ML20114B418

Responds to 850116 Order & Provides Rev to Interim Mitigation Factors for Nonoutage Related App R Mods,Per 850117 Telcon

ML20114B418
Person / Time
Site:	Hatch
Issue date:	01/17/1985
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
1369N, NED-85-040, NED-85-40, TAC-43754, TAC-43755, TAC-47143, TAC-48071, TAC-48072, TAC-48701, TAC-48702, TAC-48748, TAC-48749, NUDOCS 8501290158
Download: ML20114B418 (2)

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)y Georgia Power Curreany 333 Piedrnont Avenue Atirta. Georgia 30308 Te:ephone 404 526 6526 Maihrg Address:

Post Off;ce Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwa the southem c4xtoc system Manager Nuclear Eng:neer:ng and Chief Nuc; ear Engineer NE M 5-040 1369N January 17, 1985 Director of Nuclear Peactor Regulation Attention: Mr. John F. Stolz, Chief operating Reactors Branch No. 4-Division of Licensing U. S. Nuclear Regulatory Cmmission Washington, D. C.

20555 NRC DOCKITS 50-321, 50-366 OPERATING LICENSE DPR-57, NPF-5 EDWIN I. HN1DI NUCLEAR PIANU UNITS 1, 2 REVISION TO INTERIM MITIGATION FACIDPS EDR NON-OUTAGE RELATED APPENDIX R MODIFICATION Gentlemen:

'In our letter NED-84-444 dated September 4,1984, Georgia Power Company (GPC) proposed the wrapping of seven segments of electrical conduits in Kaowool fire barriers to serve as a compensatory measure for the interim period from the expiration of cne implementation schedule allowed by 10 CER 50.48 and the projected implementation date for non-outago related Apperxlix R modifications.

In supplemental correspondence (NED-84-518 dated October

- 2, 1984 and NED-84-553 dated December 20, 1984) a connitment was made to a roving fire watch to provide an equivalent level of compensatory protectim for certain other areas in which compliance with the schedule of 10 CFR 50.48 was not possible.

In an order dated January 16, 1985, the NPC issued an Exemption to 10 CFR 50.48 which was based on the assurance of adequate fire protecticri provided by the compensatory measures noted in the correspondence referenced above.

However, a revision to the proposed program of compensation has been required.

GPC herein describes these revisions as discussed with the staff of the Director of Nuclear Reactor Regulation.

In the developnent of the detailed engineering design required to

' install the Kaowool, it was determined that more extensive seismic analysis would be required than had been anticipated at the time of the proposal of their use.

Because of thic design difficulty, it has not been possible to install the proposed Faowool barriers in a timly manner.

Rather, as allowed by the terms of the Exemption to 10 CFR 50.48, the patrol area of the roving fire watch has been expanded such that all the conduits in question (i.e., thit l's ESS-II-477, in the 4160v Transformer Room and 600 V Switchgear Ibom, R25-S037-ES4-M14 in the Control Building, thit 2's 2ESB167, 2ESB168, and 2ESB170 in the Diesel Generator Building, and the common RPS hg O

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.I GeorgiaPowerd Director of Nuclear Reactor Regulation Attention:

Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 January 17, 1985 Page 'IWo -

Vertical Cable Chase conduit ESS-I-499) will be observed by the fire watch

-at the same frequency as discussed in our previous correspondence. Thus an equivalent level of assurance of fire safety has been provided as was assumed in the granting of the subject exemption. This matter was discussed by representatives of GPC with Mr. G. Rivenbark and Mr. D.

Kubicki of the NBC staff in a telephone conference call on January 17, 1985. The technical equivalency of the two compensatory measures, and the acceptability of the revisicn to GPC's program of compensatory measures under the guidelines issued by the NRC as " Guidance on Interim Measures to Support Schedular Exemption Requests" and under the provisions of the January 16, 1985 Exemption to 10 CFR 50.48 was agreed to by all parties.

Should you have any questions in this regard, please contact thic office.

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Yours very truly,

/ '[ & - A L. T. Gucwa

.wrs/mb xcs. J. T. Beckhara, Jr.

H. C. Nix, Jr.

J. P. O'Reilly (NRC-Region II)

Senior Besident Inspector l

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