ML20199G450

Responds to NRC 971219 Ltr Re Violations Noted in Insp Repts 50-348/97-14 & 50-364/97-14.Corrective Actions:Repair of Missing Seal Between Msvr & Containment Wall on Unit 2 Was Completed on 970421

ML20199G450
Person / Time
Site:	Farley
Issue date:	01/23/1998
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-348-97-14, 50-364-97-14, NUDOCS 9802040281
Download: ML20199G450 (8)

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'i Dave Morey-- Southern Nuclear 9 Vicq Prosideat Operating Company Iarley Project P.O Box 1295 Birmingham.Nabama 35201 Tel 205 992.5131 January 23, 1998 SOUTHERN COMPANY Energy to Serve hur World"-

Docket Nos.: 50 348- 10 CFR 2.201 50 364 U. S. Nuclear Regulatory Commission A'ITN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Reply To Notice Of Violations (VIO)

NRC Insocction Report Number 50 348. 364/97-14-03 and 91 14-05 Ladies and Gentlemen:

As requested by your transmittal dated December 29,1997, this letter responds to violations 50-

.348,364/9714-03 and 97-14-05," Inadequate Corrective Actions for Maintaining Main Steam Valve Room Cork Seal Flooding Barrier" and " Failure to Provide Tornado Missile Protection for TDAFW Pump Vent Stack." It should be noted that subsequent to th, .nspection, a further review of the original design documentation for FNP supports the conclusion that the existing configuration is consistent with the original design and licensing basis requirements.

The Southern Nuclear Operating Company (SNC) responses are provided in the enclosures.

Respectfully submitted, f

f )]WlV l Dave Morey EWC/maf: vio9714. doc Enclosure I and 2 / .

cc: Mr. L.- A. Reyes, Region 11 Administrator . '/ C0l Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector 9802040281 900123 PDR ADOCK 05000348 G PDR

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m ENCLOSURE 1-Response to VIO 50 348,368/97 14-03 " Inadequate Corrective Actions for Maintaining Main

- Steam Valve Room Cork Seal Floodmg Barrier" k

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VI,0 50 348,368/97-14-03, - "Isudequate Corrective Ad es for Maintaining Main Steam Valve -

Room Cork Seal Flooding darrier" states:

10 CFR Part 50, appendix B, Criterion XVI; Updated Final Safety Analysis Report, Section 17.2; and -

ne J. M. Farley Plant Operations Quality Assurance Policy Manual, Chapter 16, requires that the

- licensee take measures to assure that conditions adverse to quality are promptly identified and corrected Such measures are to be taken to assure that the cause of the condition is determined and corrective actions are taken to preclude repetition.

Contrary to the above, as early as June 1985, the licensee identified degradation of the cork seal between the containment and auxiliary building walls, a condition adverse to quality, and failed to .

promptly correct it. Furthermore, on June 22 and December 10,1996, the licensee identified that sections of the cork seal in the Unit I and Unit 2 Main Steam Valve Room (MSVR) floor were missing.

He significance of the condition was not ramgnind and corrected until April 21,1997 for Unit 2, and until June 1997 (during the scheduled outage) for Unit 1. Consequently, due to the missing MSVR floor cork scal, the plant operated outside its design basis for a main feedw3ter line break in the MSVR for a eW period of the before being corrected.

- His is a Severity Level IV violation (Supplement 1).

Admission or Denial ne violation occurred a. , acribed in the Notice of Violation, Reason for Violation Personnel error in that the cause of the adverse condition was insufficient sensitisity to design basis functions of the cork seal during inspections which prevented the timely detection of the degraded condition of the cork seal. Additional contributors wtre incorrect evaluation of the deficiency and prioritization of work of the maintenance backlog. It should be noted that a review of work orders in the backlog did not reveal any other deficiencies in the maintenance backlog concerning cork as a floodmg barrier, Furthermore, a review of work orders in the backlog did not reveal any additional examples where the design basis was in question.

At Farley Nuclear Plant (FNP), personnel assigned to review plant deficiencies are NRC operator licensed. Prior to the increased emphasis placed on FSAR discrepancies in the 1995 time frame, personnel assigned the responsibility for the review of deficiencies focused their review on the impact the deficiency had on the operability of Technical Specification equipment. Since 1995, additional emphasis has been placed on the impact that deficiencies have on the ability of the plant to meet its design basis.

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Corrective Steps Takes aed Results Achieved The repair of the missing seal between the MSVR and the conta* m ment wall on Unit 2.was

. completed on April 21,1997. The sections of missing seal between the MSVR and the containment wall on Unit I were repaired during the last refueling outage per a design change which allowed use of a material that is_less likely to degrade over time.

CormtinStennIhat WdlBe.Taken To Avoid Further Violation

1. E A maintenance procedure has been prepared which provides the necessary instructions for the periodic inspection of these seals.

2.- Those personnel who are responsible for reviewing deficiency reports for operability impact have reviewed this incident to heighten their awarenessc

_ 3. - A review of the corrective maintenance backlog was conducted to ensure that the proper priority -

had been established for the scheduling and repair of each item in the backlog.

- 4c FNP has significantly increased its sensitivity to design basis discrepancies. Over the past year, numerous topics have been covered, with personnel responsible for the review of deficiencics, for

. the purpose ofincreasing their sensitivity to design basis issues. Furacrmore, FNP began its FSAR review in 19% for the purpose ofidentifying deviations between actual plant conditions and FSAR design requirements. Additionally, Southern Nuclear and FNP established a Configuration Management group for the purpose of addressing these issues.

5, De appropriate pir.nt procedure will be enhanced to include design considerations in the review of deficiencies.

6. He need to review deficiencies for impact on design basis issues will be discussed with personnel responsible for the review of deficiencies.

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Date of Full Compliance ,

March 20,- 1998 -

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• ENCLOSURE 2 -

VIO 50 348,364/97-14-05

" Failure to Provide Tornado Missile Protection for TDAFW Pump Vent Stack"

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Vl'O 50 348,368/9714-05: Failure _ to Provide Tornado Missile Protection for TDAFW Pump zYent Stack" states:

10 CFR Part 50, Appendix B, Criterion Ill, requires that applicable regulatory requirements and design basis are correctly translated into drawings, procedures and instructions.

10 CFR 50, Appendix A, Criterion 2, requires that structures, syste.ns, and components important to safety shall be designed to withstand the effects of natural phenomena such as tomadoes without the loss of capability to perform their safety functions.

De Licensee's Operations Quality Assurance Program, Updated Final Safety Analysis Report (UFSAR) 17.2.3, states that measures are established ta assure that applicable regulatory requirements, quality standards, and design bases are properly translated into specifications, drawings, procedures, and instructions.

- UFSAR Section 3.5.4 states that Category I equipment and piping outside containment are either housed in Category I structures or buried underground. UFSAR Sections 6.5.1, 3.2.1.3, 3.2.1.5 and Table 3.2-1 identify the Auxiliary Feedwater equipment as Category 1.

- Contrary to the above, as of March 14,1997, the above regulatory requirements and design bases were not correctly translated into drawings, procedures and instructions in that tlw TDAFW pump vent stack

- was installed on the roof of the auxiliary building and was not designed and installed to withstand the - J I

cffects oTtomadoes.

his is a Severity Level IV violation (Supplement I).

Admission or Denial

' Farley Nuclear Plant is denying the violation.

Reason for Violation FSAR Section 3.5.4 states that Category I equipment and piping outside containment are either housed in Category I structures or buried underground. Further, FSAR Sections 6.5.1,3.2.1.3,3.2.1.5, and Tabic 3.2 1 identify the Auxiliary Fecdwater equipment as Category 1. FSAR Section 3.5.4 also states that external missile barriers have been designed to protect systems and components such that failure of one system or component cannot cause the failure of another system or component. The Turbine Driven Auxiliary Feedwater (TDAFW) pump turbine exhaust was not installed to withstand the effect of a tornado generated missile. However, an assumed loss of the TDAFW pump due to tornado-generated missile will not cause a failure of the two motor driven auxiliary feedwater pumps..

Derefore, missile protection of the TDAFW pump turbine exhaust was not required for sa'lc shutdown followmg this event or included in the original design of FNP.-

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. During the, NRC A&E inspection in March 1997, the team observed that the TDAFW pump turbine exhaust stack was installed outside, on the roof of the Auxiliary Building. His exhaust _was not ._ _

protected from a tornado-generated missile. De inspection report stated that the installed condition of

the safety-related TDAFW pump turbine exhaust did not craform to FNP design and licensing basis requirement.

• FNP is designed such that safe shutdown can be achievx1 in the event that a tornado-generated missile causes an assumed loss of the TDAFW pump. It should be noted that the FNP design basis does -

' include the consequential failures which are the direct result of the tornado generated missile, but do not assume an additional single active failure. This design basis was confirmed by the original A&E 4

. organization (Bechtel Ps ver Corporation). FNP was licensed prior to the issuance of Regulatory Guide

_ l.117, ' Tornado Design Classification," dated 1978, and has not committed to its guidance as stated by FSAR section 3A. De GDC, FSAR, industry standards, e.nd Bechtel files were reviewed to determme the original design and licensing philosophy of postulating the appropriate combination of natural occurrences and failures. Review of Bechtel internal memos in conjunction with the GDC, FSAR, and FNP design shows it is evident that a single failure criterion was not to be applied in assessing the acceptability of the plant design to cope with a brnado missile. Bechtel interoffice memorandum (R. L.

' Ashley to Distribution dated June 1,1977) documented discussions between R. L Ashley, Nuclear Chief, and the NRC Accident Analysis Branch Chief and the Auxiliary Systems Branch Chief p 0 to the issuance of Regulatory Guide 1.117. It was clear that the single failure criterion was not intended to be considered in evaluating a plant for tomado missiles. "Both (meaning the NRC Accident Analysis Branch Chief and the Auxiliary Systems Branch Chief) confirmed that the NRC is not applying the sinbl e failure criterion in determining the acceptability of plant designs to cope witi' .ornado missiles.

Deir rationale lies in the low probability of occurrence associated with the design oasis tomado characteristics (Regulatory Guide 1.76) ami the existence of the missiles defmed it. SRP 3.5.1.4."

Design c iteria B-TOP 3," Design Criteria for Nuclear Power Plants Against Tornadoes," referenced in FSAR Section 3.3.2, stated tornado effects should be considered to assure the ability to shut down the reactor and to maintain integrity of containment and essential decay heat removal systems. This design criteria does not discuss the combination of assumed single failures in conjunction with a design basis tornado Additionally, this design philosophy was discussed with licensing and design engineers associated with the design and licensing of Farley during the early 1970s. Their recollection of the original design basis confirmed that the intent of the Farley design was not to consider a single failure in conjunction with the consequential failure which is a direct result of the initiating natural phenomena, in this case a tomado-

. generated missile.

- As a result, tl.c vulnerability of the TDAFW pump exhaust vent to a potential tornado-generated missile L does not impact the ability of the auxiliary feedwater system to bring the plant to hot standby Two ~

motor driven pumps would be available to deliver flow *., the steam generators with steam being exhausted through the atmospheric relief valves or safety relief valves.

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,- o FS'AR Section 3.5.4 accurately describes missile protection for the TDAFW pump turbine exhaast in that adequate barriers have been designed to resist missile penetration such that failure of the TDAFW pump cannot cause the failure of the two MDAFW pumps, %c statement in Section 3.5.4 regarding Category I piping outside the containment was housed in Category I structures is balanced by the statemcet found in section 3.5.4 which states timt extemal missile barriers have been designed to protect systems and components such that failure of one system or component cannot cause the failure of another system or component. he heat sink removal function of the AFW system can be accomplished by the two motor driven AFW pumps. Based on the above description, the TDAFW pump turbine exhaust confome to the FNP design and licensing basis requirements. Derefore, a violatie to the regulatory requirements does not exist in this case.

- Corrective Steos Taken and Results Achieved

- No corrective actions have Nen taken.

Corrective Stens That Will Be Taken To Avoid Further Violation Appropriate portions of the FSAR will be revised to clarify that a portion of the TDAFW pump turbine exhaust is not protected from tornado-generated missiles.

Date of Full Compliance June 1,1998 C

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