ML20107F181

Provides Basis for Request for Exemption from 10CFR50.48 Requirements Re Implementation of non-outage Related 10CFR50,App R Mods.Fire Protection Enhancement Program Cannot Be Implemented within Expected Time Frame

ML20107F181
Person / Time
Site:	Hatch
Issue date:	10/26/1984
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-84-558, TAC-54802, TAC-57415, TAC-57416, NUDOCS 8411050321
Download: ML20107F181 (3)

Text

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Gec gia Power Ccmpany 333 Padmcat Avenue .

Attanta, Georgia 30308 Telephcne 404 5266526 Maing Address:

Post 0;.lce Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwe the southern eiectu:c system j Manager Nuclear Engineering

' and Chief Nuclear Engineer NED-84-558 l

' October 26, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Ccmnission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSIE DPR-57, hPF-5 ENIN I. HA'IG NUCLEAR PIANT UNITS 1, 2 BASIS FOR RECUEST FOR EXEMPTIN 'IO 10 CFR 50.48 Gentlenen:

In discussions between the NRC staff and representatives of Georgia Pow & Cmpany (GIC) the need to splify upon the necessity for schedular exenption to the provisions of 10 CFR 50.48 was disclosed. GPC sutmits the following discussion pursuant to that need.

10 CFR 50.48 provides a schedular requirenent which, in part, allows nine months after termination of the tolling provision of Section C [6] for implenentation of non-outage related 10 CFR 50 Appendix R modifications.

Similarly, an allowance to the end of a specific outage (as defined in Section C [3]) is provided for outage related modifications. These schedular allowances for design, procurenent, and installation of Appendix R modifications were established through conventional rulemaking to address a typical progra for meeting what were then perceived to be the rquirenents of Amendix R. It was noted by public ccmnents submitted in response to the proposed 10 CER 50.48, published in the May 29, 1980 Federal Register, that insufficient time was provided for cm.pliance. In - recognition of these connents, and the fact that the effective date of the rule was beyond the stated schedule for empliance, 10 CFR 50.48's implenentation requirenents were revised to the schedular allowances noted above. However, these allowances are still inadquate for implanentation of a project of the magnitude of the fire protection enhancement progrm at Plant Hatch. In order to gauge the scope and extent of the progre being undertaken, one 8411050321 841026 0ph PDR ADOCK 05000321 F PDR v

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COrgia P0%ki

= Director of Nuclear Reactor Ragulation

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Attention: Mr. John F. Stolz, Chief-M^ - . Operating Reactors-Branch No. 4-

~ . October 26, 1984-- '

Page h o a should note;the projected cost of approximStely twenty-five~ million dollars (excluding the alternate . shutdown l system for. the control room / cable .

i spreading ; rom - fire) . = Such a progra cannot- be practically -or : effectively

-impleented within the time free estimated in the developent of a the '

Appendix 1R. regulation.. %is insufficient schedular allowance in the

regulation is ' the fundmental cause . of our requested exemption to the provisions of 10 C m 50.48.

In the specific case. of Plant Hatch, see additional' considerations are -

worthy of review. Plant design is not static --

Appendix R' is being impleented on a plant . undergoing change. Consequently, design is 4

predicated on a predicted- plant configuration.' One of the, fund mental

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concepts employed in our defense-in-depth - fire protection design .is the~

4 establishment of fire barriers about safe shutdown related equipent. and -

l cables. Currently, extensive redesign - and modification _ of such sluipent . I and . cables is underway in response to progres such as equipent l qualification, operational safety enhance ents, and plant _ reliability -

%ese projects are inherently interdependent and, in fact,

improvments.

j the design for Appendix R cableway barriers must in many cases follow the i_ final - design of the equipent . qualification project.. Indeed, the two designs empliment .one another wherever possible such that installation of the new equipent and its related cabling meet the separation requirements

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, of Appendix R and preclude the need of barriers installation. W e scope and implementation delays of the equipent qualification- progre have been the l subject of separate correspondence. %e intergration of these efforts is ~

1 necessary for effective safe modification of the plant to. meet ' current i regulation and hence implementation of Appendix R is _directly impacted by delays in these other progras. Sis special relationship was cited in our

letter NED-84-035 dated January 25, 1984.

i %e design sequences of the Appendix R modifications themselves are more l emplex than is imediately obvious. After the extensive analysis raguired l to establish what plant equipent and circuits require protection, design must sequentially address several factors. In the case of wrapping a cable tray for exmple, the designer must: 1) perform a design walkdown to confirm design assmptions; 2) perform a seimic reanalysis of the cable tray; 3) redesign the cable tray supports to account for the increased mass of the barrier material; and - 4) design the barrier wrap. Neither the final bill-of-saterials with its potential ' associated delivery problems, nor the specifications - for . the bidding of installation contracts can proceed until l[ - . - . , . ,, , . . , -- .-_ _ . , _ - . - _ , , ~ . - . _ _ . - . . - . - . . - - , _ , . . - . - _ _ . - . - - - -

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GeorgiaPbwerI i- Director of Nuclear: Reactor Regulation Attention: Mr. John F. Stolzi Chief I Operating Reactors Branch No.-4  !

October 26, 1984 l Page hree  !

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' the design is s near -its final stages.. Following design, . implenentation must-

-logically wait for any rerouting- of cables fra Appendix R or equipnent qualification modifications. Further, any extensive . fire detection 1 or suppression . modifications in the inmediate vicinity' which might 11ead to

d a age .of the wrap 'must be . factored 'into the implementation process.

. Finally, upgrading of the tray supports, as necaaamry, and tray wrapping may

-be acceplished. This exmple points out see of the difficulty in-implenentation which leads to schedules which are longer .than were

, anticipated during the development of the regulation.' ,

I The final. design must follow . acceptance .by the NRC of .the conceptual approach to compliance with Appendix R. This is provided for by 10 CFR

j. 50.48.C [6]. However, in order to meet a schedule such as was last proposed

in our letter NED-84-523, dated October 19,'1984, analysis and design has in-fact proceeded at .our risk since the issuance of Appendix R. A' significant dedication of - the design resources available to GPC from its architect 4

engineers and consultants has been made to achieve the projected cepliance with Appendix R. Such resources are concurrently _ being soployed to reet other regulatory and safety-related issues at Plant Hatch. No one

!- requirement or safety enhancenent can-be considered -exclusive of the total i demands on available resources. In this light, GPC has assigned a high priority to compliance with Appendix R and = the proposed implenentation schedule has been the result.

, GPC requests a timely response to our_ requested extension so that we may -

proceed on our best reasonable effort to meet the requirenents of Appendix R. If further information is required, please contact this office.

Very truly yours,

/f f - e i L. T. Gucwa WEB /inb xc: J. T. Beckhm , Jr.

, H. C. Nix, Jr.

J. P. O'Reilly (NRC- Region II) i Senior Resident Inspector' I

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