IR 05000321/2003009

IR 05000321-03-009 and 05000366-03-009, on February 14, 2006, E. I. Hatch Nuclear Plant, Units 1 and 2

ML060930219
Person / Time
Site:	Hatch
Issue date:	03/31/2006
From:	Payne D NRC/RGN-II/DRS/EB2
To:	Sumner H Southern Nuclear Operating Co
References
IR-03-009
Download: ML060930219 (8)

Text

March 31, 2006Southern Nuclear Operating Company, Inc.ATTN:Mr. H. L. Sumner, Jr.Vice President P. O. Box 1295 Birmingham, AL 35201-1295SUBJECT:EDWIN I. HATCH NUCLEAR POWER PLANT - NRC INSPECTION REPORT NOS. 05000321/2003009 AND 05000366/2003009

Dear Mr. Sumner:

On February 14, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an in-officereview related to an unresolved item identified during the Triennial Fire Protection Inspection of 2003. A meeting was held in the Region II office with regional staff and Mr. R. Baker and Mr. D. Parker on December 7, 2005, to discuss the status of SNC's proposed resolutions for protecting the affected cables of eleven safety-relief valves and to clarify the staff's position regarding the use of local operator actions in lieu of circuit protection as required by NRC regulations. Following completion of additional review in the Region II office, a final exit was held by telephone with Mr. D. Madison and other members of your staff on March 31, 2006.The in-office review consisted of evaluating the safety significance of particular spurious valveoperations and reviewing your compensatory measures and various proposed final resolutions.

The issue remains unresolved for reasons described in the enclosed report.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system(ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this letter, please contact us.

Sincerely,

\\RA\\D. Charles Payne, ChiefEngineering Branch 2 Division of Reactor Safetycc w/encl - See next page SNC2Docket Nos.: 50-321, 50-366License Nos.: DPR-57, NPF-5

Enclosure:

NRC Triennial Fire Protection Inspection Report Nos. 05000366/2003009,05000321/2003009 w/Attachment: Supplemental Information

REGION IIDocket Nos.:50-321, 50-366License Nos.: DPR-57, NPF-5Report No.:05000321/2003009 and 05000366/2003009Licensee:Southern Nuclear Operating Company Facility:Edwin I. Hatch Nuclear Plant, Units 1 and 2Location:P. O. Box 2010 Baxley, GA. 31513 Dates:February 14, 2006Inspector:N. Staples, Reactor InspectorApproved by:D. Charles Payne, ChiefEngineering Branch 2Division of Reactor SafetySummary of FindingsIR 05000366/2003-009, 05000321/2003-009; 02/14/2006; E. I. Hatch Nuclear Plant, Units 1 and 2.

EnclosureThe report covered an in-office review of an unresolved item related to fire protection by a RegionalInspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactorsis described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.NRC-Identified and Self-Revealing Findings NoneB.Licensee-Identified Violations None EnclosureREPORT DETAILS4.OTHER ACTIVITIES4OA5Other(Discussed) URI 05000366/2003006-01: Concerns Associated with Potential Opening of SRVsIntroduction: The Inspector reviewed an unresolved item (URI) involving the failure to protect circuitsagainst fire which could lead to spurious opening of all eleven safety relief valves (SRV). The team hadfound instrumentation cables, that could cause maloperation of safe shutdown equipment, in FA 2104without adequate spatial separation or fire barriers. The finding remains unresolved pending review ofproposed corrective actions for the circuit design of the eleven SRVs. Description: During the 2003 Triennial Fire Protection Inspection, the inspection team performed acircuit analysis of Group A safety relief valves for which the licensee took safe shutdown credit for firesin Fire Area 2104, Unit 2 East Cableway. The requirements of 10 CFR 50, Appendix R, Section III.G.2,apply to this fire area. The team identified that two reactor pressure instrument cables (for circuitsABE019C08 and ABE019C09) were located in the same cable tray and thereby exposed to the sameheating rate which could potentially cause both circuits to simultaneously fail high and result in all elevenSRVs spuriously opening. Each cable consisted of a single twisted pair of insulated conductors, anuninsulated drain wire that was wound around the twisted pair of conductors, and a foil shield. Theconductor insulation and jacket material of each cable was cross-linked polyethylene (XLPE). A thermalassault on instrument cables could result in (false high) signals, generated as a result of leakage currentin each damaged cable. These undesired false high signals could actuate the SRV electrical backupscheme and cause all eleven SRVs to open. In addition, this failure mode would defeat the capability tomanually control these SRVs. Normally, whenever a SRV lifted, it would remain open until nuclear boilerpressure was reduced to about 85% of its overpressure lift setpoint. However, if the instrument loopshave failed high, the trip unit master relays and the trip unit slave relays would continue to energize thepilot valve of the individual SRV and maintain the SRV open. As a result, this failure mode could resultin spurious actuation of all eleven SRVs with the eleven SRVs subsequently remaining open.In response to this finding, the licensee initiated Condition Report 2003008203 and promptly revisedAOP 34AB-X43-001-2, Fire Procedure, Version 10.8 dated May 28, 2003. The procedure changeenabled the local operator actions to prevent all eleven SRVs from opening simultaneously to beaccomplished earlier during a fire in the Unit 2 East Cableway, or in other fire areas that were vulnerableto the potential for spuriously opening all eleven safety relief valves. While, the revised procedure wasan acceptable interim compensatory measure, it was not a permanent resolution to the circuit damageissue because Appendix R,Section III.G.2 does not allow use of local operator actions in lieu of circuitprotection to ensure safe shutdown. On December 7, 2005, NRC staff met with the licensee to discussproposed options for protecting cables from a fire in FA 2104 and to clarify the staff's position onregulation regarding the use of local operator actions in lieu of circuit protection. While various optionswere presented by the licensee, the licensee had not yet determined a final resolution. This URI willremain open pending the licensee's final resolution.4OA6Meetings, Including ExitExit meeting SummaryOn March 31, 2006, the regional staff presented the status results to Dennis Madison and othermembers of his staff, who acknowledged the findings. The inspectors asked the licenseewhether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

AttachmentSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee Personnel

R. Baker, Licensing Supervisor (Corporate)I. Luker, Senior Engineer, LicensingD. Madison, General Manager for Plant HatchD. Parker, Senior Engineer, ElectricalK. Underwood, Performance Analysis SupervisorJ. Vance, Senior Engineer, Mechanical & CivilO. Vidal, Principal Engineer, LicensingP. Wells, Plant Support General ManagerLIST OF ITEMS DISCUSSEDDiscussed05000366/2003006-01URIConcerns Associated with Potential Opening of SRVsLIST OF DOCUMENTS REVIEWEDProcedure:AOP 34AB-X43-001-2, Fire Procedure, Version 10.8 DrawingsH-11821, Fire Hazards Analysis, Turbine Bldg. El. 130

=-0@, Rev. 0H-26014, R.H.R. System P&ID Sheet 1, Rev. 49H-26015, R.H.R. System P&ID Sheet 2, Rev. 46 H-26018, Core Spray System P&ID, Rev. 29H-11821, Fire Hazards Analysis Drawing, Turbine Building, Rev. 11Calculations, Analyses, and EvaluationsE. I. Hatch Nuclear Plant Units 1 and 2 Safe Shutdown Analysis Report, Rev. 20.Edwin I. Hatch Nuclear Plant Fire Hazards Analysis and Fire Protection Program, Rev. 20Corrective Action ReviewedCR 2003008203, Safety relief valves Manual Action Steps in Fire Procedure 2AttachmentLicense Basis DocumentsHatch UFSAR Section 6.3, Emergency Core Cooling System, Rev. 21Safe Shutdown Analysis Report for E.I. Hatch Nuclear Plant Units 1 and 2, Rev. 26Fire Hazards Analysis for E. I. Hatch Nuclear Plant Units 1 and 2, Rev.18 C, dated 7/00

_________________________OFFICERII:DRSRII:DRSRII:DRPRII:DRSSIGNATURENLS2PJFCWR1DCPNAMENStaplesPFillionCRappDPayneDATE3/17/20063/20/20063/21/20063/31/20064/ /20064/ /20064/ /2006 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO