te itself may have changed. You can check the current page or check for previous versions at the Internet Archive. Yahoo! is not affiliated with the authors of this page or responsible for its content.
February 5, 2004 EA-04-207
February 5, 2004
EA-04-207
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 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.
Your Safe Shutdown Analysis (SSA) and Fire Procedure differ from your additional information
with respect to HPCI vulnerability to a runaway condition due to fires; consequently, those
documents are not current with your latest information.
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 NRCs 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 NRCs document system (ADAMS). SNOPCO
2
ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html
(the
Public Electronic Reading Room).
Should you have any questions concerning this letter, please contact me at (404) 562-4600.
Sincerely,
/RA/
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 Mail 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 contd- 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 SNOPCO
4
Distribution w/encl:
S. Bloom, NRR
C. Evans, RII EICS
L. Slack, RII EICS
RIDSNRRDIPMLIPB
PUBLIC
OEMAIL
OFFICE
RII:DRS
RII:DRS
RII:DRS
RII:EICS
RII:DRS
RII:DRP
OE
SIGNATURE
RA
RA
RA
RA
RA
RA
RA VIA E-MAIL
NAME
RSchin
CSmith
KODonohue
CEvans
COgle
BBonser
DNelson
DATE
1/13/2004
1/13/2004
1/14/2004
1/15/2004
1/22/2004
1/16/2004
2/5/2004
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
PUBLIC DOCUMENT
YES
NO
OFFICIAL RECORD COPY DOCUMENT NAME: C:\ORPCheckout\FileNET\ML040430224.wpd Enclosure
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 NRCs 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 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 [for fires in fire areas 2016, west 600 volt switchgear room; 2014, east cableway; 2404,
switchgear room 2E; and 2408, switchgear room 2F], 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," as per 10 CFR 50, Appendix R, Section
III.G.2. 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 licensees corrective action program, this
violation is being treated as an NCV, consistent with Section VI.A of the NRCs Enforcement
Policy: NCV 50-366/03-06-04, Unapproved Manual Operator Actions for Post-Fire Safe
Shutdown.
Specific Procedure Steps With Unapproved 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." Step 4.15.4.5; ...If 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: 2 TT-75 in panel 2H11-P601 TT-76 in panel 2H11-P601" Step 4.15.4.6; ...If 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 Licensees Response to NCV 50-366/03-06-04
The licensees 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 regar