NL-09-0344, Request for Extension of 10 CFR 50 Appendix R Enforcement Discretion
| ML090680143 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 03/06/2009 |
| From: | Ajluni M Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-09-0344 | |
| Download: ML090680143 (6) | |
Text
SOllthern Nuclear Operating Company, Inc.
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COMPANY March 6, 2009 Energy to SenJe Your World Docket Nos.: 50-321 NL-09-0344 50-366 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Request for Extension of 10 CFR 50 Appendix R Enforcement Discretion Ladies and Gentlemen:
Regulatory Issue Summary (RIS) 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions" was issued on June 30, 2006 to clarify NRC expectations with regard to compliance with 10 CFR 50 Appendix R, III.G.2 requirements. NRC has been exercising enforcement discretion over the use of operator manual actions in order to allow licensees to come into compliance, as described in Enforcement Guidance Memoranda EGM 98-02, Rev. 2 (February 2,2000) and EGM-07-004 (June 30,2007), with March 6,2009 specified as the date for the completion of corrective actions.
Non-compliant operator manual actions were first identified at Southern Nuclear Operating Company's (SNC's) Edwin I Hatch Nuclear Plant (HNP), Units 1 &2, during the 2003 Triennial Fire Protection Inspection. SNC initiated a condition report (CR 2003110070) on this issue, which the resultant inspection reports, (05000321/2003006 and 0500036612003006, September 1, 2003) characterized as a non-cited violation (NCV 50-366/03-06-04).
SNC initially disputed this NCV in a letter dated October 1, 2003 but in early 2006 the NRC denied the request to withdraw the NCV. As a result of the denial, SNC reopened CR 2003110070 to complete root cause and corrective action (RCCA) determination, including a broadness review which identified additional manual action issues.
SNC originally planned to submit exemption requests addressing these manual actions, as provided by EGM-07-004. However, based on SNC's monitoring of industry and NRC enforcement actions, including revised guidance on manual actions, a more conservative approach was established. SNC initiated design modifications to eliminate all non-compliant operator manual actions. These design modifications (described in Enclosure 1) involve physical modifications to the plant, including inside the Main Control Room, which require a unit outage for implementation.
U. S. Nuclear Regulatory Commission NL-09-0344 Page 2 While the Unit 2 changes will be completed during the refueling outage now in progress on that unit, the timing of design change development with respect to the 24 month HNP operating cycle did not permit change implementation during the 2008 Unit 1 refueling outage. These changes can not be completed until the next Unit 1 refueling outage, in spring 2010.
Accordingly, SNC requests an extension of enforcement discretion with respect to the requirements of 10 CFR 50, Appendix R, III.G.2 for HNP Unit 1 from March 6, 2009 to the scheduled end of the next Unit 1 outage, March 17, 2010 for the five operator manual actions identified in Enclosure 1. This extension would allow the continued use of operator manual actions, in the specific instances identified in. to achieve and maintain hot shutdown conditions in lieu of the cable separation criteria of Section III.G.2.
The NRC commitments contained in this letter are provided as a table in. If you have any questions. please advise.
Sincerely, M. J. Ajluni Manager, Nuclear Licensing MJAlDWD/daj
Enclosures:
- 1. HNP Unit 1 - Status of App. R Operator Manual Action Elimination
- 2. NRC Commitments - List of Regulatory Commitments cc:
Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. R. Madison, Vice President - Hatch Mr. D. H. Jones, Vice President - Engineering RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R.
Martin, NRR Project Manager - Hatch Mr. J. A. Hickey, Senior Resident Inspector - Hatch
Edwin I. Hatch Nuclear Plant Request for Extension of 10 CFR 50 Appendix R Enforcement Discretion HNP Unit 1 - Status of App. R Operator Manual Action Elimination HNP Unit 1 Status of App. R Operator Manual Action Elimination Fire Operator Area Manual Action Description of Modification Design Modification Status Generic Close the 3 AC supply breakers to the battery charger switches on 600V switchgear control panel 1 H21-P245.
Generic Close the 3 AC supply breakers to the battery charger switches on 600V switchgear control panel 1 H21-P246.
0014 Open breaker 21 in 1 R25-S002 and verify closed or close the breakers in Frames 8B, 8M and 8T of 1 R23-S004.
0014 Open 30-A breaker SA in 1 R23-S004, Frame 8, and verify closed or close 1 R23-S004 Frame 4B.
1101 If unable to close or verify position, manually close valve 1 P41-F31 OB using the handwheel.
1104 Rack out breaker 17B in MCC 1 R24 S012 and manually reopen E51-F105 prior to RCIC restart.
1205
' Rack out breaker in 1 R23-S004 Frame 6M and manually reopen E51 F105 prior to RCIC restart.
Install control switches in the Implement Main Control Room Spring 2010
- Outage Enforcement discretion requested Install control switches in the Implement Main Control Room Spring 2010 Outage-Enforcement discretion requested Reroute cables out of Complete unprotected trays in area.
Reroute cables out of Complete unprotected trays in area.
Install interposing relay to isolate Implement circuit.
Spring 2010 Outage-Enforcement discretion I requested Install new cable in dedicated Implement conduit.
Spring 2010 Outage-Enforcement discretion requested Install new cable in dedicated Implement conduit.
Spring 2010 Outage Enforcement discretion requested E1-1
Edwin I. Hatch Nuclear Plant Request for Extension of 10 CFR 50 Appendix R Enforcement Discretion NRC Commitments - List of Regulatory Commitments NRC Commitments List of Regulatory Commitments The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.
[1.] SNC will implement design changes to eliminate operator manual actions not in compliance with 10 CFR 50 Appendix R, III.G.2 requirements, as described in of this submittal.
DUE DATE I EVENT End of HNP Unit 1 spring 2010 outage, currently scheduled for March 17,2010.
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