ML20149M564
| 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: |
| References | |
| EA-96-410, NUDOCS 9612170397 | |
| Download: ML20149M564 (5) | |
See also: IR 05000348/1996009
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December 4. 1996
EA 96-410
Southern Nuclear Operating Company. Inc.
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ATTN:
Mr. D. N. Morey
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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 -
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$50.000 (NRC INTEGRATED INSPECTION REPORT NOS. 50-348 AND
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50-364/96-09)
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Dear Mr. Morey:
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This refers to the inspection conducted during the period September 1 through
October 12. 1996, at your Farley Nuclear Plant (FNP).
The inspection included
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a review of the fire protection program associated with the installation and
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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
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inspection were discussed with members of your staff on October 17, 1996, and
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were formally transmitted to you by letter dated November 8. 1996.
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addition, on November 7, 1996. you submitted Licensee Event Report
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No. 96-006-00 which addressed Kaowool fire barrier installation deficiencies.
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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
apparent violations, the root causes, and corrective actions to preclude
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recurrence. A list of conference attendees. NRC slides, and a copy of your
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presentation materials are enclosed.
In addition. at the conference, you
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identified errors in and/or disagreement
ith certain statements expressed in
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the subject inspection report. The dispositon of your comments in this regard
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are also enclosed,
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Based on the information developed during the ins)ection and the information
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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
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enclosed Notice of Violation and Proposed Imposition of Civil Penalty
(Notice), and the circumstances surrounding them are described in detail in
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the subject inspection report.
The violation described in Part I of the
Notice involved three examples of Southern Nuclear Operating Company Inc.'s
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(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
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required for safe shutdown. The components affected by the discrepant
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conditions were the dedicated B Train high head safety injection pump and its
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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.
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9612170397 961204
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ADOCK 05000348
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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
intervention which are not proceduralized and cannot be assured for 10 CFR 50,
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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.
Because your
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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
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establishment of fire watches: (2) the conduct of a walk-down of motor-
operated valve Kaowool installations following identification of deficiencies
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by the NRC: (3) conduct of a comprehensive inspection of all Kaowool
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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
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flammastic installation discrepancies over a several month period was required
before you took comprehensive corrective actions. Although engineering
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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
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It involved the failure to adequately implement a program
for the periodic inspection of Kaowool installed fire barriers.
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inadequate inspections, lack of qualified inspectors, and incomplete
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inspection criteria contributed to failure to identify the Kaowool
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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
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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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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
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2.
Conference Attendees (Not to be Published in NUREG-0940)
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3.
Comments on Inspection Report No. 96-09 (Not to be Published
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in NUREG-0940)
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4.
NRC Presentation Materials (Not to be Published in
5.
Licensee Presentation Materials (Not to be Published in
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
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Company. Inc.
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42 Inverness Center Parkway
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Birmingham. AL 35242
R. D. Hill. Jr.
General Manager. Farley Plant
Southern Nuclear Operating
Company. Inc.
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P. O. Box 470
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Ashford. AL 36312
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J. D. Woodard
Executive Vice President
Southern Nuclear Operating
Company. Inc.
P. O. Box 1295
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Birmingham AL 35201
State Health Officer
Alabama Department of Public Health
434 Monroe Street
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Montgomery. AL 36130-1701
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M. Stanford Blanton
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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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