ML20203J883

Forwards Rev 0 to Vols 1-5 of 03-1380-1111, Ei Hatch Nuclear Plant Units 1 & 2 Updated Fire Hazards Analysis & Fire Protection Program, for Review & Approval Per 10CFR50.48,10CFR50,App R & Generic Ltr 86-10

ML20203J883
Person / Time
Site:	Hatch
Issue date:	07/22/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20203J887	List: ML20203J883
References
2848N, GL-86-10, SL-1004-A, TAC-61626, TAC-61627, TAC-62123, TAC-62124, NUDOCS 8608060062
Download: ML20203J883 (6)

Text

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Georgia Power Company 333 Piedmont Avenue Atlanta, Georg:a 30308 Telephor.e 404 526-6526 Po Of e 54 5 Atlanta. Georgia 30302 b Georgia Power L. T. Gucws 'he saut"em e;ectnc sys:em Manager Nuclear Safety and Licensing SL-1004-a 2848N July 22,1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Comission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 10 CFR 50.48 AND APPENDIX R UPDATED FIRE HAZARDS ANALYSIS AND FIRE PROTECTION PROGRAM Gentlemen:

As mentioned in previous correspondence, a reanalysis has been performed to confirm the original safe shutdown analysis which was the basis of the Georgia Power Company (GPC) " Response to 10 CFR 50.48 and Appendix R" first submi'.ted in July 1982. This reanalysis of the safe shutdown capability was performed to incorporate: 1) the additional guidance contained in Generic Letter 8 5- 01 , and 2) the information obtained from the NRC regior.a1 workshops held in the spring of 1984, as well as the additional plant modifications made to resolve other concerns unrelated to fire protection.

This reanalysis resulted in the need to file additional exemption requests which were contained in our May 16, 1986, submittal and were further discussed during our July 16, 1986, meeting held in your office.

In addition to the shutdown reanalysis, a complete new fire hazards analysis (FHA) of the plant also has been performed. The reason for this reanalysis was to ensure that adequate and consistent techniques for i

evaluating fire hazards were applied to all plant areas. This reanalysis also provides the framework for maintaining the long-term validity of the FHA during day-to-day plant activities. The new FHA is now complete and is i

enclosed for your information. The new FHA also resulted in the need to file additional exemption requests which were also contained in the May 16, 1986 submittal. Many of the justifications for these new exemption requests are based upon information contained in the new FHA.

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GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller,' Project Director BWR Project Directorate No. 2 July 22,1986 Page Two The updated FHA is to be the comprehensive document which describes the GPC Fire Protection Program for both safety-related and non-safety related elements and incorporates, as well as u our previous submittal s.

This document includes the 10 CFR 50.48(a) pdates, Fire Protection Program plan, th fire protection surveillance and operability requirements, and all specific exemptions to the Appendix R rule granted and pending. Since the Appendix R shutdown analysis is also a fire protection feature, a summary of the results of this analysis is provided for each plant area. Plant Technical Specifications changes to delete fire protection requirements which are currently contained in the FHA will be requested by a separate letter.

Final Safety Analysis Report (FSAR) revisions being submitted concurrent to this letter reference the new FHA for all fire protection features and requirements. The concept of consolidating all fire protection issues is consistent with the guidance provided in Generic Letter 86-10. It should be noted that the new FHA describes the plant as it will exist following the completion of all fire protection design changes. Certain modifications are not scheduled for completion prior to November 30, 1986. This ongoing work is either unrelated to Appendix R compliance or is covered in requested schedular exemptions. All items of this nature are discussed in the FHA.

Changes have been made to the Safe Shutdown Components List and to the number and type of plant modifications previously outlined in the " Response to 10 CFR 50.48 and Appendix R" submi ttal . The new FHA supersedes the original submittals with the exception of the specific exemption requests and their related justifications. The modifications which are required for compliance are indicated in the actual safe shutdown analysis for each fire area.

Appendix B to the FHA contains the new fire protection surveillance and operability requirements which will not become effective until the related plant Technical Specifications changes are approved by the NRC. We are requesting that these requirements become effective on December 1, 1986.

Should additional plant modifications necessitate changes to Appendix B, the changes will be resubmitted in conjunction with the requested Technical Specifications changes, or will be controlled per 10 CFR 50.59 requirements following the approval of the requested Technical Specifications changes.

Georgia Power Company believes that the most logical and efficient approach to minimizing the inconsistencies related to the fire protection license conditions discussed in Generic Letter 86-10 is the implementation of the plan described herein.

2848N 70077$

GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 22,1986 Page Three Thirty copies of the Hatch Fire Hazards Analysis and Fire Protection Program are transmitted for your review. NRC approval is needed for those portions of the FHA which require review and approval in accordance with 10 CFR 50.48; and 10 CFR 50, Appendix R; and Generic Letter 86-10.

If you have any questions in this regard, please contact this office at anytime.

Sincerely, f%

L. T. Gucwa JDH/mb Enclosures c: Georcia Power Company U. S. Nuclear Regulatory Commission Mr. t . P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Senior Resident Inspector i Mr. H. C. Nix, Jr.

I G0-NORMS 2848N

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Georgia Power Company 333 Ptomont Avenus Atttnta, Georgia 30308 Tri:enone 404 526-6526 Mailing Address:

Post Office Box 4545 Attanta, Georgia 30302 Georgia Power L T. Guewe ":he southem eiectrc system Manager Nuclear Safety and Licensing SL-1004-a 2848N July 22,1986 Director of Nuclear Reactor Regulation i Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boil _ing Water Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 i'

OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2

.' 10 CFR 50.48 AND APPENDIX R UPDATED FIRE HAZARDS ANALYSIS AND FIRE PROTECTION PROGRAM i

j Gentlemen:

) As mentioned in previous correspondence, a reanalysis has been performed

)

to confim the original safe shutdown analysis which was the basis of the

' Georgia Power Company (GPC) " Response to 10 CFR 50.48 and Appendix R" first submitted in July 1982. This reanalysis of the safe shutdown capability was performed to incorporate: 1) the additional guidance contained in Generic Letter 8 5 - 01 , and 2) the information obtained from the NRC regional workshops held in the spring of 1984, as well as the additional plant modifications made to resolve other concerns unrelated to fire protection.

This reanalysis resulted in the need to file additional exemption requests '

which were contained in our May 16, 1986, submittal and were further discussed during our July 16, 1986, meeting held in your office.

l In addition to the shutdown reanalysis, a complete new fire hazards analysis (FHA) of the plant also has been performed. The reason for this reanalysis was to ensure that adequate and consistent techniques for evaluating fire hazards were applied to all plant areas. This reanalysis also provides the framework for maintaining the long-term validity of the The new FHA is now complete and is FHA during day-to-day plant activities.

enclosed for your information. The new FHA also resulted in the need to i

file additional exemption requests which were also contained in the May 16, 1986 submittal. Many of the justifications for these new exemption requests are based upon information contained in the new FHA.

I

GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 22,1986 Page Two The updated FHA is to be the comprehensive document which describes the GPC Fire Protection Program for both safety-related and non-safety related elements and incorporates, as well as updates, our previous submittals.

This document includes the 10 CFR 50.48(a) Fire Protection Program plan, the fire protection surveillance and operability requirements, and all specific exemptions to the Appendix R rule granted and pending. Since the Appendix R shutdown analysis is also a fire protection feature, a summary of the results of this analysis is provided for each plant area. Plant Technical Specifications changes to delete fire protection requirements which are currently contained in the FHA. will be requested by a separate letter.

Final Safety Analysis Report (FSAR) revisions being submitted concurrent to this letter reference the new FHA for all fire protection features and requirements. The concept of consolidating all fire protection issues is consistent with the guidance provided in Generic Letter 86-10. It should be noted that the new FHA describes the plant as it will exist following the completion of all fire protection design changes. Certain modifications are not scheduled for completion prior to November 30, 1986. This ongoing work is either unrelated to Appendix R compliance or is covered in requested schedular exemptions. All items of this nature are discussed in the FHA.

Changes have been made to the Safe Shutdown Components List and to the number and type of plant modifications previously outlined in the " Response to 10 CFR 50.48 and Appendix R" submittal . The new FHA supersedes the original submittals with the exception of the specific exemption requests and their related justifications. The modifications which are required for compliance are indicated in the actual safe shutdown analysis for each fire area.

Appendix B to the FHA contains the new fire protection surveillance and operability requirements which will not become effective until the related plant Technical Specifications changes are approved by the NRC. We are requesting that these requirements become effective on December 1, 1986.

Should additional plant modifications necessitate changes to Appendix B, the changes will be resubmitted in conjunction with the requested Technical Specifications changes, or will be controlled per 10 CFR 50.59 requirements following the approval of the requested Technical Specifications changes.

Georgia Power Company believes that the most logical and efficient approach to minimizing the inconsistencies related to the fire protection license conditions discussed in Generic Letter 86-10 is the implementation of the plan described herein.

2848N

GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 22,1986 Page Three Thirty copies of the Hatch Fire Hazards Analysis and Fire Protection Program are transmitted for your review. NRC approval is needed for those portions of the FHA which require review and approval in accordance with 10 CFR 50.48; and 10 CFR 50, Appendix R; and Generic Letter 86-10.

If you have any questions in this regard, please contact this office at anytime.

Sincerely,

-~Y C x--~

L. T. Gucwa JDH/mb Enclosures c: Georsia Power Company U. S. Nuclear Regulatory Commission Mr.s. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Senior Resident Inspector Mr. H. C. Nix, Jr.

G0-NORMS W

2848N

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