ML20214L093
| ML20214L093 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/04/1986 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| NLS-86-321, NUDOCS 8609090306 | |
| Download: ML20214L093 (2) | |
Text
_
CD&L Carolina Power & Light Company SERIAL: NLS-86-321 SEP 0 41986 Director of Nuclear Reactor Regulation Attention:
Mr. Dan Muller, Director j
BWR Project Directorate #2 Division of BWR Licensing United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 APPENDIX 3 EXEMPTION REQUEST
Dear Sir:
1 On August 13,1986, a conference call was held with members of your staff to discuss the pending Appendix 3 exemption request dated October 25,1985. As a result of the call, Carolina Power & Light Company committed to submit additional information regarding the exemption request. This letter provides the requested information.
EXEMPTION NO. 2:
Lines Terminating Below Minimum Torus Level The Company has reviewed the alternate water test of these valves as suggested by the i
NRC. Since modifications would be necessary in order to perform the alternate test, it is more feasible to continue the current air test. As such, the Company hereby l
withdraws Exemption Request No. 2.
1 EXEMPTION NO. 3:
H / O Monitor Isolation Valves 2
2 Carolina Power & Light Company was asked to provide additional information regarding the impact of performing the required Type C testing of these valves. Brunswick presently performs approximately 185 local leak rate tests (LLRT). A typical refueling outage requires numerous regulatory modifications or preventive maintenance actions on containment boundaries. Since premaintenance and postmaintenance LLRTs are required for these actions, the number of tests for one outage can run as high as 300. This scope of work can cause a major impact on outage duration.
Based on the reasons stated in the October 25,1985 request, it was determined that Type C testing of the H / O2 m nitor isolation valves is not required. Removal of these 2
valves from the test program reduces the number of required tests by 20 per unit.
Since: (1) the system is open post-LOCA, (2) previous ILRTs have not indicated leakage problems with the entire system exposed, and (3) FSAR calculations for a total shear in an instrument line indicate a thyroid dose of 1.7 mrem and a whole-body dose of less than 0.1 mrem at the site boundary, CP&L believes these tests add additional manpower requirements, system manipulation, and coordination requirements to an already extensive leak test program without significant gain.
8609090306 860904 PDR ADDCK 05000324 P
PDR J
f 411 Fayetteville street e P. O Box 15$1 e Raleigh. N C 27602
' g[p y = d%2"R"E
{
m m. r=v ru o m
o-
', Director of Nucl:ar Recctor Regulation NLS-86-321/ Page 2 In order to maintain effective health physics control and to minimize safety hazards, access to the drywell is limited to a maximum of 50 people at a time. Deletion of these tests would reduce personnel in the drywell. Additionally, a dose savings of approximately.5 man-rem per outage would be realized.
Based on the above reasoning, the Company believes that the benefits derived from not performing Type C testing of these valves outweighs the slight additional assurance of valve operability gained as a result of the test.
Please refer any questions regarding this matter to Mr. Stephen D. Floyd at (919) 836-6901.
Yours very truly, ww~
S.
i merman Manager Nuclear Licensing Section MAT /vaw (4065 MAT) cc:
Mr. W. H. Rutand (NRC-BNP)
Dr. J. Nelson Grace (NRC-RII)
Mr. E. Sylvester (NRC) 1
_ _ _ _ _ _ ~.
_ _ _. -. _ -