ML042380287

E-mail, Robert Schin to Sunil Weerakkody, Draft Letter to Hatch for Your Concurrence

ML042380287
Person / Time
Site:	Hatch
Issue date:	01/15/2004
From:	Schin R NRC/RGN-II
To:	Sunil Weerakkody Office of Nuclear Reactor Regulation
References
EA-03-207, FOIA/PA-2004-0277, IR-03-006
Download: ML042380287 (11)

Text

.-L1411tFb n. Vqltl - LIMIL LULLUI ty nULU11 JUI YUUF uunryurrence Pag~e 1 Paae 1 4IdII fl. LILJIU - LJIUIL LULWI LU niwi iur yuur curiuurrence From: Robert Schin / e.rD To: Weerakkody, Sunil Date: 1/15/04 4:44PM

Subject:

Draft Letter to Hatch for your concurrence Sunil, Per your discussion with Chuck Ogle, attached is our DRAFT letter to Hatch for your review and concurrence.

This letter Is in response to a Hatch 'denial' of a Green finding and NCV of Appendix R, Section Il.G.2.

Hatch had unapproved local manual operator actions Instead of compliance with Ill.G.2 requirements for physical protection of cables from fire damage. (Hatch personnel told me they thought that III.G.1 allowed local manual operator actions.) Region II had documented this finding in an inspection report, following your guidance in IP 71111.05.

I had previously discussed this Issue with Eva Brown and Phil Qualls and sent them a previous draft of this letter.

Since the NRC process provides for no further licensee appeal of this NCV, we think that your concurrence on this letter would be beneficial toward effective NRC communication with licensees.

Thanks for your cooperation In this matter.

Bob Schin CC: Brown, Eva; O'Donohue, Kathleen; Ogle, Charles R.; Qualls, Phil

'10RIG~O' UNITED STATES A0 NUCLEAR REGULATORY COMMISSION REGION II i ; SAM NUNN ATLANTA FEDERAL CENTER 4 me 61 FORSYTH STREET SW SUITE 23T85 ATLANTA, GEORGIA 303038931 EA-03-207 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 0500036612003006

Dear Mr. Sumner:

Inyour 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) 50-366103-06-04, 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 Inthe 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 llI.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 Inthe NRC Public Document Room or from the Publically Available Records (PARS) component of the NRC's document system (ADAMS).

SNOPCO 2 ADAMS is accessible from the NRC Web site at http://www.nrc.gov/readinp-rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact me at (404) 562-4600.

Sincerely, Charles A. Casto, Director Division of Reactor Safety Docket Nos.: 50-321, 50-366 License Nos.: DPR-57, NPF-5

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 Mall 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 cont'd- 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

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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. Unanproved Manual Ooerator 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. 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 VI.A of the NRC's Enforcement Policy: NCV 50-366/03-06-04, Unapproved Manual Operator Actions for Post-Fire Safe Shutdown.

Specific Procedure Stens With UnaDproved 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.m e Step 4.15.4.5; ...lf HPCI fails to automatically trip on high RPV level... OPEN the following links to energize 2E41 -F1 24, 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 2H1 1-P601 Enclosure

2

• 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."

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 falls 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 Ill.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

3 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 lIl.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 lll.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 Inthe 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

4 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 Inany 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 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, where there was a vulnerability to fire damage to cables that could result in a HPCI runaway.

5 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.

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Subject:

Draft Letter to Hatch for your concurrence Creation Date: 1/15/04 4:44PM From: Robert Schin Created By: RPS @nrc.gov Recipients nrc.gov ATLPO.ATLDO CRO CC (Charles R. Ogle)

KFO CC (Kathleen OTDonohue) nrc.gov owf2_po.OWFNDO PMQ CC (Phil Qualls)

SDW1 (Sunil Weerakkody) nrc.gov owf4_po.OWFNPO EAB1 CC (Eva Brown)

Post Office Route ATLPO.AThDO nrc.gov owf2_po.OWFNDO nrc.gov owf4_po.OWFNDO nrc.gov Files Size Date & Time Hatch-NCVdenial-ResponseRl.wpd 120588 01/15/04 04:07PM MESSAGE 1751 01/15/04 04:44PM Options Expiration Date: None Priority: High Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard