ML20211K816

Notice of Violation from Insp on 970818-22.Violation Noted: Noted:Nrc Identified That Licensee Failed to Correctly Translate Applicable Design Specfication Input Requirements for Kaowool Electrical Raceway Fire Barrier Sys at Plant

ML20211K816
Person / Time
Site:	Farley
Issue date:	09/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211K788	List: IR 05000348/1997012 ML20211K785 ML20211K816
References
50-348-97-12, 50-364-97-12, NUDOCS 9710100047
Download: ML20211K816 (2)

Text

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NOTICE OF VIOLATION Southern Nuclear Operating Company Docket Nos: 50 348 and 50 364 Farley Nuclear Plant. Units 1 and 2 License Nos: NPF 2 and NPF-8 During a NRC inspection conducted on August 18 through August 22, 1997, a violation of NRC requirements was identified, in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG-1600, the violetion is listed below:

License No. NPF-2. 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 Report (FSAR).

FSAR. Appendix 98. Fire Protection 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 Seu ion 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.

The Kaowool electrical raceway fire barrier system (ERFBS) at Farley consisted of two 1-inch layers of Kaowool and an overall layer of Zetex fabric installed 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 separated. Holding bands were installed on each side of the butt joints on the outer Kaowool blanket wrap. The Kaowool ERFBS blanket wrap design specification drawings A-177541. Sheets 18K and 18H. specified the separation distances of the inner and outer layer butt joints at 15 inches for a cable tray raceway and 14 inches for a conduit. The Kaowool ERFBS blanket wrap design specification drawings A-177541.

Sheets 18K and 18M. specified a maximum allowable distance of 3-inches for the location of the holding band from the side of the butt joint on the outer Kaowool 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 specification input requirements for the Kaowool ERF8S butt joint separation distance and banding location into the plant installation drawings. procedures and instructions. The licensee failed to maintain ENCLOSURE 1 Nfb$N G

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2 in effect all provisions of the approved fire 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 different and less conservative butt joint separation j distances than those specified in the design specification '

drawings.

2. Section 6.2.6 of procedure FNP 0 PMP 507. Revision 7. Kaowool I installation Procedure, specified an allowable holding band i placement of up to four inches from the side of any butt joint for a cable tray raceway ERFBS. This represented a different and less conservative butt joint band location than the maximum three inch distance represented in design specification drawings.

This is a Severity level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201. Southern Nuclear Operating Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission. ATIN: Document Control Desk. Washington, DC 20555, with a copy to the Regional Administrator Region II. and a copy to the NRC Resident Inspector. Farley Nuclear Plant, within 30 days of the date of j' the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the' basis for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to l the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR. and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta Georgia this 26th day of September 1997 l

ENCLOSURE-1

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