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Discusses Insp Repts 50-348/96-09 & 50-364/96-09 on 960901- 1012 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000
	ML20149M564
Person / Time
Site:	Farley
Issue date:	12/04/1996
From:	Ebneter S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Dennis Morey; SOUTHERN NUCLEAR OPERATING CO.
Shared Package
ML20149M566	List: ML20149M564; ML20149M577;
References
	EA-96-410, NUDOCS 9612170397
	Download: ML20149M564 (5)
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December 4. 1996

EA 96-410

Southern Nuclear Operating Company. Inc. !

ATTN: Mr. D. N. Morey l

Vice President :

P. O. Box 1295 !

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Birmingham. AL 35201

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SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - l

. $50.000 (NRC INTEGRATED INSPECTION REPORT NOS. 50-348 AND i

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. 50-364/96-09)

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Dear Mr. Morey: l

! This refers to the inspection conducted during the period September 1 through !

October 12. 1996, at your Farley Nuclear Plant (FNP). The inspection included l

. a review of the fire protection program associated with the installation and !

inspection of Kaowool fire barriers to meet the requirements of Ap)endix R to

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10 CFR Part 50 and the FNP Fire Protection Plan. The results of t11s i

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inspection were discussed with members of your staff on October 17, 1996, and !

i were formally transmitted to you by letter dated November 8. 1996. In i

i addition, on November 7, 1996. you submitted Licensee Event Report !

1 No. 96-006-00 which addressed Kaowool fire barrier installation deficiencies. !

p A closed predecisional enforcement conference was conducted in the Region II :

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office on November 18, 1996, with you and members of your staff to discuss the ;

i apparent violations, the root causes, and corrective actions to preclude l

> recurrence. A list of conference attendees. NRC slides, and a copy of your i

presentation materials are enclosed. In addition. at the conference, you !

i identified errors in and/or disagreement ith certain statements expressed in l

the subject inspection report. The dispositon of your comments in this regard

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are also enclosed, j

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Based on the information developed during the ins)ection and the information !

, that was provided during the conference, the NRC las determined that ;

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violations of NRC requirements occurred. The violations are cited in the ;

) enclosed Notice of Violation and Proposed Imposition of Civil Penalty

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(Notice), and the circumstances surrounding them are described in detail in l

the subject inspection report. The violation described in Part I of the

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Notice involved three examples of Southern Nuclear Operating Company Inc.'s :

) (SNC) failure to assure that one-hour fire barriers. in this case Kaowool !

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enclosures, were installed on Unit 1 electrical cables associated with systems ;

required for safe shutdown. The components affected by the discrepant )

conditions were the dedicated B Train high head safety injection pump and its !

room cooler; the swing high head safety injection pump and its room cooler

when aligned to the B Train: one B Train main steam line isolation valve: and

the B Train motor driven auxiliary feedwater pump discharge flow control

valves. The Kaowool in these areas was not installed as described in design

drawings and your 10 CFR Part 50. Appendix R commitments. l

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9612170397 961204 ,

PDR ADOCK 05000348 ,

a PDR

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At the conference. you admitted the violation and provided additional

background information related to the circumstances surrounding the

discrepancies and their identification. You described the root causes of the

violation as personnel error and insufficient design guidance during initial

installation, and stated that there was no reason to believe that a breakdown

in your configuration management program occurred.

Although the failure to install Kaowool fire barriers adequately did not

result in an actual safety consequence. under certain circumstances, a fire

could have adversely impacted your ability to achieve and maintain safe plant

shutdown conditions (e.g., loss of charging). Overall, the violation is of

significant regulatory concern in that the degraded fire barriers increased

the vulnerability of safety related equipment to potential fire hazard or

damage and compromised the design objective of defense-in-depth. At the

conference you stated that alternate methods were available to mitigate the

consequences of a fire affecting these safety related components. Although

NRC agrees that alternate methods were available to mitigate the consequences

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of a fire, several of these methods rely on operator recognition and

i intervention which are not proceduralized and cannot be assured for 10 CFR 50,

Appendix R compliance; and, the fire suppression system relied upon to

mitigate a fire involving both trains of high head safety injection

experienced failures during April 1994 and 1995 surveillance testing.

Furthermore, NRC is concerned that your independent verification program at

the time of initial installation (implemented by your construction

organization) failed to identify the nor-conformances as has your periodic

inspection program since then. This resulted in unknown. degraded fire

barriers for an extended period of time. Therefore, this violation is

classified in accordance with the " General Statement of Policy and Procedures

for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, as a Severity

Level III violation.

In accordance with the Enforcement Policy, a br.e civil cenalty in the amount

of $50,000 is considered for a Severity Level Ill violat'on.

i Because your

facility has not been the subject of escalated ereforcement action within the

last two years, the NRC considered whether credit was warranted for Corrective

Action in accordance with the civil penalty assessment process described in

Section VI B.2 of the Enforcement Policy. At the conference, you stated that

your corrective actions taken and/or planned include: (1) the prompt i

establishment of fire watches: (2) the conduct of a walk-down of motor-

operated valve Kaowool installations following identification of deficiencies

! by the NRC: (3) conduct of a comprehensive inspection of all Kaowool

! installations in the plant utilizing newly trained Level II ins)ectors:

(4) correction of identified Kaowool installation discrepancies )y

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January 31. 1997; (5) revision of Procedure FNP-0-FSP-43 to clearly identify

the appropriate Kaowool periodic inspection criteria by January 31. 1997: and

(6) conduct of additional training for the individuals who will implement the

periodic inspection program. Although it appears that your corrective actions

were ultimately comprehensive, the NRC determined that credit was not

' warranted for Corrective Action in that collectively. your actions were not

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timely. Specifically, NRC identification of multiple examples of Kaowool and

l flammastic installation discrepancies over a several month period was required

before you took comprehensive corrective actions. Although engineering

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SNC 3

reviews and evaluations were being performed as issues were identified, you

did not institute the necessary positive actions to assess the extent of the

condition and to characterize the Kaowool fire barrier discrepancies fully

until NRC identified examples of missing Kaowool.

Therefore, to emphasize the importance of maintaining an adequate fire

protection program for the protection of safety related equipment and the need

for prompt and comprehensive corrective actions. I have been authorized, after

consultation with the Director. Office of Enforcement, to issue the enclosed

Notice in the base amount of $50,000 for the Severity Level III violation.

The violation described in Part II of the Notice has been categorized at

l Severity Level IV. It involved the failure to adequately implement a program

for the periodic inspection of Kaowool installed fire barriers. These

inadequate inspections, lack of qualified inspectors, and incomplete

i inspection criteria contributed to failure to identify the Kaowool

I installation and material condition discrepancies earlier.

You are required to respond to this letter and should follow the instructions '

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specified in the enclosed Notice when preparing your response. The NRC will

l consider your response, in part, to determine whether further enforceinent

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action is necessary to ensure compliance with regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a co3y of

this letter, its enclosures, and your response will be placed in the NRC

Public Document Room (PDR),

Sincerely.

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l Original Signed by E. W. Merschoff

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Stewart D, Ebneter

Regional Administrator

Docket Nos. 50-348. 50-364

License Nos. NPF-2 NPF-8

Enclosures: 1. Notice of Violation and Proposed

Imposition of Civil Penalty

i 2. Conference Attendees (Not to be Published in NUREG-0940)

l 3. Comments on Inspection Report No. 96-09 (Not to be Published

i in NUREG-0940)

! 4. NRC Presentation Materials (Not to be Published in

NUREG-0940)

5. Licensee Presentation Materials (Not to be Published in

NUREG-0940)

cc w/encls: (See Page 4)

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cc w/encls:

M. J. Ajluni. Licensing

Services Manager B-031

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Southern Nuclear Operating

l Company. Inc.

! 42 Inverness Center Parkway l

Birmingham. AL 35242

R. D. Hill. Jr.

General Manager. Farley Plant :

Southern Nuclear Operating

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Company. Inc. ,

l P. O. Box 470

l Ashford. AL 36312

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l J. D. Woodard

Executive Vice President

Southern Nuclear Operating

Company. Inc.

P. O. Box 1295 ,

Birmingham AL 35201

State Health Officer

Alabama Department of Public Health

434 Monroe Street l

Montgomery. AL 36130-1701 i

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M. Stanford Blanton '

Balch and Bingham Law Firm .

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P. O. Box 306

1710 Sixth Avenue North

Birmingham. AL 35201

Chairman

Houston County Commission

P. O. Box 6406

Dothan, AL 36302

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Distribution w/encls:

PUBLIC

JTaylor. EDO

JMilhoan. DEDR

GTracy. OEDO

SEbneter. RII

LChandler. OGC

JGoldberg 0GC

RZimmerman NRR

EJulian. SECY

BKeeling. CA

Enforcement Coordinators

RI. RIII. RIV

JLieberman. OE

OE:EA File (BSummers) (2 letterhead)

MSatorius OE

EHayden. OPA

GCaputo. 01

EJordan. AE00

HBell DIG

CEvans. RII

Buryc. RII

KClark. RII

RTrojanowski. RII

EMerschoff. RII

PSkinner RII (IFS Action Required)

RWright, RII

AGibson, RII

HBerkow, NRR

JZimmerman NRR

NRC Resident Inspector

U.S. Nuclear Regulatory Commission *

7388 N State Highway 95

Columbia. AL 36319

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ML20149M564

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