IR 05000348/1997014

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-348/97-14 & 50-364/97-14 on 971229.Evaluated Denial of Violation B & Determined That Violation B Did Not Constitute Violation

ML20237B362
Person / Time
Site:	Farley
Issue date:	08/12/1998
From:	Plisco L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
References
50-348-97-14, 50-364-97-14, EA-97-571, EA-98-407, NUDOCS 9808180211
Download: ML20237B362 (6)

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o August 12, 1998 EA 97-571 EA 98-407 Southern Nuclear Operating Company, Inc.

ATTN: Mr. D. Vice President P. O. Box 1295 Birmingham. AL 35201 SUBJECT: NRC INSPECTION REPORT NOS. 50-348/97-14 AND 50-364/97-14

Dear Mr. Morey:

Thank you for your res3onse of January 23. 1998, to our Notice of Violation (NOV), issued on Decem]er 29, 1997, concerning activities conducted at your Farley Nuclear Plant. We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. Your response included the denial of Violation B. Our evaluation of your response has been completed. A summary of the response is provided by enclosure to this letter.

You denied Violation B of the NOV on the basis that tornado missile protection of the turbine-driven auxiliary feedwater pump (TDAFW) turbine exhaust was not included in the original plant design because of the two motor-driven auxiliary feedwater pumps that are protected from tornado missiles by being located in the Category I Auxiliary Building. You indicated that this design was consistent with Section 3.5.4 of the Updated Final Safety Analysis Report (UFSAR) in that a loss of the TDAFW pump due to tornado generated missiles  ;

will not cause a failure of the two motor-driven auxiliary feedwater pumps. j After reviewing your letter, we have determined that Violation B of the l December 29, 1997, NOV did not constitute a violation. Although there was no '

violation, we do not agree with the statements in your January letter that the Farley design and licensing basis does not require the postulation of a single I active failure in conjunction with consequential failures which are the direct I result of a design basis tornado. However, because of the remaining i

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redundancy of the two motor-driven auxiliary feedwater pumps following a loss of the TDAFW pump due to tornado induced failures. we have also concluded that ,

the TDATW pump turbine exhaust stack does not need to be protected from I tornado generated missiles. Accordingly, we will adjust our records to reflect that no violation of regulatory requirements occurred with respect to item No. B.  ;

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9008180211 980812 PDR ADOCK 05000348 G PDR i

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SNOPC0 2 We appreciate your cooperation in this matter.

Sincerely

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Original' signed by Loren R. Plisco Loren R. Plisco, Director Division of Reactor Projects Enclosure: Task Interface Agreement Response cc w/ encl:

M. J. Ajluni. Licensing Services Manager, B-031'

Southern Nuclear Operating Company, Inc.

42 Inverness Center Parkway Birmingham, AL 35201-1295 M. Stinson General Manager, Farley Plant Southern Nuclear Operating Company, Inc.

P. O. Box 1295 Birmingham, AL 35201-1295 J. D. Woodard

' Executive Vice President Southern Nuclear Operating Company, Inc.

P. O. Box 1295 Birmingham, AL 35201-1295 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, AL 36130-1701 M. Stanford Blanton

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Balch and Bingham Law Firm P. O. Box 306

, ~1710 Sixth Avenue North l Birmingham, AL 35201 l

Chairman Houston County Commission P. O. Box 6406 Dothan. AL 36302 l

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SN0PC0 3 Distribution w/ encl:

L. Plisco. RII P. Skinner. RII B. Holbrook. RII J. Zimmerman. NRR J. Lieberman. OE B. Summers. OE PUBLIC NRC Resident Inspector U. S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia. AL 36319

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0FFICE

• For previous concurrence see attached page Ril:DRS* All:DRS* All:DRS, RII:DRP* RM@

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SNOPC0 3 Distribution w/ enc 1:

L. Plisco, RII.

P. Skinner, RII B,ti0lbak-R. Carrion, RII J. Zimmerman, NPsR J. Lieberman. OE B. Summers, OE PUBLIC NRC Resident Inspector U. S. Nuclear Regulatory mmission 7388 N. State Highway 9 Columbia. AL 36319 i

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Enclosure

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l TASK INTERFACE AGREEMENT RESPONSE BY THE OFFICE OF NUCLEAR REACTOR REGULATION TORNADO PROTECTION OF TURBINE DRIVEN AUXILIARY FEEDWATER PUMP TURBINE VENT STACK (TAC NOS. MA1067 AND MA1068)

SOUTHERN NUCLEAR OPERATING COMPANY. INC.

JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364 1.0 INTRODUCTION By letter dated February 24,1998, you requested NRR's technical assistance in evaluating whether the Farley design and licensing basis requires the licensee to assume a single active failure of a design basis tomado, and if so, whether the turbine driven auxiliary feedwater (TDAFW) pump turbine exhaust must be protected from tomado missiles to meet the single failure criterion.

2.0 EVALUATION Region'll issued a Notice of Violation 54348,364/97-14-05 (dated December 29, 1997) regarding the lack of missile protection and various statements in the Updated Final Safety Analysis Report (UFSAR) that indicated the AFW system and its piping are either housed in Seismic Category I structures or buried underg"ound. By letter dated January 23,1998, the licensee denied the violation on the be. sis that missile protection of the TDAFW pump turbine vent was not required bect,use of the two motor-driven (MD) AFW pumps that are tornado missile protected.

In that denial, the licensee stated that they are not committed to Regulatory Guide (RG) 1.117, " Tornado Design Classification," dated 1978, and are not required to assume a single active failure in conjunction with the consequential failures, which are the direct result of the tornado generated missile. In defense of this position (no

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single failure), the licensee has provided the following quote from a June 1,1977, internal memo .

l Both (meaning the NRC Accident Analysis Branch Chief and the Auxiliary l Systems Branch Chief) confirmed that the NRC is not applying the single failure criterion in determining the acceptability of plant designs to cope with tornado 3 missiles. Their rationale lies in the low probability cf occurrence associated with

! the design basis tornado characteristics (Regulatory Guide 1.76) and the  ;

existence of missiles defined in SRP 3.5.1.4. j The licensee discusses that the above discussion and quote occurred prior to the issuance of RG 1.117 and, therefore, supports the claim that single active random failures, concurrent with a tornado, were not considered by the staff during that

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i licensing time frame for Farley. However, RG 1.117 was issued for comment in June 1976,. and reflects the staff's tornado missile protection philosophy of the early and mid 1970s. It is relatively clear from the appendix to the draft RG that the staff did not consider it acceptable to protect only one train of safe shutdown equipment from tornado generated missiles. The subsequent RG 1.117 issued in April 1978, clarified specifically that single failures should be assumed in conjunction with tornaoo missile damage. While the discussion quoted by the licensee may have taken place in some form, we cannot be sure as to !

the exact wording or of subsequent phone calls that may have corrected any incorrect '

or misunderstood statements. Unless there is documented evidence to the contrary, it is our belief, and hence our position, that single active failures were considered by the staff in conjunction with direct tornado induced failures during the licensing of Farley, Units 1 and 2.

With respect to the protection of the TDAFW pump turbine vent, it is possible that the staff (Auxiliary and Power Conversion Systems Branch) was aware of the vulnerability but considered it acceptabla based on the redundancy afforded by the two MDAFW pumps. There are a number of three pump plants where the TDAFW pump may not be completely seismic, or completely tornado missile protected, or both. At these plants, a single MDAFW pump is adequate to remove heat following either of these natural phenomena. Farley is one of these plants as shown by Section 6.5.1 of the UFSAR where it is stated that each of the MDAFW pumps is sized to supply 100

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percent of the required feedwater flow for a normal safe cooldown of the reactor coolant system. This has been reaffirmed by the staff in NUREG 0611, " Generic Evaluation of Feedwater Transients and Small Break Loss of-Coolant Accidents in !

Westinghouse-Designed Operating Plants." In NUREG-0611,Section X.3, the staff's criterion for success of the Farley AFW system is the operation of any one AFW pump for all the loss of feedwater events considered.

Based on the uncertainties in the depth of the staff's review for tornado missile )

protection during the Farley licensing process, and the known capabilities of the J Westinghouse three-pump plants, the design appears to meet the staff's criteria for l protection against tornado generated missiles. Although there may be no violation, the licensee's basis for the denial of the violation is not acceptable because we believe single active failures are part of the design basis and should be considered coincident with a tornado. However, the UFSAR does not appear to accurately portray the actual plant design (UFSAR implics all of AFW system is tornado missile protected) and should be clarified in this regard.

3.0 CONCLUSION The staff concludes that the design and licensing basis does require the postulation of a single active failure in conjunction with consequential failures, which are the direct result of a design basis tornado. However, because of the remaining redundancy of the two motor-driven auxiliary feedwater pumps following a loss of the TDAFW pump ,

l due to tornado induced failures, we have also concluded that the TDAFW pump l

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l turbine exhaust stack does not need to be protected from tornado generated missiles.

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