ML050540471

Portions of Draft NRC Letter to Southern Nuclear Operating Company Re Hatch IR 05000321-03-006 and 05000366-03-006

ML050540471
Person / Time
Site:	Hatch
Issue date:	01/31/2004
From:	NRC/RGN-II
To:	Sumner H Southern Nuclear Operating Co
References
EA-03-207, FOIA/PA-2004-0277 IR-03-006
Download: ML050540471 (2)

See also: IR 05000321/2003006

Text

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! ,UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET SW SUITE 23T85

'4 >ATLANTA,

2 GEORGIA 303034

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

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.

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).

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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, a review of the referenced documents by the Region II Counsel

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

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