ML20096F838
| ML20096F838 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/04/1984 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NED-84-444, TAC-43754, TAC-43755, TAC-47143, TAC-48071, TAC-48072, TAC-48748, TAC-48749, TAC-57415, TAC-57415M, TAC-57416, NUDOCS 8409100235 | |
| Download: ML20096F838 (8) | |
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Georgia Power Company 333 Piedmort Avenue Attanta, Georgia 30308 Televone 404 5266526 Maang Address:
Post Ofrece Box 4545 At'anta. Georgta 30302 Georgia Power L T. Gucwa the southem e#ectrc system Manager NucMar Engineering and cNet Nuclear Eng'neer NED-84-444 Septenber 4, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Ogerating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Cmunission Washington, D. C.
20555 NRC DOCKETS 50-321, 50-366 OPEPATING LICENSES DPR-57, NPF-5 EDWIN I. HA'IG NUCLEAR PIANT UNITS 1, 2 SCHEDULER EXEMPPIONS FOR NON-OUTAGE-REIA'IED APPENDIX R MODIFICATIONS Geratlenen:
By letter dated May 25, 1984, Georgia Power Cmpany (GPC) resubnitted a request.for scheduler exenption for implenentation of Appendix R
modifications.
In that letter we proposed to meet on a fire area-by-fire area basis either itrins 1 or 2, and iten 3 as identified in your " Guidance on Interim Measures to Support Scheduler Exenption Rsluests" for the period of time fra expiration of the 10 CER 50.48 schedule allowance until the specific fire area is in empliance with paragraphs III.G.2 and III.G.3 of AIpendix R as modified by the exenptions granted by NRC's letter of April 18, 1984.
While your letter of June 8,
1984 indicated that the aforenentioned GPC letter lacked the specificity needed to grant our scheduler exenption request, you indicated that the proposed schedules I
appeared acceptable provided GPC and NRC could reach agreenent on empensatory measures to be hnplanented until such time as the permanent modifications were implenented.
GPC wishes ' to advise NRC that scheduler exenptions are still required and herein proposes specific cmpensatory measures to support the requested relief. to this letter addresses empensatory measures for those Plant Hatch modifications which can be acceplished during a non-outage period but which cannot be cmpleted in the time frane allowed by 10 GR 50.48..
'Ihe cmpensatory measures for the aforenentioned modifications were developed based upon the additional " Guidance on Interim
-Measures to Support Scheduler Exenption Requests" provided by the NRC Licensing Project Manager.
8409100235 840904 PDR ADOCK 05000321 F
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3 GeorgiaPoiverA Director of Nuclear Reactor Regulation
' Attention: Mr. John F. Stolz, 011ef Operating Reactors Brand) No. 4 September 4, 1984 Pye ho
% e cepensatory measures for each modification discussed in Enclosure-l will be impleented contingent upon NRC approval.
Tentative plans are to impleent the cepensatory measures for the non-outage-related modifications prior to Hatch Unit 1 restart fra the Fall 1984 maintenance / refueling outage scheduled to begin on or about October 1, 1984. - The cepensatory
- measures for Hatch Ulit 2.and those areas camon to both units will be
. scheduled to be installed by October 15, 1984 or thirty (30) days after NRC -
- approval, whichever is later.
With the sutmittal of this specific information concerning empensatory measures for those non-outage-related Appendix R modifications that cannot be empleted in the time free allowed by 10 CFR 50.48, GFC requests -that our proposed scheduler exmption be granted by NRC.
%e staffs of GPC and its consultants are available for additional discussion of these interim campensatory measures should the NRC so desire.
Should you have any questions.in this regard, please contact this office.
Sincerely yours,
- t gt:'X & - - =
L. T. Gucwa JAF/RIhinb Enclosure xc:
J. T. Beckhm, Jr.
H. C. Nix, Jr.
J. P. O'Reilly (NRC-Region II)
Senior Resident Inspector.
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-%e following is a discussion of the Appendix R-related' modifications identified in the "Edwin I. Hatch Nuclear Plant Response to 10 GR 50.48 and Appendix R" which can be_ haplanented during a non-outage period but which as
, part of the total integrated - Appendix R Lmodification schedule can not be cepleted in the time free allowed by 10 OR 50.48.
%e non-outage modifications are those which do not fit the' acceptable criteria.for the classification of work as outage-related.
ne. criteria for outage-related work are:
(a) work which requires disabling a safety. systen, (b) work in an area in which radiation would. result in unacceptable exposures to personnel
'during power operation,. (c). work whose reasonable sequence requires that the work follow an outage-related job, or (d) work which could impact safety systens indirectly including tie-ins to fire mains which cannot be isolated without undesirable effects on overall plant fire protection.
%ese modifications are grouped by fire areas as, identified _-in our July 1, 1982 subnittal and subsequent anendments.
For clarity, other modifications
. identified in that submittal. which have been determined to require a plant outage to cmplete are not listed in-this enclosure.
%e discussion contains a. listing' of the modifications in each area, the presently scheduled cmpletion - date, and the cepensatory measures proposed for the interim time period. 'It is our belief. that the measures proposed herein 3
c eply with the guidelines for interim cepensation provided by the NRC.
4.1.1 4160-V Transformer Rom - Unit 1 4
Non-Outage Modification / Implenentation Schedule o
Wrap conduit M S-II-477 with 1-h barrier - June 1986 Cepensatory Measure Lo Conduit ' ESS-II-477 will be - wrapped - within this area with
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Kaowool to provide a tenporary fire barrier.
4.1.2 West 600-V Switchgear Rom - Unit 1 7
Non-Outage Modifications / Implenentation Schedules
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o Wrap conduit ESS-II-477 with 1-h-barrier - June 1986 o
Upgrade west wall.to 3-h barrier i April 1985 Cepensatory Measures o
Conduit ESS-II-477 will be wrapped within this area with Kaowool to provide a tenporary fire barrier.
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. %e existing two hour wall serves as an interim fire barrier along with a full autmatic suppression systen which exists on the opposite side of the wall and provides additional protection.'--
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Septenber 4,1984 Page 1 C
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- 4. l'. 4 Control Building Working Floor el'll2 ft - Unit l' l
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Non-Outage Modification / Implementation Schedule Wrap raceway R25-S037-ES4-M14 with 3-h barrier - June 1986 o
.Cepensatory Measure-
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Raceway R25-S037-EE4-M14 will be wrapped within this area with o-
- Kaowool to prwide a temporary fire barrier.
1 4.1.5
- Reactor. Building North of Column Line R7 - Unit 1-Non-Outage Modifications / Implenentation Schedules o
-Install detection on 158 ft elevation and additional detectors associated;with the water. curtain on the 130 ft elevation -
February 1986 o
Wrap safe shutdown'-related cables in 20 ' f t sprinkler zone
- along R7 en elevations 130 ft and 158 ft - February 1986 Compensatory Measures o
While these modifications in the reactor-building do not specifically meet the criteria for outage-related work, they-do involve work in a radiation field and in proximity to safety-related equipnent.
heir treatznent herein as-non-outage-related work for purposes of establishing 10 CFR'
.50.48 scheduler definition may. in fact be overly
~ conservative.- However, the work (along with certain aspects Iof the outage-related work), must proceed during non-outage i
. periods in order to - meet our proposed schedule and we, therefore, propose the following:
ne 130 ft elevation presently. has.a detection systen for area-wide cover.xJe.
%e additional' detection and cable wrap are being added together with a sprinkler systen:to act as a water curtain.to ' divide the. reactor building. into two ' fire areas. ' Fire loadings are low to moderate in the area (see the July 1, 1982 subnittal for. specific ' loadings). with ' limited e
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intervening cabustibles.
Both elevations.130 ft and 158 ft are toured regularly by plant equipnent operators - (PEDS). and security-perse.mel who would be instructed to observe the area F
for the acetanulation of transient embustibles or fire-conditions.. %e radiation levels in bog areas make the use of
.a-continuous. fire watch undesirable due to ALARA oC considerations.
%e placanent of a continuous fire watch in these areas would result in an additional unnecessary exposure of approximately 17.5 man-Ren per area per - year.
%erefore, the PEOs and securicy personnel will serve the ' function of a roving fire watch -in these area.s to - supplement the area-wide autmatic detection systen already installed on the 130 ft level.
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.-Septenber 4, 1984 Page-2 b
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Cepensatory Measures (Continued)
It.should be notad that the offsite power sources at Plant Hatch are. highly reliable and diverse such that the normal systens used by the operator for plant shutdown which are powered fra offsite power should be available to the operator following a fire in the reactor building. With normal systens and procedures available, the operator has inuch greater flexibility in safely shutting down the reactor than that assmed in the Appendix R analysis.
%e majority of the reactor building areas are large open areas with high
-ceilings.
%us, the possibility in the interim period of a
-fire large enough to danage sufficient-equipnent in both shutdown -pathways and systens powered fra offsite power to prevent reaching cold shutdown is very soall.
4.1.6
. Reactor Building South of Colmn Line R7 - Unit 1 Non-Outage Modifications / Implenentation Schedules Wrap conduit ESS-II-3645 with 1-h barrier - February 1986 o
Wrap conduit ESS-II-3648 with 1-h barrier - February 1986 o
Wrap conduit ESS-I-3838 with 1-h barrier - February 1986 o
Cmpensatory Measures o
Corduits ESS-II-3645, ESS-II-3648, and ESS-I-3838 will be wrapped within this area with Kaowool to provide a tenporary fire barrier.
4.1.7 West DC Switchgear Room - Unit 1
.Non-Outage Nodification / Implenentation Schedule Upgrade wall between switchgear rom and oil conditioner rom o
to 3-h barrier - July 1985-Compensatory Measures The existing two hour wall serves as an interim fire barrier.
o-Also, a full autmatic suppression systen exists on the opposite side of the wall providing additional protection.
4.2.2 Control Building Health Physics Area - Unit 2 Non-Outage Modificatirn / Implenentation Schedule o
Extension of sprinkler systens to cover trays
- 200A801, 2CRA801, and 2WA701 - November 1985 Compensatory Measures
%e cable trays of concern are in the ceiling above the health o
physics area and are separated by approximately 40 ft with minimal intervening ca bustibles. % e ceiling tiles will be Septenber 4, 1984 Page 3
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Compensatory Measures 1 (Continued) removed ~ fra -the areas of concern to facilitate detection of any fire condition by. the health physics personnel.-
ne health. physics - area is normally occupied and manual fire fighting equipnent is available.
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' 4.2'.41 Control Building il Conditioner Room - Unit 2 Non-Outage' Modifications / Impleantation Schedules
-Wrap raceway 2E22063 with 1-h barrier April 1986 o.
Wrap raceway-2E22064 with 1-h barrier - April 1986
.o Upgrade wall to 3-h fire rating - April 1985 o
rw eensatory Measures
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. We wall is presently. 2-h rated and the rom has a full automatic supp ession syste.
l, 4.2.6 Reactor. Building North of Coltan Line R19 - Unit 2
-Non-Outage Modifications / Implementation Schedules
' Install sprinkler syste on elevution 158 ft - July 1985
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o Install detection syste on elevation 158 ft - Dece ber 1985 o-
- Crumensatory Measures o
while these modifications in the reactor building do not specifically meet the criteria for outage-related work, they do involve work in a rarliation field and. in proximity - to safety-related equipnent.
Weir
. treatment.herein
~ as non-outage-related work for purposes of establishing 10 CFR -
50.48 scheduler definition' 'may in fact be overly.
conservative.
However, the. work (along' with certain aspects
(
of the outage-related work) must proceed during non-outage-periods in order to meet our proposed schedule and we, therefore, propose the following:
The sprinkler and detection systes to be installed are part L
of the water curtain to be used to divide the reactor building
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%e cabustible loading in the 158 ft into two fire areas.
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2 (34,367 Btu /ft ).with path 1 and 2 elevation : area is low L
cmponents separated by approximately 50 ft of open' area with intervening cmbustibles.
%e area' is regularly minimal toured by PEOs and security personnel who would beiinstructed g
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to observe the area for a fire condition or accunulation of
.a cabustibles which could lead to a fire. % e radiation level in the area makes the use of a continuous fire watch-
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undesirable due to AIARA considerations.
The placement of a continuous fire watch in these areas would. result in.
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%erefore, the Lw approximately 17.5 ran-Ren per area per year.
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PEOs and security personnel will serve the function of: roving t
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. September 4,-1984' Page 4
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L C epensatory Measures (Continuedt fire watt.in these ~ areas.
It' should be noted that the offsite power. sources at Plant. Hatch are highly reliable and
~ diverse such that the: normal systens used by the operator for
. plant shutdown which _ are powered fra offsite power, should be available to. the. operator following a, fire in the reactor the building.
With normal systes' and-procedures available, operator has much greater flexibility in ~ safely shutting down
'Ihe n the reactor. than:that assmed in the Appendix R analysis.
majority of 'the reactor building ar. s are. large. open areas
-with high - ceilings.
Thus,- the - possibility in the interim
. period of a fire large enough to daage sufficient equipnent
~ in both shutdown; pathways and systens powered fra coffsite power to prevent reaching cold shutdown is very sna11..
.'4 2.9
-Turbine Building East Cableway - Unit 2
.Non'-Outage Modifications / Implementation Schedules Wrap the following conduits with 1-h barrier - November 1985:
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o 2CKA701, _2 CIA 701, 2CMA701, 2E12076, 2E12082, 2E12084, 2E12085, 2E22824,.2MR2543, 2MR2544, and 2C3R801 Cepensatory Measures
'Ihe Unit 2 : Turbine Building east-cableway presently --has an
- o' autm atic suppression systen installed.
Diesel Building Suitchgear Bom 2G - Unit 2 4.2.10 Non-Outage Modificaticns / Implenentation Schedules f
Wrap raceway 2ESB170 with 1-h barrier - July 1986 o
Wrap raceway 2ESB168 with l h barrier ~ 1 July 1986 i
o
. Wrap raceway-2ESB167 with 1-h barrier'- July 1986 o
I; cepensatory Measures Raceways 2ESB167, 2ESB168, and 2ESB170 will be wrapped within o
this area with Kaowool to provide a tmporary fire barrier.
4.3.2 control Building Corridor -.Concon.
Non-Outage Modifications / Implenentation Schedules t
Wrap the ~following raceways with 1-h barrier - June 1986:
~o l-Unit 2
- Unit 1 f_
'IM08 TIDB 172.
'IEA8-03 M 1-l
! TEA 8-04 TEJ8-01 TEH8-03 2CZA801 l
. 'IML8-01 TEB8-02
'IEH8-01 2CZB801 TEB8-03 TEB8-04 TEH8-02 l
ESS II-477 TEB8-01 I:
I.I Septenber 4, 1984 Page 5-n i'
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.a Non-Outage Modifications / Impl e entatt & thedule (Continued)-
' Extend sprinkler systs to provide full coverage - Noveber o
1985 Compensatory Measures o;
'Ihe-control building canon corridor presently contains a partial sprinkler systs and sme raceways wrapped with Kaowool as ' part of the Appendix A modifications.
- Further, there is area-wide detection syste installed.
The corridor is a high traffic area providing access between units and is often occupied by health physics personnel at radiological check points; the potential for an undetected fire is relatively low.
4.3.3 FPS and ' Vertical Cable Chase Roms - Omnon Non-Outage Modifications / Impleentation Schedules Wrap raceway ESS-I-499 with 1-h barrier - June 1986 o
Install 3-h fire-rated doors to separate RPS roms frm cable o
chase - Novmber 1984 Cmpensatory Measures o
Raceway ESS-I-499 will be wrapped within this area with Kaowool as a tmporary fire barrier. 'Ihe vertical cable chase has an autmatic suppression systs installed.
Septaber 4, 1984 Page 6 l
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