ML20133A892

Responds to Violations Noted in Insp Rept 50-348/96-09 & 50-364/96-09.Corrective Actions:Established Hourly Fire Watches Until Six Raceways Met 1 Hr Fire Barrier Requirements & Completed Corrective Maint of Six Raceways

ML20133A892
Person / Time
Site:	Farley
Issue date:	12/23/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
EA-96-410, NUDOCS 9701020156
Download: ML20133A892 (9)

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s Dave Morey Southern Nuclear

, ' yice President Operating Comp =y j . farley Project P.O. Box 1295 Birmingham. Alabama 35201  !

l Tel 205.992.5131 SOUTHERN h December 23, 1996 COMPANY

. Energy ro Serve YourWorld

Docket Nos.: 50-348 10 CFR 2.201 50-364 EA-96-410 ,

Director, Office of Enforcement U. S. Nuclear Regulatory Commission I Washington, DC 20555

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r Joseph M. Farley Nuclear Plant Reply To a Notice Of Violation (VIO) and Civil Penalty NRC Inspection Report Numbers 50-348/96-09 and 50-364/96-09 .

! Ladies and Oentlemen:

As requested by your transmittals dated November 8,1996 and December 4,1996, this letter responds to VIO 50-348,364/96-09-06, " Failure to Install Required 1-hour Fire Barriers";

VIO 50-348,364/96-09-07, " Inadequate Kaowool Inspection Program"; and the civil penalty. i j- The Southern Nuclear Operating Company (SNC) responses are provided in the three enclosures.

Enclosure 1 includes the response to VIO 96-09-06. Enclosure 2 includes the response to VIO 96-09-07. Enclosure 3 includes a check for $50,000 in response to the civil penalty.

( Mr, D. N. Morey states that he is a vice prcsident of Southern Nuclear Operating Company, and 's i authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

l Respectfully submitted, h key l Dave Morey  :

Sworn to and subscribed before me this Al day ofb%Ieq /7#

L A A n:>c0 A

" ' Notary Pu 'e My Commission Expires: *e M /f9 7 y i < -

EFB/ nov-kwol. doc /

Enclosures:

1. Response to VIO 96-09-06

2. Responte to VIO 96-09-07 /

h l n n 3. $50,000 check

, a1 Ln,0Ga cc: Mr. S. D. Ebneter, Region II Administrator Mr. J. I. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector 9701020156 961223 PDR ADOCK 05000348 G PDR < - - - , -

e ENCLOSURE 1 VIO 50-348,364/96-09-06

" Failure to Install Reauired 1-hour Fire Barriers" l

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VIO 50-348/96-09-06, " Failure to Install Required 1-hour Fire Barriers" states j l

10 CFR Part 50, Appendix R, Section Ill.G.2 requires, in part, where cables or equipment,

! including associated non-safety circuits that could prevent operation or cause maloperation of'  !

redundant trains of systems necessary to achieve and maintain hot shutdown conditions, are located -

l within the same fire area outside of contamment, the cables and equipment and associated non- i safety circuits be separated by a fire barrier having a three-hour rating, or separated by a l

horizontal distance of more than 20 feet with no intervening combustibles or fire hazards, or one  !

redundant train be enclosed in a fire barrier having a one-hour rating. f License No. NPF-2, Condition 2.C(4), for Farley Nuclear Plant (FNP), Unit 1, states, in part, that ,

i Southem Nucicar Operating Company, hic. shall implement and maintain in effect all provisions of  !

l the approved fire protection program as described in the Final Safety Analysis Report (FSAR). i

. FSAR, Appendix 9B, Fire Protection Program, documents an evaluation of the FNP fire protection l program as it complies with Appeadix R to 10 CFR 50 and embodies the contents of the Fire l Protection Program Reevaluation as approved by the NRC. Appendix 9B, Attaciunent B,10 CFR i

50 Appendix R Exemptions, provides the NRC's discussion and evaluation of the licensee's Appendix R exemption requests, and also identifies those systems and components that require i one-hour Kaowool fire barriers to meet Appendix R.  :

Coa rary to the above, the licensee failed to assure that electrical cables associated with systems

! uccessary to achieve and maintain hot shutdown conditions were enclosed in an one-hour fire l

barrier as required by Appendix 9B of the FSAR as evidenced by the following examples

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1. On October 2,1996, t% NRC identified that the IB and IC Safety Injection Pump "B train"  !

power cables in Room 160 of Fire Area 1-004 were not fully enclosed by a Kaowool fire  :

barrier (approximately 18 feet of cable tray was unwrapped).

2. During the period of October 5-8,1996, the licensee identified that th ?B and IC Safety

, Injection Pump "B train" power cables and room cooler cables in Room 175 of Fire Area 1-004 were not fully enclosed by Kaowool fire barriers (approximately 24 inches of cable from four cable trays were unwrapped).

3. During the period of October 5 8,1996, the licensee also identified that the cables for main steam isolation and auxiliary feedwater flow control in Room 319 of Fire Area 1-042 were j not enclosed by an appropriate fire barrier, i.e., Kaowool, (the entire four foot span of cable  ;

tray was unwrapped). 1 This is a Severity Level III violation (Supplement I).

Civil Penalty -$50,000 l

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! Admission or Denial .

The violation occurred as described in the Notice of Violation. He following events occurred:

[- Between late July - September,1996, an NRC resident inspector began reviewing the installation and I

inspection of Kaowool fire barners, specifically, at Motor Operated Valve (MOV) terminations. The inspector noted cases where no Flamemastic seal was appliM at the MOV terminations. A. review c-W by FNP indicated the majority of MOV's identified by the resident inspector were not -

required for Appendix R compliance. On September 5,1996, the resident inspector expressed a  !

concern about Kaowool discrepancies for several MOV's. The scope of the concern appeared to be {

limited to MOV's and ap; ved to be due to dey,radation over time. FNP confirmed the Appendix R  !

required MOV's (a total of 10) and inspected these MOV's for compliance to Appendix R. Some deficiencies were identified and an evaluation was perfonned on these deficiencies. The evaluation concluded that the Knowool fire barriers provided an adequate fire protection barrier for all the Appendix R required MOV's Deficiencies noted were considered corrective maintenance items since Flamemastic was not required at equipment termm.tions in order to provide adequate fire protection.  !

On approximately September 11, 1996, due to additional questions from the NRC, FNP began j

- investigating concerns about Flamemastic at raceway terminations as well as at MOV terminations.  :

On October 2,1996, aAer discussions with an NRC resident inspector, FNP management became [

aware of concerns that some FNP raceways may not be fully enclosed by a Kaowool fire barrier. As a conservative measure, on October 2,1996, hourly fire watches were established in all areas of Units I and 2 where Kaowool fire barrier systems were required for supporting Appendix R compliance. In i addition, an inspection plan was implemented which included development of a detailed inspection i pocedure and training of inspection personnel. He inspection procedure was developed to verify i Alation of Knowool fire barrier systems to design drawings. On October 10, 1996, inspections i and evaluations were completed on both units. It was concluded that six raceways did not meet the 1 l hour fire barrier requirements. His represented approximately 30 feet out of approximately 6000 feet j of Knowool wool wrapping required for Appendix R coml.liance at FNP.

i b8.M9kO$kSE  !

A review ofinstallation documenta+ ion and interviews with available individuals involved in the initial  !

Kaowool installation indicates the cause of this event was personnel error during the implementation l

. of design drawings (affecting 5 raceways), and insufficient design guidance provided during initial installation (affecting I raceway).

Corrective Steos Taken and Results Achieved -

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. Hourly fire watches were established on October 2,1996 and rerr: Sed in effect until the six Unit I ~

raceways met the I hour fire barrier requirements. )

The corrective maintenance associated ^vith these 6 raceways was completed on December 4,1996. l 1

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S Corrective Steos That Will Be Taken to Avoid Further Violation

Based on FNP's inspection and evaluation results this violation is considered an occurrence isolated to

) the initial installation of Kaowool and no further corrective action is warranted.

. l Date of Full Compliance December 4,1996 i

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i l ENCLOSURE 2 l

i VIO 50-348,364/96-09-07 "Inadeaunte Knowool Inspection Procram" l

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l VIO 50-348, 364/96 09-07, " inadequate Kaowool Inspection Program" states:

i License No. NPF-2, Condition 2.C(4), and License No. NPF-8, Condition 2.C(6), states, in part,.

that Southern Nuclear Operating Company, Inc. shall implement and maintain in effect all  :

provisions of the approved fire protection program as described in the FSAR.  !

l FSAR, Appendix 9B, Fire Protection Program, documents the evaluation of the FNP fire

protection program against Appendix R to 10 CFR 50 and embodies the contents of the Fire

Protection Program Reevaluation as approved by the NRC.

FSAR, Appendix 9B, Section 9B.6.1, rec,uires periodic inspections of fire protection systems and equipment to anure acceptable condition of these items. Administrative Procedure, FNP-0-AP-36, ,

Fire Surveillance Procedures and Inspections, Revision 12, required that fire surveillance procedures are performed t.4 wri: ten, by qualified personnel, and that these procedures provide the  ;

necessary detailed requirements.

Fire Surveillance Procedure, FMP-0-FSP-43, Visual Inspection of Kaowool Wraps, Revision 5, provided the acceptance criteria, instructions, and references to intallation details for conducting  ;

periodic inspections of Kaowool wraps used to provide the one-hour rated fire barriers prescribed l by the Fire Protection Program of FSAR, Appendix 9B. '

Cont ary to the above, the licensee failed to implement an adequate periodic inspection program for Kaowool one-hour fire barriers in that:

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1. The periodic inspections failed to verify that Kaowool fire barriers were being main:ained in  !

conformance v.ith installation drawings and the acceptance criteria specified in Procedure ,

FNP-0-FSP-43. During the period March 4-7,1996, licensee personnel .nspected Kaowool  !

wraps in accordance with Procedure FNP-0-FSP-43 and did not identify any deficiencies.

However, from July 24 - October 2,19%, the NRC identified multiple examples of i installation deficiencies and deteriorating conditions of Kaowool wraps. Subsuluent ,

inspections by the licensee conducted during the period October 5-8,1996, identified over a ,

hundred similar installation and degradation problems with existing Kaowool wraps around I electrical raceways. j l'  !

2. Personnel performing the periodic mspection required by Procedure FNP-0-FSP-43 during i March 1996 were not qualified, in that they were not knowledgeable regarding the design, [

installation, or material condition requirements for Kaowool wraps. These individuals were  ;

not adequately trained on Kaowool requirements nor did they have adequate prior experience .

in installing or inspecting Kaowool.  ;

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3. As of October 12,1996, Procedure FNP-0-FSP-43, Revision 5, did not clearly identify all i the critical characteristics to be inspected to assure Kaowool fire barriers were maintained in

conformance with installation drawings (e.g., flamn

astic fire seals and compression).

This is a Severity Level IV violation (Supplement I).  !

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Admission or Denial The violation occurred as described in the Notice of Violation.

Reason for Violation This violation was caused by madequate procedural guidance in that the periodic inspectSn l procedure failed to provide sufficient detail for the inspection personnel. In addition, the inspection personnel were not adequately trained to perform all aspects of the inspection.

Corrective Steos Taken and Results Achieved <

l Hourly fire watches were established on October 2,1996 for all areas where Kaowool fire barrier l

systems were required for supporting Appendix R compliance. Appropriate fire watches will remain in place until deficiencies are corrected that returns the raceways to conformance with installation drawings.

l An inspection plan was implemented which i-luded development of a detailed inspection procedure and training ofinspection personnel. 'i H inspection procedure was developed to verify l installation of Knowool fire barrier systems to design drawings. Subsequently, raceway inspections to verify agreement of as-built configuration to design drawings were begun on October l 5,1996. On October 10,1996 inspections and evaluations were completed.

l L Corrective Steps That Will Be Taken to Avoid Further Violation FNP-0-FSP-43 will be modified to provide more detailed inspection guidance. These changes will

include identification of specific Kaowool installations to be inspected.

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Training will be performed for personnel vehn perfarm these surveillance procedures to ensure they understand the requirements for acceptable configurations of Appendix R Kaowool wraps es given in the revised surveillance procedure.

The procedure modification and training will be completed by January 31,1997.

Other aspects of the fire protection inspection program that were transferred to maintenance will be evaluated to determine if similar problems exist.

l Date of Full Compliance l

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I l ENCLOSURE 3 I VIO 50-348,364/96-09-06 Civil Penalty Check for $50.000 I

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