ML050380470

Undated Draft Letter to Southern Nuclear Operating Company; Response to Inspection Report 50-321, 366/03-06

ML050380470
Person / Time
Site:	Hatch
Issue date:	02/03/2005
From:	Casto C Division of Reactor Safety II
To:	Sumner H Southern Nuclear Operating Co
References
EA-03-207, FOIA/PA-2004-0277 IR-03-006
Download: ML050380470 (6)

See also: IR 05000321/2003006

Text

EA-03-207

Southern Nuclear Operating Company, Inc.

ATTN: Mr. H. L. Sumner, Jr.

Vice President - Hatch Nuclear Plant

P. 0. Box 1295

Birmingham, AL 35201-1295

SUBJECT: EDWIN I. HATCH NUCLEAR PLANT - RESPONSE TO INSPECTION REPORT

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 a letter 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 Ill.G.2 areas, where plant shutdown would be from the control room.

Since this information differs from your Safe Shutdown Analysis (SSA) and Fire Procedure, we

expect that you will consider updating those documents accordingly.

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 NRC's "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 NRC's document system (ADAMS).

go~ID

SNOPCO 2

ADAMS is accessible from the NRC Web site at http://www.nrc.clov/readinc-rm/adams.html (the

Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact me at (404) 562-4605.

Sincerely,

Charles A. Casto, Director

Division of Reactor Safety

Docket Nos.: 50-321, 50-366

License Nos.: DPR-57, NPF-5

cc:

Distribution w/encl:

S. Bloom, NRR

L. Slack, RII EICS

RIDSNRRDIPMLIPB

PUBLIC

OEMAIL

OFFICE RII:DRS RII:DRS RII:DRS RII:EICS OE RII:DRP RII:DRS

SIGNATURE

NAME RSchin CSmith KODonohue CEvans DNelson BBonser COgle

DATE 1 /2004 / /2004 / "4 / 200 I /2004 *77204 /2004

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO

PUBLIC DOCUMENT YES NO

OFI.IAL. .... COPY....DOCUMENT... NAME: P:IIthN~eilRsas....._..... ... __.......

OFFICIAL _EOR

RECORD COPY DOCUMENT NAME: P:Mdiatch-NGVdenial-Response~wpdI

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 NRC's 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 II.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. 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 licensee's corrective action program, this

violation is being treated as an NCV, consistent with Section VL.A of the NRC's Enforcement

Policy: NCV 50-366/03-06-04, Unapproved Manual Operator Actions for Post-Fire Safe

Shutdown.

Specific steps in Abnormal Operating Procedure (AOP) 34AB-X43-001-2, Fire Procedure,

Version 10.8, that involved reliance on 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; ...lf 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-R42-001-2.0

• Step 4.15.4.5; ...lf 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:

• TT-75 in panel 2H11 -P601

• TT-76 in panel 2H11-P601"

• Step 4.15.4.6; ...lf 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."

Enclosure

2

Restatement of Licensee's Response to NCV 50-366/03-06-04

The licensee's 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."

NRC Evaluation of Licensee's 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. However, the fact that the issue was subsequently characterized as an

NCV does not constitute a basis for the NRC to withdraw the NCV.

Enclosure

3

2. The NRC does not agree with this licensee statement. The concern is not an assumed

random 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 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 lll.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.

3. The NRC agrees with this licensee statement. However, a review of the referenced

documents by the Region 11Counsel determined that they do not constitute an NRC

approval to deviate from the Section IJ.G.2 requirement for physical protection of cables

from fire damage that could result in a loss of power to the battery chargers that are

needed to maintain the vital DC electrical power that is 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

above, 10 CFR 50, Appendix R, Section lll.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.

Plant conditions during a fire-induced loss of offsite power could be significantly different

than plant conditions during a loss of offsite power 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

Enclosure

4

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 either reasonably doable (not affected by the fire) or not needed (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 licensee's 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 licensee's 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 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 Ill.G.2 fire areas, for which safe shutdown would be

accomplished from the control room using the Fire Procedure, 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. The NRC disagrees with this statement. All of the manual actions included in the NCV

were described in the licensee's Safe Shutdown Analysis and Fire Procedure such that

they appeared to represent manual actions that were relied upon instead of compliance

with the requirements of Appendix R,Section III.G.2, for installed physical protection of

cables from fire damage. This licensee statement does not constitute a basis for the

NRC to withdraw the NCV.

Enclosure