ML20198Q630
| ML20198Q630 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/05/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-348-97-10, NUDOCS 9711120288 | |
| Download: ML20198Q630 (9) | |
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Dave Morey Southern Nuclear
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Vice Prewent Operating Company f adey Project PO. Box 1295 Bamingtiam. Alabama 35201 Tel 705.932.5131 i
SOUTHE.RN co Novcsnber 5,1997 Energy to Serve YourWorli' Docket No.:
50-348 10 CFR 2.201 U.S. Nucle:r Regulatory Commission ATTN: Document Control Desk Washington, DC - 20555 Joseph M. Farley Nuclear Plant Reply To a Notice Of Violation (VIO)
NRC InspstlicultagaNumbr.t 50-348/97-10-08/05 Ladies and Gentlemen:
As requested by your transmittal dated October 6,1997, this letter responds to VIO 50-348/97-104)8 " Installation of11alf liour Knowool Fire 13arriers Without Appendix R Exemption" and VIO 50-348/97-10-05 " inadequate Configuration Control of UI RhtS Particulate Sample Lines," Enclosure I of this letter addresses the Fire Barrier Notiec of Violation; Enclosure 11 addresses the Configuration Control Notice of Violation.
Should you have any questions, please advise.
Respectfully submitted, V/ W Dave htorey LLI1:maf nov10-08 g#
Enclosure cc:
hir. L. A Reyes, Region 11 Administrator
. hir. J, I, Zimmernwn, NRR Project h1armaer hir. T. hi, Ross, Plant Sr. Resident inspector i
120072 9711120298 971105
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ENCLOSUREI 8
Installation ofilaff.Ifour o5 i f re Ba r er 4idi AWh R h4
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l Violation VIO 50-348, 364/97-10-08, " Installation of flatf Ilour Kaowool Fire 11arricts Without Appendix R Exemption" states:
1.icense No. NPF-2, Condition 2.C(4), for Farley Nuclear Plant (FhP),
Unit 1, states, in part, that Southern Nuc! car Operating Company, Inc.
shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR).
Appendix 911 of the UFSAR, Fire Protection Program, documents an evaluation of the FNP 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 911, Attachment II, e) CFR 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 1-hour Knowool fire barriers to meet Appendix R.
Specifically, Appendix 911, Attachment 11, Section 213, states that "the redundant charging pump power cables are provided with a barrier (two 1 inch thick wraps of Knowool 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 11 in rooms 175,160,and 159."
Contrary to the above, as of September 6,1997, the licensee installed a one 1 ine:h thick wrap of Kaowool on the sides and bottoms of raceways llDE 9 and IIDE-15, canying train 11 charging pump power cables in Room 160 of fire area 1004.
This is a Severity Level IV violation. This violation is applicable to Unit I only.
Atimission or Denial Farley Nuclear Plant is denying the violation.
As stated in the Notice of Violation (NOV), Southern Nuclear (SNC)"
shallimplement and maintain in effect all provisions of the approved fire protection program as described in the [FSAR)." As described below, the installed configuration of the cited raceways is in compliance with the FNP fire protection program as described in the FSAR. The FSAR contains conflicting statements regarding the fire protection requirements for Train B charging pump power cable raceways. Specifically, the FS AR statement quoted in the EI-1
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NOV concerning Iwo 1-inch thick wraps of Kaowool is in error, as explained in the L(menfor Violalien paragraph below.
SNC documented the need for correction and clariGcation of Section 9D of the FSAR on November 27,1996. The " Policy and Procedure for Enforcement Action, Departures From FSAR" policy statement (Reference Federal Register Vol. 61, No. 203, October 18, 1996 at 54461) allows the NRC to exercise enforcement discretion for a period of up to two years from October 18,1996 if the licensee has undertaken a voluntary initiative to identify and correct FSAR discrepancies. SNC letter dated January 31,1997 to the NRC entitled " Response to Request for Information Pursuaat to 10 CFR 50.54 (f) Regarding Adequacy And Availability of Design Bases Information" described the Farley FSAR review initiative in Section F of the letter. The subject FSAR discrepancy was captured as part of this initiative. SNC took prompt corrective action to resolve the issue in conjunction with this initiative, which is a Icey provision of the Policy Statement. It is our intent to fully resolve the subject FSAR discrepancy within the two year window provided in the Policy Statement. Farley Nuclear Plant (FNP) believes that enforcement discretion for FSAR errors is warranted ~
- this case in that this error meets the criteria of the Policy.
Henson for Violation The cited sentence in the FSAR is in error and is contradictory to the licensing and design basis for the Knowool wrap on cable trays HDE-9 and 15 ia room 160. This sentence was in erior in the FNP submittal of Exemption Request 1-39 and as such was introduced into the NRC SER and the FSAR.
The NRC reviewed and approved (see Table 3 of NRC letter dated April 13,1979) the following propased modification as discussed in the Farley Nuclear Plant Fire Protection Program Reevaluation (FPPR), paragraph 4.3.51, sub-paragraph 5.b:
Fire area 4 Roo:n 160. Two train B trays are located approximately 17 feet from the nearest train A cable. Sprinklers are proposed for the area, Wrapping the train B control cable tray with a half-hour barrier (Tray BilF-
- 24) and the bottom and sides only of the power cable trays (BDE-9 and 15) is proposed.
Justification: The open-top barrier for the power cable assures that the cable will not overheat it is approximately 12 feet above the floor and 5 feet below the ceiling. Thus the power tray is isolated from an exposure fire.
Based on NRC approval, the configuration described above was installed at FNP. It should be noted that FNP failed to completely comply with the above criteria until January 31,1997 (reference Licensee Event Report 96-006-00 and Notice of Violation dated December 4,1996),
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Upon issuance of 10CFR50 Appendix R, FNP submitted to NRC exemption requests to seek re-approval of our installed raceway protection con 0gurations that did not meet the requirements of Appendix R. For the specific configuration cited, Exemption Request l-39, as submitted on October 18,1985, states in part j
Fire area 1-004 contains redundant charging pump train A and B power cables. One train of redundant power cables is not provided with a fire-rated barrier for its entire route in the fire area...
l llowever, as cited in the violation, the Justification paragraph in Exemption Request
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l-39, as incorporated into the FS AR, also states that:
"The redundant power cables are provided with a barrier (two 1-in, thick wraps of Kaowool blanket)..."
This sentence is in error and is contradictory to the original licensing and design bar,is for the Kaowool wrap on cable trays DDE-9 and 15 in room 160. FNP never intended to perform design changes, since the NRC already approved the knowool con 0gurations for t
those cable raceways. The intent of this exemption was to seek Appendix R exemption for the raceway wrap configuration described above and approved by NRC via SER dated April 13,1979. Exemption request 1-39 was granted by the NRC via SER dated September 10,1986.
Corrective Stens Taken and Results Achieve 4 FNP established an bourly fire watch for Room 160 in October,1996. The fire watch will remain in place until this !ssue is resolved.
Corrective Stens That Will Be Taken to Avoid Further Violation FNP will submit a proposed revision to FSAR Appendix 9B, Attachment B
( Appendix R Exemptions), correcting various inconsistencies, inaccuracies, and other errors, to NRR by March 31,1998 for approval. FNP will incorporate the approved Appendix R Exemptions into the FSAR by October 17.1998.
Date of Full Compliance FNP will incomorate the approved Appendix R Exemptions into the FSAR by October 17, 1998.
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ENCLOSURE 11 Response to VIO $0 34H/9710-0$
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Inadequate Configuration Control of UI RMS Particulate Sample Lines t
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Violation VIO $0 348/9710 05, " inadequate Configuration Control of Unit 1 RMS Paniculate Sample Lines" states:
l 10 CFR Pad 50. Appendix B. Criterion V requires that activities affecting quality shall bc prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Operations Quality Assurance Policy Manual Section 5.1 Instructions, Procedures and Drawings states that Southern Nuclear Company - Farley Project will perform safety related activities in accordance with properly approved instructions, procedures and drawings and i
that contractor and vendor organizations will perform safety related activities in accordance with properly approved instructions, procedures and drawings.
Contrary to the above as of August 25,1997 approved Radiation Monitoring System (RMS) l' configuration control procedures and drawings were not followed or were inadequate for the following examples:
- 1. The installed Unit 1 (Ul) backup Post Accident Sampling System plant vent airborne paniculate sampler (RE 68) inlet sample line was constructed using stainless steel flexible tubing having corrugated internal surfaces rather than solid tubing as specified in drawing i
N 1-D11 (1179 554) dated Febmary 23,1984.
- 2. Drawing N 1 Dil-RE-29-E, Sheet 3, Rev. 3, dated April 4,1997 for the Ul main stack particulate sampling line was inadequate in that drawing details only specified that " filter unit furnished by APCO,"i.e., Alabama Power Company. This resulted in the installat'on of several feet of flexible stainless steel tubing having a corrugated internal surface.
This is a Severity Level IV violation (Supplement IV). This violation is applicable to Unit I only.
. Admission or Denial The violation occurred as described in the Notice of Violation.
i Reason for Violation The cause of this event is personnel error in that personnel failed to adequately implement and maintain the radiation monitoring configuration in accordance with existing design drawingt The original design.is documented on a plant' P&lD and by sketch drawings that were part of the original design change package that installed RE 29A. The original design did not allow for easy changing of the particulate filter. Shortly afler the original installation, plant personnel apparently l
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added a second filter housing and installed corrugated tubing without following Farley Nuclear-l Plant (FNP) design change procedures. The sketch drawings referenced above are field isometric j
i sketches generated to implement the original design. Had plant personnel followed the design change procedures these drawings would have be-apdated along with other required drawings.
t The wrrent plant P&lD drawing is correct except n does not reflect the modification performed by plant personnel.
For clarity the drawings referenced above in the violation should be N-1-Dil (B79 554) WO #
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10087, Rev. 2, dated April 17,1984 and N 1 Dil RE-29E, Sheet 3, Rev. 3 dated November 4, 1985.
In regards to the NRC stall's concern that the configuration of the air particulate sample lines for plant vent radiation monitors will not provide representative results when called upon, SNC can not conclusively quantify the effects of corrugated tubing on representative sample results;
- i however, our engineeringjudgment is that the effects are probably not significant with regards to
. grab sample system function.
Corrective Stens Taken and Hesults Achieved
- 1. On August 25,1997, RE 29A was removed from service. At this time, a decision was made to rely on RE 2911in order to meet the ODCM cfiluent samp'ing requirements. Unit 1 RE-2911 was placed in service to meet the ODCM cfiluent sampling requirements. RE 29B was already in service for the post accident sampling monitor for the plant vent stack.
- 2. Corrective action associated with RE-68 was completed on October 20,1997.
Corrective Stens That Will He Taken to Avoid Further Violation
- l. A walkdown inspection of all accessible radiation monitors for design configuration was completed on September 26,1997. This walkdown identified several deficiencies which are in the process of being corrected. These additional deficiencies would not have prevented the radiation monitors from perforniing their intended functions. The field deficiencies will be corrected by December 15,1997. The drawing deficiencies will be completed by February 15, 1998.
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- 2. Appropriate plant personnel will be retrained concerning the importance of maintaining design configuration for radiation monitoring systems. This will be complete by December 31,1997.
- 3. RU - 29A design is currently being assessed to facilitate filter replacement and operation.
Final design is expected to be issued by November 14,1997 and implementation by December 15,1997. Following design implementation RE-29A will be returned to ser ice for the r
collection of the Unit I weekly plant vent particulate samples and primary plant vent stack 7
" grab". sample monitor for ODCM efliuent compliance.
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- 4. A task to perform walkdowns for the remaining portions of the radiation monitors currently inaccessible will be included in the next refueling outage schedule (Unit 1 - Fall 1998, Unit 2 Spring 1998) for both units. Any deficiencies identified vill be corrected.
- 5. A review will be performed to ensure that radiation monitor design and licensing requirements are concisely documented and validated via a Functional System Description (FSD) and Self-initiated Safety System Assessment ( SSSA). Deficiencies identified will be corrected in a timely manner.
Date of Full Compliance September 1,1999 E 11 - 3