ML20237G828
| ML20237G828 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/17/1987 |
| From: | Eury L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-85-03, GL-85-3, NLS-87-144, NUDOCS 8708240252 | |
| Download: ML20237G828 (2) | |
Text
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e CD&L Carolina Power & Light Company SERIAL: NLS-87-144 AUG 171987 10CFR50.12(aX2Xii) 10CFR50.62(cX4)
United States Nuclear Regulatory Commission ATTENTION: Document Control Desk /
Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-324/ LICENSE NO. DPR-62 REQUEST FOR EXEMPTION FROM 10CFR50.62(cX4)
Gentlemen:
Pursuant to the Code of Federal Regulations, Title 10, Part 50.12(aX2Xii), Carolina Power & Light Company (CP&L) hereby requests exemption from the requirements of 10CFR50.62(cX4) for the Brunswick Steam Electric Plant (BSEP), Unit 2.
DISCUSSION 10CFR50.62(cX4) requires each boiling water reactor to have a standby liquid control system (SLCS) with "a minimum flow capacity and boron content equivalent in control capacity to 86 gallons per minute of 13 weight percent sodium pentaborate solution."
The NRC has indicated that deviations from this requirement based on vessel size would require an exemption from 10CFR50.62(cK4). The Brunswick Plant uses an injection rate of 66 gallons per minute of 13 weight percent sodium pentaborate solution because its vessel diameter is 218 inches, as opposed to 251 inches which is the basis for the 86 gallons per minute requirement.
Generic Letter 85-03,." Clarification of Equivalent Control Capacity for Standby Liquid l
Control Systems," dated January 28,1985, states, in part:
The " equivalent in control capacity" wording was chosen to allow flexibility in implementation of the requirement.
The 86 gallons per minute and 13 weight percent sodium pentaborate concentration were values used in NEDE-24222, " Assessment of BWR Mitigation of ATWS, Volumes I and II,"
December 1979 for BWR/4, BWR/5, and BWR/6 plants with a 251-inch diameter vessel.
i NEDE-24222 recognized that different values would be equivalent for smaller plants, and 1
cited 66 gallons per minute in a 218-inch diameter vessel plant as equivalent to 86 gallons per minute in a 251-inch inside diameter vessel plant.
JUSTIFICATION Carolina Power & Light Company believes this exemption should be granted pursuant to 10CFR50.12(aX2Xii), i.e., application of the regulation in the particular circumstances would not serve the underlying purpose of the rule. The purpose of the rule is to reduce the risk from ATWS events by ensuring adequate shutdown mar The need for this exemption is based on the determination that 10CFR50.62(cX4)gir, does not address I
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o Document Control Desk NLS-87-144 / Page 2 differences in vessel size in its requirements for the SLCS. Generic Letter 85-03 clarifies the statement " equivalent in control capacity" and lists as an example that an injection rate of 66 gallons per minute in a 218-inch diameter plant is equivalent to 86 gallons per minute in a 251-inch diameter plant. This information was based on i
NEDE-24222, which recognized and showed that different values would be equivalent for smaller plants. In addition, a change to the Technical Specifications incorporating the 66 gallons per minute and 13 weight percent requirements was granted for BSEP, Unit 1, on April 10,1987. The Safety Evaluation Report for that change states that the 66 gallons per minute and 13 weight percent requirements for a 218-inch diameter vesselis equivalent to the 86 gallons per minute and 13 weight percent requirements for a 251-inch diameter vessel. Therefore, the underlying purpose of the rule is achieved and served by an injection rate of 66 gallons per minute of 13 weight percent sodium pentaborate solution.
This exemption is required to support modifications being made in the upcoming BSEP-2, Reload 7 outage, scheduled to begin January 2,1988. Therefore, concurrence is required by January 15,1988. The license amendment application to implement SLCS two-pump operation is being submitted under separate cover.
If you have any questions concerning this request, please contact Mr. Sherwood R.
Zimmerman at (919) 836-6242.
Yours very truly, Lf 7 y
L. W. Eury Senior Vice President Operations Support LEW/ccj (5235 BAT) cc:
Dr. J. Nelson Grace (NRC-Rii)
Mr. W. H. Ruland (NRC-BNP)
Mr. E. Sylvester (NRC)
L. W. Eury, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.
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