'85 Ngy ;g. A9 :58 iL se.ceans -
V c,..,,~,
0FFir: y.
00Cdh mg Q.4" j
BRAncu October in, 1995
./
<] () /
t L
Mr.
N.J.
Palladino, Chairman Mr.
J.K.
Asselstine Mr.
F.M.
Bernthal Mr.
T.M.
Roberts Mr.
L.W.
Zech United States Nuclear Regulatory Commission Washington, D.C.
20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62.
EN'/IRONMENTAL OU ALIFIC ATION OF ELECTRICAL EQUIPMENT -
SCHEDULE EXTENSION REQUEST Gentlemen:
On behalf of Carolina Power & Light Company (CP&L), I want to thank you for the cocortunity to address the Nuclear-Requiatory Co mission (NRC) on October 9, 1985.
The re uested extension until Maren 30, 1986, for the Brunswick Unit 2 facility to comoly fully wit. 13 CFR 50.49 fthe eculonent cualification rule) is of ortority to CDSL and our ratecavers as well.
Your time and attention on this imocrtant matter is aooreciated.
As I exclained at the meetino, we await a decision as soon as oractical in order to minimize costs fr0- delav, but we would orefer a fullv-reasoned decision.
Whatever.
vour decision, CP&L will do whatever is necessarv to nrotect the outlic health and safety first and will incur the excenses necessary to do so.
There was an issue raised during the neeting vesterday that we feel should be clarified further.
In our remarks, we noted that the granting of an additional four months extendin the dead-line for the remaining coen items at Brunswick Unit 2 was not an issue directiv related to safety.
We substantiated this with the fact that the NRC staff has already granted justifications for con-tinued oceration (JCO) for all the ooen items.
We also quoted several passages from crior Federal Register notices concerning the nature of EO deadlines.
For example, the Commission has stated that the June 30, 1982, deadline,
.was not a generic c'!*-off date O,
C>
8512300127 851010 X JDG EQ
- = ^=" o5o 8J' g
u, I.
NRC Commissioners October 10, 1985
)
Page 2
. deadline was established to force for coeration.
Rather, the.
licensee completion of the environmental qualification orogram in a reasonable time.
.The safety of ooeration continues to be reviewed on an individual basis."
49 FR 8422, 8426 (March 7, 1934);
and, "The
. deadline was not set as a safety matter or as a cut-off date beyond which reactors could no longer operate if all of their equioment was not qualified.
.The justifications *or con-tinued ooeration are relevant to the deadline only to the extent that they reveal whether licensees have considered the effects of deficiencies in a timely manner."
49 FR 45571, 45572 (November 19, 1934).
Generic Letter 85-15 reinforces this position by allowinc for Commission-granted extensions to the November 30, 1985, deadline given, among other conditions, valid JCOs.
Also, the NRC staff stated in its recommendation of October 4, 1985, relative to grant-ing the extension, that continued operation of Brunswick Unit 2 would not pose an undue risk to the oublic health and safety.
We pointed this out to_the Commission for the ourpose of making it clear from the outset of our presentation that our request should be evaluated in its proper context, namely, that the four-month exten-sion beyond November 30, 1985, by itself did not represent a risk.to..
the public health and safety.
Unfortunately, either as a result of our misphrasing the point or simply due to the sensitivity of the topic, it appeared our remarks were misinteroreted.
Of course, EO as a program is impor-tant to safety, even though the deadline may not have a direct bear-ing on safety.
We acree with the Ccmmission that an extended period of time beyond the November, 1985, deadline could increase the pro-bability._of'a risk to the oublic health and safety.
However, we, ani the NRC staff, believe the four-month extension does not present an undue risk.
As for our recuested extension, we reiterste our position that the ecuities argue in its favor.
Man-ren exoosure,yould be reduced signi*icantly, substantial *inancial cost sould be avoided and system reliability throughout our region would be enhanced.
urthermore, we view the extension as fully consistent with the r
underlying purpose of the EQ progran in ceneral and the deadlines in oarticular.
The program is intended to orotect the oublic health and safety, with which we think the extension is consistent, and the deadlines have been intended to urge comoliance with the E0 pro-gram.
The completion of EO work at our other two operating units, the substantial and uniquely difficult work at Brunswick Unit 2 and the fact that this work is nearly comoleted all show that the proper attention has been given to the deadlines and that the deadlines have had their desired effect.
Other questions were asked and responses provided at yes-terday's meeting that may also be germane to your decision.
If fur-ther information is desired on any of these matters, such as the a
';2.0 Conmissioners October 10, 198
?aae 3 unique Brunswick Unit 2 design, the effect of high temperatures out-side containment, the cost of the EQ program at our facilities or any other matter, we would be preoared immediately to provide such additional l'n f orma t io n.
In any event, we respectfully urge that you crant the requested extension.
Yours very truly,
&L*
Sherwood H.
- Smith, SMS/wac cc:
W.J.
Dircks 9.R.
Denton
.s..
40 e
1