ML20215F730
| ML20215F730 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/09/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20215F733 | List: |
| References | |
| SL-1716-A, TAC-61626, TAC-61627, NUDOCS 8612240045 | |
| Download: ML20215F730 (8) | |
Text
Georgia Fbwer Cc npany 333 Piedment Avmue -
Atlanta, Georgia 30308 Telephone 404 526-6526 Mailing Address:
Post Office Box 4545 Atts'ita, Georgia 30302 GeorgiaPower L T. Gucwa the southem electrc system Manager Nuclear Safety and Ucensing SL-1716-a 0977C December 9, 1986 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 APPENDIX R - REQUEST FOR ADDITIONAL INFORMATION Gentlemen:
In telephone communications occurring on December 4,1986, between Mr. G. Rivenbark, et al. and Mr. J. Heidt, et al., the NRC requested that Georgia Power Company submit specific information relative to the May 16, 1986, Appendix R Exemption Request.
Enclosed please find.the requested information.
If you have any questions in this regard, please contact this office at any time.
Sincerely,
(
L. T. Gucwa JDH/ac Enclosures c: Georgia Power Company U.S. Nuclear Regulatory Commission Mr. t. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr.
Mr. P. Holmes-Ray, Senior Resident Mr. H. C. Nix, Jr.
Inspector-Hatch GO-NORMS Mr. G. Rivenbark, Licensing Project Manager 8612240045 861209 f
DR ADOCK 05000321 PDR
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ENCLOSURE 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST PLANT PROCEDURES 40AC-FPX01-0 34AB-0PS-056-1S 34AB-0PS-056-2S l
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Georgia Powerb
' ENCLOSURE 1 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST Item 1:
(Reference Section 1.4 of GPC's May 16, 1986, Exemption Request.)
Additional justification is needed for this exemption request in the form of assurance that transient combustibles will be adequately controlled in the areas where the subject components are located.
Response
Administrative control procedures have been implemented at the E. I.
Hatch Nuclear Plant to control the introduction, storage, handling, and removal of combustible material s.
(See enclosed procedure 40AC-FPX01-0.)
These procedures apply either inside or adjacent to safety-related structures and during both power and maintenance operations.
The material s controlled include transient combustibles, flammable liquids, combustible liquids, and hazardous compressed gases.
Similar procedures are in place - to control ignition sources throughout the
_ pl an t.
A hot-work procedure controls
- welding, cutting, spark-producing operations, and open flames.
Hot-work procedures are issued by foremen who are required to be trained in fire hazard recognition and protection.
During hot work, fire watches are required in areas which house safety-related equipment or significant concentrations of combustibles.
Persons performing fire watches are required to be _ trained in the use of portable extinguishers on the different classes of fires and the procedures for sounding the fire alarm.
The use of nonflammable or flame-retardant materials is enforced at Plant Hatch, wherever practical.
The fixed combustible loading of plastic is maintained as low as reasonably achievable.
Plastic bags are used for contaminated clothing and trash isolation, but the use of bags is minimized during normal power operations.
The electrical cabling is predominantly IEEE-383 qualified to ensure slow development of any cable tray fires which may occur.
Only fire-retardant lumber is approved for use as scaffolding, laydown blocks, etc.
Application of the specific requirements of the Appendix R rule to the subject components is not necessary to achieve the underlying purpose of the rule.
The. application would result in undue hardship and is an unwarranted burden on GPC's available resources.
Since the covering of these components with a 1-hour fire barrier would adversely affect the operation and qualification of the components, the only other option available would be to relocate these components.
Relocation would be a 0977C El-1 12/09/86 mm
Georgia Power d ENCLOSURE 1 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST major design change requiring new design studies, engineering time,
installation of new piping, seismic supports, electrical raceway, raceway supports, and implementation of new plant operating and maintenance procedures.
These changes would result also in increased congestion in the Reactor Buildings, thus further complicating operation, maintenance, and future modifications.
This exemption request meets the requirements of 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
4 0977C El-2 12/09/86
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'I Georgia Power b ENCLOSURE 1 ADDITIONAL INFORMATION RELATIVE T0 s
t APPENDIX R EXEMPTION REQUEST,
s s
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Item 2:
(Reference Section 1.3 of GPC's May.16,1986, Exemption Request.)
Additional justification is required for Exemption 1.3.1.1.2 for the lack of 8-hour battery-powered emergency lighting for the service water s1ve' pits located in the yard area.
Response
To supplement hand-held flashlights for manual operation of valves in the service water valve pits, portable engine-driven lighting is available in the yard area.
These lighting units are normally used to suppl.ement yard security lighting when needed.
Some of these units have been located at the service water valve pits and dedicated for fire-protection use for manual operation of the service water valves should the Appendix R
" event" occur at night.
These lighting units will be maintained on a written security surveillance procedure to assure their availability when needed.
This procedure requires that each light be functionally tested once per week.
lighting (usually along with hand-held flashlights and
- units, These additional background illumination available),
provide assurance that suffi,cient lighting will be available under all circumstances for manual operator actions in these areas.
Application of the specific requirements of the regulation is not necessary to achieve the underlying purpose of the rule.
Upgrading the lighting system would require extensive engineering, design, and installation activities.
The cost of these modifications and the associated additional maintenance and surveillance tasks pose an unwarranted burden on GPC.-
This exemption request meets the requirements of 10 CFR 50.12(a)(2)(ii) and I 10 CFR 50.12(a)(2)(iii).
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0977C El-3 12/09/86
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Georgia Powerd ENCLOSURE 1 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST Item 3:
(Reference Section 3.1 of GPC's May 16, 1986, Exemption Request.)
Clarification and confirmation were requested concerning the procedure which will be ?n place as a compensatory measure for the schedular exemptions.
Response
As stated in previous correspondence, GPC will develop and implement a procedure to direct the operators relative to restoring each required load center should its feeder breaker trip due to faults caused by a fire.
This procedure will direct load stripping such that the load center can be reset, feeding only Appendix R-required circuits.
These procedures have been developed and are now in place.
(See enclosed procedures 34AB-0PS-056-lS and 2S.)
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b 0977C El-4 1 2/09/86
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Georgia Power d ENCLOSURE 1 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST Item'4:
(Reference sections of GPC's May 16, 1986, Exemption Request as noted below.)
The NRC requested that GPC provide additional summary statements of conclusion regarding alljof. the exemption requests.
Specific additional justification was not_ requested; however, a statetent of conclusion is needed to cite the regulatory justification for each exemption.
Response
's (1) Exemption Request 1.1.2 Based upon the justifications' presented in our May.16, 1986, Exemption Request, the boundaries of these fire areas are adequate' to ensure that a fire occurring within the areas will not damage required systems located outside the areas, and that a fire occurring outside -the areas will not damage required systems located inside the areas.
The upgrading of the fire area boundaries to a 3-hour rating, as required by the rule, is not necessary to achieve the underlying purpose of the rule.
The upgrading of the fire area boundaries beyond the modifications already completed will require major architectural and structural modifications to the plant buildings.
Major engineering studies and design work will be required.
Implementation 1of such design changes will require extensive installation time and will considerably incre7se congestion in numerous plant locations, thus complicating plant operation, maintenance, and future modifications.
For these retsons, compliance will pose an unwarranted burden on the resources of GPC.
This exemptfon request meets the requirements of 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
(2) Exemption Request 1.5 Based upon the information presented in our May 16, 1986, Exemption Request and in our followup letter dated October 31, 1986, separation of the HPCI control circuits in the Unit 1 and Unit 2 Reactor Buildings is adequate to prevent fire damage to all redundant HPCI controls needed for HPCI shutdown.
In this case, application of the specific requirements of the rule is not necessary to achieve the underlying purpose of the rule.
Compliance to the specific regulatory requirements would require extensive application of additional raceway fire barrier material.
Engineering analysis of TJne added seismic loads and cable ampacity derating would be required.
Design for additional raceway supports and interference relocations would also be required.
The cost of these modifications and the impact of the resulting increased surveillance, 0977C El-5 12/09/86 700775
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Georgia Power d
~ ENCLOSURE-1 ADDITIONAL INFORMATION RELATIVE TO i
APPENDIX R EXEMPTION REQUEST along with the added complexity of future modifications, represents an unwarranted burden on GPC. This exemption request meets the requirements of 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
(3) Exemption Request.1.6 Based upon the justification presented in our May 16, 1986, Exemption Request and in our followup letter dated October 31, 1986, further protection of the supports. for certain protected raceways is not
. required.
Application of the specific requirements of the rule is unclear in this instance; however, should the specific requirements be invoked, they are not necessary in this case to achieve the underlying purpose of the rule.
Compliance with such requirements would require extensive application of additional raceway fire barrier material.
Engineering analysis of the added seismic loads would also be required.
Design for additional raceway supports and interference relocations would be required.
The cost of these modifications and the impact of the resulting increased surveillance, along with added complexity of future modifications, represents an unwarranted burden on GPC.
This exemption request meets the requirements of 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
(4) Exemption Request 1.7 l
Based upon the justifications presented in our May 16, 1986, Exemption Request and in our follewup letter dated October 31, 1986, manual operator actions (or " repairs") are acceptable for the diesel-generator voltage regulator transfer circuits.
This " repair". is deemed acceptable because of its simplicity ed because the diesel-generators are sometimes defined as " cold shutdown' equipment on BWRs.
Should the diesel-l generators be defined as " hot shutdown" equipment, application of the specific requirements of the regulation would not serve the underlying purpose of the rule.
Installation of controls to preclude the need for this " repair" would entail engineering analysis to requalify the control panels and also engineering design for installation of the switches, as well as the actual field installation costs.
These costs are not justified in light of the minimal benefits which would be achieved. This exemption request meets the requirements of 1 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
1 0977C El-6 12/09/86 T00775
GeorgiaPower d ENCLOSURE 1 ADDITIONAL INFORMATION RELATIVE TO APPENDIX R EXEMPTION REQUEST (5) Exerrption Request 2.1 Based upon the justifications presented in our May 16, 1986, Exemption Request, compliance with the specific requirements of the rule relative to area-wide suppression systems and 1-hour fire barriers is not required in the river intake structure.
Full compliance with the prescriptive requirements of the regulation in this area would require extensive work for installation of additional sprinkler systems and additional raceway fire barriers.
Engineering analysis would be required for seismic design of piping and raceway supports and for cable ampacity derating.
Engineering design would be required for the additional sprinkler systems. The capacity of the existing fire pumps to supply these systems would require review.
Long-term plant operation would be impacted by the additional surveillance and maintenance of these systems.
Because this area is extremely congested (due partially to fire protection features added under BTP APCSB 9. 5-1, Appendix A), installation of additional systems will be di fficul t.
Maintenance and surveillance of any new systems will be difficult and will make maintenance of existing equipment even more complicated. Application of the regulation would not serve the underlying purpose of the rule and would pose an unwarranted burden on the resources of GPC.
This exemption request meets the requirements of 10 CFR 50.12(a)(2)(iii.nd 10 CFR 50.12(a)(2)(iii).
(6) Exemption Requests 2.2, 2.3, 2.4, 2.5, 2.6, and 2.7 Based upon the justifications presented in our May 16, 1986, Exemption Request, the boundaries of these fire areas are adequate to ensure that a fire occurring within the areas will not damage required systems located outside the areas, and that a fire occurring outside the areas will not damage required systems located inside the areas.
The upgrading of the fire area boundaries to a 3-hour rating. as required by the rule is not necessary to achieve the underlying purpose of the rule.
The upgrading of the fire area boundaries beyond the modifications already completed would require major architectural and structural modifications to the plant buildings.
Major engineering studies and design work would also be required.
Implementation of such design changes would require extensive installation time and would increase considerably congestion in numerous plant locations, thus complicating plant operation, maintenance, and future modifications.
For these reasons, compliance with the rule would pose an unwarranted burden on the resources of GPC.
This exemption request meets the requirements of 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(iii).
I 0977C El-7 12/09/86 700775
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