ML20083D754

Forwards Revised Pages for Insertion Into 830701 Request for Exemption from 10CFR50.48 & 10CFR50,App R Requirements Re Sprinkler Head/Nozzle & Detector Placement

ML20083D754
Person / Time
Site:	Hatch
Issue date:	12/20/1983
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-83-625, TAC-43754, TAC-43755, TAC-47143, TAC-48071, TAC-48072, TAC-48748, TAC-48749, TAC-54802, TAC-54803, NUDOCS 8312280255
Download: ML20083D754 (4)

Text

a Geora.a Pouer Corrwy t.

333 Pvdmont Avenue Atlaatl GMvg a 30308 l

Tel9phrre 404 E26 tZ26 MaJ rg Addreb Pcst Off ce Bo= 4545 At:anta. Ge;ma 30i02 L

Georgia Power L T. Gucwa

+m-Manager NgCle7ar [pg:nN>rf g and en et tu war Enveer December 20, 1983 NED-83-625 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

20555 NRC DOCKEFS 50-321, 50-366 OPEPATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REVISION TO REQUESM FOR EXB1PTION FROM 10 CFR 50.48 AND 10 CFR 50 APPENDIX R Gentlemen:

Purusant to discussions with members of the NRC staff, Georgia Power Company (GPC) hereby withdraws from review our requested exemption from the perfomance of an annual sprinkler / spray system main drain test as specified by National Fire Protection Association (NFPA) Codes 13 and 15.

'Ihi s exemption is not germane to your consideration of GPC's submittial on compliance with 10 CFR 50 Appendix R and 10 CFR 50.48.

It will be resubmitted under a more appropriate format, if future circumstances warrant such consideration.

Enclosed are the appropriate revision pages for insertion into our July 1, 1982, " Response to 10 CFR 50.48 and Appendix R" as revised by our letters of May 27, 1983 and November 30, 1983.

Should you have any questions regarding this letter or its enclosure, please contact this office.

Yours very truly,

/ T-W L. T. Gucwa WEB /b1m Enclosure xc:

J. T. Beckham, Jr.

H. C. Nix, Jr.

J. P. O'Reilly h

h@di Senior Resident Inspector i

8312280255 831220 PDR ADOCK 05000321 PDR

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i RESPONSE TO 10 CFR 50.48 AND APPENDIX R 1

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AMENDMENT 2 REVISION INSERTION INSTRUCTIONS December 1983 Page 5-3 Replace l

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..t 5.2.3 DEPARTURES FROM NFPA 13 AND 15 WITH RESPECT TO SPRINKLER HEAD / NOZZLE PLACEMENT

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Sprinkler head / nozzle placement do not follow NFPA 13 and 15 criteria in all locations.

Deviations exist where congestion will not allow placement of the device within NFPA allowable tolerances.

An engineering analysis (as permitted by the special hazards philosophy discussed in the NFPA codes) is performed.on each head / nozzle that cannot be located per NFPA guidelines.

This analysis is performed on a case by case basis to ensure that the system performance meets or exceeds NFPA criteria.

Sprinkler head placement was selected with consideration for water distribution requirements, head obstruction, heat stratification, and heat banking as a result of excessive congestion of ductwork, trays, and piping to ensure timely delivery of a sufficient heat flux level such that the sprinkler head actuates.

In addition, the sprinkler densities and the selection of lower operating temperature elements, which

-exceed the minimum directions provided by NFPA, were incorporated to maintain acceptable time lag for suppression system operation.

In view of the material presented above, the system departures from NFPA are judged equal or better than the location criteria outlined for conventional structures through the applicable sections of NFPA 13 and 15.

O 5.2.4 DEPARTURES FROM NFPA 72E WITH RESPECT TO DETECTOR PLACEMENT Smoke / heat / fire detector placement.does not follow NFPA 72E criteria in all locations.

The location of each detector utilized several variables, such as smoke and heat stratification, heating, ventilation, and air conditioning (HVAC) airflow (s), ceiling congestion, distance from floor to ceiling as well as the building's configuration and the manufacturer's recommendations (as instructed by NFPA 72E) when placing the detectors.

Detectors are placed per NFPA 72E when the engineering analysis provides an acceptable system performance.

The NRC recognizes the lack of solid criteria provided by NFPA 72E as well as the limited state of the art knowledge in fire detection equipment and location.

In view of this art of detection, the detection equipment and installation is judged _as equal to the NFPA 72E series with respect to installed equipment.

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" Acceptance and Verifications for Early Warning Fire Detection Systems," prepared by the NRC by the Reactor

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Engineering Analysis Group, Department of Nuclear Energy, Brookhaven National Laboratory, Upton, N.Y.,

May 1980.

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5.2.5 DEPARTURES FROM NFPA 13, 14, 15, AND 20 WITH RESPECT TO WELDING PROVISIONS Exemption is requested from the no welding provisions of NFPA 13, 14, 15, and 20.

Justification for this exemption resides in the controls required for hot work activities, which are in accordance with other NFPA guidelines.

These controls and the requirements for Seismic Class 1 installation and restricted movement during modification or maintenance activities often require welded assemblies.

These features in conjunction with the fire watch and extensive training of site personnel assure that potential fire conditions are controlled in an acceptable manner.

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0074n AMENDMENT 212/83 54

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