ML040430224
| ML040430224 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/05/2004 |
| From: | Casto C Division of Reactor Safety II |
| To: | Sumner H Southern Nuclear Operating Co |
| References | |
| EA-04-207, FOIA/PA-2004-0277 IR-03-006 | |
| Download: ML040430224 (9) | |
See also: IR 05000321/2003006
Text
February 5, 2004
Southern Nuclear Operating Company, Inc.
ATTN: Mr. H. L. Sumner, Jr.
Vice President - Hatch Nuclear Plant
P. O. Box 1295
Birmingham, AL 35201-1295
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT - RESPONSE TO INSPECTION REPORT
NOS. 05000321/2003006 AND 05000366/2003006
Dear Mr. Sumner:
In your letter dated October 1, 2003, in response to our Triennial Fire Protection Inspection
Report 05000321/2003006 and 05000366/2003006, you made several requests. One of those
requests was that the NRC withdraw Non-Cited Violation (NCV) 50-366/03-06-04, Unapproved
Manual Operator Actions for Post-Fire SSD. In our letter to you dated November 18, 2003, we
stated that we were still reviewing additional information that you had provided in response to
that NCV. We have now completed our review of your information related to that NCV and are
advising you of our decision. Details of our review are in the enclosure to this letter, titled
Evaluation of Licensee Information.
Based on our review of your additional information, we are withdrawing the examples of the
NCV related to a high pressure coolant injection (HPCI) pump runaway. Your information has
substantiated that the HPCI pump is not vulnerable to cable failures that could cause a runaway
condition due to fires in III.G.2 areas, where plant shutdown would be from the control room.
Your Safe Shutdown Analysis (SSA) and Fire Procedure differ from your additional information
with respect to HPCI vulnerability to a runaway condition due to fires; consequently, those
documents are not current with your latest information.
However, we have concluded that your information did not provide a valid basis for withdrawing
the example of the NCV related to the local manual operator action for repowering the battery
chargers. Also, as explained in the enclosure, you may need to perform additional reviews to
verify that this operator action can be performed (will not be affected by the fire) for fires in all
fire areas where the action may be needed.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter will be
available electronically for public inspection in the NRC Public Document Room or from the
Publically Available Records (PARS) component of the NRCs document system (ADAMS).
SNOPCO
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ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Should you have any questions concerning this letter, please contact me at (404) 562-4600.
Sincerely,
/RA/
Charles A. Casto, Director
Division of Reactor Safety
Docket Nos.: 50-321, 50-366
Enclosure: Evaluation of Licensee Information
cc w/encl:
J. B. Beasley, Jr.
Executive Vice President
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution
George R. Frederick
General Manager, Plant Hatch
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution
Raymond D. Baker
Manager Licensing - Hatch
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution
Arthur H. Domby, Esq.
Troutman Sanders
Electronic Mail Distribution
Laurence Bergen
Oglethorpe Power Corporatioln
Electronic Mail Distribution
Director
Department of Natural Resources
205 Butler Street, SE, Suite 1252
Atlanta, GA 30334
(cc w/encl contd- See page 3)
SNOPCO
3
(cc w/encl contd)
Manager, Radioactive Materials Program
Department of Natural Resources
Electronic Mail Distribution
Chairman
Appling County Commissioners
County Courthouse
Baxley, GA 31513
Resident Manager
Oglethorpe Power Corporation
Edwin I. Hatch Nuclear Plant
Electronic Mail Distribution
Senior Engineer - Power Supply
Municipal Electric Authority
of Georgia
Electronic Mail Distribution
Reece McAlister
Executive Secretary
Georgia Public Service Commission
244 Washington Street, SW
Atlanta, GA 30334
SNOPCO
4
Distribution w/encl:
S. Bloom, NRR
C. Evans, RII EICS
L. Slack, RII EICS
RIDSNRRDIPMLIPB
PUBLIC
OEMAIL
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:EICS
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SIGNATURE
RA
RA
RA
RA VIA E-MAIL
NAME
RSchin
CSmith
KODonohue
CEvans
COgle
BBonser
DNelson
DATE
1/13/2004
1/13/2004
1/14/2004
1/15/2004
1/22/2004
1/16/2004
2/5/2004
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
PUBLIC DOCUMENT
YES
NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML040430224.wpd
Enclosure
EVALUATION OF LICENSEE INFORMATION
On September 1, 2003, NCV 50-366/03-06-04 was identified during a routine NRC inspection at
the Hatch nuclear plant. In a letter of October 1, 2003, Southern Nuclear Operating Company
requested that the NRC withdraw that NCV for various reasons. The NRCs evaluation of
information provided by the licensee to support that request is as follows:
Restatement of NCV 50-366/03-06-04, Unapproved Manual Operator Actions for Post-Fire Safe
Shutdown
10 CFR 50, Appendix R, Section III.G.2, requires that where cables or equipment, including
associated non-safety circuits that could prevent operation or cause maloperation due to hot
shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve
and maintain hot shutdown conditions are located within the same fire area outside of the
primary containment, one of the following means of ensuring that one of the redundant trains is
free of fire damage shall be provided: 1) a fire barrier with a 3-hour rating; 2) separation of
cables by a horizontal distance of more than 20 feet with no intervening combustibles and with
fire detectors and automatic fire suppression; or 3) a fire barrier with a 1-hour rating with fire
detectors and automatic suppression.
Contrary to the above, the licensee had not provided the required physical protection against
fire damage for power to the station service battery chargers or for HPCI electrical control
cables [for fires in fire areas 2016, west 600 volt switchgear room; 2014, east cableway; 2404,
switchgear room 2E; and 2408, switchgear room 2F], where "cables or equipment, including
associated non-safety circuits that could prevent operation or cause maloperation due to hot
shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve
and maintain hot shutdown conditions are located," as per 10 CFR 50, Appendix R, Section
III.G.2. Instead, the licensee relied on local manual operator actions, without NRC approval. In
response to this issue, the licensee initiated CR 2003800166. Because the issue had very low
safety significance and has been entered into the licensees corrective action program, this
violation is being treated as an NCV, consistent with Section VI.A of the NRCs Enforcement
Policy: NCV 50-366/03-06-04, Unapproved Manual Operator Actions for Post-Fire Safe
Shutdown.
Specific Procedure Steps With Unapproved Manual Operator Actions
Specific steps in Abnormal Operating Procedure (AOP) 34AB-X43-001-2, Fire Procedure,
Version 10.8, that involved reliance on unapproved local manual operator actions to achieve
and maintain hot shutdown, instead of physical protection of cables from fire damage as
required by Section III.G.2, included:
Step 4.15.2.2; ...If a loss of offsite power occurs and emergency busses energize
..."Place Station Service battery chargers 2R42-S026 (2R42-S029), 2R42-S027 (2R42-
S030) AND 2R42-S028 (2R42-S031) in service per 34SO-R42-001-2."
Step 4.15.4.5; ...If HPCI fails to automatically trip on high RPV level... "OPEN the
following links to energize 2E41-F124, Trip Solenoid Valve, AND to fail 2E41-F3025
HPCI Governor Valve, in the CLOSED position:
2
TT-75 in panel 2H11-P601
TT-76 in panel 2H11-P601"
Step 4.15.4.6; ...If HPCI fails to automatically trip on high RPV level... "OPEN breaker
25 in panel 2R25-S002 to fail 2E41-F3052, HPCI Governor Valve, in the CLOSED
position."
Restatement of Licensees Response to NCV 50-366/03-06-04
The licensees response is restated below and separated into six statements, each of which is
addressed by the following NRC evaluation.
1.
This issue was not initially characterized as a violation at the exit meeting conducted on
July 25, 2003, but was subsequently identified as a NCV during the re-exit held on
September 2, 2003.
2.
Two sets of steps in a fire procedure were cited as examples in the inspection report.
One step is associated with an operator manual action to reenergize certain battery
chargers after an assumed loss of offsite power event in conjunction with a fire event.
This combination of events is only required by Appendix R for alternative or dedicated
shutdown. For Plant Hatch, this represents a Control Room, Computer Room, or Cable
Spreading Room fire (Fire Area 0024).
3.
In an October 31, 1986 response to a Request for Additional Information regarding an
Appendix R Exemption Request on control room emergency lighting, the manual action
of reenergizing the battery chargers was described. The January 2, 1987 NRC SER
granting the Appendix R lighting exemption also took note of the battery chargers.
4.
The manual action is in recognition of the desirability of restoring the battery chargers
following any loss of offsite power. Even with no fire-induced cable damage, the
procedure step would be used. Thus, the step is not in the procedure for compliance
with Appendix R,Section III.G.2. Rather, the inclusion of a step in the fire procedure to
manually reenergize the subject battery chargers provides the operators with additional
actions that could be performed should such an unlikely event occur.
5.
The other steps referenced in the inspection report relate to manual actions to prevent
RPV overfill if HPCI fails to automatically trip on high level. These manual actions were
not added to the fire procedure due to a lack of separation of redundant trains of
cables. Rather, the safe shutdown function of the RCIC system is redundant to the
safe shutdown function of the HPCI system. Circuits required for the operation of
RCIC and HPCI are separated as required by Appendix R Section III.G.2. RCIC is used
for a path 1 shutdown and HPCI is used for a path 2 shutdown.
6.
Thus, neither of the manual actions described in this NCV represent a manual action
associated with Appendix R Section III.G.2. Based on this information, SNC requests
that this NCV be withdrawn.
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NRC Evaluation of Licensees Response
1.
The NRC agrees with this licensee statement. At the exit meeting on July 25, 2003, this
issue was not characterized as a violation, but instead was characterized as part of an
unresolved item. After further team in-office review of the NRC policy for documenting
such issues as Green findings, as stated in NRC Inspection Procedure 71111.05, Fire
Protection, this issue was recharacterized as a Green finding and NCV. However, the
fact that the issue was recharacterized as an NCV after the inspection team left the site
does not constitute a basis for the NRC to withdraw the NCV.
2.
The NRC does not agree with this licensee statement. The concern is not an assumed
loss of offsite power concurrent with a fire. Instead, the concern is that fires in certain
areas of the Hatch plant can cause a loss of offsite power. The Hatch SSA
conservatively assumes that a fire in any fire area can cause a loss of offsite power. A
more detailed NRC review after receipt of your October 1, 2003, letter indicated that
fires in two of the four focus areas for the inspection (4KV switchgear rooms 2E and 2F)
could cause fire damage to cables that could result in a loss of offsite power to
additional safety-related alternating current (AC) busses and consequently a loss of
power to battery chargers that are required to maintain hot shutdown conditions. The
Hatch design is such that following such a loss of offsite power, the emergency diesel
generators would automatically start but the battery chargers would not be automatically
repowered. The station batteries are designed to provide vital direct current (DC)
electrical power for two hours, and the battery chargers would have to be locally
manually reenergized within that time to maintain the vital DC electrical power that is
needed for instrumentation and control that is required to maintain the reactor in a hot
shutdown condition.
10 CFR 50, Appendix R, Section III.G.2 requires that, where fire damage to cables could
prevent operation of redundant trains of equipment necessary to maintain hot shutdown
conditions, the cables must be physically protected from such fire damage by one of
three specified methods. Local manual operation of equipment is not one of the three
specified methods. Further, the licensee had received no NRC exemption from this
requirement for power to the battery chargers. Consequently, this licensee statement
does not constitute a basis for the NRC to withdraw the NCV.
3.
The NRC agrees with this licensee statement. In the referenced documents, the
licensee requested an exemption from the requirements of Appendix R,Section III.J for
8-hour battery-powered emergency lights in the control room and the NRC granted that
exemption. However, an NRC review of the referenced documents determined that they
do not constitute an NRC approval to deviate from the Section III.G.2 requirement for
physical protection of cables from fire damage that could result in a loss of power to the
battery chargers and consequently the instrumentation and controls that are required to
maintain hot shutdown conditions. Consequently, this licensee statement does not
constitute a basis for the NRC to withdraw the NCV.
4.
The NRC agrees that the Hatch abnormal procedures that would be used following a
loss of offsite power, without a fire, would include locally manually repowering the
battery chargers. However, the specific procedure step that is addressed in this NCV is
in the Fire Procedure, which would only be used in the event of a fire. As described
4
above, 10 CFR 50, Appendix R, Section III.G.2 requires that, where fire damage to
cables could prevent operation of redundant trains of equipment necessary to maintain
hot shutdown conditions, the cables must be physically protected from such fire damage
by one of three specified methods. Local manual operation of equipment is not one of
the three specified methods. Consequently, this licensee statement does not constitute
a basis for the NRC to withdraw the NCV.
As stated in 2. above, Appendix R,Section III.G.2 requires that power to the battery
chargers be physically protected because it is needed to maintain the reactor in a hot
shutdown condition following a fire. Use of an operator action to repower the battery
chargers during non-fire conditions does not make that action acceptable during a fire.
Plant conditions during a fire could be significantly different than plant conditions with no
fire. With no fire, two trains of safe shutdown equipment should operate. However,
during a fire only one train of safe shutdown equipment may be operable since only one
train of safe shutdown equipment is required to be designed to be free of fire damage.
Also, a fire may affect the ability of operators to perform local manual operator actions.
During the onsite inspection, the licensee verified (and the NRC inspectors checked)
that, for a fire in any one of the four fire areas inspected, the local manual action to
repower the battery chargers was reasonable (met the criteria of Enclosure 2 to NRC
Inspection Procedure 71111.05) because the action was either not affected by the fire or
was not needed because the fire would not cause a loss of offsite power. However, the
licensee may need to perform additional reviews to verify that this operator action can
be performed (will not be affected by the fire) for fires in all fire areas where the action
may be needed.
5.
The Fire Procedure contained steps to respond to a generic fire issue of potential
reactor pressure vessel (RPV) overfill due to HPCI runaway. These steps applied to a
fire in any area of the plant, including the four fire areas that were selected to be the
focus of the inspection. The licensees SSA indicated that RPV overfill, which could be
caused by a fire-induced HPCI runaway, must be prevented by operator actions to
support safe shutdown. 10 CFR 50, Appendix R, Section III.G.2 requires that, where
fire damage to cables could cause maloperation of redundant trains of equipment
necessary to maintain hot shutdown conditions, the cables must be physically protected
from such fire damage by one of three specified methods. Local manual operation of
equipment is not one of the three specified methods.
Subsequent to the licensees letter of October 1, 2003, licensee personnel stated that
there was no vulnerability to a HPCI pump runaway due to fires in areas of the plant
where shutdown would be from the control room. The licensee personnel provided
additional information to the NRC showing the routing through the plant of the specific
RPV level instrument cables that could cause a HPCI runaway as a result of fire
damage. The NRC inspectors verified that there were two independent trains of high
RPV level instruments, either of which would trip the HPCI pump on high RPV level.
The inspectors further verified from a review of drawings that the cables for the two
independent trains were routed through different fire areas in the plant, except for the
cable spreading room or control room. A fire in the cable spreading room or control
room would involve evacuation of the control room and use of a different procedure for
safe shutdown of the plant. Consequently, there were no III.G.2 fire areas, for which
safe shutdown would be accomplished from the control room using the Fire Procedure,
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where there was a vulnerability to fire damage to cables that could result in a HPCI
runaway.
The additional information described above provides a basis for the NRC to withdraw
the examples of this NCV dealing with HPCI runaway. It also provides a basis for the
licensee to update their SSA and Fire Procedure accordingly.
6.
As discussed above, the additional licensee information provides a basis for the NRC to
withdraw the examples of this NCV dealing with HPCI runaway. However, the
information did not provide a valid basis for withdrawing the example of this NCV related
to the local manual operator action for repowering the battery chargers.