ML20199H095

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Forwards Insp Repts 50-348/97-11 & 50-364/97-11 on 970907- 1018 & NOV Re Failure to Protect Certain Piping,Level Transmitters,Transmitter Tubing,Cables & Conduit Associated W/Unit 1 & 2 Condensate Storage Tanks
ML20199H095
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 11/17/1997
From: Jerrica Johnson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
Shared Package
ML20199H100 List:
References
50-348-97-11, 50-364-97-11, EA-97-462, EA-97-488, NUDOCS 9711260018
Download: ML20199H095 (5)


See also: IR 05000348/1997011

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November 17. 1997

EA 97-462

EA 97 488

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Southern Nuclear Operating Company, Inc.

ATIN: Mr. D. N. Morey

Vice President

P. 0. Box 1295

Birmingham, AL 35201-1295

SUBJECT:

NRC INTEGRATED INSPECTION REPORT NOS. 50 348/97 11 AND 50 354/97-

11, NOTICE OF VIOLATION, AND EXERCISE OF ENFORCEMENT DISCRtTION

Dear Mr. Morey:

On October 18, 1997, the U.S. Nuclear Regulatory Commission (NRC) completed an

. inspection at your Farley Nuclear Plant (FNP). The findings related to this

inspection were discussed with you and members of your staff at an exit

meeting on November 5, 1997. The enclosed report _ presents the results of that

inspection.

During the 6 week inspection period, your conduct of activities at FNP was

generally characterized by safety-conscious operations, sound engineering and

maintenance practices, and careful radiological work controls.

However, seven

violations of NRC requirements were identified. We are particularly concerned

about the number of violations in the engineerin

Although the overall

safety significance of these violations is low, g area.they indicate a weakness in

. your engineerino organization's ability to conduct effective self-assessments.

The violations are cited in the enclosed Notice of Violation (Notice), and the

specific circumstances surrounding them are described in detail in the

enclosed report.

Based on the information developed during the inspection, two additional

violations of NRC requirements were also identified as described in Sections

E.8.4 and E.8.5, and E.8.14, E.8.21, and E.8.24 of the enclosed inspection

report. The first violation involves the failure to protect certain piping.

-level transmitters, transmitter tubing, cables, and conduit associated with

-the Unit 1 and Unit 2 Condensate Storage Tanks from tornado-generated

. missiles, as described in-the Updated Final Safety Analysis Report (UFSAR).

-and an adequate safety evaluation was not performed to provide the basis.that

.the changes in the facility did rot involve an unreviewed safety question

(US0), . Based on NRC's subsequent determination that a USQ did exist due to

the possibility. for equipment malfunction of a different type than previously

evaluated in the-UFSAR, it was concluded that a violation of 10 CFR 50.59

occurred. .However, in accordance with Section VII.B.6 of the " General

Statement'~of Policy and Procedures for NRC Enforcement Actions" (Enforcement

-Policy) NUREG 1600c the NRC.may refrain from issuing a Notice of Violation

-for violations involving special circumstances. After review of

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this violation and consultation with the Director. Office of Enforcement, the

NRC has concluded that, given NRC's previous regulatory determinations

regarding this issue, the low risk significance, and the your planned

corrective actions scheduled for completion by March 15. 1998, the criteria

for enforcement discretion have been met and issuance of a violation is not

warranted in this case.

The second violation involves seven NRC identified examples of the failure to

update the UFSAR to assure that it contained the latest material developed as

required by 10 CFR 50.71(e).

The violation includes discrepancies between the

as-built plant configuration and the UFSAR description for the auxiliary

feedwater, the component cooling water, and electrical systems.

In accordance

with the Enforcement Policy, this violation would normally be categorized as a

Severity Level IV violation.

However, as discussed in Vll.B.3 of the

Enforcement Policy, the NRC may refrain from issuing a Notice of Violation for

a violation that involves a past problem, such as an old engineering, design,

or installation deficiency, provided that certain criteria are met.

After

review of this issue and consultation with the Director. Office of

Enforcement, the NRC has concluded, that while a violation did occur,

enforcement discretion is warranted in this case. Therefore, to encourage

your efforts to identify and correct UFSAR discrepancies no Notice is being

issued in this case.

The specific bases for this decision were (1) your

docketed UFSAR review program would likely have identified the discrepancies:

(2) there had been no prior notice where you could have reasonably identified

the discrepancies earlier: (3) timely and appropriate corrective action was

taken or planned: (4) timely a#u effective long-term corrective actions are

being implemented to review and identify similar design deficiencies: and (5)

the design deficiencies were considered old design issues.

With regard to Violations A through F in the enclosed Notice

) lease note that

you are required to respond to this letter and should follow t le instructions

specified in the enclosed Nottte when preparing your response.

The NRC will

use your response, in part, to determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

However, with

regard to Violation G for inadequate control of safeguards information, the

NRC has concluded that information regarding the reason for the violation, and

the corrective actions taken and planned to correct the violation and prevent

recurrence, are already adequately addressed on the docket in the enclosed

inspection report.

Therefore, you are not required to respond to this

violation unless the description therein does not accurately reflect your

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ccrrective actions or your position.

In that case. or if you choose to

provide additional information, you should follow the instructions specified

in the enclosed Notice,

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

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this letter and its enclosures will be placed in the NRC Public Document Room.

.

"

Sincerely.

(Original signed by Loren R. P11 ten

for Jon R. Johnson)

!

Jon R. Johnson, Director

Division of Reactor Projects

Docket Nos.:

50 348 and 50-364

License Nos.:

NPF-2 and NPF 8

'

Enclosures:

1.

Notice of Violation

2.

Inspection Report 50-348/97-11

.

and 50 364/97-11

+

cc w/encls:

l

M. J. Aj1 uni

Licensing

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Services Manager. B-031

Southern Nuclear Operating

Company, Inc.

42 inverness Center Parkway

Birmingham, AL 35242

R. D. Hill. Jr.

General Manager. Farley Plant

Southern Nuclear Operating

Company. Inc.

P. O. Box 470

Ashford AL 36312

J. D. Woodard

Executive Vice President

Southern Nuclear Operating

Company, Inc.

P. O. Box 1295

Birmingham. AL 35201

State Health Officer

-Alabama Dep6rtment of Public Health

'434 Monroe Street

Montgomery AL 36130-1701

cc w/encls cont'd:

(See Page_4)

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Notice of Violation

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H. Stanford Clanton

Balch and Bingham Law firm

P. O. Box 306

1710 Sixth Avenue North

Birmingham AL 35201

Chairman

Houston County Commission

P. 0. Box 6406

.Dothan AL 36302

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Distribut1

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C. W. Rapp. Ra

W. P. Kleinsorge. Rll

M. E. Ernstes. Ril

J. Zimmerman. NRR

PUBLIC

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NRC Resident Inspectre

U.S. Nuclear Regulakey Commission

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7388 N State Hwy 95

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