ML20198G464
| ML20198G464 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/18/1997 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| References | |
| 50-348-97-10, 50-364-97-10, NUDOCS 9801130042 | |
| Download: ML20198G464 (6) | |
See also: IR 05000348/1997010
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December 18, 1997
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Southern Nuclear Operating Company. Inc.
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ATTN: Mr. D. N. Morey
Vice President
P. O. Box 1295
Birmingham. AL 35201-1295
SUBJECT:
NRC INSPECTION REPORT NOS. 50 348/97-10 AND 50 364/97-10
Dear Mr. Morey:
Thank you for your response of November 5. 1997 to our Notice of Violation
(N0tice) issued on October 6. 1997 concerning activities conducted at your
facility.
We have examined your response and found that-it meets the
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requirements of 10 CFR 2.201.
In your response, you denied Violation A and admitted Violation B.
After
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careful consideration of the basis for your denial of Violation A, we have -
concluded, for the reasons presented in the enclosure to this letter. that the
violation occurred as stated in the Notice.
Therefore.-in accordance with
10 CFR 2.201(a). please resubmit to this office within 30 days of the date of
this letter a written statement describing the steps which have been taken to
correct Violation A and the results achieved, corrective steps which will be
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taken to avoid further violations, and the date when full com)liance will be
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achieved.
In ) articular, you should address the reason for t le extended
scheduleinsu)mittingtheexemptionrequestforthisissueproposedbyyour
response letter dated November ,, 1997.
Although not explicitly stated in your November 5. 1997 response to
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Violation B. we have confirmed that both of the monitor sample lines
identified in the subject Notice have been rebuilt to match the current design
documents.
We will examine the implementation of your actions during future
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inspections.
We appreciate your cooperation in this matter.
Sincerely.
(Original signed by
S.R.
Plisco for J.R. Johnson)
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Jon R. Johnson. Director
Divsion of Reactor Projects
Enclosure:
Evaluations and Conclusions
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cc w/ encl: -(See Page 2)
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cc w/enci-
M. J. Ajlunt
Licensing
Services Manager B 031
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Southern Nuclear Operating
Company. Inc.
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42 Inverness Center Parkway
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Birmingham, AL 35242
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R. D. Hill. Jr.
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General Manager. Farley Plant
Southern Nuclear Operating
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Company. Inc,
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P. O. Box 470
Ashford, AL 36312
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J. D. Woodard
Executive Vice President
Southern Nuclear Operating
Company. Inc.
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P. O. Box 1295
Birmingham. AL 35201
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State Health Officer
Alabama Department of Public Health
434 Monroe Street
Montgomery. AL 36130 1701
M. Stanford Blanton
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Balch and Bingham Law Firm
P. O. Box 306
1710 Sixth Avenue North-
Birmingham AL 35201
Chairman
Houston County Commission
P. O. Box 6406
Dothan, AL 36302
Distribution w/ encl _:
P, H. Skinner, Ril
C. W. Rapp Ril
W. P,-Kleinsorge. Rll
Distribution w/ encl cont'd:
(See Page 3)
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Qistribution v:/ encl: Continued
H. E. Ernstes, Rll
J. 1. Zimmerman. NRR
PUBLIC
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NRC Resident inspector
U.S. Nuclear Regulatory Commission
7388 N State Hwy 95
Columbid, AL 36319
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[yALUATIONS AND CONCLUSION
On October 6. 1997. a Notice of Violation (Notice) was issued for a violation
identified during a routine NRC inspection.
The Southern Nuclear Operating
Company (SNC) responded to the Notice on November 5, 1997.
In its response.
SNC denied violation A and admitted violation B.
The NRC's evaluations and
conclusions regarding SNC's arguments for denying violation A are as follows:
Restatement of Violation A
License No. NPF 2 Condition 2.C(4), for Farley Nuclear Plant (FNP). Unit 1.
states in part that Southern Nuclear Operating Company. Inc. shall implement
and maintain in effcct all provisions of the approved fire )rotection program
as described in the Updated Final Safety Analysis Report (U:SAR).
Appendix 9B of the UFSAR. Fire Protection Program, documents an evaluation of
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the FMP fire protection program as it complies with Appendix R to 10 CFR 50
and embodies the contents of the Fire Protection Program Reevaluation as
approved by the NRC. Appendix 98. Attachment B.10 LFR 50 Ap)endix R
Exemptions, provides the NRC's discussion and evaluation of t1e licensee's
Appendix R exemption requests, and also identifies those systems and
components that require 1-hour Kaowool fire barriers to meet Ap)endix R.
Specifically. Appendix 98. Attachment B. Section 21.3 states t 1at "the
redundant charging pump power cables are provided with a barrier (two 1-inch
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thick wraps of Kaowool blanket) having a fire rating greater than that of the
projected fire in the following rooms in fire area 1-004: train A in rooms
161. 162. 163, and 168: train B in rooms 175, 160. and 159."
Contrary to the above. as of September 6. 1997, the licensee installed one
1-inch thick wrap of Kaowool on the sides and bottoms of raceways BDE-9 and
BDE 15. carrying train B charging pump power cables in Room 160 of fire
area 1-004.
Summary of Licensee's Resnonse to Violation A
the FSAR (ponse. SNC stated that "the cited sentence (in quotations above) in
in its res
Section 21.3) is in error and is contradictory to the licensing and
design basis for the Kaowool wrap on cable trays BDE 9 and 15 in room 160.
This sentence was in error in the FNP submittal of Exemption Request 1-39 and
as such was introduced into the NRC SER and the FSAR." SNC maintains that it
requested, and the NRC approved in a safety evaluation report (SER) dated
April 13. 1979, the use of a half-hour barrier on the bottom and sides, with
no barrier on the top, of power cable trays BDE-9 and 15 in room 160,
subsequently made an error by not specifically including the description of
this configuration as part of it's 10 CFR 50. Appendix R. exemption requests.
As such, the NRC granted SNC's Appendix R exemption request 1-39 without any
description or ap3roval of the unique half hour fire barrier configuration for
BDE-9 and -15.
54C states that it never intended to redesign the half-hour
fire barrier around cable trays BDE 9 and -15 since the NRC had already
approved the Kaowool configurations for those cable raceways.
It was merely
an omission on their part that the exemption did not include a specific
Enclosure
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description and request for re-approval of the half-hour barrier.
SNC also
believes that this error was essentially an FSAR discrepancy, and
consecuently, enforcement discretion was warranted pursuant to the " Policy and
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Procecure for Enforcement Action. Departures From FSAR." dated October 18.
1996 (Volume 61 of federal Register page 54461).
NRC Evaluation of licensee's Resnonse
The NRC staff has carefully reviewed the licensee's response and has. concluded
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that the licensee did not provide any information that was not already
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considered in determining the significance of the violation.
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On November 19. 1980. the NRC published a revised 10 CFR 50.48 and a new
Appendix R to 10 CFR 50 regarding fire protection features of nuclear power
plants.
Those nuclear power plants licensed to operate prior to January 1.
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NRC as documented in SERs.pplicable fire protection features accepted by the
1979, and already having a
were only required to address the specific
provisions of Appendix R sections III.G. J., and 0..
In order to comply with
the requirements of section Ill.G. " Fire Protection of Safe Shutdown
Capabilities " SNC submitted by letter dated May 31. 1985, numerous exemation
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requests that were enclosed as part of the "J.M. farley Nuclear Plant - Jnit
l. 10 CFR 50 Appendix R fire Hazards Analysis Reevaluatio.: May 1985." Of
these exemotion requests, number 1-39 in particular identified a number of
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plant " Conditions Requiring Exemption" located in Fire Area 1-004 of the Unit
1 Auxiliary Building.
For the )lant conditions described in sections A through 1. of Exemption
Request io 1 39. SNC requested an exemption from the provisions of
Ap)endix R. Ill.G.2.c that required one train of 7 dundant safe shutdown
caales to be enclosed by a one hour rated fire barrier with an automatic fixed
suppression system,
in section E. "Boration/ Makeup. Depressurization, and RCP
Seal Integrity." of Exemption No. 1-39. SNC stated that:
" fire area 1 004 contains redundant charging pump train A and-B )ower
cables. One train of redundant power cables is not provided wit 1 a fire
rated barrier for its entire route in the fire area. nor is full
suppression coverage provided for both redundant trains throughout their
entire route in the fire area."
In Exemption Request No. 1-39 SNC did not describe im)1y or reference the
use of a half-hour fire barrier (i.e. , one 1 inch thicc wrap) that is only
partially wrapped around a redundant train of charging pump power cables.
SNC specifically stated in their justification analysis for Section E of
Exemption Request 1-39 that:
"The redundant power cables are provided with a barrier (two 1-in.-thick
wraps of Kaowool blanket) having a fire rating greater than that of the
-projected fire in the following rooms in fire area 1-004: train A in
rooms 161. 162. 163, and 168: train B in rooms 175, 160. and 159 "
Enclosure
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in section 8 of the SER dated September 10. 1986. the NRC granted Exemation
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Request Nc. 1-39 as described above.
In section 8.3 of this SER, the
1RC
reiterated the following as a specific part of and basis for approving
Exemption Request No. 1-39:
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"The redundant Charging Pum) power cables are provided with a barrier
(two 1 inch thick wraps of (aowool blanket) having a fire rating greater
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than that of the projected fire in the following rooms in fire
area 1 004:
Train A in rooms 161.-162. 163, and 168: Train B in rooms
175, 160, and 159."
In this regard, the NRC considers the Appendix R licensing basis documentation
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to be very clear in describing the fire protection features for train B
charging pump power cables (contained in cable trays BDE-9 and BDE 15) in Room
160 of fire area 1-004.
If SNC perceives that errors were made in their May
31. 1985 submittal, they should submit a revised exemption request for NRC
approval that includes appropriate justification and addresses the "special
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circumstances" of 10 CFR 50.12(a).
Changes to rior NRC approved Appendix R
exem tions, that SNC has reprinted in the farle UFSAR. can not be made via 10
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CRp0.59aspartofaroutineUFSARupdate.
T ie NRC must first approve a
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revised exemption request before SNC can update their UFSAR.
The licensing
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basis appears clear that two 1 inch thick wraos of Kaowool are to be installed
around cable trays BDE-9 and BDE-15.
Sincethediscrepantconditioninvolves
a previously approved Appendix R exemption request, the NRC does not consider
its " Policy and Procedure for Enforcement Action. Departures From FSAR" to be
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relevant.
Consequently, enforcement discretion as an identified UFSAR
discrepancy is not applicable.
NRC Conclusion
for the above reasons, the NRC staff concludes that the violation occurred as
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stated.
Enclosure
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