ML20212H563
| ML20212H563 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/27/1987 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-87-042, NLS-87-42, NUDOCS 8703060146 | |
| Download: ML20212H563 (2) | |
Text
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Cp&L Carolina Power & Light Comoany FEB 2 71987 SERIAL: NLS-87-042 10 CFR 50, Appendix 3 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk : 3 Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 SUPPLEMENT TO EXEMPTION REQUEST APPENDIX 3 Gentlemen:
On Cctober 25,1985, Carolina Power & Light Company (CP&L) requested an exemption to the testing requirements specified in Appendix 3 of 10 CFR 50 for certain primary containment isolation valves. During a meeting held on February 4,1987, the Staff requested CP&L to provide an analysis of Exemption 3, H /0 Monitoring Isolation 2
2 Valves, under the provisions of 10 CFR 50.12(a), which was revised subsequent to the Company's request. Carolina Power & Light Company has reviewed Exemption 3 of the October 25,1985 submittal and determined that:
1.
The proposed exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. System integrity is ensured by periodic Type A testing and by the soap bubble testing committed to in the Company's December 11,1986 submittal.
2.
Compliance with Appendix 3 with regard to the H /0 Monitoring Isolation 2 2 Valves is not necessary to achieve the underlying purpose of the rule which is to ensure containment integrity. Since these valves are open post-LOCA and are not required for containment isolation purposes, failure of the H /0 2
7 monitoring system valves would result in no hazard to the public. In addition, system integrity is ensured by periodic Type A and soap bubble testing. As such, any benefit gained in performance of the Type C testing is outweighed by the additional outage manpower and man-rem exposure incurred as a result.
3.
Compliance with Appendix 3 with regard to the H /0 Monitoring Isolation 2
2 Valves results in undue hardships in excess of those contemplated when the regulation was adopted. The requirement for Type C testing of this system results in 20 periodic tests per outage for each unit. These tests involve drywell entry in order to disconnect instrument tubing, thereby providing test connections. The Company estimates that this Type C testing cost is approximately $21,000 per outage.
G703060146 870227 i
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DR ADOCK 05000324 PDR 411 Fayetteville street
- P. O Box 1551
- Raleign, N C. 27602 n.
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Docum:nt Contrcl Desk NLS-87-042 / Pags 2 Please refer any additional questions regarding this matter to Mr. Stephen D. Floyd at (919) 836-6901.
Yours very truly, e
. Zimm man Mana r Nuclea nsing Section MT/bmc (5140 MAT) cc:
Dr. 3. Nelson Grace (NRC-RII)
Mr. W. H. Ruland (NRC-BNP)
Mr. E. Sylvester (NRC) 4 h
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