ML20215N464
| ML20215N464 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/30/1986 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| NLS-86-394, NUDOCS 8611050447 | |
| Download: ML20215N464 (2) | |
Text
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C9&L
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Carolina Power & Light Company SERIAL: NLS-86-394 OCT 3 0 "
Director of Nuclear Reactor Regulation Attention:
Mr. Dan Muller.
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 REVISED FIRE PROTECTION EXEMPTION REQUEST
Dear Sir:
Carolina Power & Light Company (CP&L) submitted the Alternative shutdown capability Assessment Report for the Brunswick Steam Electric Plant (BSEP) Unit Nos. I and 2 on April 24,1984 (NLS-84-159). As part of this submittal, CP&L requested eleven (11) exemptions from Section III.G.2, Ill.G.3, and 111.3. These exemptions were requested under the provisions of 10 CFR 50.12. In January 1986,10 CFR 50.12 was revised and established specific circumstances when exemptions would be granted.
In a recent phone conversation with your staff, CP&L was requested to provide additional information concerning the "special circumstances" required to be provided under the revised 10 CFR 50.12 rule. The purpose of this letter is to provide this information for the above exemptions. CP&L believes that there is a special circumstance which warrants granting the above-referenced exemptions as provided by the Commission in Section 50.12(aX2Xiii).
Application of 10 CFR 50, Appendix R, would have resulted in undue hardships to CP&L. The objective of the regulation was to provide fire protection features for the safe shutdown systems and their associated circuits. The Brunswick site has fulfilled the underlying purpose of the rule by the alternate shutdown approach submitted to the NRC on April 24,1984. The above exemptions were necessary to support the III.G.3 alternate shutdown approach used by BSEP.
In order to achieve verbatim compliance with the III.G.2 separation criteria, CP&L would have to have changed some of the basic structures of the plant. In addition, without these exemptions, CP&L would have had to install a dedicated shutdown capability.as delineated in Section III.L of Appendix R to 10 CFR 50. 'Ine installation of a dedicated shutdown system would have required longer plant outages in order to facilitate tying in -
the dedicated systems and would have still required the protection of associated circuits.
Based on a survey of other utilities and industry estimates, CP&L estimated that the cost of installing a dedicated shutdown system at BSEP could range from 35 to 45 million dollars. Even though the CP&L estimate was arrived at without performing a detailed cost analysis, CP&L concluded that the cost of installing a dedicated shutdown s/ stem would have significantly exceeded the cost of installing the proposed alternate shutdown capability with no corresponding increase in fire protection capability.
D 00 411 reyettevme street
- P O Box 1551
- Ralengh, N C 27602 i0 8611050447 861030 cm N n n '%
PDR ADOCK 05000324 F
PDR L
Director of Nuclear Reactor Regulation
.NLS-86-394 / Page 2 Technical justification for the exemptions were submitted as part of the Alternate Shutdown Capability Assessment Report and concluded that an equivalent level of fire protection has been achieved for the fire protection areas discussed in the exemptions.
Therefore, CP&L believes that " compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted." Therefore, a special circumstance is present as defined in 10 CFR 50.12(aX2Xiii).
Should you have any questions concerning this letter, please contact Mr. Patrick P.
Carier at (919) 836-8165.
Yours very truly, S. R Zi l merman Manager Nuclear. Licensing Section PPC/kts (5029PPC) i cc:
Mr. W. H. Ruland (NRC-BNP)
Dr. J. Nelson Grace (NRC-R!!)
Mr. E. Sylvester (NRC) i i
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