ML20198M734
| ML20198M734 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/24/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-348-97-12, 50-364-97-12, GL-86-10, IEIN-93-041, IEIN-93-41, NUDOCS 9710290095 | |
| Download: ML20198M734 (5) | |
Text
0 Dave Mor:y Southern Nucl:ar Vu Prevdent Op:ratit*0 Company Iailey Ptopet P0 Boa 1795 Birmingham. Alabama 35201 Tel 205.932 5131 October 24, 1997 SOUTHERN COMPANY Energ ro Serve hurWorld*
Docket No.:
50 348 10 CFR 2.201 50-364 U. S. Nuclear Regulatory Commission ATFN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Reply To a Notice Of Violation (VIO)
NRC Insocctionicport Number 50 348. 364/97-12-02 Ladies and Gentlemen:
As requested by your transmittal dated reptembe 26,1997 this letter responds to VIO 50 348, 364/97 12-02 " inadequate Design Control For the Kaw.vool Electrical Raceway Fire Barrier System (ERFBS)." The Southem Nuclear Operating Company (SNC) response is provided in the enclosure. Conceming Knowool installation at Farley Nuctur Plant (FNP), SNC understands that there are NRC compliance issues; Inwever, SNC believes that they are based on individual interpretation of the level of documentation necessary to justify installation details that deviate from the vendor tested con 6guration. SNC believes there is no safety signi.Scance to this issue.
Southern Nuclear Operating Company (SNC) believes that Knowool as installed at FNP will perform its intended design function. The staffis aware that Kr.owool was approved by the NRC for fire protection use in the late 1970's and installed at FNP in the early 1980's. Various exemption requests to Appendix R were submitted by FNP that requested approval for the use of Kaowool at FNP. The use of Knowool at FNP was based upon design engineering and vendor guidelines. The installed Knowoc,1 configurations used at FNP vere NkC approved in 1085 following extensive inspections by the NRC. Minor installation tolerances or deviations were not identified as a concern. Additional NRC inspections in 1988 identined no violations or dcviations c gk relative to Knowool installations. Although not cited, a recent NRC inspeciion suggests that a 46 compliance issue is present in that the level of documentation necessary to justify installation f
details that deviate from the vendor tested con 6guration is insufficient.
1 s
9710290095 971024 PDR ADOCK 05000348 0
h.hllll hl PDR i
U S. Nuclear Regulatory Conunission Page 2 Infonnation Notice 93-41 "One llour Fire Endusance Test Results" recognized the acceptance of Knowool. Specifically, this IN recognized that the tested configuration was not representative of the in plant cunfigurations, and that the staff will evaluate whether further generic conununications are needed to address these issues. To date no further generic written communication concerning installation details deviating from the tested configuration has been distributed by the NRC.
On October 16,1996 in a conference call with the NRC, NRR infonned SNC that GL 8610 question / answer evaluations (Section 3.2.2) cannot be applied to Kaowool at FNP since it was " grandfathered" from the Appendix R requirements. In addition, NRC stated that FNP should maintain its barriers in the originally designed configurations. As noted in Oc subject inspection Report, SNC was asked by the inspector to produce 86 10 Enclosure 2 cvaluations, it appears to SNC that the NRC is changing its inspection standards or criteria without providing industry notification or proper evaluation. It also appears to SNC that there is confusion within the i
NRC as to its current interpretation ofinspection standards and criteria in this area. SNC is l
uncertain of the stafTposition in this regard and has requested a meeting with staff to discuss this cnd other fire protection issues.
Should you have any questions, please advise.
I Respectfully submitted, fl
)N Dave hiorey REhi/ mar nov9712. doc Enclosure cc:
hir. L. A. Reyes, Region 11 Administrator hir J.1. Zimmennan, NRR Project hinnager hir. T. hi. Ross, Plant Sr. Resident inspector
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ENCLOSURE Response to VIO 50 348,364/9712 02 Inadequate Design Control For the Kaowool Electrical Raceway Fire Barrier System (ERFDS) l l
l l
RESPONSE TO VIO 50-348,364/9712-02 VIO 50 348,364/9712-02," Inadequate Design Control For the Kaowool Electrical Raceway Fire Barrier System (ERFBS)" states:
License No. NPF 1, Condition 2.C(4), and License No. NPF 8, Condition 2.C(6), states, in part, that Southern Nuclear shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Repoit (FSAR).
FSAR, Appendix 9B, Fire Frotection Program, documents the evaluation of the 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 98, Section 98.2.5.1, and FSAR Section 17.2.3 require a design control program for fire protection design activities for the operating nuclear plant to assure that applicable regulatory requirements and the design basis are properly translated into specifications, drawings, procedures, and instructions.
l The Knowool electrical raceway fire barrier system (EKFDS) at Farley consisted of two 1 inch I
layers of Kaowool and an overall layer of Zetex fabric installe 1 on cable trays and conduits.
Along the length of the protected raceway, where one blanket ended and another began, the blankets were butted together. The butted joints of the inner blanket and outer blanket of the raceway configurations were offset and separ.ned. Ilolding bands were installed ou cach side of I
the butt joints on the outer Knowool blanket wrap. The Kaowool ERFBS blanket wrap design specification drawings A 177541. Sheets 18K and 1HM, spxi6cd the separation distances of the inner and outer layer butt joints at 15 inches for a cab'e tray raceway and 14 inches for a conduit. The Kaowool ERFBS blanke* wrap design specification drawing A 177541, Sheets 18K and IRM, specified a maximum allowable distanc-of 3 inches for the location of the holding band from the side of the butt joint on the outer Kaowoc! blanket wrap for cable trays.
Contrary to the above, on August 20,1997, the NRC identified that the licensee failed to correctly translate the applicable design rpecification input requirements for the Kaowool ERFBS butt joint separation distance and banding location into the plant installation drawings, procedures, and instructions. The licensee failed to maintain in effect all provisions of the approved iire protection program in that:
1.
Section 6.2.5 of procedure FNP-0 PMp 507, Revision 7, Kaowool Installation Procedure, specified a butt joint separation distance of 12 inches for any wrapped cable tray or conduit raceway. These represented difTerent and less conservative butt joint separation distances than those specined in the design specification drawings.
2.
Section 6.2.6 of procedure FNP-0-PMP 507, Revision 7, Knowool Installation Procedure, speci6cd an allowable holding band placement of up to four inches from the side of any butt joint for a cable tray raceway ERFBS. This repre;,ented a different less conservative butt joint band location than the maximum three inch distance represented in design specification drawings.
This is a Severity Level IV violatien (Supplement 1).
RESPONSE TO VIO 50-348,364/9712-02 4
Admission or Denial Farley Nuclear Plant is denying the siolation.
Reason for Violation 1he governing installation criteria for Knowool, including overt: p and banding separation, which is consistent with the manufacturer's application guide, is documented in drawing A 177541, sheet 1811.
This criteria specifically states that the "... exterior la>cr of blanket are not within 12 inches of any butt joints on the interior blanket wrap." It further states, "The bands shall be placed not more than 4 inches from any buttjoint on the exterior blanket..,". As hoted on drawing A 177541 sheet 1811, sheets K and M are referred to for general installation details. Sheets K and M do not specify maximum or minimum butt joint separation and band to buttjoint diruensions. Therefore, procedure FP-0-PMP 507 correctly applied the design criteria.
Corrective Steos Taken and Results Achieved No adverse condition exists.
A complete review of FNP-0-PMP 507 against drawing A-177541 confirmed that minimum butt joint separation and maximum band to butt joint dimension guidance was met. FNP-0 PMP 507 complies with the guidance provided by drawing A 177541 and the Kaowool manufacturer's application guide.
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Corrective Steps That Will Be Taken to Avoid Further Violation As an enhancement to climinate possible ambiguity in installatiot, details, Farley Nuclear Plant will revise drawing A 177541, sheets 18K and IBM, to reflect a minimum butt joint separation of 12 inches and maximum band to butt joint dimension of 4 inches.
Date of Full Compliance Drawing A 177541 will be revised by January 20,1998.
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